IN THE CIRCUIT COURT OF GREENE COUNTY STATE OF MISSOURI

IN THE CIRCUIT COURT OF GREENE COUNTY STATE OF MISSOURI STATE OF MISSOURI ex rel. ATTORNEY GENERAL JOSHUA D. HAWLEY and DANIEL PATTERSON, Petitioners, Cause No. 1731-CC v. Div. GOLDEN MASSAGE f/k/a GOLDEN MASSAGE SPA, LLC SERVE AT: 4728 South Campbell #112 Springfield, MO 65810; DAQUIONG WANG SERVE AT: 4728 South Campbell #112 Springfield, MO 65810; PHOENIX MAGIC MASSAGE LLC, d/b/a PHOENIX MASSAGE SERVE REGISTERED AGENT: c/o Hongbo Qi 1261 East Republic Springfield, MO 65804; PHOENIX ORIENTAL MASSAGE LLC, d/b/a PHOENIX MASSAGE SERVE REGISTERED AGENT: c/o Hai Biao Fu 1261 East Republic Springfield, MO 65804; WANHUA TIAN, d/b/a PHOENIX MASSAGE SERVE AT: 1405 Camino Alto Springfield, MO 65804 1

ZEMIN GUO, d/b/a PHOENIX MASSAGE SERVE AT: 1405 Camino Alto Springfield, MO 65804 HONGBO QI SERVE AT: 1261 East Republic Springfield, MO 65804; RELAX MASSAGE, a/k/a RELAX SPA SERVE AT: 2022 South Stewart Springfield, MO 65804; SHENG YANG SERVE AT: 2022 South Stewart Springfield, MO 65804; XIAO CHEN SERVE AT: 2022 South Stewart Springfield, MO 65804; HUI OTIS d/b/a ANGEL MASSAGE SERVE AT: 3731 South Glenstone, #284, Springfield, MO 65804 FENGHUA LI d/b/a ANGEL MASSAGE SERVE AT: 2015 West University Street, Apt #D408, Springfield, MO 65807 YANG YONGZHEN d/b/a ANGEL MASSAGE SERVE AT: 2

2015 West University Street, Apt #D408, Springfield, MO 65807 GREAT SPA SERVE AT: 2841 South Fremont Springfield, MO 65804; MEI XIANG CUI SERVE AT: 2841 South Fremont Springfield, MO 65804; YANMEI WANG d/b/a ASIAN MASSAGE SERVE AT: 2412 South Fort Avenue, Springfield, MO 65807 Respondents. PETITION Petitioners State of Missouri, at the relation of Attorney General Joshua D. Hawley and Prosecutor Daniel Patterson, bring this Petition, and upon information and belief, state as follows: Nature of the Action 1. In this action, Attorney General Joshua D. Hawley and Greene County Prosecutor Daniel Patterson seek to enjoin sixteen defendants from conducting flagrant human trafficking and prostitution activity in Springfield, Missouri, under the false pretenses of operating massage parlors. Under Missouri law, [a]ny room, building or other structure regularly used 3

for any prostitution activity by this chapter is a public nuisance. 567.080.1, RSMo. The attorney general, circuit attorney or prosecuting attorney may, in addition to all criminal sanctions, prosecute a suit in equity to enjoin the nuisance. 567.080.2, RSMo. All persons, including owners, lessees, officers, agents, inmates or employees, aiding or facilitating such a nuisance may be made defendants in any suit to enjoin the nuisance, and they may be enjoined from engaging in any prostitution activity anywhere within the jurisdiction of the court. 567.080.3. Pursuant to this authority, Attorney General Joshua D. Hawley and Prosecutor Daniel Patterson seek preliminary and permanent injunctive relief barring the persons, entities, and locations involved in these human-trafficking and prostitution activities from any further participation in prostitution activity. Parties 2. Joshua D. Hawley is the duly elected Attorney General of the State of Missouri and brings this action in his official capacity pursuant to Chapter 567 of the Missouri Revised Statutes. 3. Daniel Patterson is the duly elected Prosecuting Attorney of Greene County, Missouri and brings this action in his official capacity pursuant to Chapter 567 of the Missouri Revised Statutes. 4

