1 social media.”197 2 149. Facebook’s admissions that it should have done more to prevent the genocide in 3 Burma—and its subsequent efforts, if any—came too late for the tens of thousands of Rohingya 4 who have been murdered, raped, and tortured, and for the hundreds of thousands who are now 5 living in squalid refugee camps and displaced from their home across the world. 6 FACTS SPECIFIC TO JANE DOE 7 8 150. Rakhine State, Burma. 9 10 Plaintiff Jane Doe is a Rohingya Muslim woman who previously lived in the 151. In 2012, Plaintiff was about 16 years old, her father was detained, beaten, and tortured for two weeks by the Myanmar military. 11 152. Around the same time, many young Rohingya girls in Plaintiff’s village and 12 nearby villages were being taken from their families. Members of the Myanmar military came to 13 Plaintiff’s village, and anyone who left their homes was killed. Plaintiff saw at least seven men 14 killed, as well as an elderly woman. Plaintiff knew that many others in her village were also 15 killed, including women and children, but she could only see those directly in the vicinity of her 16 home. 17 18 153. Fearful that she would be abducted and sexually assaulted or killed herself, Plaintiff’s family eventually urged her to flee Burma alone. 19 154. Plaintiff joined a group of Rohingya fleeing by boat to Bangladesh. She traveled 20 to Thailand and then Malaysia, where the UNHCR eventually arranged for her resettlement in 21 the United States. 22 155. Plaintiff is gravely concerned about her parents and her sisters, who remain in 23 Burma. Their homes and the small store that was their livelihood were destroyed during ethnic 24 violence. Plaintiff’s family land, home, and personal property were eventually seized and those 25 that remained behind in Burma were forced from their homes. They lack any reliable source of 26 197 27 28 Giulia Saudelli, Facebook whistleblower warns company is neglecting languages other than English, DW, https://www.dw.com/en/facebook-whistleblower-warns-company-isneglecting-languages-other-than-english/a-59739260. CLASS ACTION COMPLAINT 64 Case No. __________________