Buza V Yahoo Complaint

Case4:11-cv-04422-DMR Document1
Filed09/06/11 Page1 of 50
0
Michele Floyd (SBN 163031) MFloyd@Mintz.com Robert Sturtevant Eaton (SBN 240761) REaton@Mintz.com MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO, P.C. 5 Palo Alto Square, 4th Floor 3000 El Camino Real Palo Alto, CA 94306-2155 ~elephone: (650) 25 1-7700 Facsimile: (650) 25 1-7739
,
Attorneys for Defendant, YAHOO! Inc.
UNITED STATES DISTRICT COURT

9 10 MARK s . B u z A , Plaintiff, VS. YAHOO! Inc, Defendant. l5
NORTHERN DISTRICT F
I - -.- 11 4422
NOTICE OF REMOVAL OF ACTION UNDER 28 U.S.C. 5 1331 AND 28 U.S.C. 5 1441 et seq. [Federal Question]
&r
LIFORNIA
l
1 11
TO THE CLERK OF THE ABOVE-REFERENCED COURT: PLEASE TAKE NOTICE that defendant Yahoo! Inc. ("Yahoo!"), hereby removes to this Court the state court action described below: 1. On July 8,2010, an action was filed in the Superior Court of California, San
i7
Francisco County, entitled: MARK S. BUZA v. YAHOO, INC., Case No. A true and correct copy of the summons and complaint as Yahoo! received them is attached hereto 2o 21 as Exhibit A.
I I
22
23
24
25
26
I1 I/ II1(
2. received a copy 1 was personallyDefendant Yahoo! firstthe summons andof the complaint on August 8,2011 when it served with a copy of complaint.
3. Jurisdiction: Removal to this Court is proper because this action is a civil action of
which this Court has original jurisdiction under 28 U.S.C. to this Court by defendants pursuant to 28 U.S.C.
5 1331 and is one which may be removed
1441, subdivisions (b) and (c) because it arises
27 28
under the laws of the United States and contains related state law causes of action as follows:
Notice of Removal of Action
Case No:
a.
The Second Cause of Action of the Complaint asserts a cause of action against
Yahoo! arising under the First Amendment of the United States Constitution. Thus, this Court has original jurisdiction founded on a claim or right arising under the United States Constitution. 28 U.S.C. 5 1331. b. The Fifth Cause of Action of the Complaint appears to assert a cause of action
against Yahoo! for violation of the Stored Communications Act, 18 U.S.C. $5 2701 to 27 12. The Fifth Cause of Action also references 42 U.S.C. 5 1985, subdivision (3) and therefore appears to arise under the laws of the United States. Therefore, this Court has original jurisdiction founded on a claim or right arising under the laws of the United States. 28 U.S.C. 5 1331. c. The First and Third Causes of Action allege violations of Article I, Section 2 of
California's Constitution and Trespass to Chattels, respectively. Both state law claims arise from a common nucleus of operative fact and thus jurisdiction over both causes of action is proper pursuant to 28 U.S.C. 5 1441(c). d. The Fourth Cause of Action in the Complaint is entitled "Intellectual Property" and
alleges Yahoo! "deleted" Plaintiffs "intellectual property." Due to the lack of specificity in the allegations of the Complaint, the exact nature of this claim cannot be determined at this time. However, federal jurisdiction is appropriate in any event under either 28 US.C. event this amounts to a state law cause of action, 28 U.S.C. 5 1441(c). 5. This notice is timely under 28 U.S.C. 5 1446(b) in that it is filed with this Court
5 1331 or, in the
within thirty days after receipt by Yahoo! through service or otherwise of Plaintiffs Complaint. 6. True and correct copies of all pleadings, process and orders that have been served
upon Yahoo! are attached hereto as Exhibits A. A copy of the state court's entire file on this matter is attached hereto as Exhibit B. 7. Pursuant to 28 U.S.C. 4 1446(d), promptly after the filing of this Notice of Removal,
written notice will be given to all parties and a copy of this Notice of Removal will be filed with the Clerk of the California Superior Court, County of San Francisco.
Notice of Removal of Action
Case No:
8.
Intradistrict Assignment: Pursuant to Local Rule 3-2(C), assignment of this action to

yahoo!'^
either the Santa Clara or San Francisco Division is appropriate as
principle place of
business is located in Sunnyvale, California, County of Santa Clara, and pursuant to the caption of the complaint, plaintiff is a resident of the City and County of San Francisco. WHEREFORE, Defendants request that this case proceed as an action properly removed hereto.
Dated: September 6,20 1 1
Respectfully submitted, OVSKY AND POPEO, P.C.
By: Michele Floyd Robert S. Eaton Attorneys for Defendant
5496992~. 1
Notice of Removal of Action 3
Case No:
EXHIBIT A
SLIM~~~ONS
(CITACION JUDICIAL)
NOTICE TO DEFENDANT: ( A m 0 AL DEMANDADO):
Yahoo! Inc.
YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE):
Mark S. Buza
I
NOTICE1 You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a wriiten response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court fonn that you can use for your response. You can find these court forms and more information at the California Court Online SeKHelp Center (w.cowllnfo.ce.gov/sellhe~), county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask your the court clerk for a fee waived form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to-callan attorney referral service. If you cannot afford an atlorney, you may be eligible for free legal sewices from a nonproffl legal services program. You can locate these nonprofd groups at the California Legal Services Web site (w.lewhelpcelifomia.oq),the California Courts Online SeCHelp Center (w.courtin~,c~.gov/selfhelp), contacting your local court or county bar associaiion. NOTE: The court has a stalutory llen for waived fees and or by costs on any senlement or arbitratlon award of 510,000or more in a civil case. The court's lien must be paid before the court will dismiss the case. jAMSO! Lo hen demandecb. Si no responde dentro de 30 dlas, la M e puede deddlr en su contra sin escudiar su versibn. Lea la infomacidn e wntinuacibo. Tiem 30 D ~ A DE CALENDAR10 despu8s de que le entmguen esta citacidn y papeleslegales parapresentar una respuesta porescrito en esta S mite y hawf que se enbwgue una cope a1demandante. Una c a d o una llamada bleh5nicano lo pmtegen. Su respueda por emit0 tiene que edar en Lbnneb legalw m t o si desea que pnwasen su caso en la corte. Es posi'ble que haya un h u l s r i c que ustedpuedausarpara su respuesta. Poede encontrar estos formularies de la corte y mas inkumacih en el Cenlro de Ayuda de /as Codes de Celifomia &ww.suwrte.ca.gov), en la biblioka de leyes de su condado o en la code que k, quede m4s c e m . Si no puede pager la cuofa de pmsentecikr, pida a1secn9kO tie I c o d s que le d6 un formulado de exencibn de pago de cmtas. Sino presenta su respuesla a tiempo, puede peider el caso poi inwmplimientoy la carte kt podre quitar su sueldo, dinem y bienes sin m4s advertencia. Hay obvs requisites legales. Es recomendeble qua Ikme a un abogado inmediatamente. Si no c o r n a un ebogacb, puede Ikmar a un servicio de remisidn a abogados. Si no puede pagar a un ebogedo. e pdsible que cumple con los mquisitos para obtener servicios legales gmtuitos de un s pfttgrama de dcios legales sin flnes de lum. Puede enwntrar esbs grupos sin fines de locn, en el sitb web de Califomia LagalService$ (wviw.tawhdpcalifomia.org),en e l CenbP de Ayuda de /as Cortes de California. (www.suwrte.ca.gov) o ponsndose en contaclr, con la corte o el wlegb de abogados locales. AVISO: Par ley, la cotte fiene derechoa redamar 18s cuotas y h mstos exentas PIX imponar un gravamen sobm walquhr recupereddn de $ i O , W O 6 d s de valor mcibida mediante un acuerdo o urn concesidn de arbitraje en un caso de derecho u r 77ene que v% pager el grevamen de la corte antes de que la code puede desechar el caso.
I
'The name and address of the cwrt is: (El nombre y direw'on de la wrte es):
CASE NUMBER
Sari Francisco Superior Court
$00 McCallister St San Francisco, Ca 94102 Mark S. Buza Pro Se 1060 Howard St. San Farncisco, Ca 94103
" ~ ~ = ) ' . 1 5 12 30 7 7
The name, address, and telephone number of plaintiffs attorney, or plaintiffwithout an attorney, is: (El nornbre, la direccibn y e l numem de tel6fono del abogado del demandante, o del demarldante que n o tiene abogado, esJ:
DATE: July 8th 20 1 1 OF COURT Clerk, by fsecreta"o) (Fecha) (Forproof of service o f this summons, use Proof of Service of Summons (fom POS-OIO).) (Para prueba de entrega de esta citatidn use e l formulario P r m f of Sewice of Summons, (POS-010)). NOllCE TO THE PERSON SERVED: You are served 1. as an indtvidual defendant. 2. as the person sued under the fctitious name of (specify):
CLERK
THE
% 9
,(Adjunto) Deputy
0 0
3.
0on n h a H of (specifyl:
under:
0CCP 416.1 0 (corporation)

