See official court documents from July 2013 concerning legal addresses of most mugshot company owners including Kyle Prall of bustedmugshots.com, convicted felony drug user, drug dealer, and gang/organized crime member.  Copy the lawsuit to file for yourself and apply the appropriate state laws which are easily looked up online.

Disclaimer : The public record information available here reflects the docket entries and journals required by Ohio law to be kept by the Lucas County Clerk of the Court of Common Pleas. This information reflects the actual documents filed and kept at the Clerk of Courts Legal Division, located in the Lucas County Courthouse, at Adams and Erie Streets in Toledo, Ohio, 43624. The data entry, though generally deemed reliable, cannot be guaranteed. The information may appear on the Internet Docket before the entry is actually signed and journalized. Of course the proposed action is official only when signed and journalized. In no event shall the Lucas County Clerk of the Court of Common Pleas, or any other Lucas County department, agency, or official be held liable for damage of any nature, direct or indirect, arising from the use of this Internet product; including loss of profits, loss of savings, or other incidental or consequential damages.

IN THE COURT OF COMMON PLEAS LUCAS COUNTY, OHIO

Debra Lashaway, 7127 Washington Dr. Holland, Ohio 43528,

Phillip Kaplan 2425 Robinwood Ave. Toledo, Ohio 43620

Otha Randall 803 Hildebrand Ave Toledo, OH 43604-831

on behalf of themselves and all others similarly situated

Plaintiffs,

-vs-

ARTHUR D’ANTONIO III Owner of JustMugshots.com Owner of Mugshots.mobi 3400 Ave. Of the Arts APT B110 Costa Mesa, CA 92626,

CITIZENS INFORMATION ASSOCIATES LLC Owner of BustedMugshots.com Owner of MugshotsOnline.com c/o Registered Agent: Joseph Centrich, Esq. 2002 Timberloch Place Suite 200 The Woodlands, Texas 77380,

Case Case No. No. 2012

2012-6547

Judge Judge Hon. Hon. Ja

James D. Jensen

AMENDED AMENDED C

COMPLAINT, INCLUDING INCLUDING CLASS ACTION CLAIMS CLAIMS UN

UNDER CIV. R. 23, PRAYER FOR FOR LEGAL

LEGAL AND EQUITABLE RELIEF, RELIEF, WI

WITH JURY DEMAND ENDORSED ENDORSED HEREON

Fritz Fritz Byers Byers (0

(0002337) 414 414 N. N. Erie Erie S

Street, 2nd Floor Toledo, Toledo, Ohio Ohio 4

43604 Phone: Phone: 419-34

419-341-8013 Fax: Fax: 419-241-

419-241-4215 Email: Email: fritz@f

fritz@fritzbyers.com

Scott Scott A. A. Ciole

Ciolek (0082779) Ciolek Ciolek Ltd. Ltd. - - A

Attorneys at Law 520 520 Madison

Madison Ave. Suite 820 Toledo, Toledo, Ohio Ohio 4

43604 Tel: Tel: (419) (419) 740

740-5935 Fax: Fax: (866) (866) 89

890-0419 Email: Email: scott@

scott@counselor.pro

Jon Jon D. D. Richar

Richardson (0011833) 414 414 N.Erie N.Erie St

Street, 2nd Floor Toledo, Toledo, Ohio Ohio 4

43604 Phone: Phone: 419-24

419-241-6168 Fax: Fax: 419-241-

419-241-4215 Email: Email: jonrich

jonrich42@gmail.com

Attorneys Attorneys for for Plaintiffs

 GUILLERMO CUEVAS Owner of findmugshots.com m 1164 Ginger Cir. Weston, Florida 33326,

JEREMY BROOKS 2006 W. New Hope Dr. Cedar Park, Texas 78613,

JUSTMUGSHOTS.COM CORP. ORP. Registered Agent: Virtual Post Solutions, Inc. . 340 S. Lemon Ave. Walnut, CA 91789,

KYLE PRALL 9201 Brodie LN Austin, Texas 78748,

RYAN RUSSELL 2128 Sage Creek Loop Austin, 78704,

STAR NINE VENTURES, , INC. INC. Registered Agent: Joseph Centrich, Centrich, Esq. Esq. 2002 Timberloch Place Suite ite 200 200 The Woodlands, Texas 77380 80

Openbare Dienst Internationale, ionale, LLC LLC Owner of Mugshots.com International Whois Privacy cy Services Services Limited 35 New Road, P O Box: 2391 91 Belize City, Belize City 00000 000 BZ BZ

Unpublish LLC Whois Privacy Services Pty y Ltd Ltd PO Box 923 Fortitude Valley QLD 4006 6 AU AU

John Does 1-10

Defendants. Defendants.

