SPRAY TAN LA Rob Lonardo Rob thinks we're all idiots! Internet

Law Offices of
LARRY CASTRUITA
9663 Santa Monica Blvd. Suite 903
Beverly Hills, CA 90210
Larry Castruita, Esq.
Direct: (323) 366 - 0650
larrycastruita@gmail.com
______________________________________________________________________
March 21, 2012
CEASE & DESIST AND OFFER TO SETTLE
Sent Via U.S. MAIL Delivery
Andrea M. Somerville
3 Markham Grove Place
Shenandoah, TX 77381-2993
55 Columbia Crest Place
The Woodlands, TX 77382
Ms. Somerville:
This office represents Robert Lonardo and Spray Tan Los Angeles, Inc. (including subsidiary companies). Mr.
Lonardo has asked me to review your actions in connection with him and his company and has requested
commencement of legal action against you for civil damages growing out of your collective repeated false
allegations, harassment, slander, libel, defamation, and tortuous interference with business relations.
Before initiating legal action, this letter is an offer to settle the matter amicably.
More than most common remedies available to him at law, Mr. Lonardo simply wants to move beyond any
connection to you, and to try to put this matter behind him and his company.
I have read your work on websites such as ripoffreport.com and others. While I respect your first amendment right
to voice your opinion, there are very strict laws prohibit you from making false, or grossly negligent statements, and
statements that are intended to unlawfully interfere with business relations. Stating publically that Spray Tan LA
and the owner Rob Lonardo are currently running a spray tan scam that offers a free tan and then they bill you for a
full tan package even though you never agreed to it is prima facie libel unless you were a witness or victim of this
exact occurrence. In a more extreme example, publically stating that someone is drug running without any factual
basis for this claim would satisfy all elements for slander, and painting in false light. Purposely publically making
these, and many other, false statements on nationally interactive websites intending to negatively affect future
business of Spray Tan LA, brings about, yet another cause of action for interfering with business relations and is the
crux of all a majority of the claims listed above. The damages you have already cases for these three actions alone
are serious and ongoing.
I believe the easiest way to get past this is;
(1) For you to, obviously, cease and desist from your repeated acts of defamation and harassment of
Robert Lonardo, Spray Tan Los Angeles, Inc. (including subsidiary companies), and any person or entity, affiliated
or doing business with Spray Tan Los Angeles, Inc. (including but not limited to online posts); and
(2) To respond within 20 days of your receipt of this letter with a letter signed by you which states that your
accusations in all posts regarding Robert Lonardo, Spray Tan Los Angeles, Inc. (including subsidiary companies),
and any person or entity, affiliated or doing business with Spray Tan Los Angeles, Inc. were knowingly false and
exaggerated and caused by emotion rather than any factual knowledge.
While I assume, based on your past correspondence with my client, your initial reaction to the above may be less
that accepting, I can tell you that by simply fulfilling the above demands, which basically puts everybody back to
where they were, you will avoid various state and federal civil and criminal liabilities, not to mention what could be
a very expensive legal process, especially if/when you end up having to pay my bill (see section on legal fees
below). Furthermore, the letter requested is specifically because the websites that you have chosen to post false and
damaging information have a very strict policy of not removing any posts. The easiest way to refute your decision
to post such unlawful statements would be this simple letter that my client could simply show to prospective
customers and affiliates in an effort to patch up the very big mess you have made.
Simply put, writing a simple letter will save you a tremendous amount of time and a substantial amount of money.
. . .
As much as your correspondence states your interpretation of Texas law. You will likely be compelled to defend
this case in California, for which I would encourage you to seek representation of a California certified attorney.
The agreement with Spray Tan Los Angeles, Inc. that you validly executed on February 14, 2011 states that
California Law would govern the contract. As a courtesy I will tell you that not understanding the ramifications of
what is included in a contract you sign is not a defense. I am sure your attorney will tell you about a case called
Burger King v. Rudzewicz wherein two business men entered into an agreement to franchise a store in Michigan.
The Supreme Court held that they purposefully availed themselves of the protections of Florida, therefore subject to
jurisdiction Florida and that due process would not be violated because the defendants should have reasonably
anticipated being summoned into court in Florida for breach of contract.
Moreover, a state has personal jurisdiction over any party whose actions intentionally reach another party in the state
and are the basis for the cause of action. Your internet posts, although written in Texas, were intended to reach the
entire audience of the websites you posted them on. Specifically the fact that you knew the name of the company
refers to a city in California where the company was incorporated lends itself to the fact that you were attempting to
intentionally reach and affect Spray Tan LA, a California corporation and would subject you to jurisdiction in
California.
I strongly encourage you to stop doing those actions that have created this trouble and return to a life as though
Spray Tan Los Angeles, Inc. does not exist, and you can forward the letter of apology to me at either the mailing or
email address at the top of this letter. I realize and do not care that the apology may be insincere. Please refrain
from any further contact with my clients. I encourage you to have your attorney contact me at the contact info at the
top of this letter in an effort to further this offer to settle along.
This letter does not constitute a complete or exhaustive statement of all or any of our clients rights or claims.
Nothing stated herein is intended as, nor should it be deemed to constitute, a waiver or relinquishment of any of my
clients rights or remedies, whether legal or equitable, all of which are hereby expressly reserved. This letter is a
confidential legal communication and is not for publication.
Very truly yours,
//ELECTRONICALLY SIGNED//
Larry Castruita, Esq.