Golden Massage 4. Respondent Golden Massage holds itself out as a massage parlor and has a principal place of business at 4728 South Campbell Avenue, Suite 112, Springfield, Missouri 65810. Golden Massage had previously been operating as Golden Massage Spa, LLC, d/b/a Golden Massage. On June 7, 2017, the Missouri Secretary of State administratively dissolved Golden Massage Spa, LLC for failure to maintain a registered agent. On information and belief, Golden Massage is no longer registered with the State of Missouri. 5. Daquiong Wang is an owner, officer, agent, or employee of Golden Massage, and, on information and belief, resides in Missouri and can be found at 4728 South Campbell Avenue, Suite 112, Springfield, Missouri 65810. Phoenix Massage 6. Phoenix Massage holds itself out as a massage parlor with a principal place of business at 1261 East Republic Rd, Springfield, Missouri 65804. 7. Phoenix Massage is licensed with the City of Springfield under the name Phoenix Magic Massage, LLC. 8. Phoenix Massage is a fictitious business name registered with the State of Missouri and owned by Phoenix Oriental Massage, LLC, Wanhua Tian, and Zemin Guo. Phoenix Massage; Phoenix Magic Massage, LLC, d/b/a 5

Phoenix Massage; Phoenix Oriental Massage, LLC, d/b/a Phoenix Massage; Wanhua Tian, d/b/a Phoenix Massage; and Zemin Guo, d/b/a Phoenix Massage will be collectively referred to as Phoenix Massage. 9. Phoenix Magic Massage, LLC is Missouri limited liability company and an owner or agent of Phoenix Massage, and has a principal place of business at 1261 East Republic Road, Springfield, Missouri 65804. 10. Phoenix Oriental Massage, LLC is an owner or agent of Phoenix Massage, and has a principal place of business at 1261 East Republic Road, Springfield, Missouri 65804. 11. Wanhua Tian is an owner, officer, agent or employee of Phoenix Massage, and resides at 1405 Camino Alto, Springfield, Missouri 65804. 12. Zemin Guo is an owner, officer, agent or employee of Phoenix Massage, and resides at 1405 Camino Alto, Springfield, Missouri 65804. 13. Hongbo Qi, also known as Qi Hong Bo, is an owner, officer, agent, or employee of Phoenix Massage. Hongbo Qi, on information and belief, resides in Missouri and can be found at Phoenix Massage, 1261 East Republic Road, Springfield, Missouri 65804. Relax Massage 14. Relax Massage, a/k/a Relax Spa, holds itself out as a massage parlor and has a principal place of business at 2022 South Stewart Avenue, Springfield, Missouri 65804. Relax Massage is not registered with the State 6

of Missouri, but it has a business license from the City of Springfield under the name Relax Massage. 15. Sheng Yang is an owner, officer, agent, or employee of Relax Massage, and, on information and belief, can be found at 2022 South Stewart Avenue, Springfield, Missouri 65804. 16. Xiao Chen is an owner, officer, agent, or employee of Relax Massage, and occasionally resides at Relax Massage, 2022 South Stewart Avenue, Springfield, Missouri 65804. Angel Massage 17. Angel Massage holds itself out as a massage parlor and is a fictitious business name registered with the State of Missouri and owned by Hui Otis, Fenghua Li, and Yang Yongzhen. Angel Massage has a principal place of business at 1774½ South Grant Avenue, Springfield, Missouri 65807. This business is licensed with the City of Springfield as Angel Massage Spa. Angel Massage; Angel Massage Spa; Hui Otis, d/b/a Angel Massage; Fenghua Li, d/b/a Angel Massage, and Yang Yongzhen, d/b/a Angel Massage will be collectively referred to as Angel Massage. 18. Hui Otis is an owner, officer, agent, or employee of Angel Massage, and resides at 3731 South Glenstone, #284, Springfield, Missouri 65804. 7

