Fulton County Superior Court

***EFILED***TV
Date: 2/1/2017 10:24:21 AM
Cathelene Robinson, Clerk

IN THE .$IAPE.I<1C)R ColAjq oF-

FULTON COUNTY, e.,!:.D ~61IA

CHAD RUSKEY and )

BRANDREP, lNC., )
)
Plaintiffs, )
vs. ) Civil File Action:
) No.: 2014 CV 251879
JAY TOKARZ, JEFF TOKARZ, JOEL )
TOKARZ, SHANE TOKARZ, AND J01m AND )
JANE DOES 1-10, )
)
Defendants.

AGREED ORDER AND PERMANENT INJUNCTION

Upon consideration of the Complaint filed by Chad Ruskey and Brandkep, Inc.

(collectively, "Plaintiffs"), and ooting that Plaintiff and defendant Jay Tokarz

e'Defeodant")-posting on Ripoff Report as "Ruskey Rip Off" and "ChadVictim"-bave signed

and approved the substance and form of this .Agreed Order and Permanent Injunction, the Court

finds the following:

JUDGMENT

IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Defendant

pseudonymously published unlawful statements regarding Plaintiffs on the Internet,

including=-but not limited to-that "Chad Ruskcy is a fraud and thief," "Chad Ruskey is a thief

and snake," "Brandrep.com Thief - Fraud - Liar," and "I was lured into doing business with

Chad Ruskey by his lies and misrepresentations."

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that these statements

published about Plaintiffs, which are incorrect and causing damage to Plaintiffs, are presently

located at the following URLs:

 3) http://www.ripoffi:eport.com!rlChad-RuskeYlLas- V cgas-NevadaiChad-Ruskey-
SEOCORECOM-JOBSOFIW ARECOM-Managerjobscom-Healthjobcom-
Analystjobcom-1087007; and
4) http://www.ripoffrcport.comir/Chad-Ruskey/nationwidelCbad-Ruskey-Job-
Software-Zerply-B,.andrepcolD~ Thief-Fraud-Liar-Dirt-Bag-Mounfaj-] 150274.

PERMANENTINJUNCTION

IT IS THEREFORE ORDERED, ADJUDGED AND DECREED as follows:

a) Defendant and his agents and assigns are prohibited from any further acts of
defamation or publication of false and/or misleading statements, comments, or
information about Plaintiffs on Ripoff Report or any other website or publication;

b) The Parties ate mandated to take aJl reasonable actions they can under the law to
remove the Ripoff Report postings including, but not limited to, Defendant personally
removing all. defamatory, disparaging, libelous, false and materially misleading
statements about Plaintiffs that Defendant posted on Ripoff Report about Plaintiffs
and requesting that Ripoff Report remove the offending content;

c) The Parties are mandated to request that Internet search engines such as Google,
Yahoo! and Bing remove from their' search indices the following URLs:

1) http://www.ripoffreport.comMChad-Rl1skey/Las-Vegas-NevadalCbad-
Ruskey-SEOCORECOM-JOBSOFTW ARECOM-Managerjobscom-
Healthjobcom-Analystjobcom-I087007; and
2) http://www.ripoffreport.comlr/Chad-RuskeY!nationwide/Chad-Ruskey-Job-
Software-Zerply-Brandrepcom- T'hief-Fraud-Liar-Dht-Bag-Mollntai-1150274;

d) The Parties are mandated, as it is foreseeable that the above-referenced URLs and
statements contained thereon will be referenced on additional webpages in the future
including, but not limited to, index, directory, and search results pages, to take all
actions available under the law to remove all such web pages from the Internet,
including requesting removal from the Internet search engines Google, Yahoo], and
Bing, of all such webpages.

DAMAGES, FEES AND COSTS

IT IS FURTHER ORDERED that no damages are awarded to any party in this matter;

. IT IS FURTHER ORDERED that all costs of Court expended or incurred in this matter

are taxed against the party incurring same;

IT IS FURTlIER ORDERED that each party shall b·ear its own attorney's fees;
 r
-------------... . ....

IT IS FURTHER ORDERED that tills Court retains jurisdiction to enforce this Agreed

Order and Permanent Injunction;

IT IS FURTHER ORDERED that this cntry hereby resolves any and all claims that are

currently pending in this matter and closes this case.

IT IS SO ORDERED.

This31~ of .J4UJ.(4Jlj-, Wt6.

20[7.
 HAVING SEEN AND AGREED:

and

Colleen M. Devanney
Ohio Bar Number 0083795, admitted pro hac vice
VORYS, SATER, SEYMOUR AND PEASE LLP
30) East Fourth Street
Suite 3500, Great American Tower
Cincinnati, Ohio 45202
Tel: (513) 723-4000
Fax: (513) 852-7828

Attorneys for Plaintiffs

Debra McLean h'/

Georgia Bar N~. _3J!1kkt2
8325 Dunwoody Place
Building Two
Atlanta, GA 30350
Tel: (770) 558-8375
debramclean9@gmail.com

Attomey for Defendant Jay Tokar?