Declaration of Lisa Liberi in Support of Plaintiffs Opposition To Intelius' Motion For Summary Judgment Doc 463

Case 8:11-cv-00485-AG-AJW Document 463 Filed 02/20/12 Page 1 of 22 Page ID #:10637
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Philip J. Berg, Esquire Pennsylvania I.D. 9867 LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 E-mail: philjberg@gmail.com
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION : : : : Plaintiffs, : : : : : : : : : : Defendants. : : : CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) DECLARATION OF LISA LIBERI Date of Hearing: March 12, 2012 Time of Hearing: 10:00 a.m. Location: Courtroom 10D
LISA LIBERI, et al
vs.
ORLY TAITZ, et al,
Declaration of Lisa Liberi I, Lisa Liberi am over the age of 18 and am a party to the within action. I have personal knowledge of the facts herein, and if called to do, I could and would competently testify. I am making this Declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. I purchased a background report on myself April 10, 2010 from
Intelius at their website www.intelius.com. The report I purchased, and Intelius
Declaration of Lisa Liberi
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furnished was person specific to me, not my name, but me and my family members. Intelius filed a Motion to Dismiss on or about September 16, 2011, Docket Number [DN] 380-3. In support of Intelius Motion, they included the Declaration of Benjamin Nelson, Custodian of Records for Intelius, DN 380-3. Mr. Nelson in his declaration at page [p. or pp.] 3, 6 that he was attaching a true and correct copy of the report I purchased from www.intelius.com as Exhibit 2, DN 380-5. Mr. Nelsons Exhibit 1, which he claimed was a true and correct copy of the report Orly Taitz purchased on me, appeared to be identical to his Exhibit 2 in which Mr. Nelson was claiming was a true and correct copy of the report I had purchased. Mr. Nelsons Exhibit 2 was not a copy of the report I purchased and received from Intelius, as explained in my Declaration of September 24, 2011, DN 389. I attached as Exhibit A to my Declaration the report I had purchased from www.intelius.com and received from Intelius, see DN 389, Exhibit A, pp. 8-18. Mr. Nelsons report was thirty (30) pages long with names I had never heard of, addresses I had never seen. In fact, I had never seen an Intelius report like the one attached to Mr. Nelsons Declaration as Exhibits 1 and 2, DN 389-4 and 389-5. When compared to the one I actual received from Intelius, which was ten (10) pages long, they were nothing similar. 2. In this same Declaration, Mr. Nelson also attached as Exhibit 3, DN
380-6, what he claimed was a true and correct copy of the TalentWise report that
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I had purchased on myself also on April 10, 2010, see DN 380-6 and 380-3 at p. 3, 6. Same occurrence, the TalentWise report attached to Mr. Nelsons Declaration as Exhibit 3, DN 380-6 was not the same TalentWise report I purchased and received from Intelius. See my Declaration of September 24, 2011, DN 389-2 at pp. 20-23. 3. The differences in the Intelius.com report I purchased, the TalentWise
report I purchased and Mr. Nelsons Exhibits 1, 2 and 3, were that the reports attached by Mr. Nelson showed different copyright dates, dates a year after I had purchased my report and two (2) years after Orly Taitz had purchased her reports on me. 4. All of the above was brought to the Courts attention. The Court
chose not to consider Intelius Motion to Dismiss, whether it was due to the perjured testimony, newly created documents, or for some other reasons is unknown. 5. Now Intelius has filed a Motion for Summary Judgment, DN 455. In
support of their Summary Judgment Motion, they include the Declaration of Ronald V. Thunen, III, see DN 456. Mr. Thunen also states in his Declaration at pp. 6-7, 16 that he has attached a true and correct copy of the TalentWise Report I purchased April 10, 2010, as Exhibit 4, DN 456-4. Mr. Thunens
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Exhibit 4 appears to be the same as Mr. Nelsons Exhibit 3, DN 380-6, neither of which are the same as the Report I purchased and received from TalentWise. 6. Below is a screen shot of Mr. Nelsons Exhibit 3, DN 380-6:
7.
Below is a screen shot of Mr. Thunens Exhibit 4, DN 456-4:
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8. 9.
As can be seen, the two above screen shots appear to be the same. Below is a screen shot of my TalentWise report filed in my September
24, 2010 Declaration as Exhibit 3, DN 389-2, pp. 20-23:
10. Screening
As can be seen, they are different reports. My report says Intelius Customer Service with an email address of
customerservicesolutions@intelius.com in the top right corner. Mr. Nelson and Mr. Thunens says TalentWise Customer Support with an email address of customersupport@talentwise.com. They are not the same. My report states
Report Status: Pending; Request Submitted: Apr. 10 2010 9:36 pm in the middle to the right of my name. Mr. Nelson and Mr. Thunens says Report Status: Complete; Request Submitted Apr 10 2010 9:36 pm; Completion Time
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4 business days, 15 hours. Again, they are different. I never received a report from Intelius Talentwise with the information appearing in the Exhibits filed by Mr. Thunen and Mr. Nelson. 11. In the middle of the page, my report has my Applicant ID, and
underneath Applicant ID is my name; under my name is my date of birth; and under my date of birth is my address. 12. Mr. Nelson and Mr. Thunens reports have Applicant ID, and
underneath Applicant ID is my name; to the right of my name is my address; under my name is my Social Security number; and under my Social Security number is my date of birth. Again, it is different from my report. 13. The last page of each TalentWise report, Mr. Nelsons, Mr. Thunens
and mine all have copyright stamps. 14. Screen shots of Mr. Nelsons and Mr. Thunens page with the
copyright stamp both show 2003 2011 TalentWise Solutions, LLC: Mr. Nelsons Exhibit 3, DN 380-6, last page: // // // // // // // // // // //
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Mr. Nelsons Exhibit 3, DN 380-6 showing the copyright stamp as 2003 2011 TalentWise Solutions, LLC
Mr. Thunens Exhibit 4, DN 456-4, last page showing 2003 2011 TalentWise Solutions, LLC
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15.
On the last page of my TalentWise report, DN 389-2, p. 23, in the top Intelius Screening
left corner, the copyright stamp shows 2003 2010 Solutions DBA TalentWise, see below:
16.
There is no question, Mr. Nelsons Exhibit 3, DN 380-6; Mr.
Nelsons Exhibit 4, DN 456-4; and my Exhibit 3, DN 389-2, pp. 20-23 are not the same reports as testified to under the penalty of perjury by Mr. Nelson and Mr. Thunen. 17. Same goes for Mr. Nelsons Exhibits 1, DN 380-4 (Map date shows
2011) and the Report Orly Taitz purchased on me in or about March 2009; and Mr. Nelsons Exhibit 2, DN 380-5 (Map date shows 2011) and the Intelius report I purchased on myself was on April 10, 2010.
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18.
Intelius through Mr. Nelson and Mr. Thunen have newly created the
reports they are claiming are the reports I purchased. 19. And, to substantiate all of this, Mr. Thunen himself states in his
Declaration, DN 456, on p. 5, 12 that they do not maintain copies of the reports sold to their customers. In fact, Mr. Thunen states: Intelius does not retain copies of the actual reports it sells to users of its website 20. So there is no way that Mr. Thunens Exhibit 4, DN 456-4 is a true
and correct copy of the report I purchased, as identified above. Same goes for Mr. Nelsons Exhibits 1 through 3 to his September 16, 2011 Declaration, DN 380-3 through 380-6. Intelius is creating documents in attempts to support their motions and are perjuring their testimony in the process. Neither Mr. Nelson nor Mr. Thunens testimony are credible. 21. Intelius in their Summary Judgment Motion claims that no one ran
searches on Lisa Ostella, and states that the only parties who purchased reports on me were Defendant Orly Taitz. But, Mr. Nelson in his Declaration, DN 380-3 states Katrinka Lawson; Teresa Loggia; and Julieana Choy purchased reports on me as well as the reports I purchased on April 10, 2010. 22. On September 18, 2011, I purchased another background check
through Intelius under my maiden name. I did this because Intelius claimed they
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had removed us from their databases and their affiliates, which was not true, see the September 18, 2011 report, Report No. 49346983 attached as EXHIBIT A1. This Sept. 18, 2011 report was again person specific, it showed my maiden name, date of birth, married name, where I resided, my unlisted phone number at the time I was at the particular address, my average household income, my home value, it had Judgments showing from over 10 years ago, a map to the house I resided in, etc. And, in this specific report Intelius threw in a few more Lisa Richardsons only where they report criminal and civil judgments. I also noticed Intelius had changed its website and how it delivered reports. I believe they are spoiling evidence. 23. I ran another background report on myself on February 10, 2012. I ran
these reports under my maiden name and different ways. The first one I ran was a people search, not a background, phone and address search, criminal record search, associates, etc., my Intelius Order number is 54680593, see EXHIBIT B. This report is 20 pages long. In this report, it had several Richardsons listed. My information came up as number 2 beginning on page 3 of this report. As can be seen, it has my name, addresses (including addresses I have never
For economy and due to the amount of paper being filed in our Opposition to Intelius Motion for Summary Judgment, I have only included my receipt, a screen shot from my Intelius account control panel, and the first page of the reports I ran on myself, due to the confidential nature of the information contained in the reports and the length of the
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resided at); my date of birth; my age; relatives; etc. I also notice Intelius had again changed their website and what information was contained in reports. 24. After reviewing the report in EXHIBIT B, I decided to purchase a
background report on my maiden name. I purchased my Intelius background report, Report Number 54680809, purchased February 10, 2012, see EXHIBIT C. This report is 69 pages long. This report had my maiden name, and listed aliases with my date of birth and additional dates of birth the Report shows me using, which is incorrect, and incorrect addresses, all associated with my date of birth, relatives, and my data. Ironically, some of the names and years of birth are those that I disputed with Intelius on November 1, 2010, see my declaration filed September 24, 2010, DN 389-2, pp. 28-31, which Intelius failed to correct and/or respond to. Ironically, the incorrect information Intelius is reporting on me, also matches the incorrect information that the Reed Defendants are reporting on me. 25. The more I thought about the background check and Intelius
continued improper statement that their background reports are not person specific, I decided to run another background on myself. On February 12, 2012, I went into my Intelius account and ran a search, exactly as I had done on February 10, 2012, under my maiden name, this time, my information was gone, Intelius had deleted
reports. I am more than willing to file the entire reports under seal with this Court, should the Court prefer.
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or blocked my information from me since I had purchased my report on February 10, 2012, again Spoiling Evidence. 26. I decided, again to prove that Intelius reports are person specific, to
run my Background report by Social Security number. I input my maiden name and my old Social Security number ending in 6858. I was able to purchase my background report which matched the background report I purchased on myself February 10, 2012, Report number 54753781 see EXHIBIT D. This report is 29 pages long. As explained above, this report also had incorrect birthdates showing as me using, incorrect names and addresses, all associated with my actual birthdate in 1965, my relatives, and property I had owned. As Im sure this Court is aware, running a background by your Social Security is unquestionably a person specific consumer report. Social Security numbers are only assigned to one person, not several individuals with the same or similar name, as Intelius has been attempting to claim. I have also attached as EXHIBIT E a print screen [picture] of my purchase screen from my Intelius control panel, so the Court can see I ran my February 12, 2012 Report by my Social Security number. 27. I have conducted numerous searches on Intelius and their false claims
that they are not governed by the Fair Credit Reporting Act [FCRA]. I came across an interview with Ed Peterson; Executive Vice President of Intelius People Search and People Finders located on the Internet at
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http://www.identitytheftsecrets.com/intelius-review-an-interview-with-inteliuspeople-search-and-people-finders-ed-petersen. In this June 10, 2008 Interview, Ed Peterson states that they obtain (purchase) their information from outside sources, analyze it, augment it and stitch it together to ensure the reports their consumers purchase are accurate reports pertaining to the person being searched, see this Interview attached hereto as EXHIBIT F. This simply confirmed that Intelius was the creator of all the reports in which they sell to their customers. Mr. Petersons Bio located on Intelius website at