19. Fenghua Li is an owner, officer, agent, or employee of Angel Massage, and resides at 2015 West University Street, Apt #D408, Springfield, Missouri 65807. 20. Yang Yongzhen is an owner, officer, agent, or employee of Angel Massage, and resides at 2015 West University Street, Apt #D408, Springfield, Missouri 65807. Great Spa 21. Great Spa holds itself out as a massage parlor and has a principal place of business at 2841 South Fremont, Springfield, Missouri 65804. Great Spa is not registered with the State of Missouri, but it has a business license from the City of Springfield under the name Great Spa. 22. Mei Xiang Cui is an owner, officer, agent, or employee of Great Spa, and may be found at 2841 South Fremont, Springfield, Missouri 65804. Asian-Rainbow Massage 23. Asian Massage holds itself out as a massage parlor and is a fictitious business name registered with the State of Missouri and owned by Yanmei Wang. Yanmei Wang, d/b/a Asian Massage, has a principal place of business at 2005 East Kearney Street, Suite I, Springfield, Missouri 65803. This business is licensed with the City of Springfield as Asian Massage. This business is sometimes held out to the public and advertised as Rainbow 8

Massage. Asian Massage, Rainbow Massage, and Asian-Rainbow Massage will be collectively referred to as Asian-Rainbow Massage. 24. Yanmei Wang is an owner, officer, agent, or employee of Angel Massage, and resides at 2412 South Fort Avenue, Springfield, Missouri 65807. 25. All respondents have done business within the State of Missouri, including Greene County, by operating massage parlors that are regularly used for prostitution activity. Jurisdiction 26. This Court has subject matter and personal jurisdiction over this action under Art. V, 14 Mo. Const. and 506.500, RSMo. Venue 27. Venue is proper in this Court pursuant to 508.010.2, RSMo, in that there are several defendants, and venue lies in any county in which a Defendant resides. 28. Venue is proper because Respondents businesses reside within Greene County. Statutory Authority 29. Section 567.080, RSMo, declares the regular use of a room, building, or structure for prostitution activity to be a public nuisance, and allows the Attorney General to prosecute a suit to enjoin the nuisance. The 9

Attorney General may include owners, lessees, officers, agents, or employees as defendants in such an action to enjoin prostitution activity. Respondents Human Trafficking and Prostitution Activities 30. For years, massage parlors located throughout Springfield, Missouri have been creating a public nuisance by providing sexual contact for pay and/or unlawful prostitution activity on premises located in Greene County, Missouri. At each location, Respondents utilize young and, typically, Asian immigrant females ( Victims to carry out sexual contact with customers of the massage parlors in exchange for money and/or other items of value. 31. The Missouri State Highway Patrol has carried out hundreds of hours of surveillance of dozens of massage parlors located in Greene County, including all Respondent massage parlors herein. 32. The Missouri State Highway Patrol and Springfield Police have each contacted numerous individuals seen leaving the Respondents businesses. Individuals reported receiving massages at Respondents businesses while fully nude and without the cover of a privacy towel. At each Respondent s business, individual(s reported that they were offered to the opportunity to receive, and did receive, hand-to-genital contact by the Victim on the customer during the massage, for the purpose of the customer s sexual gratification, in exchange for money and/or things of value. 10

33. Respondents advertise their services on Craigslist.com, Backpage.com, and Rubmaps.com. Craigslist.com and Backpage.com are frequently used to advertise prostitution services under the category of massage services. Rubmaps.com allows users to post reviews of massage parlors, including the type of sexual contact that is allowed at the massage parlor. In the course of their investigation, the Missouri State Highway Patrol could not find evidence that some of the Respondents advertised anywhere else other than these pages. Golden Massage 34. Golden Massage is located at 4728 South Campbell #112, Springfield, Missouri 65810. 35. The building or unit occupied by Golden Massage has been regularly used for prostitution activities. 36. Golden Massage is registered with the City of Springfield, with its owner listed as Daquiong Wang. On information and belief, Daquiong Wang is aware of the prostitution activities taking place at Golden Massage, and those prostitution activities take place at the direction of Daquiong Wang. On information and belief, Daquiong Wang knowingly profits from the prostitution activities. 37. The prostitution activity occurring at Golden Massage includes but is not necessarily limited to engaging in sexual conduct and/or sexual 11

