Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 1 of 18
`
`RUSSEL DAVID MYRICK
`The RDM Legal Group
`7979 Ivanhoe Ave, Ste 200
`La Jolla, CA 92037-4505
`Tel. No. 888-482-8266
`Fax No. 858-244-7930
`Email: russel@rdmlg.com
`
`SAMUEL P. KING, JR.
`735 Bishop Street, Suite 304
`Honolulu, Hawaii 96813
`Tel. No. 808-384-6325
`Fax No. 808-533-4745
`Email: sam@kingandking.com
`Application for Appearance
` Pro Hac Vice Pending
`
`Attorneys for Plaintiffs
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`ADRIENNE SEPANIAK KING and
`CHRISTOPHER EDWARD
`SEPANIAK KING,
`
`
`
`) Civ. No. ________________
`)
`
` COMPLAINT FOR DAMAGES AND
`) DECLARATORY AND INJUNCTIVE
`) RELIEF; DEMAND FOR JURY
`FACEBOOK, INC., a Delaware corpor- ) TRIAL
`ation,
`
`))
`
`)
`Defendant.
`________________________________ )
`
`))
`
`))
`
`Plaintiffs,
`
` vs.
`
`
`
`RUSSEL DAVID MYRICK
`The RDM Legal Group
`7979 Ivanhoe Ave, Ste 200
`La Jolla, CA 92037-4505
`Tel. No. 888-482-8266
`Fax No. 858-244-7930
`Email: russel@rdmlg.com
`
`SAMUEL P. KING, JR.
`735 Bishop Street, Suite 304
`Honolulu, Hawaii 96813
`Tel. No. 808-384-6325
`Fax No. 808-533-4745
`Email: sam@kingandking.com
`Application for Appearance
` Pro Hac Vice Pending
`
`Attorneys for Plaintiffs
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`ADRIENNE SEPANIAK KING and
`CHRISTOPHER EDWARD
`SEPANIAK KING,
`
`
`
`) Civ. No. ________________
`)
`
` COMPLAINT FOR DAMAGES AND
`) DECLARATORY AND INJUNCTIVE
`) RELIEF; DEMAND FOR JURY
`FACEBOOK, INC., a Delaware corpor- ) TRIAL
`ation,
`
`))
`
`)
`Defendant.
`________________________________ )
`
`))
`
`))
`
`Plaintiffs,
`
` vs.
`
`
`
`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 2 of 18
`
`COMPLAINT FOR DAMAGES AND DECLARATORY
`AND INJUNCTIVE RELIEF
`
`Plaintiffs ADRIENNE SEPANIAK KING (“KING”) and CHRISTOPHER
`
`EDWARD SEPANIAK KING (“CKING”) state for their Complaint for Damages and
`
`Declaratory and Injunctive Relief against Defendant FACEBOOK, INC.
`
`(“FACEBOOK”) as follows:
`
`PRELIMINARY STATEMENT
`
`1. KING had a Personal Account (“King Facebook Account”) with
`
`FACEBOOK which she established approximately ten years ago to her recollection.
`
`Over the years, KING used the King Facebook Account extensively and eventually
`
`had about 1,000 “Friends” around the world. On the King Facebook Account, KING
`
`shared personal information about family and non-political material, and KING
`
`shared political material and discussed political topics from a conservative point of
`
`view. On or about November 17, 2020, KING discovered, when she attempted to log
`
`on to the King Facebook Account, that she was unable to do so. In attempting to
`
`discover the problem, on or about November 19, 2020, KING received a message
`
`from FACEBOOK that her account had been “disabled.” No reason was given for
`
`FACEBOOK’s disabling of KING’s account. On or about November 19, 2020,
`
`KING and CKING, KING’s son who live with her, attempted to reinstate KING’s
`
`account but received a message from FACEBOOK that her account was disabled
`
`because “it did not follow our Community Standards. This decision can’t be
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 3 of 18
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`reversed.” No explanation was provided as to how KING had allegedly violated
`
`FACEBOOK’s Community Standards. Despite further attempts made by KING and
`
`CKING with FACEBOOK to discover why her account was permanently disabled,
`
`FACEBOOK made no further communication back to KING.