http://edpetersen.intelius.com/corp/bio/edward-petersen is attached hereto as EXHIBIT G. 28. I also conducted searches in Intelius website at www.intelius.com
and on October 25, 2011, I located their Security and Compliance statements at http://www.intelius.com/corp/security, see EXHIBIT H. In Intelius Security Agreement they state: Intelius is a certified credit reporting agency [emphasis added]. Intelius has changed their website since, but, their Security compliance is still available at http://www.intelius.com/corp/security, and now states Intelius is a certified credit reporting agency abiding by all FCRA standards as well as a level 1 Merchant by the Payment Card Industry Data Security Standards. [emphasis added], see EXHIBIT I.
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29.
I went to Intelius home page at http://www.intelius.com/corp/, and
on their home page they again repeat, We are pioneers in the information commerce industry, innovating technologies to collect, interpret and deliver information to consumers and businesses onlineWe do much more than deliver reliable and accurate information-we augment, interpret, and present it based on your unique needs, creating valuable and trusted solutions for our millions of customers across lifestyles and industries., see EXHIBIT J. 30. Intelius also advertises their consumer background reports on their
website at http://www.intelius.com/corp/consumer, a true and correct cop of this website page is attached hereto as EXHIBIT K. Intelius repeats that their background reports include: Intelius background checks contain a criminal report augmented by additional information including an address history, property and neighborhood report, aliases and associates, civil judgments, liens and bankruptcies, among others. Background checks enable consumers to take a deeper dive into an individual's background, giving them the information they need to feel secure that their potential date, neighbor, caretaker or business partner is who they say they are. Intelius again proves the reports they sell on individuals are consumer reports as defined by the FCRA, Intelius has met all the elements outlined in the FCRA. 31. In Intelius report to the Security and Exchange Committee [SEC]
filed as Exhibit 1 to our Request for Judicial Notice, Intelius states on p. 14: Our consumer information services are based on an extensive collection of information about people, businesses and assets that is
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dynamically accessed, managed, integrated, cleansed and validated in real time to provide accurate, timely and useful informationOur analytics technologies verify and augment multiple terabytes of data, usually in disparate formats and having varying degrees of accuracy and completeness, from a myriad of sources in order to make inferences and predictions based on this data. [emphasis added] 32. I also searched the Federal Docketing System, PACER for cases
against Intelius, if any. I found several. In particular, Moore v. Intelius, Inc., U.S. District Court, Northern District of Alabama, Western Division, Case No. 7:08-cv01062-SLB, which was a case against Intelius for FCRA violations. Intelius not only settled this case, they filed an Affirmation of Settlement deeming the Plaintiff (Ms. Moore) the prevailing party, see our Request for Judicial Notice, Exhibit 3. I also found another FCRA case settled by Intelius, Williams v. Intelius, Inc., U.S. District Court, Northern District of Oklahoma, Tulsa Division, Case No. 4:09-cv00217-TCK, see our Request for Judicial Notice, Exhibit 4. 33. Intelius admits in their SEC filing, Plaintiffs Request for Judicial
Notice, on pages 18, 24-25: Because we use personal information in providing our information services, we are subject to government regulation and vulnerable to adverse publicity. We provide many types of data and services that already are subject to regulation under the FCRA, Gramm-LeachBliley Act, Drivers Privacy Protect ion Act and, to a lesser extent, various other federal, state and local laws and regulations. Violation of these laws or regulations may result in substantial fines, judgments and other penalties. These laws and regulations are designed to protect the privacy of the public and to prevent the misuse of personal information in the marketplace.
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And on Plaintiffs Request for Judicial Notice, page 27, Intelius states: We face potential liability from individuals, classes of individuals, customers or regulatory bodies for claims based on the nature, content or accuracy of our services and the information used and reported by us. This potential liability includes claims of noncompliance with laws and regulations governing our services and claims of defamation, invasion of privacy, negligence, and copyright, patent or trademark infringement. In some cases, this potential liability may be determined without faultInsurance may not be adequate to cover us f or all risks to which we are exposed or may not be available to cover these claims at all. For example, punitive damages, which generally are not covered by insurance, may be available under the FCRA to consumers for the failure to comply with the FCRA Intelius continues in their report, Plaintiffs Request for Judicial Notice, on pages 28-29 states: Our customers could improperly use the information on our websites, and we may be held liable. 34. admissions. 35. Intelius in their Memorandum of Points and Authorities on page 10, Intelius knows they are governed by the FCRA by their own
states I never identified anything inaccurate in my reports I purchased from Intelius and that I admitted the reports I purchased were accurate, see also Intelius Proposed Undisputed Facts, number 24. This is completely untrue and
dishonest; I have never admitted the reports I purchased were accurate, what I stated was the reports I purchased pertained to me, see my September 24, 2011 Declaration, DN 389-2, page 2, 3. Additionally, on November 10, 2010 I sent a
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letter to Intelius, signature required regarding the inaccurate information Intelius maintained on me, see my Declaration of September 24, 2011, DN 389-2, page 7, 7 and my Exhibit D, DN 389-2, pages 28-31. Benjamin Nelson, Intelius Custodian of Records admitted receipt of said letter in his October 3, 2011 Declaration, DN 397, page 2, 3. I will be happy to refurnish any document that has been previously filed, if that is easier on the Court. In addition, my attorney on April 14, 2010, before my letter of November 1, 2010, sent a letter to Intelius explaining the problems with the information maintained on me and Mrs. Liberi and the illegal disclosures of our files. 36. Intelius in their Memorandum, B, page 6 and in Intelius Proposed
Undisputed Facts number 23 admits my attorney, Mr. Berg, sent Intelius a letter informing Intelius of the incorrect information they maintained on me and Mrs. Ostella. 37. Intelius on page 6 of their Memorandum again restates that I admitted
my reports were accurate. Again, this is untrue, as stated above, I stated the reports pertained to me, the reference to the reports were to show that Benjamin Nelson in is Declaration of September 16, 2011, DN 380-3, 380-5 and 380-6 were not the reports that I purchased and received. The reports I purchased and received from Intelius and TalentWise were attached to my Declaration as exhibits A and B, see DN 389-2, pages 1-2, 1-3 and Exhibits A and B, pages 8-18. My letter
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to Intelius on November 10, 2010 attached as Exhibit D to DN 389-2 addressed the incorrect information. 38. Intelius falsely states in their Memorandum on page 6 and in the
Proposed Undisputed Facts, number 24, that Mr. Berg sent a letter on April 14, 2010 to Intelius claiming that my TalentWise Report I had pulled contained wrong Social Security numbers, dates of birth, names, etc. This is untrue and Mr. Bergs letter speaks for itself. Nowhere in Mr. Bergs April 14, 2010 is letter to Intelius the name TalentWise mentioned. Mr. Bergs letter to Intelius stated I repulled my report and found incorrect information, in which Mr. Berg outlined, which is true. Mr. Berg never mentioned which report I pulled. I pulled my report from U.S. Search, owned and operated by Intelius, NOT TalentWise. 39. Intelius on page 6 of their Memorandum states Besides Liberi
herself, the only other party to this suit to run a search on the name Lisa Liberi through Intelius is Orly Taitz (UF No. 26). This is another lie. Benjamin Nelson, Intelius Custodian of Records, in his September 16, 2011 Declaration, DN 380-3, states on page 7, 19: In the interests of completeness, three other individuals ran searches on the name Lisa Liberi through Intelius: (Katrinka Lawson; (ii) Teresa Loggia; and (iii) Julieana Choy.
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Attached hereto as EXHIBIT L is Benjamin Nelson, Intelius Custodian of Records, September 16, 2011 Declaration, DN 380-3 without the Exhibits.2 As stated above, I also purchased a background report on myself September 18, 2011; and Plaintiff Lisa Ostella purchased reports on me and her November 30, 2011. I am also attaching as EXHIBIT M my letter of November 1, 2010 outlining and disputing the incorrect information contained in my credit file with Intelius that Nelson acknowledged, see Nelson Decl. of October 3, 2010, DN 397, page 2, paragraph 3. 40. Intelius attempts to get creative with the Court in their Proposed
Uncontroverted Statement of Facts and in their Brief, they claim we accused them of publishing our data. We never stated Intelius published anything. Instead, what we stated was Intelius was the information provider of consumer reports that Intelius was responsible for the development of Plaintiffs credit /consumer reports and was responsible for its distribution. Intelius solicits and purchases private information on individuals, creates reports based on the information, markets the reports and sells it to anyone with a credit card in violation of the FCRA. What we said was Intelius illegally sold our private consumer reports to Taitz and others; that Intelius created the reports in which they sell, which they do by their own
The Court sealed Intelius filing of September 16, 2011 as a result of Intelius filing my full Social Security number; my date of birth; my home addresses; and the confidential
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admissions. Intelius does not publish the reports in which they sell. All reports sold by Intelius are provided to their customer in an Intelius password protected account; and the link to the report is sent to you in an email from Intelius, which takes you back to the sign in page, which you must sign into your password protected account to access. You cannot purchase a report from Intelius without setting up a password protected account and storing your information and credit card details. Intelius provides the reports in which you purchase, to you in your password protected account. Intelius also emails you a receipt, as shown in
EXHIBITS A through D hereto, with a hyperlink to access the report you purchased in your password protected account. My EXHIBIT E is a print screen of my Intelius Account control panel, and it shows the reports in which I purchased. 41. Intelius also continues claiming Orly Taitz purchased her report from
them on April 12, 2009. Defendant Orly Taitz and the Sankey Defendants purchased the reports on Plaintiffs prior to April 12, 2009, as Defendants Taitz and Sankey were sending our Plaintiffs private data before then as outlined in our First Amended Complaint and documented in our exhibits filed with this Court, see DN 190 through 190-27. Where is the report(s) purchased by Orly Taitz? Taitz in her Declaration, DN 455-3 does not make one mention of purchasing a report, instead
information of Lisa Ostella and her husband. For this reason, I am not including the
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she talks about searches she performed. Taitz does not make one reference to Terms and Conditions, as falsely claimed by Intelius, in her Declaration; nor does Orly Taitz attach a copy of the report she purchased on the Plaintiffs. There is no mention of Defendants, Law Offices of Orly Taitz, Defend our Freedoms Foundations, Inc., or Orly Taitz, Inc. 42. Intelius advertises all over the Internet its products, including
comprehensive background reports on individuals. As Intelius reported to the SEC, copy of which is attached as Exhibit 1 to our Request for Judicial Notice, Intelius states: We have established relationships with leading online portals and directories, including Yahoo! and AT&T that market our services on their websites and direct visitors to our websites 43. The events giving rise to our suit, occurred in or about early 2009,
however, we did not discover some of the issues with Intelius and the Reed Defendants until early/mid 2010. 44. As a result, as previously stated in my declarations, my husband and I
have suffered severe damages, mental anguish and medical complications. Including but not limited to full Identity Theft; threats; cyber-stalking; harassment; cardiac complications; extensive medical bills; severe mental anguish; and many other damages. Intelius should not be permitted to continue damaging individuals
Exhibits to Mr. Nelsons Declaration as they contain private data.