0
CCP 416.20 (defunct corporation) CCP 416.40 (association or partnership)
1CCP 416.60 (minor) 0 CCP 416 70 (consenratee)
a CCP 416.90 (authorized person)

PIpelOfl
4.
Form Adopt&
laf M e M a t q Use J d W a I C m . 1 d Cdilomh SUM.rW [REV. JIJY I. MOB]
other (specify): by personal delivery on (date):
SUMMONS
WITHOUT AlTORNEY (Name, Sf
r number, and &real:
1060 Howard St. San Francisco, Ca 94103

TELEPHONE NO.:
N/A
FAX NO.:
Sm F . c o ountv Sumrior Cou
F-I & E
~j
A ~ ~ R N E Y p-i: FOR
Pro Se
San Francisco 400 McAllister Street
SUPERIOR COURT OF CAUFORNI~COUNTY OF

STREETADDRESS: MAILING ADDRESS:
c m m up cooc:
BRAHCHWME:
San Francisco, CA 94102 San Francisco Superior Court

Complex Case Designation
CASE NAME:
CIVIL CASE COVER SHEET
Counter Joinder (Amount J U m demanded is Filed with first appearance by defendant DEPT$25,000 or less) (Cal. Rules of Court, rule 3.402) Items 1-6 below must be completed (see instnrctionson page 2). (1. Check one box below for the case type that best describes this case: -. Auto Tort Conttact Provisionally Complex Clvll LWgation Il S Breach of mntramarranty (06) (Gal. Rules of Court, rJF 3.400-3.403) Auto (22) (Amount demanded exceeds $25,000)
(JI Unlimited
0Limited
AntitrusVTrade regulalim (03) Rule 3.740 colledlons (09) Construction defect (10) Other collections (09) Othw PVPDWD (Pemonal InjurylProperty DamageMlrongful Death) Tort Mass tort (40) Insurance coverage (18) Asbestos (04) Securities Migation (28) Other contract (37) Product liability (24) Real Property EnvimnmentaUToxictort (30) Medical malpradice (45) Eminent domaln/lnvene Insurance coverage clains arising from the condemnation (14) above listed provisionally complex case Other PllPDMlO (23) WPM (41) Wrongful eviction (33) Nan-PVPDIWD(Other)Tort Enforcement of Judgment Business torVunfair business pradice (07) Other real property (26) Enforcement of judgment (20) Unlawful Detalner Civil rights (08) Commercial (31) Mfscellaneous Civil Complaint Defamation (13) Residential (32) RICO (27) Fraud (16) Drugs (38) lntelledual properly (19) Other complaint (not specif& above) (42) Pmfessionalnegligence (25) Judilal Review Miscellaneous Civil Petition Other non-PIPDMIDtort (35) Asset forfeiture (05) (Partnershi and corporete governance (21) Employment Petition re: arKMtlon award (11) petUion specme,, (43) Wngful termination (36) Wlit of mandate (02) Other employment (15) Other judicial review (39) 2. This case Is LL] is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the . . fadors requiring excep60nal judicial management: a. Large number of separately represented parties d. ) Large number of witnesses Coordination with related actions pending in one or more courts I e n s i v e motion practice raising difficult or novel e. ( b. issues that will be time-consuming to resolve in other counties, states, o countries, or in a federal court r c. Substantial amount of documentary evidence f. Substantial postjudgmentjudicial supervision
0 0Uninsuredmotorist (46) 0
C ]
0 0 0
0 0 0 0
0 0 0 0 0
n n
1
0
0
0
CI]
0 0 0
3. Remedies sought (checkall that apply): a . l monetary 4. Number of causes of action (speciw): Five Constitutional, Tresspass to Chattels, 5. This case is is not a class action suit. 6. If there are any known related cases, file and serve a notice of related case.
0 b. 0 nonnmonetary; declaratory or injunctive relief
c.
punitive
Intellectual Property, USC 2701
Date:
Julm-2:
Y5
&rc
m E OR PRINT HAME) P
b
NOTICE
(SIGNATURE OF P A R ~ A ~ R N NFOR PARW R
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed under the Probate Code, Family Code, or Welfare and [nstnutionsCode). (Cal. Rules of Court, rule 3.220.) Failure to file may resun in sanctions. File this cover sheet in addition to any cover sheet required by local court rule. If this case is complex under rule 3.400 et seq. of the Califomla Rules of Court, you must serve a copy of this cwer sheet on all other parties to the action or proceeding. Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onk.,
I -
. - .-. -
om w fa e d m
a y Use ~ u d uCand d Cfdbrnm l c ~ o i [Rev. ~ u ) y1. zm7] a
C S i us of co.~~. 233 3.224 3 40~4.403.3 ~ !s ? n*u 744 COL Stamarch d M ~ I mmatrmm. a 3.10 m **r.c~uni~.~n.gov
Mark S. Ruza I060 Howard St. San Francisco, Ca 94103 Email: markb~za@~mail.com Plaintiff Pro Se
JUL
-8
2011
SUPERIOR C O U R T FOR THE STATE OF CALIFORNTA
COUNTY OF SAN FRANCISCO
Mark S. Buza,
Plaintiff,
GIN^:
CGC-11 -512307
vs .
Yahoo! Inc.,
Defendant.
1 1 1 1 1 1
CIVIL ACTION AGAINST YAHOO1 INC.
(1) CALIFORNIA CONSTITUTIONAL ARTICLE I (2) US. CONSlTTUnONAL AMENDMENT I (3) TRESSPASS TO CHATTELS (4) INnLI-ECTUAL PKOPER'N 1 (5) 1auscg2701 1
Plaintiff Mark S. Bum appearing pro se files this original complaint against die defendant Yahoo! Inc. for various casuses of action, and rherefore alleges.
PART~/HISTORY
This action is brought by plaintiff Mark S. Buza who is a citizen of che United States, and the State of California. Mark S. Buza is also die founder, and leader of the National Psychoanalytic Socialist Movanent a political group.
Against defendant Yahoo! Inc. which is a American internet corporation. The company is perhaps best known for its web portal, search engine, direaory, email service, advenising, video sharing, and social
Civil Action Agairuc Yahoo Inc.
websites such as the now dehnct geocities, and Yahoo groups service. Yahoo! Inc. is considered one of the largest websites in the United States, The address of Yahoo! Inc. is 701 First Avenue Sunnyvale, CA 94089.
STATEMENT OF FACTS
I. At the time, in the year of two-thousand and eight the main National PsychoanaIytic Socialist
Movement (NPSM) website, and a secondary NPSM site were located on Yahoo servers. 'The main National Psychoanalytic SociaIisc Movement site was located on Yahoo groups at the URL of
http://proups.vahoo.com/proup/NPSM/,
- .
and the second National Psychoanalytic Socialist Movement
site was located on Yahoo geocities at the URL of h~://www.p.eocicies.com/freudian~ladiatorI966. The main NPSM sice included relevant world news stories, and the persona1 writings of Mark S. Buza's for the National Psychoandytic Socialist Movement. At the time of this event both sites mentioned here were the plaintiffs properties. For some unknown reason both sites were terminated by direct infringement by being taken off Yahoo servers between the dates of October seventeenth of the year of two-thousand and eight, and October wenty-fifth of the year of wo-chousand and eight. The majority (99%) of the informarion contained on both sites is no longer in the existence. possession nor known to still be in
2. Afcer finding the NPSM sites off Yahoo! Inc. servers, and no longer on Yahoo groups, nor geocities
Yahoo war immediately contac~ed (see exhibit A-I). A investigative service was also immediarely contacted. The main National Psychoanalytic Socialist Movement site was removed from Yahoo! Inc. servers between 9 prn on October twenty-fourth of the year of two-thousand and eight, and I:30 pm on October twenty-fikh of the year twethousand and eight. N o reason has been given by Yahoo! Inc. for the NPSM removal (see exhibits A-2 and A-3). National Psychoanalytic Socialist Movement was founde on May fouah of the year two-thousand and five, and subsequently established on Yahoo servers on Yahoo groups that same day.
Civil Accion Against Yahoo Inc.

