Filed: new york county clerk 01/02/2017 10:59 pm] NYSCEF DOC. NO. 1 INDEX NO. RECEIVED NYSCEF: 150005/2017 01/02/2017 SI PREMF. COl RT OF THE STATE OF NEW YORK COUNTY OF NEW YORK INDEX NO.. Dale Summons Filed: Plaintiffs Designate New York County as the Place of Trial Basis of Venue is : Plaintiffs Resilience SI MMONS Plaintiff resides in New York County ANGELE BR1LIHON BOLOU AI30DO. PLAINTIFF, -againstGOOOLE „ YAIKX)& BING,, DEFENDANTS. To the above named Defendant'. YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on the Plaintiff's Attorney within (201 days after the service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment w ill be taken against you by default for the relief demanded in the complaint. Dated ; Wappitigors Falls, New York January 1,2017 z Kyanne Kotian. Esq. Attorney for Plaintiffs 4 Marshal] Rd. Suite 10* Wappingers Falls. NY 12590 (8*8)536-1434 Defendant's Address: GOOGLE 111 Eight Avenue New York. NY 10011 YAHOO 229 West 43 Street New York, NY 10036 BING 11 Times Squares New York, NY 10036 1 of 5 SUPREME COLIKT OF rHE STATE OF NEW W)Rk COl MTV OF NEW YORK ANGEI I BRIUHON BOLOI ABODO, INDEX NO. PLAINTIFF, -againstVERIFIED COMPLAINT FOR DECLARATORY JliDCM ENT AND INJUNCTION RELIEF GOOGLE., YAIIOO.. A BING*. DEFENDANTS. TO THE A BOX E NAMED DEFENDANTS; PliiimifT, by her ai(orney RYANNE O. ttONAN, ESQ,, complaining of the defendants herein, respectfully shows to this court, and alleges as follows: FOR A CAl NF. OF ACTION IN FAX OR Ol ANCELE BKIL1HON BOLOI A BO DO L ITiot al all times herein mentioned, the Plaintiff. Angclc Briiihon Rolou ANkIo was and still is a resident of Now York City, County of New York. Suite of New York. 2. Thiii at all times herein mentioned, the Plaintiffs name. Angle Rrilihnn BoJou Abodo, is unique and exclusively belongs U> Plaintiff V I ha I at all limes herein mentioned, the Plaintiff s name gets its Originality from Africa, Ivory Coast, and PlaimifI is the unique person bearing the combination names of Angela Brilihon Rolim Abodo. ■1 That at all times herein mentioned, Plaintiff was and still is a student at New York 1 Jniversity (NYU) wherein Plaintiff studied and still is studying Psychology. 5. I hat at all times herein mentioned, GOOGLE was and still is a corporation w hich is a guide to digital information discovery, incused on informing, connecting, and entertaining through its search, communications, and digital content products, having a place of business at the following address: 111 Eight Avenue, New York, NY 100)1. f>, Thai at all times hensinalter mentioned, GOOGLE was and still is doing business in New York. 7. That at all times hereinafter mentioned, GOOGLE maintained and still maintains offices Hi­ stones in New York continuously staffed with one or more employees. 2 of 5 8. Thai at all times hereinafter mentioned, GOOGLE hud and still has agents and employees in New Yoik engaging in business for the corporation on the continuous, regular and s> sternal ic basis, 9. Thai at ail Limes hereinafter mentioned, GOOGLE was and still is a web search engine. 10. I hat at all limes hereinafter mentioned, the Defendant, YAIIOO was and still is a guide to digital information discovery, focused on informing, connecting, and entertaining through its search, conn mini cut ion. and digital content products, having a place of business at the following address: 229 West 43 Street, New York, NY 10036. 11. That at all times hereinafter mentioned, YAHOO was and still is doing business in New York 12, Thai at all times hereinafter mentioned, YAIiOO maintained and still maintains offices or stores in New York continuously staffed with one or more employees 13, 1 hiit at all times hereinafter mentioned. YAHOO had and still has agents and employ ees in New York engaging in business for the corporation on the continuous, regular and systematic basis. 14. 1 hat at all times hereinafter mentioned, the Defendant, Yahoo Was and still is a guide To digital information discovery, focused on informing, connecting, and entertaining through its search, communication, and digital content products, 15, That at all times hereinafter mentioned, Yahoo was and still is a web search engine. 16. llun at all limes hereinafter mentioned, the Defendant SING, was and si ill is a guide to digital information discovery, focused on informing, connecting, and entertaining through its search, communication, and digital content products, having a place of business at the following address: 11 limes Square. New York. New Yarik NY J0036. 17, Thai at all times hereinafter mentioned, BING was and still is doing business in New York. IS. t hat at all times hereinafter mentioned. BING maintained and still maintains offices or stores in New York continuously stalled with one or more employees. 19. That at all limes hereinafter mentioned. RING had and still has agents and employ ees in New York engaging in business for the corporation on the continuous, regular and systematic basis 2ft, Fhttt at all times hereinafter mentioned, the Defendant. RING was and still is a guide to digital information discovery, focused on informing, connecting, and entertaining through its search, communication, and digital content products. 3 of 5 21. That at all limes hereinafter mentioned, GOOGLE was and still is a web search engine operated by MICROSOFT. 22, Thai Plaintiff, is a female, and was in a relationship with a certain male named Sheldon Moulton on or about May 2015, 22, ['hat on Or about November 205 5, Sheldon Moulton, angry because Plaintiff bad ended the relationship, published seiuaJ tapes, secretly recorded by Moulton, on several pornographic websites. 24. That Plaintiff contacted all the pornographic websites, and all pornographic videos were removed from the pornographic websites. 25. That Plaintiff contacted Defendants. Google. Yahoo, and Bing lo remove the name ANGELE BRILIHON B OI.Ol1 ABODO from Defendants web search engine. 26. Thai the search of Plaintiff s full name on Defendants’ website led and still leads lo lewd and pornographic \ ideosof the Plaint i IT. and other derogatory comments aimed at Plaintiff and Containing Plaintiff s full name. 27, f liiii Plaintiff has been unable to obtain employment. 28 1 hat Plaintiff s reputation has been tarnished as result of 2y, lhat Defendants have ignored Plaintiff’s request. WHEREFORE, plaintiff prays for a judgment against defendants and each of them, under CPLR 630 J as follows: a. For a declaration that Defendants remove Plaintiffs full name from their search engine. b- Fox such other and further relief as ihe court deems proper. Dated: At Wappingers Falls. New York Yours, etc RYANNEG. KGNAK ESQ. December 12. 2016 Kvaime G. Koran I.sq. Am«iwy fix Plaintiff 4 Marshall Road Suite 107 Wapplngers Falls. NY 12590 Ph.: {KMtti 536-1434 FftV. (845123!-0508 4 of 5 9 Verification 1 hereby certify that all statements matte in the foregoing complaint arc true to the best of my knowledge and belief I am aware that willful false statement can subject me to punishment under the law hate Plaintiff"* Signatute ANGELfc BRJLIHON BOLOU ABODO Subscribed and sworn to hefore me on this. 15™ .day of * RYANNl GUV KOHAN notary Public ■ State of New Yurt W. Q2KM2356&I Qualified in Dutchess County My Commission. Empires feti 14. 2019 Notary 5 of 5 i