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and their families, and they certainly should not be permitted to continue their attempts of defrauding the court, prejudicing me and the other Plaintiffs by their fraudulent tactics. 45. With no disrespect to this Court intended, all through this Case, me
and the other Plaintiffs have been honest and supported everything we have said. I am disgusted that Intelius and their attorneys have been allowed, and/or gotten away with, and continue to, lie, twist our wording, use fraudulent tactics, file documents as genuine claiming them to be copies of what the parties received, when in fact Intelius newly created them a year and two after the parties obtained them, and perjure their testimony as outlined above. These deceptive practices of Intelius and their attorneys is and has been prejudicial to me and the other Plaintiffs, and if they are allowed to get away with these improper actions, it will truly be an injustice to us. I declare under the penalty of perjury of the Laws of the United States and the State of California that the foregoing is true and correct. Executed this 18th day of February, 2012 in the State of New Mexico.
Lisa Liberi, Declarant
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EXHIBIT A
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https://mail.google.com/mail/?ui=2&view=bsp&ver=ohhl4rw8mbn4 From: Intelius <DoNotReply@intelius.com> Date: Sun, Sep 18, 2011 at 8:43 PM Subject: Intelius Purchase Receipt - Order #49347294 To: lisaliberi@gmail.com
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This section lists summary, neighbors, relatives and area data associated with the property when available. The Relatives and Associates section lists potential relatives or previous occupants associated with an individual and / or their address from public records. The Neighbors Around the Property section lists the immediate neighbors around the property. These sections can help confirm the people linked to your subject and provide additional people that may have current or forwarding information on the whereabouts of your subject. ADDRESS & CONTACT INFO: 6880 Landriano Pl Rancho Cucamonga, CA 91701
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Owner Name Mixon Edgar A Mixon Guendolyn J
Property Info Sq. ft.: 2,186 Bedrooms: 4 Taxes: $3,420 (2009)
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Name Daryl Van Dran 6879 Landriano Pl Rancho Cucamonga, CA 91701 (909) 948-0606 Ron Noggle 6872 Landriano Pl Rancho Cucamonga, CA 91701 (909) 948-9303 Felipe Molina 6887 Landriano Pl Rancho Cucamonga, CA 91701 (909) 989-9544 Background Check Background Check Background Check
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Total Population 39,055
Avg. House Price $198,100
Avg. Household Income $66,668
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https://mail.google.com/mail/?ui=2&view=bsp&ver=ohhl4rw8mbn4 From: Intelius <DoNotReply@intelius.com> Date: Fri, Feb 10, 2012 at 7:27 PM Subject: Intelius Purchase Receipt - Order #54680593 To: lisaliberi@gmail.com
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Name 1 Lisa Robinson Richardson Address / Phone Address 1: 3419 E Lafayette St Stockton, CA 95205 Address 2: 5450 N Winthrop Ave Chicago, IL 60640 RELATIVES: Becky Martinez Address 3: Po Box 13884 Silver Spring, MD 20911 (313) 675-8991 Complete Background Check Address 4: 2200 W Kilbourn Ave Milwaukee, WI 53233 (414) 897-0785 Address 5: 4410 N Dover St Chicago, IL 60640 (773) 506-2912 Address 6: 18282 Manorwood S Clinton Township, MI 48038 (773) 752-5935 Address 7: 420 Ainsworth Cir Ypsilanti, MI 48197 345-1453 Previous Cities Stockton, CA Chicago, IL Silver Spring, MD Milwaukee, WI Clinton Township, MI Ypsilanti, MI Westland, MI Detroit, MI Ann Arbor, MI Mount Pleasant, MI Racine, WI Kalamazoo, MI
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DOB: Jun 15th, 1973 AGE: 38 years old
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Case 8:11-cv-00485-AG-AJW Document 463-2 Filed 02/20/12 Page 5 of 5 Page ID #:10667 Racine, WI 53404
(773) 752-5935 Address 27: 453 Hoekje Hall Kalamazoo, MI 49008 (269) 382-6438 Address 28: 4217 Durand Ave Racine, WI 53405 Address 29: 700 Goold St Racine, WI 53402 Address 30: P.o. Ypsilanti, MI 48198 (313) 433-4473 2 Lisa R Richardson Address 1: Rr Hh Buena Park, CA 90620 (714) 827-7606 Address 2: 7020 Pozallo Pl Rancho Cucamonga, CA 91701 446-3508 Address 3: 8921 Watson St Cypress, CA 90630 (562) 868-2417 Address 4: 32464 Crown Valley Pkwy Dana Point, CA 92629 (909) 945-2637 Address 5: 11465 Mount Ritter St Rancho Cucamonga, CA 91737 Address 6: 7020 Pozallo Pl Chino, CA 91709 (909) 945-2637 Address 7: 8301 Etiwanda Ave Rancho Cucamonga, CA 91739 (909) 944-2627 Address 8: 11433 Carson St Lakewood, CA 90715 (562) 868-2417 Address 9: 3134 Casa Loma Dr San Bernardino, CA 92404 (562) 868-2417 Address 10: 32464 Crown Valley Laguna Niguel, CA 92677 (949) 493-7312 Address 11: 3126 W 1st St Santa Ana, CA 92703 (562) 868-2417 Address 12: 8641 Moody St Cypress, CA 90630 (909) 945-2637 Address 13: 11031 Slater Ave Fountain Valley, CA 92708 (562) 868-2417 Buena Park, CA Rancho Cucamonga, CA Cypress, CA Dana Point, CA Chino, CA Lakewood, CA San Bernardino, CA Laguna Niguel, CA Santa Ana, CA Fountain Valley, CA Houston, TX Albuquerque, NM Conroe, TX Complete Background Check
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DOB: May 28th, 1965 AGE: 46 years old RELATIVES: Tony Courville Billie Courville
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EXHIBIT C
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https://mail.google.com/mail/?ui=2&view=bsp&ver=ohhl4rw8mbn4 From: Intelius <DoNotReply@intelius.com> Date: Fri, Feb 10, 2012 at 7:35 PM Subject: Intelius Purchase Receipt - Order #54680809 To: lisaliberi@gmail.com
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Case 8:11-cv-00485-AG-AJW Document 463-3 Filed 02/20/12 Page 3 of https://www.intelius.com/report.php?reportID=ZGV0YWlsUmVwb3J0SUQ9NjA2MTEy 5 Page ID #:10670 NDgmdHhuSUQ9NTQ2ODA4MDkmcHVyY2hhc2VJR D0mcmVwb3J0VXNlcklEPTc5MDAxMDI=
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Aliases: Lisa R Richardson Lisa C Richardson Lisa R Courville Lisa D Courville Lisa R Reynolds Lisa Courricharcourri Richardson Lisa Courville
Relatives: Tony Courville Billie Courville
Dates of Birth: May 28th, 1965 (Age 46) Jul 1963 (Age 48) 1966 (Age 46)
Address History For Lisa Richardson

