Complaint Review: Rob Lonardo Spray Tan LA

An explanation that you believe the report is not accurate in some way
(PLEASE BE SPECIFIC If you think the report is a hoax, please say so and
demand that the author provide some proof that the transaction/event really happened);

Contact information for people to reach you if they want more information;Any
other useful information which you believe an interested reader needs to know about you or your business.

My name is Rob Lonardo, owner of Spray Tan LA and I am here to defend my
reputation against this false, slanderous and unsubstantiated post.

Andrea Marcella Somerville was an independent contractor working with my company, Spray Tan LA.  As I was training her, she came into one of her training session drinking an alcoholic beverage with a friend of hers.  Immediately, I terminated our relationship with Andrea Marcella Somerville.

After the termination of our business relationship, Andrea Marcella Somerville decided to go on an online rampage of defaming posts in an attempt to hurt my company and hurt me personally.  Andrea Marcella Somerville stalked my staff and I so much that we were forced to file a formal report with the Houston Police Department.  

Spray Tan LA & I are not running any scams.  If you feel that we are I strongly encourage you to contact your local authorities.  My company and I are not hiding from anyone and our contact information as well as where you can find us will be at the end of this rebuttal.  Spray Tan LA does not employ shady sales tactics nor pressure sales (Please explain what you're speaking about here Andrea as you were a mere spray tan stylist trainee).  Spray Tan LA and I do not take advantage of girls wanting a tan as that would be a criminal offense.  All of these posts are personal attacks from Andrea Marcella Somerville of Houston, TX who is not playing with a full deck and has a tremendous amount of anger due to the fact her working relationship with Spray Tan LA was terminated.  I have never stolen money from people nor businesses and I would be happy to provide anyone with my personal details to background check me anytime ( I will even pay for any report fees).  I have never been a client of Sunset Tan as stated by Andrea Somerville.  I am not a scam artist after money and sex.  I am a good business man who sure is after making money and please google my pictures as you will see I have no problem in my personal life with females.  If anyone feels my company should be investigated by the IRS, please contact them and I will be happy to provide you with our FEIN number or anything else to help the IRS with any investigation your feel they should do.  Please be specific with your accusations of frauding different businesses, credit card fraud, real estate fraud, event promoters, etc.  Please provide concrete details on any of these false accusations with confirmable information.  I was in Houston, TX growing my company from starting in Los Angeles, then to Las Vegas, then to Houston.

Andrea Marcella Somerville, grow up.  Stop defaming good people who do good business.  You cannot substantiate one claim that you have here.  I am not hiding like you are with your ANONYMOUS post.  

If what you're saying is true why have you not filed a police report nor a suit.

Anyone can feel free to contact me anytime as I am not hiding anywhere:
Rob Lonardo
Spray Tan LA
7857 W. Sample Rd., #133
Coral Springs, FL  33065
323-549-9190

Thanks and Happy Tanning!

