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While working as a hostess at a Hollywood nightclub, Barnes posed nude for the “Pet of the Month” photo layout in the March 1976 issue of Penthouse magazine under the pseudonym Joann Witty. Penthouse later wanted to republish the photos under Barnes’ real name in 1982 after she had become famous in Three’s Company. The dispute ended up in court, as Penthouse wanted a judge to rule on the legality of publishing the pictures using her real name. At issue was a handwritten addendum to the standard model release contract that all models sign. When Penthouse lost the initial case, they appealed to the 9th Circuit Court of Appeals. The appeal court mostly sided with Barnes and ruled that the handwritten addendum was legally binding and that Penthouse could not republish the photos using her real name.