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Lisa R Richardson (714) 827-7606
Rr Hh Buena Park, CA 90620
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Lisa R Richardson 446-3508
7020 Pozallo Pl Rancho Cucamonga, CA 91701 Property Report
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https://mail.google.com/mail/?ui=2&view=bsp&ver=ohhl4rw8mbn4 From: Intelius <DoNotReply@intelius.com> Date: Mon, Feb 13, 2012 at 12:03 AM Subject: Intelius Purchase Receipt - Order #54753781 To: lisaliberi@gmail.com
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Background Check & People Search Powered by Intelius
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Aliases: Lisa R Richardson Lisa C Richardson Lisa R Courville Lisa D Courville Lisa R Reynolds Richardson Lisa Courville Lisa Courricharcourri
Relatives: Billie Courville Tony Courville
Dates of Birth: May 28th, 1965 (Age 46) Jul 1963 (Age 48) 1966 (Age 46)
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Case 8:11-cv-00485-AG-AJW Document https://www.intelius.com/myaccount/reports.php 463-5 Filed 02/20/12 Page 2 of 4 Page ID #:10679
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 2 of 13 Page ID http://www.identitytheftsecrets.com/intelius-review-an-interview-with-intelius-people-search-and-people-finders-ed-petersen #:10683
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Intelius Review: An interview with Intelius People Search and People Fin...
http://www.identitytheftsecrets.com/intelius-review-an-interview-with-int...
Identity Theft Secrets

