Petition To Seize Assets of Asian Massage Businesses and Owners in Missouri

You might also like

Download as pdf or txt
Download as pdf or txt
You are on page 1of 22

Electronically Filed - Greene - July 20, 2017 - 02:00 PM

1731-CC00950

IN THE CIRCUIT COURT OF GREENE COUNTY


STATE OF MISSOURI

STATE OF MISSOURI ex rel. )


ATTORNEY GENERAL JOSHUA D. )
HAWLEY and DANIEL PATTERSON, )
)
Petitioners, )
) Cause No. 1731-CC______
v. )
) Div. ___
GOLDEN MASSAGE f/k/a GOLDEN )
MASSAGE SPA, LLC )
SERVE AT: )
4728 South Campbell #112 )
Springfield, MO 65810; )
)
DAQUIONG WANG )
SERVE AT: )
4728 South Campbell #112 )
Springfield, MO 65810; )
)
PHOENIX MAGIC MASSAGE LLC, )
d/b/a PHOENIX MASSAGE )
SERVE REGISTERED AGENT: )
c/o Hongbo Qi )
1261 East Republic )
Springfield, MO 65804; )
)
PHOENIX ORIENTAL MASSAGE LLC, )
d/b/a PHOENIX MASSAGE )
SERVE REGISTERED AGENT: )
c/o Hai Biao Fu )
1261 East Republic )
Springfield, MO 65804; )
)
WANHUA TIAN, d/b/a )
PHOENIX MASSAGE )
SERVE AT: )
1405 Camino Alto )
Springfield, MO 65804 )

1
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
)
ZEMIN GUO, d/b/a )
PHOENIX MASSAGE )
SERVE AT: )
1405 Camino Alto )
Springfield, MO 65804 )
)
HONGBO QI )
SERVE AT: )
1261 East Republic )
Springfield, MO 65804; )
)
RELAX MASSAGE, a/k/a RELAX SPA )
SERVE AT: )
2022 South Stewart )
Springfield, MO 65804; )
)
SHENG YANG )
SERVE AT: )
2022 South Stewart )
Springfield, MO 65804; )
)
XIAO CHEN )
SERVE AT: )
2022 South Stewart )
Springfield, MO 65804; )
)
HUI OTIS d/b/a ANGEL MASSAGE )
SERVE AT: )
3731 South Glenstone, #284, )
Springfield, MO 65804 )
)
FENGHUA LI d/b/a ANGEL MASSAGE )
SERVE AT: )
2015 West University Street, )
Apt #D408, )
Springfield, MO 65807 )
)
YANG YONGZHEN d/b/a )
ANGEL MASSAGE )
SERVE AT: )

2
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
2015 West University Street, )
Apt #D408, )
Springfield, MO 65807 )
)
GREAT SPA )
SERVE AT: )
2841 South Fremont )
Springfield, MO 65804; )
)
MEI XIANG CUI )
SERVE AT: )
2841 South Fremont )
Springfield, MO 65804; )
)
YANMEI WANG d/b/a )
ASIAN MASSAGE )
SERVE AT: )
2412 South Fort Avenue, )
Springfield, MO 65807 )
)
Respondents. )

PETITION

Petitioners State of Missouri, at the relation of Attorney General

Joshua D. Hawley and Prosecutor Daniel Patterson, bring this Petition, and

upon information and belief, state as follows:

Nature of the Action

1. In this action, Attorney General Joshua D. Hawley and Greene

County Prosecutor Daniel Patterson seek to enjoin sixteen defendants from

conducting flagrant human trafficking and prostitution activity in

Springfield, Missouri, under the false pretenses of operating massage parlors.

Under Missouri law, “[a]ny room, building or other structure regularly used

3
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
for any prostitution activity by this chapter is a public nuisance.”

§ 567.080.1, RSMo. “The attorney general, circuit attorney or prosecuting

attorney may, in addition to all criminal sanctions, prosecute a suit in equity

to enjoin the nuisance.” § 567.080.2, RSMo. “All persons, including owners,

lessees, officers, agents, inmates or employees, aiding or facilitating such a

nuisance may be made defendants in any suit to enjoin the nuisance, and

they may be enjoined from engaging in any prostitution activity anywhere

within the jurisdiction of the court.” § 567.080.3. Pursuant to this authority,

Attorney General Joshua D. Hawley and Prosecutor Daniel Patterson seek

preliminary and permanent injunctive relief barring the persons, entities,

and locations involved in these human-trafficking and prostitution activities

from any further participation in prostitution activity.

