With the racy contents of her storage locker back on the Internet, newly-liberated Paris Hilton has added an offshore company and an Arizona Web designer to the list of those she deems liable for invading her privacy.

Hilton's original complaint provided little detail about who exactly bought her property for $10 million and displayed it on the ParisExposed Web site. A judge in February ordered that the site be shut down after neither of the named defendants –- Bardia Persa and Nabila Haniss –- contested Hilton's motion for a preliminary injunction.

In apparent violation of the court order, ParisExposed -- a veritable treasure trove of Hilton-alia, including topless photos and personal letters -- resurfaced recently amid the media frenzy over Hilton's jail sentence. And now the hotel heiress has filed an amended complaint that names six "Website Defendants," including Persa and Green Brothers Ltd., a company registered in the Caribbean island of St. Kitts.

“Although the defendants initially took their website down, they have brazenly relaunched the site,” she alleges in again seeking injunctive relief and unspecified damages.

Persa, Reza Karamooz, Stephen Thomas and Kevin Green are all alleged to be “officers, directors, shareholders, and/or managing agents of Green Brothers,” which, the suit says, “is a mere shell, instrumentality and conduit through which [they] have conducted business.” Hilton does not specify how another defendant, Chazz Hoffman, is associated with ParisExposed.

According to various Web sites, Karamooz is a Scottsdale, Ariz., Web designer and entrepreneur, whose ventures include REZA Fitness Resort, “the World's first and only 'Boutique Fitness Resort.'” In 1998, he founded Softrade Partners, a Web design and logistics company which “provides many types of Web Hosting solutions at ISPs throughout the world.”

In relaunching ParisExposed, the site's operators boasted that Hilton's belongings had been secreted “on hundreds of servers around the world behind firewalls in jurisdictions that will not bow to the heiress and her overpaid legal team.”

Injunctions issued by U.S. courts are not normally enforceable against overseas defendants. But Hilton identifies Karamooz and Thomas as U.S. residents and, if she can pierce the “corporate veil” of Green Brothers, she may at least be able to establish personal liability against them.

“[A]dherence to the fiction of the separate existence of Green Brothers from Persa, Green, Karamooz, and Thomas would permit an abuse of the corporate privilege, would sanction fraud, and would promote an injustice,” the amended suit argues.

Karamooz could not be reached for comment at his contact telephone number.

Hilton's locker was rented from a Culver City, Calif., storage facility in the name of the moving company she had hired to put some of her belongings there. After the movers failed to pay the rent, Public Storage auctioned off the contents for $2,775 to Haniss, who then allegedly sold them to the operators of ParisExposed.

"Haniss knew or had reason to believe that the Website Defendants were not merely voyeurs who were paying hundreds of thousands of dollars to view Hilton's items in the privacy of their homes," Hilton alleges.

By Matthew Heller
7/2/07