2

For their Amended Complaint, plaintiffs Debra Lashaway, Phillip Kaplan and Otha Randall, on behalf of themselves and all other members of the class of persons defined in this Amended Complaint, allege:

OVERVIEW

1. This is an action for violation of Ohio’s Right of Publicity statute, R.C. 2741.01, et seq., and Ohio’s Pattern of Corrupt Activities Act, R.C. 2923.32. It is brought by the named plaintiffs on behalf of themselves and all other members of a state- wide class consisting of more than 250,000 persons, seeking redress for injuries caused by the unlawful conduct of the defendants, who have acted individually and collectively and whose actions have injured plaintiffs.

2. The defendants’ conduct that is the subject of this civil action entails their wrongful appropriation, without consent, of the names, photographs, images, and likenesses of the plaintiffs for a commercial purpose that benefits only the defendants, and to extort money from the plaintiffs.

3. Specifically, defendants, acting individually and in concert, publish on various websites the names and photographs (commonly called “mugshots”) of individuals who have had some involvement with the state’s criminal judicial process, along with information purporting to be a statement of the allegations or charges brought against the individual.

4. The defendants, acting individually and in concert, then offer to remove this information from the website in exchange for a “removal” or “takedown” fee.

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5. Upon payment of the fee, the picture may or may not disappear from the website, but then appears on another website operated by or affiliated with the entity that charged the fee.

6. This shakedown proceeds serially through websites operated by or in conjunction with the defendants, alternately operating as disclosure and takedown sites.

7. Through this activity, defendants have been able to extract millions of dollars from the named plaintiffs, and from countless members of the putative plaintiff class.

8. They will continue to do so until they are enjoined from their intentional and malicious violation of plaintiffs’ rights.

THE PARTIES

9. Plaintiff Debra Lashaway is a resident of Lucas County, Ohio.

10. Plaintiff Phillip Kaplan is a resident of Lucas County, Ohio.

11. Plaintiff Ova Tate is a resident of Lucas County, Ohio.

12. Defendant JustMugshots.com Corp. is a body corporate organized under the laws of the state of California. It operates a website with the URL justmugshots.com. and conducts business in the State of Ohio.

13. On information and belief, Defendant Arthur D’Antonio III is the owner of JustMugshots.com Corp. He is sued in his individual capacity and also as a shareholder of JustMugshots.com Corp.

14.Defendant Citizens Information Associates, LLC (hereinafter “CIA”) is a limited liability company with its registered agent, Joseph Centrich, Esq., at 2002

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Timberloch Place, Suite 200, Woodlands, Texas, 77380. CIA operates the websites BustedMugshots.com and  MugshotsOnline.com, and conducts business in the State of Ohio.

15. Defendant Jeremy Brooks is a resident of the state of Texas. He is sued in his individual capacity and also, based on information and belief, in his capacity as owner, officer, and employee of CIA and Star Nine.

16.Defendant Kyle Prall is a resident of the state of Texas. He is sued in his individual capacity and also, based on information and belief, in his capacity as owner, officer, and employee of CIA and Star Nine.

17. Defendant Ryan Russell is a resident of the state of Texas. He is sued in his individual capacity and also, based on information and belief, in his capacity as owner, officer, and employee of CIA and Star Nine.

18. Defendant Star Nine Ventures Inc. is a Texas Domestic For-Profit Corporation with its registered agent, Joseph Centrich, Esq., at 2002 Timberloch Place, Suite 200, Woodlands, Texas, 77380. Star Nine Ventures operates, promotes, and markets the websites BustedMugshots.com and MugshotsOnline.com, as a well as others and conducts business in the State of Ohio.

19. On information and belief, defendant Gullermo Cuevas is a resident of the state of Florida. He is the owner and operator of a website with the URL FindMugshots.com, which does business in the state of Ohio.

20. On information and belief, Defendant Openbare Dienst Internationale, LLC operates a website with the URL mugshots.com. Its principal place of business

5

in in Nevis, West Indies. It conducts business in the State of Ohio, but appears not to be authorized to do so.