Parties

2. Joshua D. Hawley is the duly elected Attorney General of the

State of Missouri and brings this action in his official capacity pursuant to

Chapter 567 of the Missouri Revised Statutes.

3. Daniel Patterson is the duly elected Prosecuting Attorney of

Greene County, Missouri and brings this action in his official capacity

pursuant to Chapter 567 of the Missouri Revised Statutes.

4
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
Golden Massage

4. Respondent Golden Massage holds itself out as a massage parlor

and has a principal place of business at 4728 South Campbell Avenue, Suite

112, Springfield, Missouri 65810. Golden Massage had previously been

operating as Golden Massage Spa, LLC, d/b/a Golden Massage. On June 7,

2017, the Missouri Secretary of State administratively dissolved Golden

Massage Spa, LLC for failure to maintain a registered agent. On information

and belief, Golden Massage is no longer registered with the State of Missouri.

5. Daquiong Wang is an owner, officer, agent, or employee of Golden

Massage, and, on information and belief, resides in Missouri and can be

found at 4728 South Campbell Avenue, Suite 112, Springfield, Missouri

65810.

Phoenix Massage

6. Phoenix Massage holds itself out as a massage parlor with a

principal place of business at 1261 East Republic Rd, Springfield, Missouri

65804.

7. Phoenix Massage is licensed with the City of Springfield under

the name Phoenix Magic Massage, LLC.

8. Phoenix Massage is a fictitious business name registered with

the State of Missouri and owned by Phoenix Oriental Massage, LLC, Wanhua

Tian, and Zemin Guo. Phoenix Massage; Phoenix Magic Massage, LLC, d/b/a

5
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
Phoenix Massage; Phoenix Oriental Massage, LLC, d/b/a Phoenix Massage;

Wanhua Tian, d/b/a Phoenix Massage; and Zemin Guo, d/b/a Phoenix

Massage will be collectively referred to as “Phoenix Massage.”

9. Phoenix Magic Massage, LLC is Missouri limited liability

company and an owner or agent of Phoenix Massage, and has a principal

place of business at 1261 East Republic Road, Springfield, Missouri 65804.

10. Phoenix Oriental Massage, LLC is an owner or agent of Phoenix

Massage, and has a principal place of business at 1261 East Republic Road,

Springfield, Missouri 65804.

11. Wanhua Tian is an owner, officer, agent or employee of Phoenix

Massage, and resides at 1405 Camino Alto, Springfield, Missouri 65804.

12. Zemin Guo is an owner, officer, agent or employee of Phoenix

Massage, and resides at 1405 Camino Alto, Springfield, Missouri 65804.

13. Hongbo Qi, also known as Qi Hong Bo, is an owner, officer, agent,

or employee of Phoenix Massage. Hongbo Qi, on information and belief,

resides in Missouri and can be found at Phoenix Massage, 1261 East Republic

Road, Springfield, Missouri 65804.

Relax Massage

14. Relax Massage, a/k/a Relax Spa, holds itself out as a massage

parlor and has a principal place of business at 2022 South Stewart Avenue,

Springfield, Missouri 65804. Relax Massage is not registered with the State

6
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
of Missouri, but it has a business license from the City of Springfield under

the name “Relax Massage.”

15. Sheng Yang is an owner, officer, agent, or employee of Relax

Massage, and, on information and belief, can be found at 2022 South Stewart

Avenue, Springfield, Missouri 65804.

16. Xiao Chen is an owner, officer, agent, or employee of Relax

Massage, and occasionally resides at Relax Massage, 2022 South Stewart

Avenue, Springfield, Missouri 65804.

Angel Massage

17. Angel Massage holds itself out as a massage parlor and is a

fictitious business name registered with the State of Missouri and owned by

Hui Otis, Fenghua Li, and Yang Yongzhen. Angel Massage has a principal

place of business at 1774½ South Grant Avenue, Springfield, Missouri 65807.

This business is licensed with the City of Springfield as Angel Massage Spa.

Angel Massage; Angel Massage Spa; Hui Otis, d/b/a Angel Massage; Fenghua

Li, d/b/a Angel Massage, and Yang Yongzhen, d/b/a Angel Massage will be

collectively referred to as “Angel Massage.”

18. Hui Otis is an owner, officer, agent, or employee of Angel

Massage, and resides at 3731 South Glenstone, #284, Springfield, Missouri

65804.