Law Offices of
LARRY CASTRUITA
9663 Santa Monica Blvd. Suite 903
Beverly Hills, CA 90210
Larry Castruita, Esq.
Direct: (323) 366 - 0650
larrycastruita@gmail.com
______________________________________________________________________
March 21, 2012
CEASE & DESIST AND OFFER TO SETTLE
Sent Via U.S. MAIL Delivery
Andrea M. Somerville
3 Markham Grove Place
Shenandoah, TX 77381-2993
55 Columbia Crest Place
The Woodlands, TX 77382
Ms. Somerville:
This office represents Robert Lonardo and Spray Tan Los Angeles, Inc. (including subsidiary companies). Mr.
Lonardo has asked me to review your actions in connection with him and his company and has requested
commencement of legal action against you for civil damages growing out of your collective repeated false
allegations, harassment, slander, libel, defamation, and tortuous interference with business relations.
Before initiating legal action, this letter is an offer to settle the matter amicably.
More than most common remedies available to him at law, Mr. Lonardo simply wants to move beyond any
connection to you, and to try to put this matter behind him and his company.
I have read your work on websites such as ripoffreport.com and others. While I respect your first amendment right
to voice your opinion, there are very strict laws prohibit you from making false, or grossly negligent statements, and
statements that are intended to unlawfully interfere with business relations. Stating publically that Spray Tan LA
and the owner Rob Lonardo are currently running a spray tan scam that offers a free tan and then they bill you for a
full tan package even though you never agreed to it is prima facie libel unless you were a witness or victim of this
exact occurrence. In a more extreme example, publically stating that someone is drug running without any factual
basis for this claim would satisfy all elements for slander, and painting in false light. Purposely publically making
these, and many other, false statements on nationally interactive websites intending to negatively affect future
business of Spray Tan LA, brings about, yet another cause of action for interfering with business relations and is the
crux of all a majority of the claims listed above. The damages you have already cases for these three actions alone
are serious and ongoing.
I believe the easiest way to get past this is;
(1) For you to, obviously, cease and desist from your repeated acts of defamation and harassment of
Robert Lonardo, Spray Tan Los Angeles, Inc. (including subsidiary companies), and any person or entity, affiliated
or doing business with Spray Tan Los Angeles, Inc. (including but not limited to online posts); and
(2) To respond within 20 days of your receipt of this letter with a letter signed by you which states that your
accusations in all posts regarding Robert Lonardo, Spray Tan Los Angeles, Inc. (including subsidiary companies),
and any person or entity, affiliated or doing business with Spray Tan Los Angeles, Inc. were knowingly false and
exaggerated and caused by emotion rather than any factual knowledge.
While I assume, based on your past correspondence with my client, your initial reaction to the above may be less
that accepting, I can tell you that by simply fulfilling the above demands, which basically puts everybody back to
where they were, you will avoid various state and federal civil and criminal liabilities, not to mention what could be
a very expensive legal process, especially if/when you end up having to pay my bill (see section on legal fees
below). Furthermore, the letter requested is specifically because the websites that you have chosen to post false and
damaging information have a very strict policy of not removing any posts. The easiest way to refute your decision
to post such unlawful statements would be this simple letter that my client could simply show to prospective
customers and affiliates in an effort to patch up the very big mess you have made.
Simply put, writing a simple letter will save you a tremendous amount of time and a substantial amount of money.
. . .
As much as your correspondence states your interpretation of Texas law. You will likely be compelled to defend
this case in California, for which I would encourage you to seek representation of a California certified attorney.
The agreement with Spray Tan Los Angeles, Inc. that you validly executed on February 14, 2011 states that
California Law would govern the contract. As a courtesy I will tell you that not understanding the ramifications of
what is included in a contract you sign is not a defense. I am sure your attorney will tell you about a case called
Burger King v. Rudzewicz wherein two business men entered into an agreement to franchise a store in Michigan.
The Supreme Court held that they purposefully availed themselves of the protections of Florida, therefore subject to
jurisdiction Florida and that due process would not be violated because the defendants should have reasonably
anticipated being summoned into court in Florida for breach of contract.
Moreover, a state has personal jurisdiction over any party whose actions intentionally reach another party in the state
and are the basis for the cause of action. Your internet posts, although written in Texas, were intended to reach the
entire audience of the websites you posted them on. Specifically the fact that you knew the name of the company
refers to a city in California where the company was incorporated lends itself to the fact that you were attempting to
intentionally reach and affect Spray Tan LA, a California corporation and would subject you to jurisdiction in
California.
I strongly encourage you to stop doing those actions that have created this trouble and return to a life as though
Spray Tan Los Angeles, Inc. does not exist, and you can forward the letter of apology to me at either the mailing or
email address at the top of this letter. I realize and do not care that the apology may be insincere. Please refrain
from any further contact with my clients. I encourage you to have your attorney contact me at the contact info at the
top of this letter in an effort to further this offer to settle along.
This letter does not constitute a complete or exhaustive statement of all or any of our clients rights or claims.
Nothing stated herein is intended as, nor should it be deemed to constitute, a waiver or relinquishment of any of my
clients rights or remedies, whether legal or equitable, all of which are hereby expressly reserved. This letter is a
confidential legal communication and is not for publication.
Very truly yours,
//ELECTRONICALLY SIGNED//
Larry Castruita, Esq.

I have been a cerrtified stylist at Spray Tan LA for acouple months now.My opinion is that infact if a company was not professional at all they would have celebrity clientel as we do..and because of that if our products and tans were "horrible" as i quote then those celebrities would infact bash us in the magazines we all read or news papers today so no one would come to us at all.That has not happend besides on this website and the and the dirty.Which by surprise those are the little websites were random people state their "opinion"..or bash.If infact what the origional report stated was true the bussiness would not be attending GSN live and be praising us for our good work ethic and great service.Rob Lonardo is the CEO of our company but he is not a scam artist.As for only hiring an attractive female staff for his own benefit is not true.Our stylist have to learn the guidlines,training manual and handbook before they can become a stylist at Spray Tan LA.This is to ensure Rob and our clients that they are being well taken care of and that we "can" answer any question that they might have.Before being a professional stylist you also have to pass a test that you must take after your training to reasure Rob that you are well educated on all the products and training beofre you can become part of the staff.So,if Spray Tan LA was not a professional company then why would Rob go through the trouble of having a test to prove that you are ready to represent his company in a professional and organized manner?..with that being said i believe in this company and i have not heard from any of our celebrity clientel or any "REAL" client that this company is a scam and they didnt benefit from our services so i strongly suggest you dont believe every negative thing you read.Try our products and services for yourself and see what the outcome maybe.