-2-
Inc. While using Yahoo! Inc's products nlany of the ernail addresses prior t o the removal of the NPSM sites used by the plaintiff for the NationaI Psychoanalytic Socialist Movement were tetminated including one at the same time as the two NPSM sites were terminated, except for the latter reasons given were that the passwords being used went against Yahoo! Inc. policies.
FIRST CAUSE OF ACTION

VIOLATION FO CALIFORNIA C O N S T I T U T I O N ARTICLE I Sec. 2
4. PlaintifTredeges, and incorporates by reference herein the allegation contained in paragraphs 1-3.
5. Yahoo! Inc. is in violation of California Constitutional Article I Sec. 2 by proximate cause in deleting
the founder of the National Psychoanalytic Socialist Movement Mark S. Buza's main NPSM site located a the URL of hm://proups.vahoo.com/proup/~PSM/, and secondary NPSM site located at the URL of
ht~://www.~eocities,com/freudian~ladiatorI966 therefore limiting the power of NPSM, and its founder

and leader Mark S. Burs by suppressing NPSM's essence from public view.
S E C O N D CAUSE OF ACTION
U.S. C O N s r m m O N A L A M E N D M E N T I
6. Plaintiff realleges, and incorporates by reference herein the allegation contained in paragraphs 1-3.
7. Mark S. Buza claims that Yahoo! Inc, by its proxy's, and by proximate cause wrongLlly suppressed the
plainti6 and the National Psychoanalytic Socialist Movement in violation of the United Scates Constitutional Amendment I by deleting the founder of the Nanonal Psychoanalytic Socialist Movement and Mark S. Buza's main NPSM site Iocated at the U R L of httv://proups.vahoo.com/prou~/~~SM/, secondary NPSM site locared at the U R L of http://www.aeociries.com/freudian~ladiato1966 therefore
Civil Action Against Yahoo Inc.
I
limiting the power of NPSM, and ~ t founder, and leader Mark S. Bwa by suppressing NPSM's essence s from public view.
3
4
THlRD CAUSE OF ACTION

TRESSPAS TO CHAl'TELS
5
6 7
8. Plaintiff realleges, and incorporates by reference herein the allegauon contained in paragraphs 1-3.
9 10 11
12
13
9. Mark S. Buza claims that Yahoo! Inc. by its proxy's, and by proxima~e cause wrongf;Uy trespassed on
plaintiffs Mark S. Buza's personal property, and thereby interfered with the hnctioning of NPSM by deleting rhe founder, and leader of che National Psychoanalytic Socialist Movement sites located on Yahoo! Inc. servers that were located at the URL's of http://qroups.vahoo.com/et~~p/NPSM/, and
htt~://www.~eocities,com/freudianpladiatorI966.
14
15
16
17
FORTH CAUSE OF ACTION

INTELLECTUAL PROPERTY
18
19
20
21
22
10. Plainttff realleges, and incorporates by reference herein the allegation contained in ~ a r a g r a ~ h s 1-3.
I I. Yahoo! Inc. by ~ c proxy's, and by proxunate cause deleted the founder of h e National Psychoanalytic s
Socialist Movement Mark S. Buza's main, and secondary sites which contamed intellectual propetty which is no longer in the p[aintiffs possession in which the intellectual property mentioned in this compla~nt was previously located at the URL's of herp://prouws.vahoo.com/urou~/NPSM/,and
23
24
25
h~://www.peocities.corn/freudianpladiatorI966.
26
27
28
Clvll Action Aganst Yahoo Inc.
-4-
mFTH CAUSE OF ACTION