21. Defendant Unpublish, LLC is a limited-liability company with its principal place of business in Belize City, Belize. It conducts business in the State of Ohio, but appears not to be authorized to do so. It Conducts business its own name and under an agency agreement with defendant Openbare Dienst Internationale, LLC.

22. The Defendants solicit customers in the State of Ohio. Upon information and belief, the Defendants have many paying customers who reside in the State of Ohio who each use the Defendants respective services in the State of Ohio. Upon information and belief, the Defendants conduct continuous and systematic business in the State of Ohio.

23.John Does 1 through 10 are individuals who have participated in managing, organizing, marketing, facilitating, and profiting from the operations of the websites owned and controlled by the other defendants.

FACTS

24. Each plaintiff had a booking photo taken in the State of Ohio.

25. With respect to each plaintiff, one or more defendants, without the permission, consent or knowledge of the plaintiff, reproduced, publicly displayed and distributed the plaintiff’s booking photo on the defendant’s or defendants’ respective websites.

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26.Plaintiffs’ images have commercial value, as is shown by defendants profiting from the unlawful appropriation of those images for commercial purposes.

27. Defendants’ respective websites, along with Plaintiffs’ images, were indexed by Google.com, and the images appear under Google Images when a web search for Plaintiffs’ name is conducted.

28. Each defendant’s use of the plaintiffs’ images is for a commercial purpose, among other purposes.

29. For example, Defendant CIA charges a monthly membership fee ranging between $12.95 to $19.95 to individuals who want to view the plaintiffs’ photos that are displayed on BustedMugshots.com.

30.Each defendant operates one or more websites that are used to display the plaintiffs’ images as part of a commercial enterprise.

31.The display by defendants of plaintiffs’ images is intended, among other things, to subject the individual plaintiff to hatred, contempt, or ridicule, or to damage the plaintiff’s personal or business repute, or to impair the plaintiff’s credit.

32. Each defendant, acting on its own or in conjunction with one or more of the other defendants, makes available to plaintiffs a service to remove the plaintiff’s image for a removal fee: By way of example, Defendant BustedMugshots charges an image and name removal fee of approximately $178 for rush removal of the booking photos from its website.

33. Unless Defendants are enjoined from further use and publication of Plaintiffs’ images and names, Plaintiffs will suffer further irreparable injury.

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CLASS ALLEGATIONS

34. Plaintiffs reallege the factual allegations of paragraphs 1 through 33, above.

35. The named plaintiffs bring this action under Civ. R. 23 on behalf of themselves and all other members of the class, defined as:

a. All persons who reside in Ohio and whose mugshot has been displayed by one or more of defendants’ websites; and

b. All persons who reside in Ohio and who have been offered a mugshot- removal service in exchange for a fee or other consideration.

Numerosity

36. The exact number of members of the class, or subclasses, set forth above is not known, but is estimated to exceed 250,000, and is therefore so numerous that joinder of all class members is impracticable.

Commonality

37. There are questions of law or questions of fact, or both, common to the class, including but not limited to the following:

a. Whether defendants have used the names and photographs of the members of the plaintiff class;

b. Whether the defendants’ use of the names and photographs of the members of the plaintiff class has been for a commercial purpose;

c. Whether the defendants’ use of the names and photographs of the members of the plaintiff class is intended to subject the individual

8

plaintiff to hatred, contempt, or ridicule, or to damage the plaintiff’s

personal or business repute, or to impair the plaintiff’s credit.

Typicality

38. The claims of the plaintiffs are typical of the claims of the other members of the putative class. The representative parties’ claims arise from the same practice and course of conduct that give rise to the claims of the other class members, and the claims are based on the same legal theories.

39. The legal infringements suffered by the plaintiffs are typical of the legal infringements suffered by the other class members.

40. The plaintiffs’ claims for statutory damages are typical of the statutory-damages claims of the other class members.

Adequacy of Representation

41. The named plaintiffs will adequately fairly and adequately protect the interests of the class.

42. The named plaintiffs’ interests are not antagonistic to, but rather are in unison with, the interests of other class members.

43. The named plaintiffs’ counsel have substantial experience in handling complex litigation, including civil actions involving rights of privacy and publicity, false-light invasion of privacy, and related claims.

