1 income and live in constant fear of further attacks by the Myanmar military or by Buddhist 2 monks. 3 4 5 6 7 156. Plaintiff also has an aunt and uncle who fled to a refugee camp in Bangladesh, where they have remained for several years. 157. Plaintiff remains traumatized by the ethnic violence and threats of violence inflicted on her and her family. 158. Plaintiff did not learn that Facebook’s conduct was a cause of her injuries until 8 2021. A reasonable investigation by Plaintiff into the causes of her injuries would not have 9 revealed this information prior to 2021 because Facebook’s role in the Rohingyan genocide was 10 not widely known or well understood within the Rohingya community. Further, even if such 11 information was known to various journalists or investigators at earlier points in time, Plaintiff’s 12 ability to discover such information was significantly hindered by her inability to read or write. 13 14 15 CLASS ACTION ALLEGATIONS 159. Class Definition. Plaintiff seeks to represent the following proposed Class pursuant to California Code of Civil Procedure § 382: 16 All Rohingya who left Burma (Myanmar) on or after June 1, 2012, and arrived in the United States under refugee status, or who sought asylum protection, and now reside in the United States. 17 18 The following are excluded from the Class: (1) any Judge or Magistrate presiding over this 19 action and members of their families; (2) Defendant, Defendant’s subsidiaries, parents, 20 successors, predecessors, and any entity in which Defendant or its parents have a controlling 21 interest, and its current or former employees, officers, or directors; (3) Plaintiff’s counsel and 22 Defendant’s counsel; and (4) the legal representatives, successors, and assigns of any such 23 excluded person. 24 160. Ascertainability and Numerosity. The Class is so numerous that joinder of all 25 members is impracticable. At least 10,000 members of the Class reside in the United States. 26 Class members are ascertainable and can be identified through public records. 27 28 CLASS ACTION COMPLAINT 65 Case No. __________________