`
`2. FACEBOOK’s permanent disabling of the King Facebook Account
`
`subjected her to embarrassment and derision with her approximately 1,000 Facebook
`
`Friends and caused her emotional distress. As further alleged in this Complaint,
`
`FACEBOOK was without authority pursuant to the Communications Decency Act
`
`of 1996 (“CDA”), particularly 47 U.S.C. 230(c)(2)(A), to disable the King Facebook
`
`Account.
`
`3. KING seeks special, general, and punitive damages in excess of $75,000
`
`against FACEBOOK for intentional or reckless infliction of emotional distress and/or
`
`negligent or grossly negligent infliction of emotional distress, and for action against
`
`KING in disabling the King Facebook Account in violation of the CDA without good
`
`faith. KING also seeks 1) declaratory relief against FACEBOOK regarding its abuse
`
`of the CDA and the application of FACEBOOK’s Community Standards to restrict
`
`constitutionally protected speech in violation of KING’s protected right to Free
`
`Speech pursuant to the provisions of 47 U.S.C. 230(c)(2)(A), and 2) injunctive relief
`
`enjoining FACEBOOK from further action against KING in disabling the King
`
`Facebook Account. KING also seeks reinstatement of the King Facebook Account
`
`3
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 4 of 18
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`and all posts, photographs, and other material associated with the King Facebook
`
`Account, and reinstatement of all posts and communications sent by her to other users
`
`of FACEBOOK (this would include reestablishing information about KING’s email
`
`address and phone number for users of facebook.com searching for KING).
`
`4. CKING, as the son of KING who lives in the same household as KING,
`
`seeks special, general, and punitive damages against FACEBOOK for intentional or
`
`reckless infliction of emotional distress and/or negligent or grossly negligent
`
`infliction of emotional distress, loss of consortium, and action by FACEBOOK
`
`against KING in disabling the King Facebook Account in violation of the CDA
`
`without good faith which damages against FACEBOOK exceed $75,000.
`
`JURISDICTION AND VENUE
`
`5. Plaintiffs bring this action pursuant to diversity of citizenship jurisdiction
`
`provided in 28 USC 1332(a)(1) as all Plaintiffs, KING and CKING, on the one hand,
`
`and FACEBOOK, on the other hand, are citizens of different states as further alleged
`
`below and the amount in controversy exceeds $75,000 as to each Plaintiff. See also
`
`28 USC 1367(a).
`
`6. Plaintiffs also bring this action pursuant to the civil liability provisions of
`
`the CDA set forth in 47 U.S.C. 320(c)(2)(A). A substantial federal question is
`
`involved regarding the applicability of the CDA to this Complaint, and federal
`
`question jurisdiction is invoked pursuant to 28 U.S.C. 1331.
`
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 5 of 18
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`7. Declaratory relief is authorized pursuant to 28 U.S.C. 2201 and 2202.
`
`8. Injunctive relief is authorized by the Federal Rules of Civil Procedure, Rule
`
`65.
`
`9. In its Terms of Service, FACEBOOK has a provision entitled “Disputes”
`
`(paragraph 4 of Section 4 entitled “Additional Provisions”) which provides in part:
`
`For any claim, cause of action, or dispute you have against us that arises
`out of or relates to these Terms [of Service] or the Facebook products
`(“claim”), you agree that it will be resolved exclusively in the U.S.
`District Court of the Northern District of California or a state court
`located in San Mateo County. You also agree to submit to the personal
`jurisdiction of either of these courts for the purpose of litigating any
`such claim, and that the laws of the State of California will govern these
`Terms [of Service] and any claim, without regard to conflict of law
`provisions.
`
`Based on this forum-selection provision of FACEBOOK’s Terms of Service, with
`
`respect to venue, Plaintiffs have filed this action in the District Court for the Northern
`
`District of California.
`
`PARTIES
`
`10. KING and CKING are, and at all times relevant to this Complaint have
`
`been, residents of the State of Hawaii.
`
`11. FACEBOOK is, and at all times relevant to this Complaint has been, a for-
`
`profit corporation incorporated in the State of Delaware and has its principal offices
`
`and place of business in the State of California
`
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 6 of 18
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`STATEMENT OF FACTS
`
`12. KING had a Personal Account (“King Facebook Account”) with
`
`FACEBOOK which she established approximately ten years ago to her recollection.
