2Birthdate June 15, 1987; Age 18; an authentic image of Jane Roe at her then-current age; and thestatement that her ideal match included a male “who could last for a long time” (Complaint ¶¶ 198,205).Plaintiff began chatting online through SexSearch with Jane Roe, and the two eventuallydecided to schedule a sexual encounter to take place at Jane Roe’s home on November 15, 2005. Themeeting went as planned, and Plaintiff and Jane Roe engaged in consensual sexual relations(Complaint ¶¶ 219, 222). However, as it turned out, Jane Roe was not actually 18, but a 14-year-oldchild.On December 30, 2005, Plaintiff’s home was surrounded by law enforcement officers, and hewas arrested and charged with three separate counts of engaging in unlawful sexual conduct with aminor, all felonies of the third degree (Complaint ¶¶ 226-33). As a result of the charges, Plaintiff could face fifteen (15) years in prison, and a classification that might include lifetime registration asa sex offender (Complaint ¶¶ 235-36).
On March 1, 2007, Plaintiff filed this Complaint, naming as Defendants the owners of SexSearch, which include: Sexsearch.com; Sexsearchcom.com; Cyber Flow Solutions, Inc.; ManicMedia, Inc.; Stallion.com FSC Limited; DNR; Experienced Internet, Inc.; Fiesta CateringInternational, Inc.; Adam Small; Camelia Francis; Damian Cross; Ed Kunkel; Mauricio Bedoya;Patricia Quesada; and Richard Levine (Defendants) (Complaint ¶¶ 15-33, 40). Defendants contendDefendant/Intervenor Cytek, Ltd. is the true owner of the SexSearch website and business, and thusis the only proper party.
Case 3:07-cv-00604-JZ Document 153 Filed 08/22/2007 Page 2 of 29