The Secrets that Identity Thieves Don't Want You To Know
Home About Contact Solution? Investigators Texas Takes Steps to Protect Consumers from Identity Theft Iron Clad Protection for Personal and Business Laptop Computers
Intelius Review: An interview with Intelius People Search and People Finders Ed Petersen
Posted by Jonathan Kraft on June 10th, 2008
Click here to go to Intelius and try it out on yourself for free. Intelius People Search Intelius is a company providing more than people search and people finder services. However, that is what people most know Intelius for. In this review and interview with Ed Petersen, Executive Vice President for Intelius, we spoke about Intelius collecting cellphone numbers, their people search and enterprise-level services, and challenges people have had with Intelius accounts.
Intelius Review: Download the MP3
Identity Theft Secrets: This is Jonathan Kraft with Identity Theft Secrets and today I am talking with the Executive Vice President of Intelius, Ed Petersen, about Intelius services as well as what they do within the realm of people search and knowing what people are actually, I guess, knowing a bunch of information about people. So, Ed, thank you very much for taking the time to join us today. Intelius: No problem, its a pleasure to be here, Jonathan. Identity Theft Secrets: Well, lets just get started. What, what does Intelius do? I think a lot people maybe dont know what Intelius does exactly. Intelius: Intelius was developed to provide protection and safety services to both consumers and businesses and so the goal of the company has been to provide consumers and businesses with intelligent information so they can make better decisions about people, businesses and assets that affect their daily lives. And, so, whether someone is making a decision to hire a contractor, or hire a nanny, or to go out on a date with someone theyve met online, or dropping their kids off at a soccer practice, or for protecting their identity by monitoring public record data or credit report data, those are the types of services and the types of solutions that Intelius brings to the market.
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 4 of 13 Page ID #:10685 Identity Theft Secrets: Awesome. And how long has the company been in business? Intelius: So we founded the company in January of 2003, so right around five and a half years. Identity Theft Secrets: And basically people search then, is at the core of what you do, right? Intelius: I wouldnt necessarily say its the core, but it is certainly one of the entry points, I think, for our customers and our consumers. Were by far the largest online public records company and certainly a material component of that is people search. We run the people search components for many sites including Yahoo, including AOL, Yellow Book, a lot of the large directory-type sites and so Intelius is very, very advanced in that type of technology. I think that what ends up happening with people search from our standpoint is that people search is an enormous space online. In fact, youll see stats out there; I think that there was a Business Week article a few months back that said that 30% of all internet searches are people search-related. Now, about half of those 30% are actually celebrity searches. But still, even 15% of all internet searches are regular, hey, Im looking for Ed Petersen, how do I find him? And so, the space itself is enormous, but what weve ended up seeing is that once people connect, they want to take that next step and they want to get a little bit deeper information about the person they are trying to connect with. So, Ive found Ed Petersen, Ive used Intelius to find Ed Petersen. The next step is, Id love to get a little more background information on that specific person before I may reach out to them. Identity Theft Secrets: So, I knew Ed Petersen in high school, and so, now Ive found where he is; but hey, Id like to find out what hes been up to for the last ten years. Intelus: You got it. Before you show up on his doorstep or pick up the phone, you may want to make sure that there isnt anything in there that would give you pause. Identity Theft Secrets: Sure! How does Intelius collect all of this information on people? If youre providing the backend for some of the larger people searches online how do you go about collecting all this information? Intelius: Intelius literally has about 19 billion records at Intelius so, in-house, and so one of the things Intelius has always done is try to provide the deepest information and the most reliable information out there; which is a very difficult problem to solve. And, so, we have, as I said, at Intelius, about 19 billion records in-house. We also have real time data feeds from numerous sources. So right now, I think we have about, north of a hundred different data suppliers that give us information, and that some of that is on a very daily updated basis, some of that is on a more sporadic updated basis. But what we try to do is to use a ton of heuristic processes and the Intelius technology that allows us to match information together, stitch information together to present a very accurate report for our customers. Identity Theft Secrets: So that kind of sounds a little scary, if there is over a hundred data sources feeding the information into Intelius. What information, for example, could someone buy about me through Intelius? Intelius: Sure, and I think that really the important thing to know here is that everything that Intelius has is public record information or publicly available information. There certainly is information that Intelius does not have. We do not have health records, and we dont just, you cant call up someone and they call up Intelius and say, hey, Id love to check out Jonathans credit report, can you give that to me. We cant do that. So, it is all public information that we have. What a user can check out is they can call up, or they can go online to the Intelius website, and they can get information, for example, on your address history. They can get your current contact information; they can see if you have a criminal record. They can see if you are on the sex offender registry. They can see if youve had any civil litigation; for instance, a bankruptcy or a tax lien. They can see what type of professional licenses you may have. They can run a report on your property to see, hey, what is the value of a piece of property that you may own. So, there are numerous things like that that are all really geared towards giving someone a better picture of who they interact with. And, so, I think from Intelius standpoint, one of the things that is important is if you look at the trends that weve seen in the U.S. over the last decade or so, and even a little longer back than that, is that Intelius has really seen this trend of over 200,000 people moving every day in the U.S. And so, whats happened is the days of hey, Id like to add a deck onto the back of my house, where you say great, my next door neighbor is a guy I went to high school with, his brother-in-law is a contractor. Ill just write him a check, leave a key under the mat, and head off to work. And, either leave him alone in the house or leave him alone with my family in the house. Those days are really gone because there is such a transient-type society that we
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 5 of 13 Page ID #:10686 live in, that network of self-check really is no longer there. And I think thats the role that Intelius has fulfilled for many consumers, where they dont really think that the world is an evil place. But what they do want to do is before they make major decisions about either letting someone into their home or around their family, or making a financial decision, or protecting their identity, they want to make sure they are making the right decision and have all the most important information at their fingertips. Identity Theft Secrets: So someone, I think that is really a good example of it because we, I mean, just as a society we are moving a lot more than we ever did for sure. Could someone go though and buy on the personal security site, could someone buy my, for example, social security number through Intelius? Intelius: No, not at all. We would never sell a social security number to somebody. There is no chance. Identity Theft Secrets: Do you have that information though? Intelius: We have on certain spots on credit headers and so forth, we certainly do have social security data. It is actually very, very secure. What we do is we break it, if you will, and then encrypt it in two different databases. One of the interesting things about Intelius is all the different, because of the level of data we have, all the different security levels that we have to go through; we get audited, not only by our partners, but we also have the highest level of security authentication from VeriSign that you can receive to make sure that all of that information is safe. Now, calling in and saying what we do use, is we also do a large amount of employment screening. So if you look at, for example, FedEx Ground, we do the majority of their employment screening. So if a guy comes to your door and delivers a FedEx package to you, most likely Intelius has given FedEx the green light that that person is OK to hire. The level of data that we have to go through a screen of that nature is pretty substantial and, so, we really do hold ourselves to a higher standard of trying to be good stewards of that information. Identity Theft Secrets: So a business like FedEx, for example, could come to you and say, hey, weve got social security numbers for these twelve applicants. We want to run them through your system and see what they come up with. Intelius: Yeah, we want to verify that this person is who they claim to be. Absolutely. Identity Theft Secrets: Ok. Intelius: Absolutely. Now, if you come to Intelius and you have a name and an SSN; you can run a background report on that. You cannot come to Intelius and say hey, Id like to get Ed Petersens social security number. We do not do that. So, you cannot go buy social security numbers. If you have, and you just cant go to the site and punch in a social security number and get the name or the information associated with it either. You have to have a match. Identity Theft Secrets: So, could you explain more about that? Intelius: So, if you go in and you want to run a background check off of a social security number and you had, well I could use myself as an example. If I went to Intelius and I had my social security number, I can punch that in, but then I also would have to have, I have to know the name that is associated with the social security number to be able to actually run the report. And so, Id have to go in and type Ed Petersen, SSN is, you know, so forth, is this, hit submit, and if the SSN matches the name, then well run the report. Its just another way to narrow down the information for people, but we certainly by no stretch of the imagination allow people to just punch in a name and get an SSN. Identity Theft Secrets: Sure, OK. Well, from an identity theft perspective if an identity thief already had lets say, my name and social security number, and they brought it to your system, they could potentially get a lot more information about me. I mean, if they already have my name and social security number, Im in trouble anyway, but Intelius: Yeah, I would say that actually it goes the other way, generally, you know. It would be if someones already got your name and social security number, theyve already got the information anyway. Identity Theft Secrets: Right. Intelius: It would be unlikely (laughs) because the information they would be getting would be, are you a criminal, do you have any civil judgments or liens against you. Or what is your address history; those types of things, and those things are more readily available in public records than getting an SSN. And, if someone has gone to the trouble of getting a SSN, and, illegally getting an SSN if you will, chances are that the problem of them having other information is not real high.
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 6 of 13 Page ID #:10687 actually a relatively young group of people and they are, a lot of them are in their mid- to late-twenties. And, if you ask them, do you mind having a cell phone directory? or would you care? Their answer would be unequivocally absolutely not, it doesnt bother me at all! If someone calls me on my cell phone, and I dont recognize the number, I just dont answer it. And thats just a major shift. And I think its very similar, you know, you see when the first White Pages went on to the internet; the very first White Pages went online, there was a backlash on that as well. You had that backlash of geez, youre putting the White Pages online and now youre even linking to maps and directions. Now of course, over the years, over the last decade, that reaction to that has become nullified. Its just commonplace. So, I think that what you are going to see is an evolution of this where as cell phones become the only line that people have, youll see that that really will replace the White Pages and a cell phone directory eventually will come back, it will come back. I think that Intelius was early to market on it, but cell phone companies when they tried it, you know, four or five years ago, were early to market on it. I dont think that you have seen the end of it though would be my guess. Identity Theft Secrets: Well, I think Arthur Shopenhauer has sort of said that ideas come around and they go through three stages. Theyre ridiculed, and then theyre violently opposed, and then they serve as self-evident. And you know, its very interesting, I think, what you are talking about there. I remember using Mapquest, the first time I used Mapquest and I got directions from my high school, and this dates me; but from my high school to my parents house and I used those to get people to a party at my parents house. And, it blew me away, like this is scary, like this technology can do. So, I guess kind of switching away from that point about the cell phones, some of the biggest critics of Intelius say that the information that you sell isnt really worth anything. Even Techdirt, there was this Techdirt article that went to say its not hard to find many, many, many people who claim that the information is next to useless. What do you say to those critics about the value of the services that you provide? Intelius: I think that if you look at Intelius in general, theres a couple of things that I would point out. One, were a top 100 website. So, the volume of people that come into Intelius is enormous. The customer, were also the only player in the space who has live customer support; U.S.-based customer support you can call into a 1-800 number, and they are going to talk with a live body thats here in our building. So, we take our interaction with our customers extremely seriously. I think that if you look at any product, I mean I can go out and get the resources to build a car if I wanted to, right? I could go out and build a boat on my own if I wanted to. You could do anything you want, right? And you could put that information together. You certainly yes, without a doubt, if you wanted to look up an old friend or get information on an old friend, lets say Im trying to track down a buddy who I went to college with and hes living in Chicago now. I could hop on the plane and go back to Chicago, go down to the Cook County Courthouse, go into the courthouse, flip through all the records, find the information, pull it out, hop back on the plane, fly back to Seattle, dial up the phone number, and talk to the person and track him down that way and then make the decision whether I wanted to see him or not. I mean, my point is that, you know, that is sort of a reach of an example, but my point is, anything is possible. One of the things that Intelius does is that we try to pull together the most accurate representation of what is in public record, and pull it together in a way that is very compelling for customers and consumers so that they dont have to do that work themselves. The one thing I will point to is, we have an enormously high return customer rate. And so, if we were just trying to sort of, if customers did not see the value in our products, if they did not see the true value in our subscription services or our product offerings, they wouldnt come back time and time and time again. I also would have to hire, for the amount of traffic that comes into the Intelius store, if you will, I would have to hire an army of customer service agents if we had that many unhappy customers. Now, when you get to the volume of transactions that we have, you certainly, unfortunately, you are going to have a couple of customers that do not agree with the product offerings and that happens. In a digital good space, its always, I think, even more difficult. You know one of the things, if you look at Amazon, right, its a little different, right? They can ship you a book and if you dont like the book, you can send it back to them and they can resell it. With a digital good, once I display the product, Ive had to pay for everything. Ive had to pay for the product and so forth. I cant resell it. Its out the door. Ive just accepted all the cogs, all the cost of the goods, and the product is, its a perishable inventory. And so theres certainly, its a little bit interesting model from that standpoint and interacting with the customers because of some of those unique things. But, I think overall weve done a very good job there
