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JOHN O'GRADYCLERK OF THE FRANKLIN COUNTY COMMO. PLEAS COURT, COLUMBUS, OHIO 43215CIVIL DIVISION

HANA HAAS406 EAST HARROGATELOOPWESTERVILLE, OH 43082-0000,

PLAINTIFF,VS.ANONIM ZER IKC#4265694 MISSION CENTER ROADSAN DIEGO, CA 92108-0000,

DEFENDANT.12/21/01UMIIONS

TO THE FOLLOWING NAKED DEFENDANT:ANONYMIZER INC*4265694 MISSION CENTER ROADSAN DIEGO, CA 92108-0000

YOU HAVE BEEN NAMED DEFENDANT IN A COMPLAINT FILED IN FRANKLIN COUNTYCOURT OF COMMONPLEAS, FRANKLIN COUNTY BALL OF JUSTICE, COLUMBUS, ORIO,BY: BANA NAAS406 EAST HARROGATELOOPWESTERVILLE, OR 43082-0000,

PLAIIfTIFF(S)A COpy OF THE COMPLAINT IS ATTACHED HERETO. THE NAME AND ADDRESS OFTHE PLAINTIFF'S ATTORNEY IS:TIMOTHY A. PIRTLEATTORNEY AT LAW1380 ZOLLIKGER ROADCOLUMBUS, OH 43221-0000YOU ARE HEREBY SUKKONEDAND REQUIRED TO SERVE UPON THE PLAINTIFF'SATTORNEY, OR UPON THE PLAINTIFF, IF HE HAS NO ATTORNEY OF RECORD, A COpyOF AN ANSWERTO THE COMPLAINT WITHIN TWENTY-EIGHT DAYS AFTER THE SERVICEOF THIS SUKMONSON YOU, EXCLUSIVE OF THE DAY OF SERVICE. YOUR ANSWERMUST BE FILED WITH THE COURT WITHIN THREE DAYS AFTER THE SERVICE OF ACOpy OF THE ANSWERON THE PLAINTIFF'S ATTORNEY.IF YOU FAIL TO APPEAR AND DEFEND, JUDGMENTBY DEFAULT WILL BE RENDEREDAGAINST YOU FOR THE RELIEF DEMANDED N THE COMPLAINT.JOHN O' GRADYCLERK OF THE CONNONPLEASFRANKLIN COUNTY, OHIO

JOHN HYKES, DEPUTY CLERKY:

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JOHN 0' GRADYCLERK OF THE FRANKLIN COUNTY COMMON LEAS COURT, COLUMBUS, OHIO 432~5CIVIL DIVISION JUDGE J. BRUNNER

HANA NAASET. AL.,

PLAINTIFF,OlCVC-12-12620

VB. CASE NtTMBERANONYMIZER IHCET. AL., DEFENDANT.

CLERK'S ORIGINAL CASE SCHEDULE LATEST TIMEOF OCCURRENCE12/21/01ASE FILED

INITIAL STATUS CONFERENCE05/10/02NITIAL JOINT DISCLOSURE OF ALL WITNESSES07/05/02UPPLEMENTALJOINT DISCLOSURE OF ALL WITNESSES07/19/02RIAL CONFIRKATION DATE09/27/02ISPOSITIVE MOTIONS10/11/02ISCOVERY CUT-OFF11/22/02ECISIONS ON MOTIONS12/06/02 0130PIIFINAL PRE-TRIAL CONFERENCE/ORDER OR BOTH)01/02/03 0900AKTRIAL ASSIGNMENT

NOTICE TO ALL PARTIES

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

BY ORDER OF THE COURT OF COMMONPLEAS,FRAHKLIN COUNTY, OHIO

JOHK 0 I GRADY, CLERK(CIV363-S10)

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IN THE COURT OP COIOCONPLBASFRANKLIN COUNTY, OKlOHana Naas406 East Harrogate LoopWesterville, Ohio 43082 Case No.and B~"'nnerudgeSuliman Dregia406 East Harrogate LoopWesterville, Ohio 43082

Plaintiffs,va

Anonymizer, Inc.#4265694 Mission Center RoadSan Diego, California 92108,andYousif Khaddaraddress currently unknown,andJohn Doe il,John Doe #2,John Doe #3,

Defendants.RECI:TALS

Hana Naas is the spouse of Suliman Dregia, and the daughteJof Abdelrahim Haas.

COKPLADrl'FIRST CAUSE OF ACTION

DEFAMATIONDefendant John Doe posted numerous communications via the1.

internet defaming Kana Naas

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

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

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

Defendant John Doe posted numerous communications via theinternet accusing Hana Naas of spying for foreign governments

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

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

Defendant John Doe posted numerous communications via theinternet defaming Hana Naas' father

Defendants communicated that plaintiffs engaged in criminalconduct.10 Defendants had no expectation of profiting from this actionand actions were solely vindictive and made with malice.

