JOHN O'GRADY CLERK OF THE FRANKLIN COUNTY COMMO.

PLEAS COURT, COLUMBUS, OHIO 43215 CIVIL DIVISION

HANA HAAS 406 EAST HARROGATELOOP WESTERVILLE, OH 43082-0000,

PLAINTIFF,
VS. ANONIMI ZER IKC #426 5694 MISSION CENTER ROAD SAN DIEGO, CA 92108-0000,
DEFENDANT. SUMIIONS 12/21/01

TO THE FOLLOWING NAKED DEFENDANT: ANONYMIZER INC *426 5694 MISSION CENTER ROAD SAN DIEGO, CA 92108-0000

YOU HAVE BEEN NAMED DEFENDANT IN A COMPLAINT FILED IN FRANKLIN COUNTY COURT OF COMMON PLEAS, FRANKLIN COUNTY BALL OF JUSTICE, COLUMBUS, ORIO, BY: BANA NAAS 406 EAST HARROGATELOOP WESTERVILLE, OR 43082-0000,
PLAIIfTIFF(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 ZOLLIKGER ROAD COLUMBUS, OH 43221-0000 YOU ARE HEREBY SUKKONEDAND REQUIRED TO SERVE UPON THE PLAINTIFF'S ATTORNEY, OR UPON THE PLAINTIFF, IF HE HAS NO ATTORNEY OF RECORD, A COpy OF AN ANSWERTO THE COMPLAINT WITHIN TWENTY-EIGHT DAYS AFTER THE SERVICE OF THIS SUKMONSON 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 ANSWERON THE PLAINTIFF'S ATTORNEY. IF YOU FAIL TO APPEAR AND DEFEND, JUDGMENTBY DEFAULT WILL BE RENDERED AGAINST YOU FOR THE RELIEF DEMANDEDIN THE COMPLAINT. JOHN O' GRADY CLERK OF THE CONNONPLEAS FRANKLIN COUNTY, OHIO

BY: JOHN HYKES, DEPUTY CLERK

JOHN 0' GRADY CLERK OF THE FRANKLIN COUNTY COMMON PLEAS COURT, COLUMBUS, OHIO 432~5 CIVIL DIVISION JUDGE J. BRUNNER
HANA NAAS ET. AL.,

PLAINTIFF, OlCVC-12-12620
VB.
CASE NtTMBER

ANONYMIZER IHC
ET. AL.,

DEFENDANT.

CLERK'S ORIGINAL CASE SCHEDULE LATEST TIME OF OCCURRENCE CASE FILED INITIAL INITIAL STATUS CONFERENCE JOINT DISCLOSURE OF ALL WITNESSES 05/10/02
07/05/02 07/19/02

12/21/01

SUPPLEMENTAL JOINT DISCLOSURE OF ALL WITNESSES TRIAL CONFIRKATION DATE DISPOSITIVE MOTIONS

09/27/02 10/11/02 11/22/02
12/06/02 0130PII

DISCOVERY CUT-OFF DECISIONS ON MOTIONS FINAL PRE-TRIAL CONFERENCE/ORDER (OR BOTH)
TRIAL ASSIGNMENT

01/02/03

0900AK

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 ATTORNEYSAND PARTIES TO PURSUE THEIR CASES VIGOROUSLY FROM THE DAY THE CASES ARE FILED. DISCOVERY MUST BE UNDERTAKENPROKPTLY IN ORDER TO COMPLY WITH THE DATES LISTED IN THE RIGHT-HAND COLUMN. BY ORDER OF THE COURT OF COMMON PLEAS, FRAHKLIN COUNTY, OHIO

JOHK 0 I GRADY, CLERK (CIV363-S10)

IN THE COURT OP COIOCONPLBAS FRANKLIN COUNTY, OKlO Hana Naas 406 East Harrogate Westerville, Ohio Loop 43082

Case No.

and Judge
Suliman Dregia 406 East Harrogate Westerville, Ohio Plaintiffs, Loop 43082

B~"'nner

va
Anonymizer, Inc. #426 5694 Mission Center San Diego, California

Road 92108,

and
Yousif Khaddar

address currently and
John Doe il, John Doe #2,
John Doe #3, Defendants.

unknown,

RECI:TALS Hana Naas is the spouse of Suliman Dregia, and the daughteJ

of

Abdelrahim

Haas. COKPLADrl' FIRST CAUSE OF ACTION DEFAMATION

1.

Defendant

John Doe posted
Kana Naas

numerous communications

via

the

internet

defaming

2.

Defendant

John

Doe posted of

numerous being

communications impure,

via using

the

internet numerous

accusing words

Hana Naas and phrases. John

sexually

3.

Defendant

Doe posted of

numerous abandoning

communications her children

via

the

internet

accusing

Hana Naas

and being

an unfit

mother
John Doe posted children numerous of being communications of impure birth. via the via the

4.

Defendant

internet 5

accusing

Naas

Defendant

John

Doe posted of

numerous spying numerous defaming numerous being for

communications foreign

internet

accusing

Hana Naas John

governments via the

6.

Defendant

Doe posted

communications third parties.

internet

accusing

Hana Naas of John Doe posted of

7.

Defendant

communications

via

the

internet 8

accusing

Hana Naas John

untruthful. communications via the

Defendant

Doe posted

numerous father that plaintiffs

internet 9

defaming

Hana Naas' communicated

Defendants

engaged

in

criminal

conduct.