UNLAWFUL ACCESS TO S T O R E D COMMUNICATIONS
12. Plainc~ff redeges, and incorporates by reference herein the allegati.on contained in paragtaphs 1-3.
13. Yahoo! Inc. by its proxy's, and by proximate cause did not have authorizati.on to access the plaintiffs
stored communications i.e. property; and thereby obtained, altered, and prevented the plainriffs Mark S. Buza's authorized access to his electronic communications while the plaintiffs electronic information was on Yahoo! lnc. servers in which all content mentioned was previously located at the URL's of htt~://uroups.vahoo.com/eroup/NPSM/, and hctp://w~w.peocities.com/freudianeladiatorI966. Whereupon limiting the power of NPSM, and its founder, and leader Mark S. Buza by suppressing NPSM's essence from public view, and erasing all copies of the plaintiffs property.
14. The plaintiff has an interest in the following legal docnine 42 USC 1985(3) since the censorship of
the National Psychoanalytic Socialist Movement site from the Yahoo servers most Uely did not involve only one individual working at Yahoo! Inc therefore at: this time be referenced as "doe" defendants I- m. There an interest in pursuing a contact of adhesion claim if Yahoo! Inc. states that any Nacional PsychoanaIytic Socialist Movement sire material violated any Yahoo Inc's terms of service (See exhibit one, and paragraph three). I would also like the court to keep in mind California civil code section 51.
Civil .kction Against Yahoo Inc

-5-
DAMAGES
The defendant(s) conduct as alleged above was the only factor in actually, and proximately causing the plaintiffs harm, and was malicious, oppressive, and in total disregard of the plaintiffs rights therefore entitling plaintiff t o damages. WHEREFORE, the plaintiff respectfully requests this court to entitle too:
Exemplary damages for the defendanqs) yahoo! Inc.'s willfill acts of malicious, oppressive, fraudulent wanton, and grossly reckless conduct towards the plaintiff Mark S. Buza.
Actual damages for real damages incurred to compensate for the loss rhat has actudy occurred
Statutory damages for intellectual property infringement by the defendant Yahoo! Inc.
Compensatory damages for rhe injury suffered as a result of the unlawll conduct of the defendant Yahoo! Inc.
Incidental damages compensation for commercially reasonable expenses incurred as a result of the defendant Yahoo! Inc.'s breach.
Consequential damages as a consequence of the initid act by the defendant Yahoo! Inc.
Treble damages
Pro Se legal fees
Al damage%in the amount of twenty-million dollars. l
CIVII Action Against Yalloo lnc.
-6-
"I declare under pendty of perjury chat the foregoing is true and correct"
Dated chis
8th
day of
July
,2011
San Francisco, Ca
777~~ &
Mark S. Buza Plaintiff, Pro Se Advocate
C I V Actjon Agalnsr Yahoo Inc. I~ -7-
EXHIBITS
Exhibit A-1
On Sat, 1 0 / 2 5 / 0 8 , Yahoo! Customer Care -ail-no-reply@cc.yahoo-inc.com,
wrote:
From: Yaho:,! Customer Care <mail-no-replylcc.yahoo-inc.com> Subject: Transcript of your chat To: "Mark Buza" <buzamark@yahoo.corn> Date: Saturday, October 25, 2008,
1:56 PM
General Info Chat start time Oct 25, 2008 4:40:11 Chat end time Oct 25, 2008 4:54:24
PM
EST
PM ZST
Duration (actual chatting time) Operator Sean
00:14:12
Chat Transcript info: Please wait for a Yahoo! agent to respond. info: You are now chatting with Sean Mark Buza: http://groups.yahoo.com/group/NPSM/
Sean: Hi! Welcome to our Yahoo! Mail Live Chat service. I'm glad you've joined us.
Sean: Thank you for providing us the details of your issue. Mark Buza: ok Sean: As I understand, the Psychoanalytic Socialist Movement Yahoo! Group has been removed and you want it restored. Am I right? Mark Buza: yes the sooner the better
EXHIBITS
A-1
w i l l t r y my b e s t t o h e l p you.
Mark Buza: I would l i k e t o know t h e r e a s o n t h i s i s t h e s e c o n d g r o u p t h a t h a s been d e l e t e d by Yahoo Sean: To be a b l e t o h e l p you, I w i l l need t o r e d i r e c t you t o o u r Yahoo! Groups team ! s i n c e t h e y h a v e t h e r i g h t t o o l s t o h e l p you w i t h your i s s u e . Sean: L e t me p r o v i d e you t h e l i n k where you can c o n t a c t them d i r e c t l y . Sean: P l e a s e c l i c k h e r e t o c o n t a c t o u r Yahoo! Groups team. Mark a u z a : ok b u t t h e y d i d n t do a n y t h i n g t h e l a s t t i m e Sean: I u n d e r s t a n d . But, t h e y a r e t h e r i g h t d e p a r t m e n t t o a s s i s t you w i t h your i s s u e . Mark Buza: I a l r e a d y s e n t them a e m a i l today : Sean: T h i s avenue o f s u p p o r t i s f o r Yahoo! Mail i s s u e s and i n q u i r i e s o n l y . Mark Buza: c h a t would be b e t t e r Sean: T h a t is o u t o f o u r e x p e r t i s e . Mark Buza: is t h e r e a phone number
II
I11I
Sean: U n f o r t u n a t e l y , you c a n c n l y r e a c h them t h r o u g h t h e ].ink t h a t I h a v e p r o v i d e d
Mark Buza: ok Sean: I n t h e meantime, i s t h e r e a n y t h i n g e l s e I c a n h e l p you w i t h r e g a r d i n g your Yahoo! Mail a c c o u n t ? Mark Bura: o h i f o r g o t t h e y d e l e t e d m e m a i l a c c o u n t y Mark Buza: npsm-high-command@yahoo.com Sean: P l e a s e g i v e me two t o t h r e e minutes t o check on t h a t and s e e what I c a n do t o h e l p you. Mark Buza: ok Mark Buza: t h a t was t o d a y a l s o Sean: I ' m s o r r y f o r t h e d e l a y . I ' l l be w i t h you a s soon a s I c a n .
EXHIBITS
A-1
II II
Sean: Are you receiving any error message when you tried to access that account? Mark Buza: no error message Sean: Thank you for the confirmation. Mark Buza: ok Sean: Since you are unable to login to that account, I will need you to contact our Abuse team since they have the right tools to assist you further with your issue. Sean: Let me provide you the link where you can contact them. Kark Buza: ok Sean: Please click here to contact our Abuse team.
II
Mark Buza: ok Sean: I would suggest that you contact our Yahoo! Groups and Abuse team so that they can help you resolve your issue as soon as possible. Sean: Would there be anything else I may assist you with? Mark Buza: right now
II II
Mark Buza: that. should do it Sean: If you won't mind, it would be much appreciated if you can complete a short survey to give us your comments/srggestion on how we did today. Sean: All you need to do is click on the word "Close" at the top right of the chat window. Sean: Thank you for using Yahoo! Mail.
If you have any other questions, please feel
free to come back and chat with us at any time. Sean: Thanks so much for visiting. Please be j n touch any time. We're always here! . Sean: Take care. Sean: Goodbye.
EXHIBITS
- A-1 -
I
1
2
TRAt49~iISSIDNV E R I F I C 4 T I D i REPORT
E X l r n a S TIME
E x h i b i t A-2
NAME
FAX
: 10/2112818 1 4 : : SWORDS : 4152524790
TEL
3
SER. ff : C83632783
: 4152524788
FAX NO. /NME WRATIW