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 7 of 13 Page ID #:10688 and I think our return customer base and the fact that were the only one that really have onsite, true 1-800 customer service, customer support where we can interact with our customers has helped us out a great deal. Identity Theft Secrets: Awesome. Well in talking about the growth of the business, your CEO filed for an IPO to make the company a public company with the Securities and Exchange Commission, um, not that long ago. Can you talk about that? I dont know if you can or not, but fortunately, for the IPO (laughs). Intelius: Yeah, actually, we are in a quiet period, but I can tell you that yes, we did, you know, Im certainly one of the founders of the company and so were walking through that process. We filed for it; well see how it goes and the S-1 has been filed. In fact, I think we just updated that a little while ago so that theres a more recent S-1A thats been out there that you can look up. But talking about it specifically, I think our General Counsel would be kicking me under the table. Identity Theft Secrets: Displeased alright (laughs). Well, in listening to this interview, Im sure theres going to be somebody who listens to this interview and goes, wow, so they have all of that information about me compiled in one place; I dont want all that information out there about me. So is it possible for someone to get their information removed? Or lets say you have inaccuracies about them on their report, if they order their own, is it possible to get the information removed or corrected? Intelius: Yes to both of those. And so, without a doubt, we have an opt-out policy. I think one of the interesting things about our opt-out policy is that weve got, we just like to make sure that the person who calls in to change, edit, delete information out of the system is, in fact, who they claim to be. So we just have, on our site, there is a spot where it is outlined what you need to do just to make sure that you are who you claim to be, and then we have a very straightforward opt-out policy. In fact, once you contact us, I think it is, I think it states that youll be opted out within 24 hours. Its either 24 or 48 hours. Identity Theft Secrets: Ok. And then if there is inaccurate information, somebody could get that corrected as well. Intelius: Yeah, we can just certainly update it and again what you want to do and it depends on what type of information youre trying to change, if you will. If you are changing your address and you are calling in and saying hey, my address and my phone number is, I moved and you guys dont have it there yet; which would be unusual, because usually we have it the next day. But thats one level of authentication, if you will, that you would go through for that. If youre calling in and saying, hey, I have a criminal record and this has been expunged and I need, and youre listing it on the site, and I need to get that off of there. There is just another set of rules that you need to go through, rules of engagement if you will, that you will need to go through with Intelius. Identity Theft Secrets: So, you just said something really interesting, that it would be odd if I moved and you didnt have the information the next day. Intelius: Yes. Identity Theft Secrets: Thats going to freak some people out. Intelius: (laughs) Identity Theft Secrets: Knowing some of the, you know, I mean, Im very familiar with how quickly data moves around the world, but Intelius: Right. Identity Theft Secrets: I think a lot of people really arent. And so, how do you, again you said that you grabbed the information from a hundred different sources, but, could you walk me through just a little more in-depth how that process works? Intelius: Yeah, I think, you know, there is, we get daily feeds that come in from a variety of spots and, what we do, is a daily update on much of our data sets. And so, particularly in the address, the residential data suite, we update that information on a very regular basis and so, we have daily feeds that come in where, if someone has moved, so if there has been a connect or a disconnect from a phone company or something along those lines, we generally know about it the next day. Identity Theft Secrets: And you know about that through just some simple public record searches? Intelius: Yeah again, Intelius does not have any super secret, you know, back channel, you know, I know the secret handshake and Im slipping the guy five bucks to get some data off his back door at some weird spot. Its all public available information and thats really it. I think the big thing that Intelius has done well is
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 8 of 13 Page ID #:10689 weve put together a data infrastructure that allows us to handle and deal with the data, deal with the information, and dealing with updating that information on such a regular basis. Thats where we have excelled. Its nothing that is not in public record or publicly available data. Identity Theft Secrets: Well, who are some of the biggest competitors for what you do, as far as your service is concerned and whats the best thing about you versus those other companies? Intelius: Yeah, I think that theres a couple, because there are a couple good players in the space. If you look that, on the consumer side, US Search is certainly a good company. They certainly do some things, nice things there. Were a bit larger than they are, quite a bit larger than they are, but we certainly consider them a competitor. On the employment screening space, First Advantage, we certainly compete with; ChoicePoint we compete with; Hire Rate we compete with. So there a number of companies in that space as well. Those are the types of companies on the transaction side that we work with. On the identity theft protection side of the business, you know, LifeLock is certainly someone that we keep an eye on. There are a handful of companies across multiple different levels of our business that we watch, on a regular basis. I think that the big thing with Intelius, if you look at, I think, some of the things that we think we understand very, very well, one is data. I think we understand very, very well how to pull data together, how to use heuristic-type processes to be able to create better reports on Intelius than anywhere else, which means they are more accurate, they are deeper, they are presented in a better fashion than anywhere else. I think we understand consumer marketing pretty well. We certainly have done some things where we have got some room for improvement, just like any company. We were talking about, for instance, the cell phone directory, but I think that Intelius has done that pretty well and I think we understand how to get users into a site and how to navigate them through a site so they can answer the questions that theyve got as fast and as efficiently as possible. Identity Theft Secrets: Awesome. Well, I dont want to take up too much of your time today. I know you are probably running to a bunch of different things all the time, but is there anything else that people should know about your company or about Intelius or the people search services that you offer; really anything else about what it is that Intelius does? Intelius: I think the biggest thing that I would remind people is the goal of Intelius is protection and safety services. And so, every product that you look at at Intelius has been built off of some personal experience with either an executive of the company or someone that we have known that has run into an issue where if they had a solution like one of the ones on Intelius, their life would be better today than it was. And so, whether that has to do as I said, with hiring a contractor, someone who wrote a check to a contractor and the guy never came back; to whether it had to do with someone driving their kids to school and that person was not a person youd ever want around your kids, let alone driving them to school. Whether it has to do with identity theft, weve had someone around here who had their identity stolen. All of the solutions that Intelius has and provides are geared toward protection and safety so consumers can make better decisions about people, businesses and assets. Those are the things that Intelius strives to accomplish. Identity Theft Secrets: Well, I want to thank you for taking a few minutes with us today and talking about some of the people search space and how Intelius is operating inside of that. And, wed love to have you back obviously if things change in the future and definitely would love to have you back to ask more questions if people have them as well as we go forward. Intelius: Absolutely, let me know, wed love to join you. Identity Theft Secrets: Thank you very much! Intelius: Bye, Jonathan. Identity Theft Secrets: This has been an interview with Identity Theft Secrets. We can be found online at www.IdentityTheftSecrets.com. Click here to go to Intelius and try it out on yourself for free. Intelius People Search
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Tags: account, accounts, cellphone, ed petersen, Ed Peterson, finder, intelius, intelus, Interview, numbers, people, people search, review, search, searches, services
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This entry was posted on Tuesday, June 10th, 2008 at 1:16 pm and is filed under Audios, Identity Theft Protection, Identity Theft Solutions. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
3 Responses to Intelius Review: An interview with Intelius People Search and People Finders Ed Petersen
1. Wones Says:
August 7th, 2008 at 4:54 pm
Intelius, Inc. is an excellent company as well but checkout website PeopleSearches.com http://www.peopleSearches.com 2. Consumer Says:
August 10th, 2008 at 3:39 pm
Intelius Revealed as a scam It turns out that the facts are in and there is no question that Intelius is a scam. What they do is outright theft from consumers. For all of the details, see the excellent blog at: http://www.techcrunch.com /2008/05/29/naveen-jains-intelius-prepares-to-go-public-how-much-of-their-revenue-is-a-scam/ Many people on blogs and comments have said they felt that these guys at Intelius deserve to be in jail. Read the TechCrunch story and the various comments and decide for yourself. There are also numerous web site where consumers have complained about these guys. Intelius claims to offer background checks and public information. Its pretty clear that all they do is to scrape public data and repackage and sell. All by itself, that is a legitimate service, but for them that is just a vehicle for a scam. All consumers should be pleased that TechCrunch did a background check on them, and found what a fraud they were, By the way, there are 100s of honest and ethical background check firm around that do a great job. 3. EY Chow Says:
December 1st, 2008 at 4:15 pm
I used Intelius for one time transaction just to find a person and the tool is very much user-friendly and
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Case 8:11-cv-00485-AG-AJW Document 463-6 Filed 02/20/12 Page 10 of 13 Page ID #:10691 easy to navigate. The service fee was charged yet I received an additional $20 charge several weeks later saying I have also purchased a Identity Protection Package which I have never authorized this transaction and the order has never shown in my first transaction. I called the customer service and it took me about an hour to get through; their customer service rep responded my dissatisfaction with theres nothing we can do because it comes along with your first people search purchase; therefore we cannot offer any refund. The ridiculous thing is, this identity protection has a totally different order number and if what he said is true, why I did NOT see any indication of this additional charge when I purchased their service the first time!? Their search tool may be useful, but I am very disappointed about how they used my account info and charge me for something I have not been notified or aware of I consider this almost like a deceit rubbing customers money & rights.
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EXHIBIT G
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Case 8:11-cv-00485-AG-AJW Document 463-7 Filed 02/20/12 Page 2 of 3 Page ID http://edpetersen.intelius.com/corp/bio/edward-petersen #:10696
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Edward Petersen: Senior Vice President , Social & Mobile Services
http://edpetersen.intelius.com/corp/bio/edward-petersen
Edward Petersen
Senior Vice President , Social & Mobile Services Edward Petersen is a co-founder and has served as our Senior Vice President, Sales and Marketing, since our inception in January 2003. From 1999 to 2002, Mr. Petersen held several senior-level positions at InfoSpace, including Vice President of Business Development, Senior Vice President of Devices and Network Equipment and Senior Vice President of Wireless Services. In 1998, Mr. Petersen founded Union-Street.com, an Internet company, where he served as its President until its acquisition by InfoSpace in 1999. From 1995 until 1998, Mr. Petersen was a Head of Program Management for Pantheon, Inc., an Internet infrastructure company. Mr. Petersen holds a B.A. degree in History and Business Administration from Whittier College.
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EXHIBIT H
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http://www.intelius.com/corp/security as of 10/25/2011 Filed 02/20/12 Page 2 of 5 Page ID Case 8:11-cv-00485-AG-AJW Document 463-8 #:10699
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Intelius - Corporate - Security - Compliance
http://www.intelius.com/corp/security
Security
Intelius recognizes the sensitivity surrounding many of its applications and the data they rely on. As such, Intelius' information security policy addresses security at all levels: personnel, technology and operations. Intelius follows the highest industry standards for protecting personally identifiable information such as Personal Names, Social Security Numbers and Credit Card Numbers. Intelius contracts with independent security companies to conduct regular audits of our security technology, policies, and procedures. The Intelius website uses Verisign issued SSL certificates to ensure secure web transactions. Intelius engages in continual security monitoring and analysis of all information technology systems including periodic external network scanning and penetration testing conducted by independent security companies. Intelius is a certified credit reporting agency. The Intelius Enterprise IT Infrastructure has been evaluated and certified under the Verisign Security Certification Program to be compliant with the following industry standards (Intelius certification letter issued by Verisign Enterprise Consulting (/intelius-certification-letter-2009.pdf) ): Payment Card Industry (PCI) Data Security Standard v1.2; Gramm-Leach-Bliley Act (GLBA); ISO 27002 (formerly 17799:2005)/27001:2005 Information Security Standards; Technical security standards from the National Institute of Standards (NIST) and the Open Web Application Security Project (OWASP); and State Security Breach Notification Law (using California's as the baseline - CIVIL CODE SECTION 1798.80-1798.84).
Compliance
We devote tremendous time and resources to assure that we have the best data available, configured to your needs. We've contracted with multiple redundant data sources so you can be confident that Intelius' information is as accurate as possible. Our technologies all meet the standards of compliance required in the following federal acts: Patriot Act-CIP (Customer Information Profile). Under the Patriot Act, financial institutions have a reporting requirement to provide on customer activity that may affect national security. Intelius can supply you with ready-made systems to ensure compliance, while still guarding you, and your customer's, privacy. The Fair Credit Reporting Act (FCRA) sets forth guidelines regarding criminal checks for tenant and pre-employment screening. Intelius is a certified credit reporting agency and can help insure you are compliant with current regulations and updates as they happen. U.S. Office of Foreign Assets Control (OFAC) tracks "Specially Designated Nationals" who may have links to individuals, groups, and entities associated with terrorist activities or narcotics trafficking with targeted countries. Intelius crossreferences this database when running HR and individual background criminal checks on individuals. This safeguards you against hiring or dealing with an individual on a government watch list.
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Case 8:11-cv-00485-AG-AJW Document 463-8 Filed 02/20/12 Page 4 of 5 http://web.archive.org/web/20090328055224/http://www.intelius.com/corp/security.html Page ID #:10701
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Case 8:11-cv-00485-AG-AJW Document 463-8 Filed 02/20/12 Page 5 of 5 http://web.archive.org/web/20090428044739/http://www.intelius.com/corp/security.html Page ID #:10702
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EXHIBIT I
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http://www.intelius.com/corp/security Document 463-9 Filed 02/20/12 Page 2 of 3 Page ID Case 8:11-cv-00485-AG-AJW #:10704
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Intelius - Corporate - Security - Compliance
http://www.intelius.com/corp/security
Security & Compliance Security