Superiority of Class Action

44. The questions of law and questions of fact that are common to the class predominate over any questions affecting only individual members.

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45. The primary question that will determine defendants’ liability to the class is whether defendants have used plaintiffs’ names, photographs, likenesses, or distinctive appearance for a commercial purpose.

46. Likewise central to the determination of defendants’ liability to the class is whether defendants have subjected the plaintiffs to hatred, contempt, or ridicule, or to damage the plaintiff’s personal or business repute, or to impair the plaintiff’s credit for the purpose of obtaining a valuable thing or benefit.

47. Each of these questions is common to the class as a whole, and each predominates over any questions affecting only individual class members.

48. A class action is superior to other available for the fair and efficient adjudication of this controversy. Requiring class members to pursue their claims individually would entail a host of separate suits, with concomitant duplication of costs, attorney fees, and demands on court resources.

49. The claims of many of the individual class members are sufficiently small that they would be reluctant to incur the substantial cost and risk of pursuing their claims individually. Certification of this case under Civ. R. 23 will enable the issues to be adjudicated for all class members with the efficiencies of class litigation.

50. This action meets the requirements of Civ. R. 23 because:

a. Common questions of law or fact predominate over questions affecting only individual class members;

10  http://www.counselor.pro/articles/class-action-lawsuit-against-mugshot-websites

http://www.reuters.com/article/2012/09/20/net-us-usa-internet-mugshots-idUSBRE88J0R020120920

Shakedown or public service? Mug shot websites spread

Thu, Sep 20 2012

By Adam Tanner

NEW YORK (Reuters) - Janet LaBarba drank two glasses of wine during dinner at an upscale Dallas restaurant the night she broke up with her boyfriend. Later at a bar she ordered a beer. At home, she found herself crying as she readied for bed. She decided to go visit a friend.

Driving back long past midnight, she ignored blinking traffic lights and cruised through a stop sign. She was hauled down to the police station, charged with drunk driving, and photographed. It was the second time in six months.

The two episodes in 2009 cost LaBarba more than $20,000 in legal fees and fines and landed her in jail for a few days each time. A judge ordered her to wear an ankle monitor for five months. Yet the most stinging punishment, she felt, came when several websites posted her arrest mug shots, so that Internet searches of her name instantly turned up the compromising photos.

"It completely screwed with my life," LaBarba said. "People Googled me and it was very embarrassing." She said the images complicated her search for a job as well as a new relationship when her boyfriend's ex-wife looked up her name.

For a fee, she could have the photos removed. She chose to pay up.

Large data brokers have historically limited who gets to see their detailed files on people through a complicated application procedure that discourages casual users. Now, on the spur of the moment, anybody can access digital secrets, including criminal records, thanks to a proliferation of personal data Internet sites. One subset of these sites features mug shots that can be removed for a fee.

Many among America's 314 million people are affected. U.S. law enforcement officials made more than 13 million arrests in 2010, according to the most recent FBI statistics, although that number includes repeat arrests. The bureau maintains fingerprints and criminal histories for 72 million people, according to its Criminal Justice Information Services. Drug abuse and drunk driving are the most common reasons for arrest.

Clare Dawson-Brown, assistant district attorney in Travis County, Texas, home to bustedmugshots.com's founder Kyle Prall, said she is concerned personal data sites sometimes list incorrect information and do not comply with state orders to erase certain cases from the criminal records. "Now that this information is out there it is ever more horrific for people to get their lives back together," she said. "How do you get this garbage out of there?"

Several legal experts interviewed for this article said seeking money to remove mug shots from the Internet does not qualify as a crime such as extortion, since extortion requires a threat ahead of time to post the image unless the mug shot subject pays.

"Wow - it does seem to come pretty close to the line," Robert Weisberg, co-director of the Stanford Criminal Justice Center, said upon learning about such sites. "I'd say it skirts the line but may stop just short. (It) depends on how a reasonable person would perceive this in terms of fear."

WANTED: EVIDENCE OF CIVIC VALUE

LaBarba, 35, an event planner, rues the irresponsibility that led to her drunk driving arrests and believes she has learned important lessons. Yet she remains bitter about the public posting of her mug shot. "How is this legal?" she asked. "My business is my business. It's like me going to your house and looking through your things."

Bustedmugshots.com responds that it only posts publicly available images. "We are publishing public records with an interest in informing the community," Prall said, speaking in a series of interviews about his business. "We have never approached anybody attempting to generate revenue from them to remove a record from our database."