PAGE(S)
DATE, TIME
REWT
MODE
1060: Mowacd Street San Fmncisco, CA '94103 Tel: (415) 2524788 Fax: (415) E2-4790
,
Re:
.
CC:
2 3
4
I l ~ r e e t i n Yahoo!: ~s This is a letter concerning that your company Yahoo! inc. is in violation of the civil rights of Mark Buza and his medium the political jyoup the National Psychoanalytic Socialist Movement. This matter encompasses violations in which your company Yahoo! inc. participate in by deleting two NPSM sites from your servers at Yahoo! One NPSM site http://www.~eocities.com/frcudian~ladiatorl966 terminated near the date of 10117/08 and w& was the main NPSM site http://~roups.yahoo.com/~roupMPSM/ deleted on 10/25/2008. This action violates Mark Buza's well-established rights of free speech, equal protection, and freedon of discrimination under the United States and California Constitutions. [ I ]
Yahoo! Inc. a L S i i ~ 6&%nue t Sunnyvale, CA 94089 el: (408) 349-3300 Fax: (408) 349-3301
EXHIBITS
10
11
l2
13
14
l5
,,
17
Some of the same issues have previously has been addressed by the courts of the United States, which the courts have decided that a ban on protest of speech violates First Amendment rights. See Tinker v. Des Moines Independent Community School District, 393 U.S. 503 (1969) In that case, the U.S. Supreme Court ruled 7-2 against the school and in favor of the students wearing armbands seeing that their actions andlor speech did not interfere with school work or the rights of others in the schools classrooms. A prohibition against expression of opiniori, without any 'evidence that the rule is necessary to avoid substantial interference with school discipline or the rjghts of others, is not permissible under the First and Fourteenth Amendments of the United States Constitution. Pp. 507-5 14.
See also Texas v. Johnson, 491 U.S. 397 (1989), Johnson participated in a political protest outside the 1984 Republican National Convention in DaIlas, Texas. At the end of the protest Johnson poured kerosene on an American flag and set it on fue. Several witnesses not participating in the protest were offended at Johnson's actions. At the time Texas had a statute which made it a crime to desecrate a state or national flag. Johnson was charged and convicted under this Texas state law. After the finding he appealed, arguing that the law was a unconstitutional infringement on his First Amendment rights. The U.S. Supreme Court ruled in favor of Johnson in this case. The Court in a 5-4 ruling said that the Texas law did violate the First Amendment as applied to Johnson's act since it determined that the prosecution of Johnson was directly related to expression.
.larrar v. Hurris et al. On Aug. 12,2006, Transportation Security Administration olficials and JetBlue Airways personnel prevented Raed Jarrar from boarding a flight at John F. Kennedy Airport until he agreed to cover hjs T-shirt, which read "We Will Not Be Silent" in Englisli and Arabic. Jarrar that day was waiting to board a JetBlue flight from the east coast to his home in Oakland, Calif., when he was suddenly approached by two TSA officials. One of the officials told Jarrar that he needed to remove his shirt because other passengers were not comfortable wit the Arabic script, telling him that wearing a shirt with Arabic writing on it to an airporl was like "wearing a T-shirt at a bank stating, 'I am a robber." On Aug. 9, 2007, the American Civil
EXHIBITS
l8 ,9
20
21
22
23
&&&iaae District Court for the Eastern District of New York. The complaint charged U.S.
that TSA and JetBlue officials violated Jarrar's civil rights under the First and Fifth and federal, state and city anti-discrimination laws. -TSA and JetBlue agreed in to give a monetary reward to Jarrar to settle the lawsuit out of court.
5 6
Liberties Union and the New York Civil o n
filed a civil rights lawsuit on Jarrar's
I am requesting Yahoo! inc. only to reconsider, renounce it's wrongdoing will be defined by Mark Buza payable to Mark Buza for numerous civil
and other legal violations. This application of settlement applying to guidelines that Yahoo's! course changed after being informed that I urge you to take this step above and resolve this matter larger business financial liability, given the well-established nature of the law governing individual rights in these circumstances. See 28 5 1983.
s
9
u.
10
11 l2 13
Because legal action is approaching rapidly, please respond to this letter as soon as possible indicating that Yahoo! inc. will change it's course and do what is right in this matter correcting the wrong that was put upon Mark Buza and his political group. If I do not hear from you soor will have to assume that you are standing by your previous position and actions, notwithstandi our having called your attention to the law set forth in this letter, and we will proceed accordingly. This letter is not intended to set forth all of the facts relating to this matter or all of the rights or remedies available to Mark Buza under the present circumstances, or the bases thereof, all of which are expressly reserved.
16
17
Thank you for your attention to this matter. All correspondence should be mailed or emailed 1 the following addresses. Mark B z ua 1060 Howard st. S ~ IFrancisco, Ca 94 103 I Email address: markbuza@gmail.com
1 With anticipation;
1 US.ConsL . m e n d . I (protecting "freedomof speech' as well as exprcsvive associariun); U.S.Const., amend. XIV (guaruntecing rilJI11s oi'rqunl protection of the Isws.' "\iberty' and inlirnalc association); CALIFORNJA CONSTITUTION ARTICLB 1 DECLAICA-TION OF ItIGH'IS states SECTION I. All pwple arc by nature free and independent and have inalienable r i ~ l l b .Among thcsc are cnjoying 'and derending lire nnd libmy, ucquiring. posswsing und protecting property, and pursuing and obtaining hsppimss, and privucy. SSC. 2. (a) Bvey person may rrwly spcuk. w i t c and publish his or herscntiments on all subjecrs, being rcsponsible for the abuse of rhis righl A law may not ratruin or ubridp libcny of p r w . SEC. 3. (a) The people have the riglit lo instruct h i r represcntatives. petition govcmmcnt for r e d m of yrievanccs, a i d ussemblr: freely
sw a,
EXHIBITS
EXHIBITS
ibit A-5
TIIYE
NAME FAX
: 12/29/2009 16:
: .
SWORDS -~ 61 5753,
1
i
5 ;
6
7
8
DATE, TIIv1E FAX NU. .i't4&fv1E DURAT1OI.I PAGE ( 5 ) ESLLT FlUDE
'
04 C K STAPIDAPZ ECbl
14883493301 08: 0 8 : 49
12/29 16:49
1060. Howard Street
San Fra.wisco, CA 94103,