7
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
19. Fenghua Li is an owner, officer, agent, or employee of Angel

Massage, and resides at 2015 West University Street, Apt #D408,

Springfield, Missouri 65807.

20. Yang Yongzhen is an owner, officer, agent, or employee of Angel

Massage, and resides at 2015 West University Street, Apt #D408,

Springfield, Missouri 65807.

Great Spa

21. Great Spa holds itself out as a massage parlor and has a

principal place of business at 2841 South Fremont, Springfield, Missouri

65804. Great Spa is not registered with the State of Missouri, but it has a

business license from the City of Springfield under the name Great Spa.

22. Mei Xiang Cui is an owner, officer, agent, or employee of Great

Spa, and may be found at 2841 South Fremont, Springfield, Missouri 65804.

Asian-Rainbow Massage

23. Asian Massage holds itself out as a massage parlor and is a

fictitious business name registered with the State of Missouri and owned by

Yanmei Wang. Yanmei Wang, d/b/a Asian Massage, has a principal place of

business at 2005 East Kearney Street, Suite I, Springfield, Missouri 65803.

This business is licensed with the City of Springfield as Asian Massage. This

business is sometimes held out to the public and advertised as “Rainbow

8
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
Massage.” Asian Massage, Rainbow Massage, and Asian-Rainbow Massage

will be collectively referred to as “Asian-Rainbow Massage.”

24. Yanmei Wang is an owner, officer, agent, or employee of Angel

Massage, and resides at 2412 South Fort Avenue, Springfield, Missouri

65807.

25. All respondents have done business within the State of Missouri,

including Greene County, by operating massage parlors that are regularly

used for prostitution activity.

Jurisdiction

26. This Court has subject matter and personal jurisdiction over this

action under Art. V, § 14 Mo. Const. and § 506.500, RSMo.

Venue

27. Venue is proper in this Court pursuant to § 508.010.2, RSMo, in

that there are several defendants, and venue lies in any county in which a

Defendant resides.

28. Venue is proper because Respondents’ businesses reside within

Greene County.

Statutory Authority

29. Section 567.080, RSMo, declares the regular use of a room,

building, or structure for prostitution activity to be a public nuisance, and

allows the Attorney General to prosecute a suit to enjoin the nuisance. The

9
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
Attorney General may include owners, lessees, officers, agents, or employees

as defendants in such an action to enjoin prostitution activity.

Respondents’ Human Trafficking and Prostitution Activities

30. For years, massage parlors located throughout Springfield,

Missouri have been creating a public nuisance by “providing sexual contact

for pay and/or unlawful prostitution activity” on premises located in Greene

County, Missouri. At each location, Respondents utilize young—and,

typically, Asian immigrant—females (“Victims”) to carry out sexual contact

with customers of the massage parlors in exchange for money and/or other

items of value.

31. The Missouri State Highway Patrol has carried out hundreds of

hours of surveillance of dozens of massage parlors located in Greene County,

including all Respondent massage parlors herein.

32. The Missouri State Highway Patrol and Springfield Police have

each contacted numerous individuals seen leaving the Respondents’

businesses. Individuals reported receiving massages at Respondents’

businesses while fully nude and without the cover of a privacy towel. At each

Respondent’s business, individual(s) reported that they were offered to the

opportunity to receive, and did receive, hand-to-genital contact by the Victim

on the customer during the massage, for the purpose of the customer’s sexual

gratification, in exchange for money and/or things of value.

10
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
33. Respondents advertise their services on Craigslist.com,

Backpage.com, and Rubmaps.com. Craigslist.com and Backpage.com are

frequently used to advertise prostitution services under the category of

massage services. Rubmaps.com allows users to post reviews of massage

parlors, including the type of sexual contact that is allowed at the massage

parlor. In the course of their investigation, the Missouri State Highway

Patrol could not find evidence that some of the Respondents advertised

anywhere else other than these pages.

Golden Massage

34. Golden Massage is located at 4728 South Campbell #112,

Springfield, Missouri 65810.

35. The building or unit occupied by Golden Massage has been

regularly used for prostitution activities.

36. Golden Massage is registered with the City of Springfield, with

its owner listed as Daquiong Wang. On information and belief, Daquiong

Wang is aware of the prostitution activities taking place at Golden Massage,

and those prostitution activities take place at the direction of Daquiong

Wang. On information and belief, Daquiong Wang knowingly profits from

the prostitution activities.

