Ung et al v. Facebook, Inc.

Filing 4

Notice To Plaintiffs of Removal of Civil Action to the United States District Court for the Northern District of California from Santa Clara County Superior Court. (Brown, Matthew) (Filed on 6/13/2011) Text modified on 6/14/2011; incorrect event type used when posting document (bw, COURT STAFF).

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COOLEY LLP
MICHAEL G. RHODES (116127) ([e-mail])
MATTHEW D. BROWN (196972) ([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant FACEBOOK, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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RYAN UNG, CHI CHENG and ALICE
ROSEN, on Behalf of Themselves and All
Others Similarly Situated,

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California Superior Court,
County of Santa Clara
Case No. 111CV200467

Plaintiffs,

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No. 11-CV-2829-PSG

NOTICE TO PLAINTIFFS OF REMOVAL OF
CIVIL ACTION TO THE UNITED STATES
DISTRICT COURT FOR THE NORTHERN
DISTRICT OF CALIFORNIA

v.
FACEBOOK, INC.,

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Defendant.
Complaint Filed: May 9, 2011

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TO PLAINTIFFS RYAN UNG, CHI CHENG, AND ALICE ROSEN AND THEIR ATTORNEYS OF RECORD:

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PLEASE TAKE NOTICE that on June 10, 2011, Defendant Facebook, Inc. filed a Notice of

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Removal of this action in the United States District Court for the Northern District of California.

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This Notice of Removal removes the above-captioned matter from the Superior Court of

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California, County of Santa Clara to the United States District Court for the Northern District of

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California.

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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UNG V. FACEBOOK, INC.
NOTICE TO PLAINTIFFS OF REMOVAL
NO. 11-CV-2829-PSG

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Dated: June 13, 2011

COOLEY LLP

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/s/ Matthew D. Brown
Matthew D. Brown (196972)
Attorneys for Defendant FACEBOOK, INC.

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1223654 v1/SF

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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UNG V. FACEBOOK, INC.
NOTICE TO PLAINTIFFS OF REMOVAL
NO. 11-CV-2829-PSG

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PROOF OF SERVICE
(FRCP 5)

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I am a citizen of the United States and a resident of the State of California. I am

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employed in San Francisco County, State of California, in the office of a member of the bar of

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this Court, at whose direction the service was made. I am over the age of eighteen years, and

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not a party to the within action. My business address is Cooley LLP, 101 California Street, 5th

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Floor, San Francisco, California 94111-5800. My e-mail address is [e-mail]. On

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the date set forth below I served the documents described below in the manner described below:

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NOTICE TO PLAINTIFFS OF REMOVAL OF CIVIL ACTION TO THE UNITED STATES
DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA;

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(BY U.S. MAIL) I am personally and readily familiar with the business practice of
Cooley LLP for collection and processing of correspondence for mailing with the
United States Postal Service, and I caused such envelope(s) with postage thereon
fully prepaid to be placed in the United States Postal Service at San Francisco,
California.

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(BY MESSENGER SERVICE) by consigning the document(s) to an authorized
courier and/or process server for hand delivery on this date.

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(BY FACSIMILE) I am personally and readily familiar with the business practice
of Cooley LLP for collection and processing of document(s) to be transmitted by
facsimile and I caused such document(s) on this date to be transmitted by
facsimile to the offices of addressee(s) at the numbers listed below.

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(BY OVERNIGHT MAIL) I am personally and readily familiar with the business
practice of Cooley LLP for collection and processing of correspondence for
overnight delivery, and I caused such document(s) described herein to be
for
deposited for delivery to a facility regularly maintained by
overnight delivery.

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(BY ELECTRONIC MAIL) I am personally and readily familiar with the business
practice of Cooley LLP for the preparation and processing of documents in
portable document format (PDF) for e-mailing, and I caused said documents to be
prepared in PDF and then served by electronic mail to the parties listed below.

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on the following part(ies) in this action:

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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UNG V. FACEBOOK, INC.
NOTICE TO PLAINTIFFS OF REMOVAL
NO. 11-CV-2829-PSG

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MILBERG LLP
JEFF S. WESTERMAN (94559)
([e-mail])
DAVID E. AZAR (218319)
([e-mail])
One California Plaza
300 S. Grand Avenue, Suite 3900
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]

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I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
Executed on June 13, 2011, at San Francisco, California.

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/s/ Sandra Warren
Sandra Warren

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

4.

UNG V. FACEBOOK, INC.
NOTICE TO PLAINTIFFS OF REMOVAL
NO. 11-CV-2829-PSG