`
`The establishment of the King Facebook Account by KING with FACEBOOK
`
`constituted a contract between KING and FACEBOOK pursuant to the provisions of
`
`FACEBOOK’s Terms of Service.
`
`
`
`13. Over the years, KING used the King Facebook Account extensively and
`
`eventually had about 1000 “Friends” around the world.
`
`14. On the King Facebook Account, KING shared personal information about
`
`family and non-political material and reposted personal information from other
`
`sources and friends. KING also shared political material and discussed political
`
`topics from a conservative point of view, and KING often reposted material from
`
`other sources with no added comment (for example, various articles about COVID-
`
`19, global warming, etc.).
`
`15. On or about November 17, 2020, KING discovered, when she attempted
`
`to log on to the King Facebook Account, that she was unable to do so.
`
`16. In attempting to discover the problem, on or about November 19, 2020,
`
`KING received the following message from FACEBOOK:
`
`6
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 7 of 18
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`Your Account Has Been Disabled
`
`For more information please visit the Help Center.
`
`Your account was disabled on November 17, 2020. If you think your
`account was disabled by mistake you can submit more information via
`the Help Center for up to 30 days after your account was disabled. After
`that, your account will be permanently disabled and you will no longer
`be able to request a review.
`
`No reason was given for FACEBOOK’s disabling of KING’s account.
`
`17. On or about November 19, 2020, KING, with the assistance of CKING
`
`who is a computer engineer, then attempted to reinstate her account but received the
`
`following message from FACEBOOK:
`
`My Personal Account Was Disabled
`
`If you think your account was disabled by mistake, please enter the
`following information and we will consider your profile for review.
`You can submit more information here for up to 30 days after your
`account was disabled. After that, your account will be permanently
`disabled and you will no longer be able to request a review.
`
`Only submit this form if your account has been disabled for violating
`Facebook’s Community Standards. If you can’t access your account for
`a different reason, please return to the Help Center to find the
`appropriate contact channel.
`
`We Cannot Review the Decision to Disable Your Account
`Your Facebook account was disabled because it did not follow our
`Community Standards. This decision can’t be reversed.
`
` No explanation was provided as to how KING had allegedly violated FACEBOOK’s
`
`Community Standards.
`
`18. Despite further attempts made by KING and CKING with FACEBOOK
`
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 8 of 18
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`over the next several days to discover why her account was permanently disabled,
`
`FACEBOOK made no further communication back to KING.
`
`19. Further attempts by CKING to contact persons working at FACEBOOK
`
`over the next few months to discover why KING’s account was permanently disabled
`
`were unsuccessful. The most recent communication received by CKING from an
`
`employee of FACEBOOK who was attempting to assist KING and CKING to
`
`discover why the King Facebook Account was disabled was received on or about
`
`March 9, 2021, and stated:
`
`I am told that the review (I placed) was rejected and that the user (your
`mother) should have been told what is the policy area they were
`violating. Unfortunately I do not have much else to add. As for the
`dowloading of data, it seems there should be a way to ask for your data.
`There should be a flow somewhere, but the person dealing with the
`problem was not sure what that was. Maybe a search can help? Let me
`know otherwise.
`Sorry man, sorry it took so long and sorry we don’t know much more,
`I suppose for FB to share with me would be absurd and not proper, so
`I suspect I cannot help you much more than this (which I am sure is not
`very satisfactory) [followed by a frowing imoji]
`
`As alleged above, FACEBOOK never gave KING a reason for disabling the King
`
`Facebook Page beyond a general reference to a violation of the Facebook Community
`
`Standards without any specifics, and KING and CKING were never able to locate any
`
`“flow” which could be used for KING to obtain her data.
`
`20. KING did nothing to violate any of the Community Standards imposed by
`
`FACEBOOK which would have caused the King Facebook Account to be temporarily
`
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 9 of 18
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`disabled or permanently disabled.
`
`21. KING did nothing to violate any of the Community Standards imposed by
`
`FACEBOOK which are allowed by and consistent with 47 U.S.C. 230(c)(2)(A) which
`
`would have caused the King Facebook Account to be temporarily disabled or
`
`permanently disabled. 47 U.S.C. 230(c)(2)(A) states that an “interactive computer
`
`service” (as this term is defined in 47 U.S.C. 230(a)(1)) like FACEBOOK is only
`
`protected from a civil action against it if it rejects in “good faith” uploaded material
`
`provided by a user like KING which is “obscene, lewd, lascivious, filthy, excessively
`
`violent, harassing, or otherwise objectionable.” KING never posted or uploaded any
`
`content or material to the King Facebook Page which would in any manner be
`
`considered as “obscene, lewd, lascivious, filthy, excessively violent, harassing, or
`
`otherwise objectionable.”