37. The prostitution activity occurring at Golden Massage includes

but is not necessarily limited to engaging in sexual conduct and/or sexual

11
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
contact, including hand-to-genital contact by the Victim on the customer for

the purpose of the customer’s sexual gratification, in exchange for money

and/or things of value.

Phoenix Massage

38. Phoenix Massage is located at 1261 East Republic, Springfield,

Missouri 65804.

39. The building or unit occupied by Phoenix Massage has been

regularly used for prostitution activities.

40. Phoenix Massage is owned by Phoenix Magic Massage, LLC,

Phoenix Oriental Massage, LLC, Wanhua Tian, and Zemin Guo.

41. Hongbo Qi assists with the operation of Phoenix Massage.

42. On information and belief, Phoenix Magic Massage, LLC,

Phoenix Oriental Massage, LLC, Wanhua Tian, Zemin Guo, and Hongbo Qi

are aware of the prostitution activities taking place at Phoenix Massage, and

those prostitution activities take place at their direction. On information and

belief, Phoenix Magic Massage, LLC, Phoenix Oriental Massage, LLC,

Wanhua Tian, Zemin Guo, and Hongbo Qi knowingly profit from the

prostitution activities.

43. The prostitution activity occurring at Phoenix Massage includes

but is not necessarily limited to engaging in sexual conduct and/or sexual

contact, including hand-to-genital contact by the Victim on the customer for

12
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
the purpose of the customer’s sexual gratification, in exchange for money

and/or things of value.

Relax Massage

44. Relax Massage is located at 2022 South Stewart Avenue,

Springfield, Missouri 65804.

45. The building or unit occupied by Relax Massage has been

regularly used for prostitution activities.

46. On information and belief, Xiao Chen is aware of the prostitution

activities taking place at Relax Massage, and those prostitution activities

take place at the direction of Xiao Chen. Xiao Chen is the son of the owner of

Relax Massage, and Xiao Chen operates Relax Massage.

47. On information and belief, Sheng Yang is aware of the

prostitution activities taking place at Relax Massage, and those prostitution

activities take place at the direction of Sheng Yang. Sheng Yang operates

Relax Massage.

48. Relax Massage is used as both a massage parlor and as a

residence for the Victims who work there. Xiao Chen monitors the Victims,

on occasion, by staying overnight at Relax Massage with the Victims and

otherwise by monitoring Relax Massage by video surveillance. On

information and belief, the purpose of this monitoring is to ensure that the

Victims at Relax Massage are not free to leave.

13
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
49. On information and belief, Sheng Yang and Xiao Chen knowingly

profit from the prostitution activities.

50. The prostitution activity occurring at Relax Massage includes but

is not necessarily limited to engaging in sexual conduct and/or sexual contact,

including hand-to-genital contact by the Victim on the customer for the

purpose of the customer’s sexual gratification, in exchange for money and/or

things of value.

Angel Massage

51. Angel Massage is located at 1774½ South Grant Street,

Springfield, Missouri 65807.

52. The building or unit occupied by Angel Massage has been

regularly used for prostitution activities.

53. Angel Massage is owned by Hui Otis, Fenghua Li, and Yang

Yongzhen. On information and belief, they are aware of the prostitution

activities taking place at Angel Massage, and those prostitution activities

take place at the direction of Hui Otis, Fenghua Li, and Yang Yongzhen. On

information and belief, Hui Otis, Fenghua Li, and Yang Yongzhen knowingly

profit from the prostitution activities.

54. The prostitution activity occurring at Angel Massage includes but

is not necessarily limited to engaging in sexual conduct and/or sexual contact,

including hand-to-genital contact by the Victim on the customer for the

14
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
purpose of the customer’s sexual gratification, in exchange for money and/or

things of value.

Great Spa

55. Great Spa is located at 2841 South Fremont, Springfield,

Missouri 65804.

56. The building or unit occupied by Great Spa has been regularly

used for prostitution activities.

57. Great Spa is registered with the City of Springfield, with its

owner listed as Mei Xiang Cui. On information and belief, Mei Xiang Cui is

aware of the prostitution activities taking place at Great Spa, and those

prostitution activities take place at the direction of Mei Xiang Cui. Mei

Xiang Cui owns or operates Great Spa. On information and belief, Mei Xiang

Cui knowingly profits from the prostitution activities.