T I : (415) 252-4788
Fax: (915) 252-4790
I .
'/t,L-G(i.
,I ,[
,q#+d,:&'$blFa:
fqbg)
Re:
pages:
CC:
..---
--.
-.
EXHIBITS
Yahoo! Inc. 701.First Avenue hlblt iSunnyvZP CA 94089 Tel: (408) 349-3300 Fax: (408) 349-3301 Greetings Yahoo!:
I Mark S. B U Z ~the owner of the National Psychoanalytic Socialist Movement has previously requested for your company Yahoo! Inc. to reconsider, renounce its wrongdoing, reinstate both National Psychoanalytic Socialist Movement sites, and pay a fine after being informed that your companies conduct is in violation of the law, and the United States Constitution for Yahoo's deletion of two NPSM sites. O n e NPSM site l~~tp://www.~eocities.com/freu~iian~laciiatosr~~& terminated near the date of 10/r7/08, was and the main NPSM site hl ~ ~ : / / ~ ~ C ~ ~ ~ S . ~ R ~ O O was deleted~ / ~ ~ O U ~ / N ~ ' S M / . C - ~ I on 10/25/2008 from the Yahoo! servers. .
Accordingly since there has not beena response by Yahoo! from the prior demand letter sen. bn t2/2g/zoog via fax to (408) 349-3301. I shall start the final process of drafting an action against Yahoo! for the purpose of imposing through legal means what will be just in this circumstance. These two political sites were not for children to tamper with, and seeing that Yahoo! is a large company well defined in the internet industry one could assume that a company of this magnitude would not do sometKing so blatant, and irresponsible upon the United States Constitution, and to a figure of stqture such as the owner, founder and soon tc be plaintiff in this matter against Yahoo!. Yahoo! has shown through its actions against the National Psychoanalytic Socialist Movement, and its founder, and leader Mark S. Buza of tampering, and erasing the history of a entity of NPSM's large magnitude is no more than censorship, and Look burning and thus your company Yahoo! should pay a very steep price for it's illegal intrusion onto history.
I
With At
. 'pation;
Mark
S . Buza
'.
EXHIBITS
EXHIBIT B
(SOLO PARA US0 DE LA CORE)
FOR COURTUSE ONLY
(Cl TACION JUDICIAL)

NOTICE TO DEFENDANT: (AVISO AL DEMANDADO):
Yahoo! Inc.
YOU ARE BEING SUED BY PLAINTIFF: (LO ESTA DEMANDANDO EL DEMANDANTE):
Mark S. Buza
I
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR DAYS afler this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask Online Self-Help Center (www.courtinfo.ca.gov/seHhelp). the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonproffl groups at the California Legal Services Web site (www.lawhelpcalifornia.org), California Courts Online Self-Help Center the (www.murtinfo.ca.gov/selfhelp), by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and or costs on any settlement or arbitration award of $10,000 more in a civil case. The court's lien must be paid before the court will dismiss the case. or jAVlSOl Lo han demandado. Si no responde dentro de 30 dlas, la corte puede decidir en su contra sin escuchar su versi6n. Lea la informacibn a continuacibn. Tiene 30 D/AS DE CALENDAR10 despubs de que le entreguen esta citacidn y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se enhgue una copia a demandante. Una carta o una llamada telefbnica no lo protegen. Su respuesta por escrito tiene que estar 1 en formato legal conecto si desea que procesen su caso en la corte. Es posible que haya un formulario que ustedpueda usar para so respuesta. Puede encontrar estos formulanos de la code y m8s infonnaci6n en el Centro de Ayuda de /as Cortes de California W.sucorte.ca.gov), en la biblioteca de leyes de su condado o en la corte que le quede mas cerca. Si no puede pagar la cuota de presentaci6n, pida a secretario de la code 1 que le d6 on forrnulario de exenci6n de pago de cuotas. Si no presenta su respuesta a tiempo, puede perder el caso por incumplimienfu y la wrte le podd quitar su sueldo, dinero y bienes sin mas advertencia. Hay otros requisifus legales. Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de remisibn a abogados. Si no puede pagar a un abogado, es posible que cumpla con 10s requisitos para obtener s e ~ c i o s legales gratuitos de on programa de servicios legales sin fines de lucro. Puede encontrar estos gnrpos sin fines de lucro en el sitio web de California Legal Services, &nw.lawhelpcalifomia.org), en el Centro de Ayuda de las Cortes de California, (www.sucorte.ca.gov)o ponidndose en contact0 con la corte o el colegio de abogados locales. AVISO: Por ley, la corte tiene derecho a reclamar /as cuotas y 10s costos exentos por imponer un gravamen sobre cualquierrecuperacidn de $10,000 6 mas de valorrecibida mediante on acuerdo o una concesi6n de arbitraje en un caso de derecho civil. Tiene que pagar el gravamen de la code antes de que la corte pueda desechar el caso.
The name and address of the court is: (El nombre y direction de la corte es):
CASE NUMBER:
San Francisco Superior Court
$00 McCallister St San Francisco, Ca 94 102

Mark S. Buza Pro Se 1060 Howard St. San Farncisco, Ca 94103
(Fecha) DATE: July
f t x ' d ~ g 1 1 l5 1 2 3 0 7 J
The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is: (El nombre, la direccibn y el ndmero de telefono del abogado del demandante, o del demandante que no tiene abogado, es):
8th 201 1
CLERK OF THE COURT
Clerk, by
% 9
, Deputy (Adjunto)
(Forproof of senlice of this summons, use Proof of Service of Summons (foml POS-010).) (Para prueba de entrega de esta citation use el formulano Proof of Service of Summons, (POS-010)). NO'I'ICE TO THE PERSON SERVED: You are served 1. as an individual defendant. 2. 1 the person sued under the fictitious name of (specify): as
IMAGED
3.
0 on behalf of (specify):
under:
0CCP 416.10 (corporation) 0 CCP 416.20 (defunct corporation)
) CCP 416.60 (minor)
0 CCP 416.70 (conservatee)
( CCP 416.40 (association or partnership) ( CCP 416.90 (authorized person) ( ooter (specify): '
4. (by personal delivery on (date):
Form Adopted for Mardatwy Use Judicial Counul of California SUM-1W [Rev. July 1, 20091
Page 1 of 1
Code of Civil Procedure 55 412.20. 465 wwwmurtinfo.cagov
SUMMONS
Order on Court Fee Waiver (Superior Court)
Clerk stamps dale hem when formIS frled
Person who asked the co to waive court fees: Name: Street or mailing address: / D C O .5
m a
5. ZvrG
city:Sr.~
Grdc ISCO
hlo dwd
4.
BY:
JUL
-8
2011
State:
C. zip:. c .-
CLERK OF THE COU

n F W TOYAMA
Lawyer, if person in @ has one (name, address, phone number,

e-mail, and State Bar number):
Fill in court name and street address:
Superior Court of California, County of
@ )
A request to waive court fees was filed
on (date): The court made a previous fee waiver order in this case on (date):
I
SUPERIOfl COURT 400 MCALLISTER STREET RM 109 SAN FRANCISCO, CA 84102