`
`22. FACEBOOK did not act in good faith by permanently disabling KING’s
`
`Facebook Account claiming that it acted pursuant to the terms of FACEBOOK’s
`
`Community Standards.
`
`23. FACEBOOK did not act in good faith by permanently disabling KING’s
`
`Facebook Account and by applying restrictions on KING that were not consistent
`
`with or allowed by 47 U.S.C. 230(c)(2)(A).
`
`24. FACEBOOK did not act in good faith by permanently disabling KING’s
`
`Facebook Account because FACEBOOK refused to state the reason why KING’s
`
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 10 of 18
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`Facebook Account had been permanently disabled, FACEBOOK refused to state
`
`what provision of FACEBOOK’s Community Standards KING allegedly violated,
`
`FACEBOOK refused to communicate with KING when she requested a dialog with
`
`FACEBOOK about the reason for the permanent disabling of her Facebook Account,
`
`and FACEBOOK destroyed all of KING’s Facebook Account and all material related
`
`to and/or stored with or under the King Facebook Account which was in no way
`
`objectionable or in violation of any of FACEBOOK’s Community Standards or in
`
`violation of any material defined in 47 U.S.C. 230(c)(2)(A). FACEBOOK did not act
`
`in good faith, and in fact was intentionally malicious, in destroying all of KING’s
`
`Facebook Account and all material related to and/or stored on, with, or under the
`
`King Facebook Account which was in no way objectionable or in violation of any of
`
`FACEBOOK’s Community Standards or in violation of any material defined in 47
`
`U.S.C. 230(c)(2)(A) without providing her any chance of saving any of these
`
`materials before the King Facebook Account was disabled by FACEBOOK.
`
`25. The fact that KING’s Facebook Account was permanently disabled by
`
`FACEBOOK, with no explanation as to the reason the account was permanently
`
`disabled, has caused KING great distress, embarrassment, and humiliation with her
`
`approximately 1,000 Facebook Friends.
`
`26. The fact that KING’s Facebook Account was permanently disabled by
`
`FACEBOOK has caused KING emotional distress, extreme emotional distress,
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 11 of 18
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`serious emotional distress, and severe emotional distress. She has lost all her contacts
`
`with family and friends over the many years she has had through the King Facebook
`
`Account, all the photographs she has sent to others and others have sent to her about
`
`families, her grandchildren, trips, and lives, and all other content that was saved on
`
`the King Facebook Account, all of which document irreplaceable memories and
`
`emotional events. Further, any and all content she shared has been deleted from the
`
`Facebook pages of all of her friends. Not only is the King Facebook Account gone,
`
`but any reference to KING anywhere in facebook.com is also gone. When KING
`
`attempted to log on to the King Facebook Account with her name and phone number,
`
`the response was the KING’s name and phone number were “not valid.” KING was
`
`particularly upset to be declared by FACEBOOK to be “not valid.” If a “friend” of
`
`KING’s looks for KING’s name on Facebook, the following message appears:
`
`“Didn’t find what you’re looking for? We’re temporarily hiding some results for this
`
`search query.” KING has suffered emotional distress from the damage to her
`
`reputation and name by being banned by FACEBOOK to the wonderment and
`
`suspicion of her Facebook friends. Because of all these losses and because of the
`
`outrageous treatment of her by FACEBOOK, KING has suffered feelings of anger,
`
`fear, horror, shock, grief, shame, humiliation, embarrassment, chagrin,
`
`disappointment, worry, nervousness, anxiety, and nausea which are intense and
`
`enduring.
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 12 of 18
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`27. CKING is, and was at all times relevant to this Complaint, KING’s son
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`who lives, and at all times relevant to this Complaint, has lived in the same household
`
`with KING. As a result of the wrongful acts of FACEBOOK as alleged above,
`
`CKING witnessed and continues to witness KING suffer her emotional distress as
`
`alleged above, and CKING was caused to suffer, and will continue to suffer in the
`
`future, severe emotional distress, loss of society, affection, assistance, and fellowship
`
`with KING, all to the detriment of his relationship with his mother. CKING was
`
`especially distressed that, in spite of his expertise as a computer engineer and his
`
`having assisted KING on many occasions successfully in the past with internet and
`
`computer-related problems, that he was unable to assist KING in resolving the actions
`
`taken against her by FACEBOOK which distressed KING so much.