10

Defendants were

had no expectation solely vindictive of defendants

of

profiting

from

this

action

and actions

and made with were untrue

malice. and/or

11

The communications

malicious

12.

The communications professional

of

defendants

were

intended

to

injure

plaintiffs'

and business of defendants

relationships were injurious to

13.

The communications business

plaintiffs'

relationships of defendants were injurious to

14.

The communications professional

plaintiffs'

reputation.

15.

The communications occupation.

of

defendants

were

injurious

to

plaintiffs'

16

The communications public ridicule.

of

defendants

were

intended

to

cause

plaintiffs

17.

The communications

of

defendants

were

intended

to

cause

plaintiffs

shame and disgrace. of defendants were intended to coerce

18

The communications

plaintiffs

19.

The communications The communications

of of

defendants defendant relationships.

are were

actionable intended to

per

se.

cause

plaintiff

damaged

personal

SECOND CAUSE OF ACTION DEFAMATION Defendant internet John Doe posted Dregia numerous being communications impure, via using the numerous communications via the

defaming

Suliman

22

Defendant

John

Doe posted

internet numerous

accusing words

Hana Naas of and phrases

sexually

23.

Defendant

John Doe posted
Hana Naas of

numerous abandoning

communications
her children

via

the

internet an unfit

accusing mother

and being

24.

Defendant

John

Doe posted children

numerous of being

communications of impure birth

via

the

internet

accusing

Naas

25.

Defendant

John Doe posted
Hana Naas of Doe posted

numerous spying numerous defaming numerous being for

communications
foreign

via

the

internet

accusing

governments via the

26.

Defendant

John

communications third parties.

internet

accusing

Hana Naas of Doe posted

27.

Defendant

John

communications

via

the

internet

accusing

Hana Naas of

untruthful.

28

Defendant stating

John that

Doe posted Suliman

numerous Dregia

communications divorce his

via wife

the Hana

internet

should

Naas
29.
Defendants communicated that plaintiffs engaged in criminal

conduct
30.
Defendants were had no expectation solely vindictive of defendants of profiting from this action

and actions

and made with were untrue

malice. and/or

31.

The communications

malicious

32.

The communications professional

of

defendants

were

intended

to

injure

plaintiffs'

and business of defendants

relationships were injurious to

33.

The communications business

plaintiffs'

relationships. of defendants were injurious to

34.

The communications professional

plaintiffs'

reputation. of defendants were injurious to

35.

The communications occupation.

plaintiffs'

36.

The communications public ridicule

of

defendants

were

intended

to

cause

plaintiffs

37

The communications

of

defendants

were

intended

to

cause

plaintiffs

shame and disgrace of defendants were intended to coerce

38.

The communications

plaintiffs

39. 40.
plaintiff

The communications The communications damaged personal

of of

defendants defendant relationships.

are were

actionable intended to

per

se

cause

THIRD CAUSE OF ACTION

DEFAMATION '1. Defendant Anonymizer, of John where Inc. facilitated the the above to the

communications servers

Doe by controlling the communications

connections posted Inc.,

and sites

were

The communications numerous being communications impure, via the

facilitated via using internet an unfit the

by Anonymizer, internet accusing words

included

Hana Naas of numerous abandoning

sexually

numerous

and phrases,

communications her via children the

accusing mother,

Hana Naas of numerous of being

and being

communications of impure birth,

internet

accusing via

Naas children the internet numerous defaming accusing

numerous spying internet for

communications foreign accusing via

accusing

Hana Naas of via the

governments, Hana Naas the of

communications third parties,

numerous being and Suliman

communications untruthful, numerous Dregia

internet

Hana Naas of father, that

communications communications should divorce profited via his

defaming the wife from

Hana Naas' stating

internet Hana Naas.

43.

Defendant

this

action

The communications 45
The communications and business

were untrue
were intended

and/or
to

malicious
injure plaintiffs'

professional

relationships were injurious to plaintiffs' business

46

The communications

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

48.

The communications

occupations

49.
ridicule

The communications

were

intended

to

cause

plaintiffs

public

so.

The communications

were

intended

to

cause

plaintiffs

shame

and disgrace 51. The communications The communications The communications damaged personal were are of intended actionable to coerce per were Be to cause plaintiffs.

52. 53.
plaintiff

defendant relationships

intended

FOURTH CAUSE OF ACTION DEFAMATION 54. Defendant Yousif Khaddar of aided action CAUSE OF ACTION DEFAMATION John Doe in the above First,

Second,

and Third

causes

FIFTH

55.

Defendants John Doe #1, John Doe #2, and John Doe #3 engaged
above conducts
their identities

in the
learning

and this

complaint

will

be amended upon

and addresses in a dollar defendants defendants compensatory amount cease within this this conduct, punitive

Plaintiffs Court's attorney damages relief jurisdiction, fees, in the

demand damages orders of

that the than

and because greater

motivations

an amount Court

damages I and othex

deems proper.

T3.mothy A. P3.rtle Licensed to practice law Ohio 0040970 Florida 0865613 Arizona 013644 1380 Zollinger Road Columbus, Ohio 43221 (614) 538-5375 (614) 538-5376 fax

.

.

in:

~ttested:

~4A.).~~'«~
Sul1.man Dregia

(l.

V~.Syc

- ~.

-

.

.:-

JURY DEMAND Plaintiffs demand a jury of their peers in this action