Here at Intelius we recognize the importance of preserving the confidentiality, integrity, and availability of our applications, the data they rely on, and the data of our customers and users. As such, Intelius's information security policies address information security at all levels; from personnel and practices to technology and operations. Intelius follows the highest industry standards for protecting personally identifiable information (PII) such as personal names, Social Security Numbers, and credit card numbers. To validate our practices and ensure the highest level of security, we contract with independent security firms to conduct regular audits, assessments, and reviews of our security technology, policies, and procedures. The Intelius website uses Verisign-issued Extended Validation (http://en.wikipedia.org/wiki/Extended_Validation_Certificate) SSL certificates to secure web transactions and provide SSL/TLS encryption with 2048bit encryption keys. Intelius performs continual security monitoring and analysis of all information technology systems including regular external network scanning and penetration testing conducted by independent security firms. Intelius is a certified credit reporting agency abiding by all FCRA standards as well as a level 1 Merchant by the Payment Card Industry Data Security Standards. The Intelius IT Infrastructure has been evaluated and certified to be compliant with the following industry standards: Payment Card Industry (PCI) Data Security Standard v2.0 and Experian Third-Party Independent Assessment
Compliance
We devote tremendous time and resources to assure that we have the best data available configured to your needs. We contract with multiple data sources to provide redundancy and ensure consistency so you can be confident that Intelius's information is as accurate as possible. Our technologies all meet the standards of compliance required in the following federal acts: The Fair Credit Reporting Act (FCRA) sets forth guidelines regarding criminal checks for tenant and pre-employment screening. Intelius is a certified credit reporting agency and can help insure you are compliant with current regulations and updates as they happen. The Payment Card Industry Data Security Standard (PCI DSS) is determined by the PCI Security Standards Council (https://www.pcisecuritystandards.org/) which comprises many representatives from credit card brands and issuing banks. The standard is designed to ensure the safety and security of credit (and other payment) cards being processed by merchants. Intelius is annually audited and certified as a level 1 Merchant by a certified and independent third party Qualified Security Assessor(QSA) to these standards. We also undergo a voluntary Sarbanes-Oxley audit on an annual basis. While we are not required to submit to this audit as publically traded companies are, we have elected to regularly undergo the process both as a way to benchmark our internal processes, procedures, and policies and to ensure that we are constantly evolving all of these to meet the ever-changing needs of the information security landscape.
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Case 8:11-cv-00485-AG-AJW Document 463-10 #:10706
Filed 02/20/12 Page 1 of 3 Page ID
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EXHIBIT J
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http://www.intelius.com/corp/ Case 8:11-cv-00485-AG-AJW Document 463-10 #:10707
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Intelius - Corporate Home
http://www.intelius.com/corp/
Intelius
There is power in predictive intelligence. Power to interpret information with accuracy, speed, and peace of mind. Power to avoid relationships with people or businesses likely to put your personal life, assets or organization at risk. Power to grow a business. But to be valuable, this intelligence must be delivered by a thoughtful ally with accuracy, integrity and your best interests at heart. Intelius is that ally. We are pioneers in the information commerce industry, innovating technologies to collect, interpret and deliver information to consumers and businesses online. We strive to facilitate an intelligent and informed decision-making process for our customers in business and life. Ranked among the top 100 commerce sites on the Internet, Intelius offers products and services ranging from basic people search and list management to comprehensive HR background checks and one of the best identity theft protection products available. We do much more than deliver reliable and accurate information-we augment, interpret, and present it based on your unique needs, creating valuable and trusted solutions for our millions of customers across lifestyles and industries.
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EXHIBIT K
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http://www.intelius.com/corp/consumerDocument 463-11 Case 8:11-cv-00485-AG-AJW #:10710
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Intelius - Consumer
http://www.intelius.com/corp/consumer
Consumer
Our consumer services include: Intelius IDWatch (http://find.intelius.com/search-name.php?searchform=idwatch) Identity theft damages more than simply credit. In fact, it can deliver a crippling blow to not only personal finances, but consumers' good names. Intelius IDWatch monitors all of a customer's identity-related information, including phone, address, driver's license profile, credit and Social Security related information, proactively preventing ID theft. Intelius' IDWatch alerts customers via SMS or email to suspicious activity 24 hours per day, and scours online forums for blackmarket SSN transactions, immediately alerting potentially affected customers. IDWatch also includes a $25,000 insurance policy on identity recovery-related costs and a personal recovery advocate in the case of identity theft. Intelius' IDWatch is an innovative, affordable, award-winning identity theft solution employing technology uniquely designed to prevent ID theft. Background checks (http://www.intelius.com/background-check.html) Intelius background checks contain a criminal report augmented by additional information including an address history, property and neighborhood report, aliases and associates, civil judgments, liens and bankruptcies, among others. Background checks enable consumers to take a deeper dive into an individual's background, giving them the information they need to feel secure that their potential date, neighbor, caretaker or business partner is who they say they are. Reverse Phone Search (https://www.intelius.com/reverse-phone-lookup.html) Intelius reverse phone searches enable consumers to feel confident about returning calls from numbers they do not recognize. Parents also find reverse phone searches helpful in understanding who their children are interacting with, and having the peace of mind that they're not placing themselves in harm's way. Criminal checks (https://www.intelius.com/criminal-check.html) Intelius criminal checks confirm that a person coming into contact with a consumer's home or family is without a criminal background. Criminal checks instantly deliver information from nationwide felony, misdemeanor, sex offender and other criminal records. People Search (http://find.intelius.com/search-name.php?searchform=name) Intelius people searches reunite thousands of people everyday with long-lost friends, family, loved ones, college roommates, military buddies, colleagues and more - instantly!
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Case 8:11-cv-00485-AG -AJW Document 463-12 8:11-cv-00485-AG-AJW Document 380-3 #:10715 #:8706
Filed 09/16/11 Page 1 of 7 Page ID 02/20/12 2 8
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John A. Vogt (State Bar No. 198677) javogt@JonesDay.com Edward S. Chang (State Bar No. 241682) echang@JonesDay.com JONES DAY 3161 Michelson Drive, Suite 800 Irvine, California 92612 Telephone: (949) 851-3939 Facsimile: (949) 553-7539 Attorneys for Defendant INTELIUS, INC. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION LISA LIBERI, et al., Plaintiffs, v. ORLY TAITZ, et al., Defendants.
Case No. 8:11-cv-00485-AG (AJWx) Assigned for all purposes to Hon. Andrew J. Guilford DECLARATION OF BENJAMIN NELSON IN SUPPORT OF INTELIUS MOTION TO DISMISS Date: Time: Dept: October 17, 2011 10:00 a.m. 10 D
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DECLARATION OF BENJAMIN NELSON I, Benjamin Nelson, declare and state: I am the Custodian of Records of the Consumer Business Unit of Intelius Inc. (Intelius). I have been Custodian of Records of the Consumer Business Unit of Intelius for six years. I make this Declaration in Support of Intelius Motion to Dismiss. I have personal knowledge of the facts set forth in this Declaration, and if called as a witness, I could and would competently testify concerning such matters. 2. Intelius owns and operates various interactive websitesincluding www.intelius.com and www.talentwise.comthat allow users to obtain, over the Internet, various public records, such as addresses, phone numbers, and court records. Intelius business is separated into two distinct divisions: The Consumer Division and the Enterprise Division. The two divisions offer very different products and services. 3. The Consumer Division serves users seeking public records The Consumer Division information for reasons other than employment screening, tenant screening, or other purposes covered by the Fair Credit Reporting Act. operates through www.intelius.com. One of the services that Intelius offers users through its Consumer Division is a generic background check search. 4. The Enterprise Division, by contrast, serves users seeking employment or tenant screening productsproducts and services that are designed to be fully compliant with the Fair Credit Reporting Act. The services Intelius offers through its Enterprise Division are provided through Intelius subsidiary, TalentWise Solutions, LLC at www.talentwise.com. 5. Intelius maintains record of every search that was ever run on any individuals name. According to Intelius records, the only defendant in this case to have ever conducted a search on Lisa Liberi was Orly Taitz on April 12, 2009 through Intelius website, www.intelius.com. That search was a generic
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background search, which contains only public information. I attach as Exhibit 1 to this Declaration, a true and correct copy of the search results Orly Taitz obtained on the name Lisa Liberi on April 12, 2009 through www.intelius.com. 6. Intelius records also indicate that Ms. Liberi herself conducted a search on the name Lisa Liberi on April 10, 2010 through www.intelius.com. I attach as Exhibit 2 to this Declaration, a true and correct copy of the search results Ms. Liberi obtained on the name Lisa Liberi on April 10, 2010 through www.intelius.com. Intelius records also indicate that Ms. Liberi conducted two searches on herself, on April 10 and 12, 2010, respectively, through www.talentwise.com. 7. I attach as Exhibit 3, a true and correct copy of the TalentWise reports Ms. Liberi purchased on herself. Before anyone can run any search through Intelius websites, including the background check searches that Ms. Taitz and Ms. Liberi ran on the name Lisa Liberi on www.intelius.com, they must agree to be bound by Intelius Terms and Conditions, which are accessible via hyperlink on the order confirmation screen. (See http://www.intelius.com/useragreement.php). This confirmation screen is a webpage that requires users to confirm their purchase, and to make the following affirmation: I accept the Terms and Conditions. The user conducting the search must then click a button on the screen titled, Complete the Purchase and Show my Report, to finalize the purchase. 8. Intelius Terms and Conditions read, in part, as follows: 1. Access to Intelius. Upon registration, Intelius grants you a nontransferable, nonexclusive license to access our databases and the information contained in the databases, solely for the purpose of performing data verification, person, property and address location and related searches for qualified individual non-commercial use only.
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Intelius may authorize broader enterprise business use through its enterprise services program. * * * FCRA Restrictions. Intelius is not a consumer reporting agency as defined in the Fair Credit Reporting Act (FCRA), and the information in the Intelius databases has not been collected in whole or in part for the purpose of furnishing consumer reports, as defined in the FCRA. You shall not use any of our information as a factor in (1) establishing an individuals eligibility for personal credit or insurance or assessing risks associated with existing consumer credit obligations, (2) evaluating an individual for employment, promotion, reassignment or retention (including employment of household workers such as babysitters, cleaning personnel, with nannies, another contractors, and other individuals), or (3) any other personal business transaction individual (including, but not limited to, leasing an apartment). A true and correct copy of Intelius Terms and Conditions are attached as Exhibit 4 to this Declaration. Although Intelius Terms and Conditions get modified and amended from time to time, I can attest the Paragraphs 1 and 4 of the Terms and Conditions (quoted above) are the same as those that were presented and agreed to Ms. Taitz and Ms. Liberi when they purchased their background check searches on the name Lisa Liberi.
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9.
A background check search through Intelius at www.intelius.com
provides users with only public information from public sources about the potential person the user is searching for (such as name, address, phone numbers). To locate public records over the Intelius website via a background check search, a user enters three search terms: first name, last name, and state of residence of the person they are searching for. The website then performs a search that accesses public records databases, and identifies all records that contain the search terms. The website retrieves the matching records, and displays them. The website almost instantly filters through millions of public records to yield results based on the search terms. Because there are many people that share the same or very similar names, a search will return public records for different individuals with the same or similar namejust as a phonebook has multiple listings for different people with the same name. 10. by Intelius. 11. None of the search results obtained by Ms. Taitz on the name Lisa Liberi contained non-public information, such as social security numbers, financial information, or credit information. 12. Intelius records indicate that Todd Sankey, Neil Sankey, Sankey Investigations, Inc., and The Sankey Firm, Inc. (the Sankey Defendants) did not run a background check or any other search on the name Lisa Liberi (or Ms. Liberi in any capacity), including on April 8, 2009. The Intelius account of Neil Sankeythe only Sankey Defendant ever having an account with Intelius was not created until November 30, 2009. 13. 14. Neither Todd Sankey, Yosef Taitz, nor Lisa Ostella has ever had an On April 14, 2010, counsel Philip Berg sent a letter to Intelius (on Intelius account. behalf of Ms. Liberi) to Naveen Jain, CEO of Intelius, dated April 14, 2010. On
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A background check does not contain any original content created
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page 5 of this letter, Mr. Berg challenges the accuracy of certain information appearing on a report that Ms. Liberi acquired on herself: social security numbers, names and addresses. The exact wording of his letter is as follows: On April 11, 2010, Mrs. Liberi again pulled her Intelius report as a result of actions of Orly Taitz, Esquire. Only this time, her Intelius record was completely changed. As of April 11, 2010, Intelius has now combined Mrs. Liberis old and new Social Security number [462xx-xxxx and 622-xx-xxxx]; added her maiden name of Richardson and other names, many of which have never belonged to or been used by Lisa Ren Liberi as well as her home [house] address. Moreover, there are approximately six [6] different Social Security numbers tied to Lisa Ren Liberis report, which have never belonged to or been used by Lisa Ren Liberi. What is more ironic are the names and multiple Social Security numbers appearing is exactly what Orly Taitz, Esquire and Neil Sankey had accused her of. Lisa Ren Liberi, Lisa M. Ostella and Mrs. Ostellas husbands Social Security numbers are now flagged showing multiple people using their numbers. A true and correct copy of the letter Mr. Berg sent on behalf of Ms. Liberi to Naveen Jain, dated April 14, 2010, is attached hereto as Exhibit 5. 15. 16. Intelius records indicate that the name Lisa Ostella was never On October 29, 2010, Ms. Ostella wrote a letter to Intelius requesting searched through Intelius or any of its affiliates. the names of any person that had ever done a search on her. A true and correct copy of that letter is attached hereto as Exhibit 6. Intelius responded to that letter
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EXHIBIT M
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Philip J. Berg, Esquire (PA I.D. 9867) E-mail: philjberg@gmail.com LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 Fax: (610) 834-7659 Attorney in pro se and for Plaintiffs UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION LISA LIBERI, et al, vs. ORLY TAITZ, et al, : : : Plaintiffs, : : : : : : Defendants. : :
CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) PLAINTIFFS CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify a true and correct copy of Lisa Liberis
Declaration in Support of Plaintiffs Opposition and Concise Statement of Disputed Material Facts to Intelius Motion for Summary Judgment was served electronically through the ECF filing system this 20th day of February 2012, upon the following:
John A Vogt, Jr., Esquire Edward San Chang, Esquire Jones Day 3161 Michelson Drive Suite 800 Irvine, CA 92612 Email: javogt@jonesday.com and echang@jonesday.com Attorney for Defendant Intelius, Inc.
Liberi, et al Plaintiffs Certificate of Service of Liberi Declaration
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Marc Steven Colen, Esquire Law Offices of Marc Steven Colen 5737 Kanan Road, Suite 347 Agoura Hills, CA 91301 Email: mcolen@colenlaw.com Attorney for Defendants: Neil Sankey; Todd Sankey; Sankey Investigations, Inc. and The Sankey Firm, Inc. James F McCabe, Esquire Morrison & Foerster 425 Market Street San Francisco, CA 94105-2482 Email: jmccabe@mofo.com Attorney for Defendants: Reed Elsevier, Inc., LexisNexis Group, Inc., LexisNexis, Inc., LexisNexis Risk and Information Analytics Group, Inc., L LexisNexis Risk Solutions, Inc., Seisint, Inc. d/b/a Accurint, Choicepoint, Inc.
/s/ Philip J. Berg Philip J. Berg, Esquire
Liberi, et al Plaintiffs Certificate of Service of Liberi Declaration

