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Complaint

in Naas et al. v. Anonymizer Inc. et al. (Dec. 21, 2001)

JOHN O'GRADY
CLERK OF THE FRANKLIN COUNTY COMMON PLEAS COURT, COLUMBUS, OHIO 43215
CIVIL DIVISION

HANA NAAS 406 EAST HARROGATE LOOP WESTERVILLE, OH 43082-0000,
PLAINTIFF,		01CVC-12-12620
VS.		CASE NUMBER
ANONYMIZER INC #426 5694 MISSION CENTER ROAD SAN DIEGO, CA 92108-0000,
DEFENDANT.

**** SUMMONS ****

12/21/01

TO THE FOLLOWING NAMED DEFENDANT:

ANONYMIZER INC
#426
5694 MISSION CENTER ROAD
SAN DIEGO, CA 92108-0000

HANA NAAS
406 EAST HARROGATE LOOP
WESTERVILLE, OH 43082-0000,

PLAINTIFF(S).

A COPY OF THE COMPLAINT IS ATTACHED HERETO. THE NAME AND ADDRESS OF THE PLAINTIFF'S ATTORNEY IS:

TIMOTHY A. PIRTLE
ATTORNEY AT LAW
1380 ZOLLINGER ROAD
COLUMBUS, OH 43221-0000

YOU ARE HEREBY SUMMONED AND REQUIRED TO SERVE UPON THE PLAINTIFF'S ATTORNEY, OR UPON THE PLAINTIFF, IF HE HAS NO ATTORNEY OF RECORD, A COpy OF AN ANSWER TO THE COMPLAINT WITHIN TWENTY-EIGHT DAYS AFTER THE SERVICE OF THIS SUMMONS ON YOU, EXCLUSIVE OF THE DAY OF SERVICE. YOUR ANSWER MUST BE FILED WITH THE COURT WITHIN THREE DAYS AFTER THE SERVICE OF A COpy OF THE ANSWER ON THE PLAINTIFF'S ATTORNEY. IF YOU FAIL TO APPEAR AND DEFEND, JUDGMENT BY DEFAULT WILL BE RENDERED AGAINST YOU FOR THE RELIEF DEMANDED IN THE COMPLAINT.

JOHN O'GRADY
CLERK OF THE COMMON PLEAS
FRANKLIN COUNTY, OHIO

BY: JOHN HYKES, DEPUTY CLERK

JOHN O'GRADY
CLERK OF THE FRANKLIN COUNTY COMMON PLEAS COURT, COLUMBUS, OHIO 43215
CIVIL DIVISION

JUDGE J. BRUNNER

HANA NAAS ET. AL.,
PLAINTIFF,		01CVC-12-12620
VS.		CASE NUMBER
ANONYMIZER INC ET. AL.,
DEFENDANT.

CLERK'S ORIGINAL CASE SCHEDULE

NOTICE TO ALL PARTIES

ALL ATTORNEYS AND PARTIES SHOULD MAKE THEMSELVES FAMILIAR WITH THE COURT'S LOCAL RULES, INCLUDING THOSE REFERRED TO IN THIS CASE SCHEDULE. IN ORDER TO COMPLY WITH THE CLERK'S CASE SCHEDULE, IT WILL BE NECESSARY FOR ATTORNEYS AND PARTIES TO PURSUE THEIR CASES VIGOROUSLY FROM THE DAY THE CASES ARE FILED. DISCOVERY MUST BE UNDERTAKEN PROMPTLY IN ORDER TO COMPLY WITH THE DATES LISTED IN THE RIGHT-HAND COLUMN.

BY ORDER OF THE COURT OF COMMON PLEAS,
FRANKLIN COUNTY, OHIO

DATE _/_/_

__________________________________
JOHN 0' GRADY, CLERK

(CIV363-S10)

IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO

Hana Naas 406 East Harrogate Loop Westerville, Ohio 43082-0000,		Case No.
and
Suliman Dregia 406 East Harrogate Loop Westerville, Ohio 43082-0000,		Judge: Brunner
Plaintiffs,
vs
Anonymizer Inc #426 5694 Mission Center Road San Diego, CA 92108-0000,
and
Yousif Khaddar address currently unknown
and
John Doe #1,
John Doe #2,
John Doe #3,
Defendants.

RECITALS

COMPLAINT

FIRST CAUSE OF ACTION

DEFAMATION

1.   Defendant John Doe posted numerous communications via the internet defaming Hana Naas.

2.   Defendant John Doe posted numerous communications via the internet accusing Hana Naas of being sexually impure, using numerous words and phrases.

3.   Defendant John Doe posted numerous communications via the internet accusing Hana Naas of abandoning her children and being an unfit mother.

4.   Defendant John Doe posted numerous communications via the internet accusing Naas children of being of impure birth.

5.   Defendant John Doe posted numerous communications via the internet accusing Hana Naas of spying for foreign governments.