58. The prostitution activity occurring at Great Spa includes but is

not necessarily limited to engaging in sexual conduct and/or sexual contact,

including hand-to-genital contact by the Victim on the customer for the

purpose of the customer’s sexual gratification, in exchange for money and/or

things of value.

59. In 2017, an undercover officer received a massage at Great Spa.

After undressing to his underwear, he was further instructed to remove his

underwear. During the massage, the Victim grabbed the undercover officer’s

15
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
genitals and began to stroke them. The undercover officer immediately

objected and told her to stop. Later in the massage, she again grabbed the

undercover officer’s genitals and began to stroke them. Once again he

objected and told her to stop. The massage then ended.

60. Online profiles by customers of Great Spa report that massages

there can include contact between the hand of the Victim and the genitals of

the customer, the hand of the customer and the genitals of the Victim, and

also hand-to-anus contact.

Asian-Rainbow Massage

61. Asian-Rainbow Massage is located at 2005 East Kearney Street,

Suite I, Springfield, Missouri 65803.

62. The building or unit occupied by Asian-Rainbow Massage has

been regularly used for prostitution activities.

63. Asian-Rainbow Massage is owned by Yanmei Wang. On

information and belief, Yanmei Wang is aware of the prostitution activities

taking place at Asian-Rainbow Massage, and those prostitution activities

take place at the direction of Yanmei Wang. Yanmei Wang owns or operates

Asian-Rainbow Massage. On information and belief, Yanmei Wang

knowingly profits from the prostitution activities.

64. The prostitution activity occurring at Asian-Rainbow Massage

includes but is not necessarily limited to engaging in sexual conduct and/or

16
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
sexual contact, including hand-to-genital contact by the Victim on the

customer for the purpose of the customer’s sexual gratification, in exchange

for money and/or things of value.

Count I – Operating a Public Nuisance


(against Golden Massage and Daquiong Wang)

65. Petitioner incorporates all of the allegations contained in

Paragraphs 1 through 64 above.

66. 4728 South Campbell Avenue, Suite 112, Springfield, Missouri

65810 is being operated by Golden Massage and Daquiong Wang as a public

nuisance in that the location is regularly used for prostitution activity.

67. Daquiong Wang, as an owner, officer, agent, or employee of

Golden Massage, aided and facilitated the nuisance.

WHEREFORE, Petitioner respectfully requests that the Court enter

judgment in favor of Petitioner preliminarily and permanently enjoining 1)

Golden Massage from engaging in any prostitution activity; 2) 4728 South

Campbell Avenue, Suite 112, Springfield, Missouri 65810 from being used for

any prostitution activity; 3) Daquiong Wang from engaging in, aiding in, or

promoting prostitution activity; and 4) such further relief as this Court deems

just and proper.

17
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
Count II – Operating a Public Nuisance
(against Phoenix Massage; Phoenix Magic Massage, LLC; Phoenix
Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi)

68. Petitioner incorporates all of the allegations contained in

Paragraphs 1 through 67 above.

69. 1261 East Republic, Springfield, Missouri 65804 is being

operated by Phoenix Massage; Phoenix Magic Massage, LLC; Phoenix

Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi as a

public nuisance, in that the location is regularly used for prostitution activity.

70. Phoenix Magic Massage, LLC; Phoenix Oriental Massage, LLC;

Wanhua Tian; Zemin Guo; and Hongbo Qi, as owners, officers, agents, or

employees of Phoenix Massage, aided and facilitated the nuisance.

WHEREFORE, Petitioner respectfully requests that the Court enter

judgment in favor of Petitioner preliminarily and permanently enjoining 1)

Phoenix Massage from engaging in any prostitution activity; 2) 1261 East

Republic, Springfield, Missouri 65804 from being used for any prostitution

activity; 3) Phoenix Magic Massage, LLC; Phoenix Oriental Massage, LLC;

Wanhua Tian; Zemin Guo; and Hongbo Qi, from engaging in, aiding in, or

promoting prostitution activity; and 4) such further relief as this Court deems

just and proper.

18
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
Count III – Operating a Public Nuisance
(against Relax Massage, Sheng Yang, and Xiao Chen)

71. Petitioner incorporates all of the allegations contained in

Paragraphs 1 through 70 above.

72. 1261 East Republic, Springfield, Missouri 65804 is being

operated by Relax Massage, Sheng Yang, and Xiao Chen as a public

nuisance, in that the location is regularly used for prostitution activity.