`
`CAUSES OF ACTION
`
`FIRST CAUSE OF ACTION (Plaintiff KING)
`[Breach of Contract/Specific Performance]
`
`28. KING restates and realleges all allegations and statements in paragraphs
`
`1-27 above.
`
`29. During the entire time that the contract between KING and FACEBOOK
`
`existed, KING did not violate any of the terms of the contract as set out in
`
`FACEBOOK’s Terms of Service and KING did not violate any of FACEBOOK’s
`
`Community Standards.
`
`30. FACEBOOK breached its contract with KING by disabling the King
`
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 13 of 18
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`Facebook Account because KING did not breach any of the terms of her contract with
`
`FACEBOOK and did not violate any of the terms of the contract as set out in
`
`FACEBOOK’s Terms of Service and KING did not violate any of FACEBOOK’s
`
`Community Standards.
`
`31. KING is entitled to an award of monetary damages in excess of $75,000
`
`for the above-stated breach of contract by FACEBOOK, or, in the alternative, if
`
`monetary damages are not awarded or are inadequate to compensate KING for the
`
`breach of contract by FACEBOOK, for an award of specific performance requiring
`
`FACEBOOK to reinstate the King Facebook Account, all data associated with the
`
`King Facebook Account, and reinstatement of KING’s name for any person searching
`
`for her name through facebook.com.
`
`SECOND CAUSE OF ACTION (Plaintiff KING)
`[Violation of 47 U.S.C. 230(c)(2)(A)]
`
`32. KING restates and realleges all allegations and statements in paragraphs
`
`1-31 above.
`
`33. FACEBOOK permanently disabled KING’s Facebook Account for reasons
`
`not permitted by 47 U.S.C. 230(c)(2)(A).
`
`34. FACEBOOK permanently disabled KING’s Facebook Account without
`
`good faith in violation of 47 U.S.C. 230(c)(2)(A).
`
`35. FACEBOOK permanently disabled KING’s Facebook Account and
`
`violated her right to constitutionally protected material without good faith in violation
`
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`of 47 U.S.C. 230(c)(2)(A).
`
`36. There is an implied cause of action for damages for violations by the
`
`provider of an “interactive computer service” (as this term is defined in 47 U.S.C.
`
`230(f)(2)) of 47 U.S.C. 230(c)(2)(A).
`
`37. FACEBOOK is a provider of an “interactive computer service” as this term
`
`is defined in 47 U.S.C. 230(f)(2).
`
`38. FACEBOOK is liable for payment of compensatory and punitive damages
`
`in excess of $75,000 to KING for its violations of 47 U.S.C. 230(c)(2)(A) as alleged
`
`herein.
`
`THIRD CAUSE OF ACTION (Plaintiff KING)
`[Intentional or Reckless Infliction of Emotional Distress]
`
`39. KING restates and realleges all allegations and statements in paragraphs
`
`1-38 above.
`
`40. FACEBOOK’s conduct in permanently disabling KING’s Facebook
`
`Account, in refusing to state how KING allegedly violated FACEBOOK’s
`
`“Community Standards, ” in refusing to discuss the matter with KING, and in
`
`destroying all of the material contained on, with, or under the King Facebook
`
`Account was outrageous.
`
`41. By permanently disabling KING’s Facebook Account, FACEBOOK
`
`caused KING to experience serious, severe, and extreme emotional distress.
`
`42. FACEBOOK acted viciously and/or intentionally in causing serious,
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`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 15 of 18
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`severe, and extreme emotional distress to KING or in reckless disregard of the
`
`probability of causing serious, severe, and extreme emotional distress to KING.
`
`43. FACEBOOK is liable for payment of compensatory and punitive damages
`
`in excess of $75,000 to KING for FACEBOOK’s intentional and/or reckless infliction
`
`of emotional distress against KING.