contact, including hand-to-genital contact by the Victim on the customer for the purpose of the customer s sexual gratification, in exchange for money and/or things of value. Phoenix Massage 38. Phoenix Massage is located at 1261 East Republic, Springfield, Missouri 65804. 39. The building or unit occupied by Phoenix Massage has been regularly used for prostitution activities. 40. Phoenix Massage is owned by Phoenix Magic Massage, LLC, Phoenix Oriental Massage, LLC, Wanhua Tian, and Zemin Guo. 41. Hongbo Qi assists with the operation of Phoenix Massage. 42. On information and belief, Phoenix Magic Massage, LLC, Phoenix Oriental Massage, LLC, Wanhua Tian, Zemin Guo, and Hongbo Qi are aware of the prostitution activities taking place at Phoenix Massage, and those prostitution activities take place at their direction. On information and belief, Phoenix Magic Massage, LLC, Phoenix Oriental Massage, LLC, Wanhua Tian, Zemin Guo, and Hongbo Qi knowingly profit from the prostitution activities. 43. The prostitution activity occurring at Phoenix Massage includes but is not necessarily limited to engaging in sexual conduct and/or sexual contact, including hand-to-genital contact by the Victim on the customer for 12

the purpose of the customer s sexual gratification, in exchange for money and/or things of value. Relax Massage 44. Relax Massage is located at 2022 South Stewart Avenue, Springfield, Missouri 65804. 45. The building or unit occupied by Relax Massage has been regularly used for prostitution activities. 46. On information and belief, Xiao Chen is aware of the prostitution activities taking place at Relax Massage, and those prostitution activities take place at the direction of Xiao Chen. Xiao Chen is the son of the owner of Relax Massage, and Xiao Chen operates Relax Massage. 47. On information and belief, Sheng Yang is aware of the prostitution activities taking place at Relax Massage, and those prostitution activities take place at the direction of Sheng Yang. Sheng Yang operates Relax Massage. 48. Relax Massage is used as both a massage parlor and as a residence for the Victims who work there. Xiao Chen monitors the Victims, on occasion, by staying overnight at Relax Massage with the Victims and otherwise by monitoring Relax Massage by video surveillance. On information and belief, the purpose of this monitoring is to ensure that the Victims at Relax Massage are not free to leave. 13

49. On information and belief, Sheng Yang and Xiao Chen knowingly profit from the prostitution activities. 50. The prostitution activity occurring at Relax Massage includes but is not necessarily limited to engaging in sexual conduct and/or sexual contact, including hand-to-genital contact by the Victim on the customer for the purpose of the customer s sexual gratification, in exchange for money and/or things of value. Angel Massage 51. Angel Massage is located at 1774½ South Grant Street, Springfield, Missouri 65807. 52. The building or unit occupied by Angel Massage has been regularly used for prostitution activities. 53. Angel Massage is owned by Hui Otis, Fenghua Li, and Yang Yongzhen. On information and belief, they are aware of the prostitution activities taking place at Angel Massage, and those prostitution activities take place at the direction of Hui Otis, Fenghua Li, and Yang Yongzhen. On information and belief, Hui Otis, Fenghua Li, and Yang Yongzhen knowingly profit from the prostitution activities. 54. The prostitution activity occurring at Angel Massage includes but is not necessarily limited to engaging in sexual conduct and/or sexual contact, including hand-to-genital contact by the Victim on the customer for the 14

purpose of the customer s sexual gratification, in exchange for money and/or things of value. Great Spa 55. Great Spa is located at 2841 South Fremont, Springfield, Missouri 65804. 56. The building or unit occupied by Great Spa has been regularly used for prostitution activities. 57. Great Spa is registered with the City of Springfield, with its owner listed as Mei Xiang Cui. On information and belief, Mei Xiang Cui is aware of the prostitution activities taking place at Great Spa, and those prostitution activities take place at the direction of Mei Xiang Cui. Mei Xiang Cui owns or operates Great Spa. On information and belief, Mei Xiang Cui knowingly profits from the prostitution activities. 58. The prostitution activity occurring at Great Spa includes but is not necessarily limited to engaging in sexual conduct and/or sexual contact, including hand-to-genital contact by the Victim on the customer for the purpose of the customer s sexual gratification, in exchange for money and/or things of value. 59. In 2017, an undercover officer received a massage at Great Spa. After undressing to his underwear, he was further instructed to remove his underwear. During the massage, the Victim grabbed the undercover officer s 15