Bustedmugshots.com does not tell people they have posted the images but waits for them to learn of it, either on their own or through friends.

LaBarba paid what the site describes as "nominal" fees - $68 per photo for service within 10 business days, $108 within 24 hours - to make the photos disappear. An Internet search of her name now leads to genial photos of LaBarba pictured with lots of friends.

Prall, 33, grew up in Bloomington, a small city in central Illinois, the son of a circuit court judge. He set up the site a year and a half ago.

In 2008, inspired by a Florida publication, he started a weekly newspaper called Busted! In Austin during his spare time. Promoting his $1 paper with the slogan "Getting arrested isn't funny... but the mug shots are," Prall expanded to bustedmugshots.com, continuing with his day job as a financial analyst at a power company until earlier this year.

His website collects its images from city, state and federal law enforcement agencies across the country, either for free or for a small fee. It has assembled more than 5 million records, he says. The company waives the fee for removing photos of those exonerated of any charges.

On the website, bustedmugshots.com describes itself as "a valuable asset to local law enforcement. Our dedication to providing criminal justice has led to breakthroughs in cold cases, and numerous tips on robberies, sex crimes and even murders." Asked for specific examples, Prall offered none. He said he plans to revamp the site to include a crime map and the ability for users to submit tips to the police.

Some local jurisdictions have resisted making mug shots available to him, although others say state public record laws oblige them to provide the images. Andrew Kossack, Indiana's former public access counselor, last year cleared the way for Prall to obtain mug shots, but he has reservations about the business: "It doesn't sit right in your stomach that this person should be someone who has so much control over your likeness."

Others complain about the drain on resources. "It takes time to distill the records," said Andrea Brandes Newsom, chief deputy corporation counsel for the city of Indianapolis. "Is it appropriate to make use of taxpayer resources in order for someone to profit?"

The U.S. Department of Justice maintains a national sex offender database, and many cities and counties offer free searches of criminal records, while some post mug shots. Because such records are not optimized for maximum Internet visibility, they typically do not turn up in average searches.

One of the most common crimes catalogued on Prall's site is drunk driving, but the advocacy group Mothers Against Drunk Driving sees little merit in public shaming. "We haven't seen evidence that tactics such as posting offenders' mug shots online leads to the reduction of drunk driving incidents or fatalities," said national president Jan Withers.

Prall says his site is a leader in a sector where competitors include mugshots.com, whosarrested.com, and gotchamugshot.com. "IS THIS YOU? Or your friend/family member? Click Here To Remove," Mugshotsworld.com tells users. "Originally $175. Discounted price of $100 available only for short time."

The sites seek to get photos prominently displayed in web searches. GotchaMugshot.com, for example, says on its site: "It's a common occurrence to find full names, profile, mug shot and offenses in the first page of most search engines like Google, Bing & Yahoo."

Officials at these other mug shot sites did not respond to calls and emails seeking comment.

'CREEPY VIGILANTE JUSTICE'

Prall has had his own run-ins with the law. As a young man he was found guilty of illegal consumption of alcohol as a minor, delivering/manufacturing of cannabis, trespassing into a car and drunk driving. A court sentenced him to 120 days in jail for the drug charge and 30 days for the drunk driving offense.

"I made a lot of little mistakes when I was young," Prall said. "I did some things in high school that were bad choices."

Prall does not make his own mug shots available on his website but said he would be comfortable publicizing his past. "I don't think all that stuff should be secret," he said.

Joelle Bem, who was arrested for crashing a friend's Ferrari while drunk in 2008, disagrees. She did not pay the roughly $400 bustedmugshots.com wanted to remove a series of images, saying she did not have the money. A Google image search of her name still quickly reveals several unflattering photos.

The divorced unemployed woman said the easy availability of the photos prompted her to move after a neighbor circulated the image to others after a disagreement. The images have also complicated the personal life of the former currency trader and financial analyst: "It's made dating really hard."

"I thought I was punished enough by Dallas County," said Bem, 38, who served 30 days in prison. "I didn't know I was going to be further punished and cyberstalked by creepy vigilante justice whose only intent is to collect money from me."

(Adam Tanner is a 2012-13 fellow at Harvard University's Department of Government)

(Editing by Claudia Parsons and Prudence Crowther)