`
`FOURTH CAUSE OF ACTION (Plaintiff KING)
`[Negligent or Grossly Negligent Infliction of Emotional Distress]
`
`44. KING restates and realleges all allegations and statements in paragraphs
`
`1-43 above.
`
`45. FACEBOOK’s conduct in permanently disabling KING’s Facebook
`
`Account, in refusing to state how KING allegedly violated FACEBOOK’s
`
`“Community Standards, ” in refusing to discuss the matter with KING, and in
`
`destroying all of the material contained on, with, or under the King Facebook
`
`Account was negligent or grossly negligent.
`
`46. By permanently disabling KING’s Facebook Account, FACEBOOK
`
`caused KING to experience serious, severe, and extreme emotional distress.
`
`47. FACEBOOK is liable for payment of compensatory damages in excess of
`
`$75,000 to KING for FACEBOOK’s negligent or grossly negligent infliction of
`
`emotional distress against KING and for punitive damages for grossly negligent
`
`infliction of emotional distress against KING.
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`FIFTH CAUSE OF ACTION (Plaintiff CKING)
`[Intentional, Reckless, Grossly Negligent, and/or Negligent Infliction of
`Emotional Distress and Loss of Consortium]
`
`48. CKING restates and realleges all allegations and statements in paragraphs
`
`1-47 above.
`
`49. Based on the emotional distress caused by FACEBOOK to KING, CKING
`
`has suffered severe emotional distress, loss of society, affection, assistance, and
`
`conjugal fellowship with KING, all to the detriment of his relationship with his
`
`mother.
`
`50. FACEBOOK is liable for payment of compensatory and punitive damages
`
`in excess of $75,000 to CKING for the emotional and other injuries alleged in
`
`paragraphs 26, 27, 45, 46, and 49 above to CKING by FACEBOOK’s intentional,
`
`reckless, grossly negligent, and/or negligent infliction of emotional distress against
`
`KING and CKING as alleged above.
`
`SIXTH CAUSE OF ACTION (Plaintiff KING)
`[Declaratory and Injunctive Relief]
`
`51. KING restates and realleges all allegations and statements in paragraphs
`
`1-50 above.
`
`52. This Court should declare that FACEBOOK enforced provisions of
`
`Facebook’s Community Standards against KING which exceeded restrictions allowed
`
`to be imposed by FACEBOOK pursuant to 47 U.S.C. 230(c)(2)(A) and that
`
`FACEBOOK thereby breached its contract with KING.
`
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`53. This Court should order that FACEBOOK reinstate the King Facebook
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`Account in toto, including all material that was stored in the King Facebook Account,
`
`and reinstate all contacts between KING and the Facebook pages of all of her friends.
`
`54. This Court should permanently enjoin FACEBOOK from disabling the
`
`King Facebook Account, either temporarily or permanently, without first providing
`
`KING with reasons therefor, and should permanently enjoin FACEBOOK from
`
`disabling the King Facebook Account, either temporarily or permanently, except for
`
`reasons permitted by 47 U.S.C. 230(c)(2)(A).
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiffs pray for compensatory and punitive damages in
`
`excess of $75,000 for each of them against FACEBOOK and as set forth in this
`
`Complaint. Further, KING prays for specific performance and for declaratory
`
`judgment as set forth in this Complaint and for injunctive relief as set forth in this
`
`Complaint.
`
`DATED: San Francisco, California, June 14, 2021.
`
` /s Russel David Myrick
`RUSSEL DAVID MYRICK
`Attorney for Plaintiffs
`
`17
`
`
`
`Case 3:21-cv-04573 Document 1 Filed 06/14/21 Page 18 of 18
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`
`ADRIENNE SEPANIAK KING and
`CHRISTOPHER EDWARD
`SEPANIAK KING,
`
`
`
`) Civ. No. ________________
`)
`
` DEMAND FOR JURY TRIAL
`)
`)
`FACEBOOK, INC., a Delaware corpor- )
`ation,
`
`))
`
`)
`Defendant.
`________________________________ )
`
`DEMAND FOR JURY TRIAL
`
`Plaintiffs demand jury trial in this case on all issues triable by a jury.
`
`DATED: San Francisco, California, June 14, 2021.
`
` /s Russel David Myrick
`RUSSEL DAVID MYRICK
`Attorney for Plaintiffs
`
`))
`
`))
`
`Plaintiffs,
`
` vs.
`
`
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