73. Sheng Yang and Xiao Chen, as owners, officers, agents, or

employees of Relax Massage, aided and facilitated the nuisance.

WHEREFORE, Petitioner respectfully requests that the Court enter

judgment in favor of Petitioner preliminarily and permanently enjoining 1)

Relax Massage from engaging in any prostitution activity; 2) 1261 East

Republic, Springfield, Missouri 65804 from being used for any prostitution

activity; 3) Sheng Yang and Xiao Chen from engaging in, aiding in, or

promoting prostitution activity; and 4) such further relief as this Court deems

just and proper.

Count IV – Operating a Public Nuisance


(against Angel Massage, Hui Otis, Fenghua Li, and Yang Yongzhen)

74. Petitioner incorporates all of the allegations contained in

Paragraphs 1 through 73 above.

75. 1774½ South Grant Street, Springfield, Missouri 65807 is being

operated by Angel Massage and Hui Otis, Fenghua Li, and Yang Yongzhen as

19
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
a public nuisance, in that the location is regularly used for prostitution

activity.

76. Hui Otis, Fenghua Li, and Yang Yongzhen, as owners, officers,

agents, or employees of Angel Massage, aided and facilitated the nuisance.

WHEREFORE, Petitioner respectfully requests that the Court enter

judgment in favor of Petitioner preliminarily and permanently enjoining 1)

Angel Massage from engaging in any prostitution activity; 2) 1774½ South

Grant Street, Springfield, Missouri 65807 from being used for any

prostitution activity; 3) Hui Otis, Fenghua Li, and Yang Yongzhen from

engaging in, aiding in, or promoting prostitution activity; and 4) such further

relief as this Court deems just and proper.

Count V – Operating a Public Nuisance


(against Great Spa and Mei Xiang Cui)

77. Petitioner incorporates all of the allegations contained in

Paragraphs 1 through 76 above.

78. 2841 South Fremont, Springfield, Missouri 65804 is being

operated by Great Spa and Mei Xiang Cui as a public nuisance, in that the

location is regularly used for prostitution activity.

79. Mei Xiang Cui, as an owner, officer, agent, or employee of Great

Spa, aided and facilitated the nuisance.

20
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
WHEREFORE, Petitioner respectfully requests that the Court enter

judgment in favor of Petitioner preliminarily and permanently enjoining 1)

Great Spa from engaging in any prostitution activity; 2) 2841 South Fremont,

Springfield, Missouri 65804 from being used for any prostitution activity; 3)

Mei Xiang Cui from engaging in, aiding in, or promoting prostitution activity;

and 4) such further relief as this Court deems just and proper.

Count VI – Operating a Public Nuisance


(against Asian-Rainbow Massage and Yanmei Wang)

80. Petitioner incorporates all of the allegations contained in

Paragraphs 1 through 79 above.

81. 2005 East Kearney Street, Suite I, Springfield, Missouri 65803 is

being operated by Asian-Rainbow Massage and Yanmei Wang as a public

nuisance, in that the location is regularly used for prostitution activity.

82. Yanmei Wang, as an owner, officer, agent, or employee of Asian-

Rainbow Massage, aided and facilitated the nuisance.

WHEREFORE, Petitioner respectfully requests that the Court enter

judgment in favor of Petitioner preliminarily and permanently enjoining 1)

Asian-Rainbow Massage from being used for any prostitution activity; 2)

2005 East Kearney Street, Suite I, Springfield, Missouri 65803 from being

used for any prostitution activity; 3) Yanmei Wang from engaging in, aiding

21
Electronically Filed - Greene - July 20, 2017 - 02:00 PM
in, or promoting prostitution activity; and 4) such further relief as this Court

deems just and proper.

Respectfully submitted,

JOSHUA D. HAWLEY
Attorney General

/s/ Darrell Moore


Darrell Moore, #30444
Deputy Attorney General
Jason S. Dunkel, #65886
Assistant Deputy Attorney General
Mary D. Morris, #60921
Caleb Aponte, #67931
Assistant Attorneys General
P.O. Box 861
St. Louis, MO 63188
(314) 340-7889
Darrell.Moore@ago.mo.gov

DANIEL PATTERSON
Prosecuting Attorney of the County of
Greene, State of Missouri
Missouri Bar No. 41848
1010 Boonville Avenue
Springfield, Missouri 65802
(417) 868-4061
FAX (417) 868-4160

Attorneys for Petitioner

22

You might also like