genitals and began to stroke them. The undercover officer immediately objected and told her to stop. Later in the massage, she again grabbed the undercover officer s genitals and began to stroke them. Once again he objected and told her to stop. The massage then ended. 60. Online profiles by customers of Great Spa report that massages there can include contact between the hand of the Victim and the genitals of the customer, the hand of the customer and the genitals of the Victim, and also hand-to-anus contact. Asian-Rainbow Massage 61. Asian-Rainbow Massage is located at 2005 East Kearney Street, Suite I, Springfield, Missouri 65803. 62. The building or unit occupied by Asian-Rainbow Massage has been regularly used for prostitution activities. 63. Asian-Rainbow Massage is owned by Yanmei Wang. On information and belief, Yanmei Wang is aware of the prostitution activities taking place at Asian-Rainbow Massage, and those prostitution activities take place at the direction of Yanmei Wang. Yanmei Wang owns or operates Asian-Rainbow Massage. On information and belief, Yanmei Wang knowingly profits from the prostitution activities. 64. The prostitution activity occurring at Asian-Rainbow Massage includes but is not necessarily limited to engaging in sexual conduct and/or 16

sexual contact, including hand-to-genital contact by the Victim on the customer for the purpose of the customer s sexual gratification, in exchange for money and/or things of value. Count I Operating a Public Nuisance (against Golden Massage and Daquiong Wang 65. Petitioner incorporates all of the allegations contained in Paragraphs 1 through 64 above. 66. 4728 South Campbell Avenue, Suite 112, Springfield, Missouri 65810 is being operated by Golden Massage and Daquiong Wang as a public nuisance in that the location is regularly used for prostitution activity. 67. Daquiong Wang, as an owner, officer, agent, or employee of Golden Massage, aided and facilitated the nuisance. WHEREFORE, Petitioner respectfully requests that the Court enter judgment in favor of Petitioner preliminarily and permanently enjoining 1 Golden Massage from engaging in any prostitution activity; 2 4728 South Campbell Avenue, Suite 112, Springfield, Missouri 65810 from being used for any prostitution activity; 3 Daquiong Wang from engaging in, aiding in, or promoting prostitution activity; and 4 such further relief as this Court deems just and proper. 17

Count II Operating a Public Nuisance (against Phoenix Massage; Phoenix Magic Massage, LLC; Phoenix Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi 68. Petitioner incorporates all of the allegations contained in Paragraphs 1 through 67 above. 69. 1261 East Republic, Springfield, Missouri 65804 is being operated by Phoenix Massage; Phoenix Magic Massage, LLC; Phoenix Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi as a public nuisance, in that the location is regularly used for prostitution activity. 70. Phoenix Magic Massage, LLC; Phoenix Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi, as owners, officers, agents, or employees of Phoenix Massage, aided and facilitated the nuisance. WHEREFORE, Petitioner respectfully requests that the Court enter judgment in favor of Petitioner preliminarily and permanently enjoining 1 Phoenix Massage from engaging in any prostitution activity; 2 1261 East Republic, Springfield, Missouri 65804 from being used for any prostitution activity; 3 Phoenix Magic Massage, LLC; Phoenix Oriental Massage, LLC; Wanhua Tian; Zemin Guo; and Hongbo Qi, from engaging in, aiding in, or promoting prostitution activity; and 4 such further relief as this Court deems just and proper. 18

