Complaint Review: Spray Tan LA & Rob Lonardo - Houston Texas

http://members.calbar.ca.gov/fal/Member/Detail/279263

Larry Castruita certainly is a lawyer with a perfect record.  Please present any evidence proving otherwise.  Thank you.

Rob Lonardo
Owner
Spray Tan LA
7857 West Sample Rd., #133 & 134
Coral Springs, FL  33065
(323) 549-9190

Wow - Rob Leonardo sure has the A TEAM of attorneys working for him! NOT! Good old Larry had been an attorney licensed in California for all of 6 months when he sent this crazy "Lawyer Letter" to the victim of Mr. Leonardo. His "Office" is really just a mail drop with a Beverly Hills address. He actually lives in a dump out in the San Fernando Valley. Since he and his client Leonardo love to threaten people by posting personal information online, It is time the tables were turned. 14065 La Rue St. in San Fernando is a long way from  "Beverly Hills" Larry. What other LIES have you told Larry?  

Maybe Larry should explain why he no longer works for Gary Fine. Let's just say his termination from the law firm was NOT amicable. 

Keep it up Larry and trust me, the State Bar will yank your law license in a heartbeat and you too could become one of Mr. Leonadro's "independent contractors". 

  

Law Offices of
LARRY CASTRUITA
9663 Santa Monica Blvd. Suite 903
Beverly Hills, CA 90210
Larry Castruita, Esq.
Direct: (323) 366 - 0650
[email protected]
______________________________________________________________________
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.

Rob, this is getting very borderline childish & I'm actually quite done with it all, honestly. Your lil' police report is bogus b/c I've never been approached about it, nor notified it was ever filed against me....that's typical procedure when there's a real criminal act been done & the police need to follow up. Now, I've attempted filling 2 on you for your shameful and leak of your true character & "professionalism" displayed on that joke of "bash site," as my lawyer referred to it. Since what was said is CLEARLY DEFAMATION OF CHARACTER, b/c everything stated in that filthy post can easily be proven false just by doing a simple Public Records search on me :) The policemen I spoke to said this is all a CIVIL matter & therefore I can file a report, but it'll go nowhere.....kinda like how you're report's gone nowhere. But, now I hear you tracked down my sister, called her demanding my home address, & other info along those lines-you're in serious trouble & pretty near to crossing that CIVIL line & into CRIMINAL territory....why else would you demand my home address, what for other than to come out here & do me harm? And, for all your CLAIMED professionalism, I have 1 word for you: Google. Type your name & do a search on yourself & read all the bad press & complaints from customers & former employees....they ALL echo my original statements made. There was nothing mentioning your own company's website until the 2nd page!!

 Wow....your own company's web page isn't even the 1st hit to pop up, you're sooooooo successful, yet you can't even afford a proper office to work from & "train" employees in & your nightly texts to your employees to go out drinking-thought you said you don't run your company like a nightclub? Well, could've fooled me!! Basically, let it go....before you go too far & really ruin your company's rep, here in the new locale you're trying to build it up in. And no, that wasn't a threat; just saying if you continue to take this further & further, well, you won't need my words to do you harm...you'll have brought all the rumors & negative hearsay upon yourself.

My name is Robert Lonardo and I am the owner of Spray Tan Los Angeles.  None of these reports that are defaming myself or my company are true.  Every person who placed a post on this website has done so anonymously and is the doing of a contractor we terminated named Andrea Somerville.  There are 16 of us who have filed criminal charges with the

Houston Police Department's homicide division against Andrea Marcella Somerville for harassment, stalking, assault, and battery.  A copy of the police report will be uploaded to this website.  The Houston police report number is 22330911G.

Please do not pay any attention to these posts by a disgruntled former business associate.  This is not reflective on my company and as you can see from her defaming posts nothing to do with our tanning business as well an me.

Here is all of my information as I have nothing to hide.  However, I do have a company and staff to be quite proud of! :>  It is VERY sad that the internet and websites like this have allowed mentally challenged people to use their keyboards as weapons of mass destruction.  Hopefully congress will limit what can be said and posted on the web to protect us all from these keyboard terrorists.