The communications of defendants were untrue and/or1malicious

The communications of defendants were intended to injure2.plaintiffs' professional and business relationships13. The communications of defendants were injurious toplaintiffs' business relationships14. The communications of defendants were injurious toplaintiffs' professional reputation.

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The communications of defendants were injurious to5.plaintiffs' occupation.

The communications of defendants were intended to cause6plaintiffs public ridicule.

The communications of defendants were intended to cause7.plaintiffs shame and disgrace.

The communications of defendants were intended to coerce8plaintiffs

The communications of defendants are actionable per se.19.The communications of defendant were intended to cause

plaintiff damaged personal relationships.SECOND CAUSE OF ACTION

DEFAMATIONDefendant John Doe posted numerous communications via the

internet defaming Suliman DregiaDefendant John Doe posted numerous communications via the2

internet accusing Hana Naas of being sexually impure, usingnumerous words and phrases

Defendant John Doe posted numerous communications via the3.internet accusing Hana Naas of abandoning her children and beingan unfit mother

Defendant John Doe posted numerous communications via the4.internet accusing Naas children of being of impure birth

Defendant John Doe posted numerous communications via the5.internet accusing Hana Naas of spying for foreign governments

Defendant John Doe posted numerous communications via the6.internet accusing Hana Naas of defaming third parties.

Defendant John Doe posted numerous communications via the7.internet accusing Hana Naas of being untruthful.

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Defendant John Doe posted numerous communications via the8internet stating that Suliman Dregia should divorce his wife HanaNaas

Defendants communicated that plaintiffs engaged in criminal9.conduct

Defendants had no expectation of profiting from this action0.and actions were solely vindictive and made with malice.

The communications of defendants were untrue and/or1.malicious

The communications of defendants were intended to injure2.plaintiffs' professional and business relationships

The communications of defendants were injurious to3.plaintiffs' business relationships.

The communications of defendants were injurious to4.plaintiffs' professional reputation.

The communications of defendants were injurious to5.plaintiffs' occupation.

The communications of defendants were intended to cause6.plaintiffs public ridicule37 The communications of defendants were intended to causeplaintiffs shame and disgrace38. The communications of defendants were intended to coerceplaintiffs

The communications of defendants are actionable per se9.The communications of defendant were intended to cause0.

plaintiff damaged personal relationships.

THIRD CAUSE OF ACTION

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DEFAMATIONDefendant Anonymizer, Inc. facilitated the above'1.

communications of John Doe by controlling the connections to theservers and sites where the communications were posted

The communications facilitated by Anonymizer, Inc., includednumerous communications via the internet accusing Hana Naas ofbeing sexually impure, using numerous words and phrases, numerouscommunications via the internet accusing Hana Naas of abandoningher children and being an unfit mother, numerous communicationsvia the internet accusing Naas children of being of impure birth,numerous communications via the internet accusing Hana Naas ofspying for foreign governments, numerous communications via theinternet accusing Hana Naas of defaming third parties, numerouscommunications via the internet accusing Hana Naas of beinguntruthful, communications defaming Hana Naas' father, andnumerous communications via the internet stating that SulimanDregia should divorce his wife Hana Naas.43. Defendant profited from this action

The communications were untrue and/or maliciousThe communications were intended to injure plaintiffs'5

professional and business relationshipsThe communications were injurious to plaintiffs' business6

relationships.The communications were injurious to plaintiffs'

professional reputationThe communications were injurious to plaintiffs'8.

occupationsThe communications were intended to cause plaintiffs public9.

ridicule

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The communications were intended to cause plaintiffs shameso.and disgrace

The communications were intended to coerce plaintiffs.1.The communications are actionable per Be2.The communications of defendant were intended to cause53.

plaintiff damaged personal relationshipsFOURTH CAUSE OF ACTION

DEFAMATIONDefendant Yousif Khaddar aided John Doe in the above First,54.

Second, and Third causes of actionFIFTH CAUSE OF ACTION

DEFAMATIONDefendants John Doe #1, John Doe #2, and John Doe #3 engaged5.

in the above conducts and this complaint will be amended uponlearning their identities and addresses

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

. .T3.mothy A. P3.rtleLicensed to practice law in:Ohio 0040970Florida 0865613Arizona 0136441380 Zollinger RoadColumbus, Ohio 43221(614) 538-5375(614) 538-5376 fax

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~ttested:

~4A.).~~'~ (l. V~.Syc .:-- ~. - .Sul1.man Dregia

JURY DEMANDPlaintiffs demand a jury of their peers in this action