Professional Documents
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Petition To Seize Assets of Asian Massage Businesses and Owners in Missouri
Petition To Seize Assets of Asian Massage Businesses and Owners in Missouri
Petition To Seize Assets of Asian Massage Businesses and Owners in Missouri
1731-CC00950
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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: )
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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
Joshua D. Hawley and Prosecutor Daniel Patterson, bring this Petition, and
Under Missouri law, “[a]ny room, building or other structure regularly used
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for any prostitution activity by this chapter is a public nuisance.”
nuisance may be made defendants in any suit to enjoin the nuisance, and
Parties
State of Missouri and brings this action in his official capacity pursuant to
Greene County, Missouri and brings this action in his official capacity
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Golden Massage
and has a principal place of business at 4728 South Campbell Avenue, Suite
and belief, Golden Massage is no longer registered with the State of Missouri.
65810.
Phoenix Massage
65804.
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
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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, and has a principal place of business at 1261 East Republic Road,
13. Hongbo Qi, also known as Qi Hong Bo, is an owner, officer, agent,
resides in Missouri and can be found at Phoenix Massage, 1261 East Republic
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
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of Missouri, but it has a business license from the City of Springfield under
Massage, and, on information and belief, can be found at 2022 South Stewart
Angel Massage
fictitious business name registered with the State of Missouri and owned by
Hui Otis, Fenghua Li, and Yang Yongzhen. Angel Massage has a principal
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
65804.
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Electronically Filed - Greene - July 20, 2017 - 02:00 PM
19. Fenghua Li is an owner, officer, agent, or employee of Angel
Great Spa
21. Great Spa holds itself out as a massage parlor and has a
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.
Spa, and may be found at 2841 South Fremont, Springfield, Missouri 65804.
Asian-Rainbow Massage
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
This business is licensed with the City of Springfield as Asian Massage. This
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Massage.” Asian Massage, Rainbow Massage, and Asian-Rainbow Massage
65807.
25. All respondents have done business within the State of Missouri,
Jurisdiction
26. This Court has subject matter and personal jurisdiction over this
Venue
that there are several defendants, and venue lies in any county in which a
Defendant resides.
Greene County.
Statutory Authority
allows the Attorney General to prosecute a suit to enjoin the nuisance. The
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Attorney General may include owners, lessees, officers, agents, or employees
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
32. The Missouri State Highway Patrol and Springfield Police have
businesses while fully nude and without the cover of a privacy towel. At each
on the customer during the massage, for the purpose of the customer’s sexual
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33. Respondents advertise their services on Craigslist.com,
parlors, including the type of sexual contact that is allowed at the massage
Patrol could not find evidence that some of the Respondents advertised
Golden Massage
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Electronically Filed - Greene - July 20, 2017 - 02:00 PM
contact, including hand-to-genital contact by the Victim on the customer for
Phoenix Massage
Missouri 65804.
Phoenix Oriental Massage, LLC, Wanhua Tian, Zemin Guo, and Hongbo Qi
are aware of the prostitution activities taking place at Phoenix Massage, and
Wanhua Tian, Zemin Guo, and Hongbo Qi knowingly profit from the
prostitution activities.
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the purpose of the customer’s sexual gratification, in exchange for money
Relax Massage
take place at the direction of Xiao Chen. Xiao Chen is the son of the owner of
activities take place at the direction of Sheng Yang. Sheng Yang operates
Relax Massage.
residence for the Victims who work there. Xiao Chen monitors the Victims,
information and belief, the purpose of this monitoring is to ensure that the
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49. On information and belief, Sheng Yang and Xiao Chen knowingly
things of value.
Angel Massage
53. Angel Massage is owned by Hui Otis, Fenghua Li, and Yang
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
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purpose of the customer’s sexual gratification, in exchange for money and/or
things of value.
Great Spa
Missouri 65804.
56. The building or unit occupied by Great Spa has been regularly
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
things of value.
underwear. During the massage, the Victim grabbed the undercover officer’s
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genitals and began to stroke them. The undercover officer immediately
objected and told her to stop. Later in the massage, she again grabbed the
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
Asian-Rainbow Massage
take place at the direction of Yanmei Wang. Yanmei Wang owns or operates
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sexual contact, including hand-to-genital contact by the Victim on the
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
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Count II – Operating a Public Nuisance
(against Phoenix Massage; Phoenix Magic Massage, LLC; Phoenix
Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi)
public nuisance, in that the location is regularly used for prostitution activity.
Wanhua Tian; Zemin Guo; and Hongbo Qi, as owners, officers, agents, or
Republic, Springfield, Missouri 65804 from being used for any prostitution
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
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Count III – Operating a Public Nuisance
(against Relax Massage, Sheng Yang, and Xiao Chen)
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
operated by Angel Massage and Hui Otis, Fenghua Li, and Yang Yongzhen as
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a public nuisance, in that the location is regularly used for prostitution
activity.
76. Hui Otis, Fenghua Li, and Yang Yongzhen, as owners, officers,
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
operated by Great Spa and Mei Xiang Cui as a public nuisance, in that the
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WHEREFORE, Petitioner respectfully requests that the Court enter
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.
2005 East Kearney Street, Suite I, Springfield, Missouri 65803 from being
used for any prostitution activity; 3) Yanmei Wang from engaging in, aiding
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in, or promoting prostitution activity; and 4) such further relief as this Court
Respectfully submitted,
JOSHUA D. HAWLEY
Attorney General
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
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