Thank you and good luck to all!

Rob Lonardo

Owner

Spray Tan Los Angeles

(310) 709-7157

[email protected]

www.spraytanla.com

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Again this is the same girl writing things about the company that is not true.As i had stated in the first report if it was not a professional company why would you have to take an exam to prove that you are worthy to represent this company.We have alot of celebrity clientel and have came out on GSN to encourage those who did not know about the company.I infact Spray Tan LA was a scam wouldnt you think that he wouldve had reports under his name already?or for this company to have gone down?..Since the company has been established no one has made any reports or remarks publicly like in the magazines or in the news paper which we have been in but have been praised for our good work ethic and professional outcome.As she put in about the credit card numbers the reason why he does this is because we do not pay for any of the equipment he provides us with everything so just like he is paying for all of our equipment for each one us he doesnt want us to run off with it and him loose out on his products and equipment and it be a free gift for us.Nothing here that is dont has been unprofessional or a scam because if it was us as stylists wouldnt be working here. This is just another case of bitterness ladys and gentlemen.From a woman who wasnt professional enough so had to be dismissed.Now a days you cant believe everything you read.We are a professional company,a mobile company,a praised company and a growing one.I suggest that you try our services before you jump to any conclusion about what has been posted by psycho daisy may.We are well noticed by the press and our celebrity clientel and by all of our clients which is why we are still in business and expanding.So dont believe every non sense like this because then you will loose out on something that you might later learn you really like.

I don't know either of you. However, the fact that you posted ID info on a internet site shows you are a person of low character.

Why would you compromise the ID of the author by posting her social security number, address, photo and all kinds of personal info? Obviously because you have either already used her ID for your own purposes or you are putting the info out for others to use. It is clear who the wacko is and it is not the original author.

I hope the owner of this site at least redacts the DL and SS info.

The author will need to freeze her credit files and go through the process of ID theft for sure now.

I don't know Andrea but I am a past employee of Spray Tan LA. I worked for Rob Lonardo months ago in Los Angeles and I am so happy I got out when I did! Luckily it only took me a few weeks to figure him out and to get away! I can tell you EVERYTHING this girl Andrea says is true. Beyond that, because luckily she didn't actually waste her time working for him. The scam is that he tells you his comapnay is so successful and they do 100's of spray tans a month. Your only commitment is to bring in 5 referrals a month. That's total BS. Spray Tan LA doesn't have 10 tans a week much less 100's a month. His goal is to hire a bunch of girls, get them to go out get all the business do all the work and only get a 30% cut. Which when he gives tans away for free or for $25 ends up being not enough for a drink at happy hour. He is verbally abusive to his employees and clients. He sexually harasses the woman and even makes scary threats to their lives, which is why so many women will not speak up. They are actually scared of what he will do to them. He is a criminal who should be locked away in prison. Perfect example...putting all of Andrea's personal information online is ILLEGAL! And OF COURSE it was him who did it! If he were an upstanding businessman who had nothing to hide he would have ignored what Andrea said as if she were not worth his time. The fact that he not only defended himself by calling her psycho but commited a crime by divulging her personal info just proves what kind of person he is. If he were an educated, knowlegeable businessman he would have NEVER compromised himself or his company by doing such a thing as putting her information online for the public. Did he really think people would turn on this poor girl because he said she way lying? All you have to do is google Rob Lonardo's name and you will see the 100's of complaints and comments on his charater. The lawsuits, the people who were robbed, the racism, the woman harassed. He is completely incapable of taking any accountability for his actions. He is a narsisitic sociapath. STAY AWAY HOUSTON!!!!! He is hazarradess to your future!

Andrea

(((REDACTED))))

TX DL # XXXXXXX

DOB: 06/24/1978

Height: 5-9

Weight: 150

Eyes: Brown

SS # XXX-XX-XXXX

This girl is a psycho and has been harassing all employees of this company and putting defaming posts which are all falsified information in a direct psychotic attempt to harm others.  Please contact her and let her know that this is not ok behavior.  Thanks.

City of Houston, Texas.

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