Alyssa Rossman v. Young Berman Karpf and Gonzalez Supplemental Amended Agreed Order and Permanent Injunction - Google Deindexing-Removal Request per Google's Lumen Database at lumendatabase.cog
Alyssa Rossman v. Young Berman Karpf and Gonzalez Supplemental Amended Agreed Order and Permanent Injunction - Google Deindexing-Removal Request per Google's Lumen Database at lumendatabase.cog
Alyssa Rossman v. Young Berman Karpf and Gonzalez Supplemental Amended Agreed Order and Permanent Injunction - Google Deindexing-Removal Request per Google's Lumen Database at lumendatabase.cog
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE 16003115 (05)
ALYSSA ROSSMAN,
Petitioner,
v.
YOUNG, BERMAN, KARPF &
GONZALEZ, P.A.,
Respondent,
PLEMENTAL Al ED ORDER AND PERI iCTION
THIS CAUSE having come before the Court upon consideration of the Settlement
‘Agreement and Release between ALYSSA ROSSMAN (“ROSSMAN”) and the law firm of
YOUNG, BERMAN, KARPF & GONZALEZ, P.A. (“YBKG"), in which the parties agree to
the entry of such a Supplemental Amended Agreed Order and Permanent Injunction, and the
Court being fully advised in the premises, it is hereby:
IT IS ORDERED, ADJUDGED, AND DECREED that:
1. This Court’s August 19, 2016 Agreed Order and Permanent Injunction is hereby
amended with respect to Google.
2. There is Digital Defamation against “YBKG" and its members which appears on:
a, _http://www.ripofireport.com/r/Y oung-Berman-Karpf-Gonzalez-PA/Ft-
Lauderdale-Florida-33394/Y oung-Berman-Karpf-Gonzalez-PA-Overbilled-Misled-Took-
‘Advantage -and-Chumned.my Di 1280768;
b.http/iwww.ri t.com/reports/young-berman-karpf-gonzalez-
Jauderdale-florida-33394/young-berman-karpf-gonzalez-pa-overbilled-misled-took-c. m.tipoffreport,com/reports/young-berman-karpf- -palft
--florida~: 1/young-berman-| f-5 \-overbilled-misled-took-
advantage-and-chumed-my-di-1289768 (collectively referred to herein as “Report
#1289768”),
3. The statements posted by ROSSMAN in Report #1289768 are inaccurate and
incomplete, thereby portraying YBKG and its members in a false light, and are therefore
unlawful. As such, ROSSMAN has voluntarily retracted her statements contained in Report
#1289768 and agrees that they should be removed from Ripoffreport.com, all websites which
reproduced her statements, and she agrees that all such websites and the aforementioned
link/teport should be delisted and removed from all scarch-engines and searck results.
4. A copy of ROSSMAN’S retraction and sworn affidavit affirming same are
attached hereto and made a part hereof as Composite Exhibit “A.”
Based on the foregoing, it is ORDERED AND ADJUDGED that:
5S. Report #1289768 located at: 1) httpy/www.ripoffreport.com/1/Young-! 7
f-Gonzalez-PA/Ft-Lauderdale-Florida-33394/Y oung-Berman-Karpf-Gonzalez-PA-
Overbilled-Misled-Took-Advantage-and-Churned-my-Di-1289768;
2)__http://www sipoffteport.com/reports/young-berman-karpf-gonzalez-pa/ft-lauderdale-florida-
1289768 is unlawful and shall be immediately removed from Ripoffreport.com. Until it is
removed, all references to YBKG or any of its named lawyers shall be redacted.6. ROSSMAN or YBKG may submit this Order to all search engines, including, but
not limited to: (1) Google; (2) Yahoo; and, (3) Bing, so that the links
(Whttp:Lfowww.i -Karpf-Gonzalez-PA/Ft-Lauderdale-Flori
|-Took-Advantage-and-Chued-
my-Di-1289768;
(2) hup://www.ripoffreport.com/reports/ young-berman-karpf-gonzalez-pa/ft-lauderdale-florida-
'394/voung-berman-karpf-gonzalez-pa-overbilled-misled-took-advantage-and- -my-di-
1289768:
@ muripoffreport.com/reports/voung-berman-karpf-gonzalez-pa/ft-lauderdale-florida-
33394/young-berman-karpf-gonzalepe-overbilled-misled-took-advantage-and-chumed-my-di-
1289768)
may be removed from their search results pursuant to their existing policies conceming de-
indexing, delisting, and/or otherwise removing from its search algorithms the defamatory and
unlawful material, such that the webpage does not appear as a search result in any search
whatsoever, including, but not limited to, any search related to YBKG or any other forms of the
Jaw firm's name or names of its attorneys, including but not limited to any searches which
include the following terms/names, whether in whole or included with additional search terms:
Young, Berman, Karpf & Gonzalez
Brian Karpf
Mitchell Karpf
Mitch Karpf
‘Andrew Berman
Andy Berman
Additionally, any negative implications related to YBKG and any of its lawyers which arose as a
result of the aforementioned webpage may also be removed in accordance with the policies and
procedures of said search engine (¢.g., the name of the firm or any of its lawyers and the word“complaint” may be removed from suggested search results, such as “Brian Karpf complaint” or
“Young Berman Karpf & Gonzalez complaint”).
7. This Order and Injunction shall not be binding on any third party to the extent it
‘would violate and be unenforceable pursuant to existing laws.
8. YBKG may submit this Order and Injunction to any entity so that such
defamation can be removed or otherwise de-indexed/delisted at any time now or in the future, if
removal is consistent with its or their policies.
9. This Order and Injunction shall similarly apply to any entity to whom it is sent as
may be necessary to accomplish the intent hereof.
it: ~ 10: YBK6Fis without am-adequate remedy at law and -will be irreparablyéajured ~
unless this Court enters this Order and Injunction. There is a genuine need and justification for
this Order and Injunction to be granted.
11, This Order and Injunction is effective immediately and shall remain in full force
and effect until further Order of this Court.
12. YBKG and/or ROSSMAN are not required to post a bond for the entry of this
(Order and Injunction,
13. This Court reserves jurisdiction to enforce this Order and Injunction and the
Seitlement Agreement and Release entered into between ROSSMAN and YBKG on August 16,
2016. s™M
DONE AND ORDERED in Chambers in Broward County, Florida on this 0 day ofINSTR # 113901731 Page 5 of 7
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‘who being by ine ft ty sworn; Gapoees und ‘ryi fiom personal nnoWedge:
1," My mame is ALYSSA ROSSMAN,
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‘eugion paapanies, suchas Googe, Yahoo, Bing, and ary other exfitics ot persocs that YB in
EXHIBIT “A”INSTR # 113901731 Page 6 of 7
‘ts sole ite dpa neceesery, ordering Histo
leith och tla della, eave or ove the Report a pai iv on
‘ph eat whence he itr any of ba mbes nach, such ha
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1 ed to remove the prior post but was usb to do so, The porting was made in reqpoue to
ini ta fhe low frm made gait me. Th noes have sac ben realved. 1 do ool contest
the foca I paid and Iam stig with he lgl service which the fem provided, Tretot wy
cuter watoments, They ee aot x compe rprosattion ofthe contentious and difSiculimacs
in ny cam or he work dane bythe lewyes, The lawyer, inehsing Bran Kapf end Mich Karp,
Lelpod me daring 4 vary dificult tne fe my tie YOU: SHOULD NOT ALLOW MY
STATEMENTS TO DETER YOU FROM HIRING THIS FIRM OR ANY OF ITS LAWYERS,
EXHBIT “B”