Count III Operating a Public Nuisance (against Relax Massage, Sheng Yang, and Xiao Chen 71. Petitioner incorporates all of the allegations contained in Paragraphs 1 through 70 above. 72. 1261 East Republic, Springfield, Missouri 65804 is being operated by Relax Massage, Sheng Yang, and Xiao Chen as a public nuisance, in that the location is regularly used for prostitution activity. 73. Sheng Yang and Xiao Chen, as owners, officers, agents, or employees of Relax Massage, aided and facilitated the nuisance. WHEREFORE, Petitioner respectfully requests that the Court enter judgment in favor of Petitioner preliminarily and permanently enjoining 1 Relax Massage from engaging in any prostitution activity; 2 1261 East Republic, Springfield, Missouri 65804 from being used for any prostitution activity; 3 Sheng Yang and Xiao Chen from engaging in, aiding in, or promoting prostitution activity; and 4 such further relief as this Court deems just and proper. Count IV Operating a Public Nuisance (against Angel Massage, Hui Otis, Fenghua Li, and Yang Yongzhen 74. Petitioner incorporates all of the allegations contained in Paragraphs 1 through 73 above. 75. 1774½ South Grant Street, Springfield, Missouri 65807 is being operated by Angel Massage and Hui Otis, Fenghua Li, and Yang Yongzhen as 19

a public nuisance, in that the location is regularly used for prostitution activity. 76. Hui Otis, Fenghua Li, and Yang Yongzhen, as owners, officers, agents, or employees of Angel Massage, aided and facilitated the nuisance. WHEREFORE, Petitioner respectfully requests that the Court enter judgment in favor of Petitioner preliminarily and permanently enjoining 1 Angel Massage from engaging in any prostitution activity; 2 1774½ South Grant Street, Springfield, Missouri 65807 from being used for any prostitution activity; 3 Hui Otis, Fenghua Li, and Yang Yongzhen from engaging in, aiding in, or promoting prostitution activity; and 4 such further relief as this Court deems just and proper. Count V Operating a Public Nuisance (against Great Spa and Mei Xiang Cui 77. Petitioner incorporates all of the allegations contained in Paragraphs 1 through 76 above. 78. 2841 South Fremont, Springfield, Missouri 65804 is being operated by Great Spa and Mei Xiang Cui as a public nuisance, in that the location is regularly used for prostitution activity. 79. Mei Xiang Cui, as an owner, officer, agent, or employee of Great Spa, aided and facilitated the nuisance. 20

WHEREFORE, Petitioner respectfully requests that the Court enter judgment in favor of Petitioner preliminarily and permanently enjoining 1 Great Spa from engaging in any prostitution activity; 2 2841 South Fremont, Springfield, Missouri 65804 from being used for any prostitution activity; 3 Mei Xiang Cui from engaging in, aiding in, or promoting prostitution activity; and 4 such further relief as this Court deems just and proper. Count VI Operating a Public Nuisance (against Asian-Rainbow Massage and Yanmei Wang 80. Petitioner incorporates all of the allegations contained in Paragraphs 1 through 79 above. 81. 2005 East Kearney Street, Suite I, Springfield, Missouri 65803 is being operated by Asian-Rainbow Massage and Yanmei Wang as a public nuisance, in that the location is regularly used for prostitution activity. 82. Yanmei Wang, as an owner, officer, agent, or employee of Asian- Rainbow Massage, aided and facilitated the nuisance. WHEREFORE, Petitioner respectfully requests that the Court enter judgment in favor of Petitioner preliminarily and permanently enjoining 1 Asian-Rainbow Massage from being used for any prostitution activity; 2 2005 East Kearney Street, Suite I, Springfield, Missouri 65803 from being used for any prostitution activity; 3 Yanmei Wang from engaging in, aiding 21

in, or promoting prostitution activity; and 4 such further relief as this Court deems just and proper. Respectfully submitted, JOSHUA D. HAWLEY Attorney General /s/ Darrell Moore Darrell Moore, #30444 Deputy Attorney General Jason S. Dunkel, #65886 Assistant Deputy Attorney General Mary D. Morris, #60921 Caleb Aponte, #67931 Assistant Attorneys General P.O. Box 861 St. Louis, MO 63188 (314 340-7889 Darrell.Moore@ago.mo.gov DANIEL PATTERSON Prosecuting Attorney of the County of Greene, State of Missouri Missouri Bar No. 41848 1010 Boonville Avenue Springfield, Missouri 65802 (417 868-4061 FAX (417 868-4160 Attorneys for Petitioner 22