Declaration of Lisa Liberi in Support of Plaintiffs Opposition To Intelius' Motion For Summary Judgment Doc 463

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Case 8:11-cv-00485-AG-AJW Document 463 Filed 02/20/12 Page 1 of 22 Page ID #:10637

Attorney for Plaintiffs

ORLY TAITZ, et al,

Intelius at their website www.intelius.com. The report I purchased, and Intelius

Declaration of Lisa Liberi

Case 8:11-cv-00485-AG-AJW Document 463 Filed 02/20/12 Page 2 of 22 Page ID #:10638

Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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Below is a screen shot of Mr. Thunens Exhibit 4, DN 456-4:

Declaration of Lisa Liberi

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24, 2010 Declaration as Exhibit 3, DN 389-2, pp. 20-23:

Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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There is no question, Mr. Nelsons Exhibit 3, DN 380-6; Mr.

Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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I went to Intelius home page at http://www.intelius.com/corp/, and

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Declaration of Lisa Liberi

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Declaration of Lisa Liberi

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Exhibits to Mr. Nelsons Declaration as they contain private data.

Case 8:11-cv-00485-AG-AJW Document 463 Filed 02/20/12 Page 22 of 22 Page ID #:10658

Lisa Liberi, Declarant

Declaration of Lisa Liberi

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Case 8:11-cv-00485-AG-AJW Document 463-1 Filed 02/20/12 Page 2 of 4 Page ID #:10660

1 Background Report Total Charge

Thank You for Your Order - Intelius.com

Case 8:11-cv-00485-AG-AJW Document 463-1 Filed 02/20/12 Page 3 of 4 Page ID #:10661

My Intelius Services Summary

Order No. 49346983

Expires on Oct 19, 2011

Personal Public Records Data What is a Personal Public Records Data?

Subject: Lisa Richardson

Aliases: Lisa R Richardson

Relatives: Lisa R Liberi