1
~ e a fhfsfo'rhcarefully. AA checked bbxesaare court orders. d
'
p @ e ~ 1 - 571 2 3 0 7 ~~
Case Name:
Fill in case numberand case name:
--
Notice:.ne cdurt may order you to answer questions about your finances and later order you to pay back the waived and fees.! 1f ~is,baipcns you do not pay, the court can make you pay the fees and also charge you collection fees. If there is a chonge,in +our financial circumstances during this case that increases your ability to pay fees and costs, you must , notify the trial court within five-days;(Use form FW-010;) Ifyou win your case, the trial court may order the other side to pay the fees. If you settle your civil case for $10,000 or more, the trial court will have lien on the settlement in the amount of the waived fees. The trial court may not dismiss the case until the lien is paid.
4 (check one): O After reviewing your following orders: the cgurt makes the
to Waive Court Fees
Request to Waive Additional Court Fees
a. (1)
"z '
Th
ourt grants your request, as follows: Fee Waiver. The court grants your request and waives your court fees and costs listed below. (Cal. Rules of Court, rule 3.55.) You do not have to pay the court fees for the following: Filing papers in Superior Court Giving notice and certificates Sending papers to another court department Making copies and certifying copies Court-appointed interpreter in small claims court sheriff's fee to give notice Reporter's daily fee for up to 60 daysfollowing thefee waiver order at the court-approved daily rate) Preparing and certifying the clerk's transcript on appeal Court fees for phone hearings
(2)
Additional Fee Waiver. The court grants your request and waives your additional superior court fees and costs that are checked below. (Cal. Rules of Court, rule 3.56.) You do not have to pay for the checked items. [7 Jury fees and expenses Fees for a peace officer to testify in court Court-appointed interpreter fees for a witness Fees for court-appointed experts Reporter's daily fees (beyond the 60-day periodfollowing thefee waiver order) Other (specifL):
(3) 0 Fee Waiver for Appeal. The court grants your request and waives the fees and costs checked below, for your appeal. (Cal. Rules of Court, rules 3.55, 3.56, 8.26, and 8.818.) You do not have to pay for the checked items. [7 Preparing and certifying clerk's transcript for appeal
[7 Other (specifL):
Judtasl Counal of Csl~forma, MW wurtmlo ca gov Rensed July 1. 2009. Mandatorv Form Govemmeni Code. S 68634(e). California Rules of Court, rule 3.52
.,
FPIao3vpage Order on Court . - Waiver ( ~ u ~ e r i o r * A o ~ ~ C - - - - - - - - - - -- - - Fee
- --. . -
- -.
or
ATTORNEY OR PARTY WlTHOUT AlTORNEY (Name,
FOR COURT USE ONLY
CM-010
Mark S. Buza 1060 Howard St. San Francisco, Ca 94 103

TELEPHONE NO.:
r number, and a d d ~ s s )
ATTORN~Y FOR (Name):
N/A Pro Se
FAX NO.:
SUPERIOR COURT OF CALIFORNIA, COUNTY OF

STREETADDRESS: MAILING ADDRESS:
San Francisco 400 McAllister Street San Francisco, CA 94 102 San Francisco Superior Court
BY:
JUL
-8
2011
CITY AND ZIP CODE:

BRANCH NAME:
CASE NAME:
Civil Action Against Yahoo! Inc.

Complex Case Designation Unlimited )Limited Counter Joinder (Amount (Amount JUDGE: demanded demanded is Filed with first appearance by defendant DEPT: exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) Items 1-6 below must be completed (see instructions on page 2). 1. Check one box below for the case type that best d e s c r i b e s 5 Contact Auto Tort Provisionally Complex Civil Litigation L Breach of contracVwarranty (06) (01- Rules of Cou% rules 3-4ob3-403) r Auto (22) Rule 3.740 collections (09) Antitrustrrrade regulation (03) A ) Uninsured motorist (46) Other collections (09) [Construction defect (10) -b Other PllPDMTD (Personal InjurylProperty DamageMTrongful Death) Tort Mass tort (40) Insurance coverage (18) 5 2 Asbestos (04) Securities litigation (28) Other contract (37) Product liability (24) Real Property EnvironmentalKoxic tort (30) A Medical malpractice (45) Eminent domainllnverse Insurance coverage claims arising from the Other PllPDMID (23) condemnation (14) above listed provisionally complex case t Pes (41 Y Wrongful eviction (33) Non-PUPDWD (Other) Tort Enforcement of Judgment Business tortlunfair business practice (07) Other real property (26) Enforcement of judgment (20) Unlawful Detainer Civil rights (08) Defamation (13) Commercial (31) Miscellaneous Civil Complaint ' Fraud (16) Residential (32) RICO (27) Drugs (38) ( Intellectualproperty (19) [Other complaint (not specifiedabove) (42) Professional negligence (25) Judicial Review Miscellaneous Civil Petition Asset forfeiture (05) Other non-PIIPDMID tort (35) Partnership and corporate governance (21) Petition re: arbitration award (11) Employment Other petniin (not specfiedabwe! (43) (Wrongful termination (36) Writ of mandate (02) (Other employment (15) complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the 2. This case is is not factors requiring exceptional judicial management: Large number of separately represented parties d. Large number of witnesses a. Coordination with related actions pending in one or more courts Extensive motion practice raising difficult or novel 6. b. issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court c. Substantial amount of documentary evidence f. ( Substantial postjudgment judicial supervision
rrur:ll-512307
0 0
0 0 n 0 0 0 0
0 0
rn
I I I
0 0 1 0
0
0 0
0 0
0 0
3. 4. 5. 6.
Remedies sought (check all that apply): a . m monetary b. nonmonetary; declaratory or injunctive relief c. [punitive Number of causes of action (specify): Five Constitutional, Tresspass to Chattels, Intellectual Property, USC 2701 This case is is not a class action suit. If there are any known related cases, file and serve a notice of related case.
(PIPE OR PRINT NAME)
NOTICE
(SIGNATURE OF P A R m R AlTORNEY FOR PARTY)
I I
I
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed under the Probate Code. Family Code. or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result in sanctions. File this cover sheet in addition to any cover sheet required by local court rule. If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all other parties to the action or proceeding. Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for.statistical purposes only.
F m Adopted for Mandatory Use Judicial Council of California CMOlO [Rev. Jub 1.2W71
ClVlL CASE COVER SHEET
page 1 o 2 t 1 Cal. Rules of Court. rules 2 30.3.220. 3.40&3.403. 3~740; C a l Standards of Judicial Adrnmistration. std. 3 10
.I
wwwnwrt;n~b.cagov
,Mark S. Buza I060 Howard St. San Francisco, Ca 94103 Email: markbuza@,mail.com Plaintiff Pro Se -
SUMMONS ISSU D
San Francisco County Supe r Court
FILED
BY:
SUPERIOR C O U R T FOR T H E STATE OF CALIFORNIA C O U i OF SAN FRANCISCO
Mark S. Buza,
)
CascNa.:
C G C - I I - 51 2 30 7.
Plaintiff,
VS
)
)
CIVIL ACTION AGAINST YAHOO! INC.
.
Defendant
) ) ) ) ) )
Yahoo! Inc.,
(I) CALIFORNIA CONSTITUTIONAL ARTICLE I (2) US. C O N S n r U n O N A L AMENDMENT I (3) TRESSPASS TO CHATELS (4) INTELLECTUAL PROPERTY
(5) I8 USC 5 2701
Plaintiff Mark S. Buza appearing pro se files this original complaint against the defendant Yahoo! Inc. for various casuses of action, and therefore alleges.
PARTIES/HISTORY
This action is brought by plaintiff Mark S. Buza who is a citizen of the United States, and the State of California. Mark S. Buza is also the founder, and leader of the National Psychoanalytic Socialist Movement a political group.
Against defendant Yahoo! Inc. which is a American internet corporation. The company is perhaps best known for its web portal, search engine, directory, email service, advertising, video sharing, and social medi