6.   Defendant John Doe posted numerous communications via the internet accusing Hana Naas of defaming third parties.

7.   Defendant John Doe posted numerous communications via the internet accusing Hana Naas of being untruthful.

8.   Defendant John Doe posted numerous communications via the internet defaming Hana Naas' father.

9.   Defendants communicated that plaintiffs engaged in criminal conduct.

10.  Defendants had no expectation of profiting from this action and actions were solely vindictive and made with malice.

11.  The communications of defendants were untrue and/or malicious.

12.  The communications of defendants were intended to injure plaintiffs' professional and business relationships.

13.  The communications of defendants were injurious to plaintiffs' business relationships.

14.  The communications of defendants were injurious to plaintiffs' professional reputation. ~ 15.  The communications of defendants were injurious to plaintiffs' occupation.

16.  The communications of defendants were intended to cause plaintiffs public ridicule.

17.  The communications of defendants were intended to cause plaintiffs shame and disgrace.

18.  The communications of defendants were intended to coerce plaintiffs.

19.  The communications of defendants are actionable per se.

20.  The communications of defendant were intended to cause plaintiff damaged personal relationships.

SECOND CAUSE OF ACTION

DEFAMATION

21.  Defendant John Doe posted numerous communications via the internet defaming Suliman Dregia.

22.  Defendant John Doe posted numerous communications via the internet accusing Hana Naas of being sexually impure, using numerous words and phrases.

23.  Defendant John Doe posted numerous communications via the internet accusing Hana Naas of abandoning her children and being an unfit mother.

24.  Defendant John Doe posted numerous communications via the internet accusing Naas children of being of impure birth.

25.  Defendant John Doe posted numerous communications via the internet accusing Hana Naas of spying for foreign governments.

26.  Defendant John Doe posted numerous communications via the internet accusing Hana Naas of defaming third parties.

27.  Defendant John Doe posted numerous communications via the internet accusing Hana Naas of being untruthful.'~

28.  Defendant John Doe posted numerous communications via the internet stating that Suliman Dregia should divorce his wife Hana Naas.

29.  Defendants communicated that plaintiffs engaged in criminal conduct.

30.  Defendants had no expectation of profiting from this action and actions were solely vindictive and made with malice.

31.  The communications of defendants were untrue and/or malicious.

32.  The communications of defendants were intended to injure plaintiffs' professional and business relationships.

33.  The communications of defendants were injurious to plaintiffs' business relationships.

34.  The communications of defendants were injurious to plaintiffs' professional reputation.

35.  The communications of defendants were injurious to plaintiffs' occupation.

36.  The communications of defendants were intended to cause plaintiffs public ridicule.

37.  The communications of defendants were intended to cause plaintiffs shame and disgrace.

38.  The communications of defendants were intended to coerce plaintiffs.

39.  The communications of defendants are actionable per se.

40.  The communications of defendant were intended to cause plaintiff damaged personal relationships.

THIRD CAUSE OF ACTION

DEFAMATION

41.  Defendant Anonymizer, Inc. facilitated the above communications of John Doe by controlling the connections to the servers and sites where the communications were posted.

42.  The communications facilitated by Anonymizer, Inc., included numerous communications via the internet accusing Hana Naas of being sexually impure, using numerous words and phrases, numerous communications via the internet accusing Hana Naas of abandoning her children and being an unfit mother, numerous communications via the internet accusing Naas children of being of impure birth, numerous communications via the internet accusing Hana Naas of spying for foreign governments, numerous communications via the internet accusing Hana Naas of defaming third parties, numerous communications via the internet accusing Hana Naas of being untruthful, communications defaming Hana Naas' father, and numerous communications via the internet stating that Suliman Dregia should divorce his wife Hana Naas.

43.  Defendant profited from this action.

44.  The communications were untrue and/or malicious.

45.  The communications were intended to injure plaintiffs' professional and business relationships.

46.  The communications were injurious to plaintiffs' business relationships.

47.  The communications were injurious to plaintiffs' professional reputation.

48.  The communications were injurious to plaintiffs' occupations.

49.  The communications were intended to cause plaintiffs public ridicule.

50.  The communications were intended to cause plaintiffs shame and disgrace.

51.  The communications were intended to coerce plaintiffs.

52.  The communications are actionable per se.

53.  The communications of defendant were intended to cause plaintiff damaged personal relationships.

FOURTH CAUSE OF ACTION

DEFAMATION

54. Defendant Yousif Khaddar aided John Doe in the above First, Second, and Third causes of action.

FIFTH CAUSE OF ACTION

DEFAMATION

55. Defendants John Doe #1, John Doe #2, and John Doe #3 engaged in the above conducts and this complaint will be amended upon learning their identities and addresses.

Plaintiffs demand damages in a dollar amount within this Court's jurisdiction, orders that defendants cease this conduct, attorney fees, and because of the defendants motivations punitivE damages in an amount greater than compensatory damages, and othex relief the Court deems proper.

__________________________
Timothy A. Pirtle Licensed to practice law in:
Ohio 0040970
Florida 0865613
Arizona 013644
1380 Zollinger Road
Columbus, Ohio 43221
(614) 538-5375
(614) 538-5376 fax

Attested:
 
____________________________
Suliman Dregia

JURY DEMAND

__________________________
Timothy A. Pirtle

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