My name is Robert Lonardo and I am the owner of Spray Tan Los Angeles.  None of these reports that are defaming myself or my company are true.  Every person who placed a post on this website has done so anonymously and is the doing of a contractor we terminated named Andrea Somerville.  There are 16 of us who have filed criminal charges with the Houston Police Department's homicide division against Andrea Marcella Somerville for harassment, stalking, assault, and battery.
 A copy of the police report will be uploaded to this website.  The Houston police report number is 22330911G.

Please do not pay any attention to these posts by a disgruntled former business associate.  This is not reflective on my company and as you can see from her defaming posts nothing to do with our tanning business as well an me.

Here is all of my information as I have nothing to hide.  However, I do have a company and staff to be quite proud of! :>  It is VERY sad that the internet and websites like this have allowed mentally challenged people to use their keyboards as weapons of mass destruction.  Hopefully congress will limit what can be said and posted on the web to protect us all from these keyboard terrorists.

Thank you and good luck to all!

Rob Lonardo

Owner

Spray Tan Los Angeles

(310) 709-7157

rob@spraytanla.com

www.spraytanla.com

Spray Tan LA has the best organic solution that does not smell and the color is so natural.  I have never been able to use any other spray tan solutions beacuse the smell was so awful I couldn't stand it. 
I have personally met the owner Rob and he has been nothing but kind to me.  He runs a very good business and is very honest. 
I think it's pretty scandalous that a disgruntled girl who came into work intoxicated (and therefor let go)and then upset because the owner wouldn't accept her sexual advances decides to try and ruin his reputation. 
The only person's reputation "you" (disgruntled girl) are ruining is yours..you look like the craziest nut job for posting all these obvious lies.

Wow! Who knew that one insanely, obviously over medicated, drunk stalking person could cause such a problem. I would suggest to  Andrea Somerville to look into some serious professional help and maybe even a hobby, since apparently she has nothing better to do then harass innocent people.

I am a current employee at Spray Tan LA, here in Houston and would like to say hands down this is a legit  company with an honest owner, Rob Lonardo, who wants nothing more then to succeed, just like everyone else. He doesnt want to do it by taking anyone down, he doesnt hire people according to how they look, although he does prefer his employees to have a brain and be dependable and sober. Show me any entrepreneur out there who lets their employees get away with not being dependable, sober, honest and intelligent, and I'll show you one who isnt going to make it very far.

Spray Tan LA is 100% certified organic and makes everyone walk away with a smile on their face along with a sun kissed glow. We are all trained and certified and very professional about the tans that we preform. We strive to make the clients happy because we want regular clients that we work with on a weekly basis. We are up front and honest about everything to do with our products and our company. We are so sure that you will love the outcome that we challenge you to try it out today!

Please disregard any of the made up lies that were posted about Rob and Spray Tan LA, as they are all just some little girl throwing a fit because she didnt get her way. If she wanted a job where she could go to work drunk, she should have applied to be a stripper.

Spray Tan LA ROCKS!! Please check out or website and call in for an appointment with Anita! Happy Tanning!
 

This is NOT Rob Lonardo, I am though a CURRENT HOUSTON EMPLOYEE, working for Spray Tan LA-Houston, and his company is completely legit, you are just jealous that he wouldn't put up with your drunken stupidity! Grow up... REALIZE that you can't drink ar work nor show up to work intoxicated with a drink in hand... who is the STUPID BROAD?? ummm you ANDREA SOMERVILLE...

HEY EVERYONE, If you are in need of a Stalker... Andrea Somerville is one hell of a stalker/harrasser!

HERE IS HER CONTACT INFO:

Facebook: http://www.facebook.com/home.php#!/profile.php?id=1075935924
Cell: 936.648.1621
Address: 3 Markham Grove Place
               The Woodlands, TX 77381
Emails:asomer@att.blackberry.net
            somervillea24@yahoo.com


CONTACT HER... and Remember Spray Tan LA is 100% Certified Organic 24/7/365 Mobile Spray Tan Company... Call us for your next tan <3

(877)STLA.USA or visit: www.spraytanla.com

Spray Tan LA is a growing business and it takes hard work to make it successful which Rob has been doing since day one. He has developed an amazing product and it is the best on the market. I love working here and only can say positive things about this company!