-1 -
websites such as the now dehnct geocities, and Yahoo groups service. Yahoo! Inc. is considered one of the largest websites in the United States. The address of Yahoo! Inc. is 701 First Avenue Sunnyvale, CA
94-089.
STATEMENT OF FACTS
I. At the time, in the year of two-thousand and eight the main National Psychoanalpc Socialist Movement (NPSM) website, and a secondary NPSM site were located on Yahoo servers. The main National Psychoanalytic Socialist Movement site was located on Yahoo groups at the
URL of
http://~rou~s.vahoo.com/~roup/NPSM/, the second National Psychoanalytic Socialist Movement and

site was located on Yahoo geocities at the
URL of htt~://www.~eocities.com/freudian~ladiatorI966.
The main NPSM site included relevant world news stories, and the personal writings of Mark S. Buza's fol h e National Psychoanalpc Socialist Movement. At the time of this event both sites mentioned here were h e plaintiffs properties. For some unknown reason both sites were terminated by direct infringement
by
being taken off Yahoo servers between the dates of October seventeenth of the year of two-thousand and :ight, and October twenty-fifth of the year of two-thousand and eight. The majority (99%) of the information contained on both sites is no longer in the plaintiffs possession nor known to still be in :xistence.
2. After &ding the NPSM sites off Yahoo! Inc. servers, and no longer on Yahoo groups, nor geocities
Yahoo was immediately contacted (see exhibit A-I). A investigative service was also immediately rontacted. The main National Psychoanalytic Socialist Movement site was removed from Yahoo! Inc. servers between 9 pm on October twenty-fourth of the year of two-thousand and eight, and I:30 pm on 3ctober twenty-fifth of the year two-thousand and eight. N o reason has been given by Yahoo! Inc. for h e NPSM removal (see exhibits A-2 and A-3). National Psychoanalytic Socialist Movement was founded 3n May fourth of the year two-thousand and five, and subsequently established on Yahoo servers on Yahoo groups that same day.
Civil Action Against Yahoo lnc.

-
2-
.3. There is some evidence to the mental h e w o r k , and contractual policies of the employees at Yahoo!
Inc. While using Yahoo! Inc's products many of the email addresses prior to the removal of the NPSM sites used by the plaintiff for the National Psychoanalytic Socialist Movement were terminated including one at the same time as the two NPSM sites were terminated, except for the latter reasons given were that the passwords being used went against Yahoo! Inc. policies.
FIRST CAUSE OF ACTION

VIOLATION FO CALIFORNIA CONSTITUTION ARTICLE I Sec. 2
5. Yahoo! Inc. is in violation of California Constitutional Article I Sec. 2 by proximate cause in deleting
the founder of the National Psychoanalytic Socialist Movement Mark S. Buza's main NPSM site located a the URL of http://proups.yahoo.com/proup/NPSM/, and secondary NPSM site located at the URL of
ht~://www.eeocities.com/fieudian~ladiatorI966 therefore limiting the power of NPSM, and its founder

and leader Mark S. Buza by suppressing NPSM's essence from public view.
SECOND CAUSE OF ACTION

U.S. CONSTITUTIONAL AMENDMENT I
7. Mark S. Buza claims that Yahoo! Inc. by its proxy's, and by proximate cause wrongf;lly suppressed the
plaintiff, and the National Psychoanalytic Socialist Movement in violation of the United States Constitutional Amendment I by deleting the founder of the National Psychoanalytic Socialist Movement Mark S. Buza's main NPSM site located at the U R L of http://proups.yahoo.com/proup/NPSM/, secondary NPSM site located at the U R L of http://www.eeocities.com/freudianpladiatorI966 and therefore
C~vil Action Against Yahoo Inc.
,limiting the power of NPSM, and its founder, and leader Mark S. Buza by suppressing NPSM's essence from public view.
THIRD CAUSE OF ACTION

TRESSPASS TO CHATTELS
9. Mark S. Buza claims that Yahoo! Inc. by its proxy's, and by proximate cause wrongfully trespassed on
plaintiffs Mark S. Buza's personal property, and thereby interfered with the functioning of NPSM by deleting the founder, and leader of the National Psychoanalytic Socialist Movement sites located on Yahoo! Inc. servers that were located at the URL's of http://groups.yahoo.com/_erouP/NPSM/, and
http://www.geocities.com/fieudian~ladiatorI966.
FORTH CAUSE OF ACTION

INTELLECTUAL PROPERTY
I I. Yahoo! Inc. by its proxy's, and by proximate cause deleted the founder of the National Psychoanalytic
Socialist Movement Mark S. Buza's main, and secondary sites which contained intellectual property which is no longer in the plaintiffs possession in which the intellectual property mentioned in this complaint was previously located at the URL's of ht~://~roups.vahoo.com/erouv/NPSM/, and
http://www.~eocities.com/fieudianpladiatorI 966.

-4-
FIFTH CAUSE OF ACTION

UNLAWFUL ACCESS TO S T O R E D COMMUNICATIONS
13. Yahoo! Inc. by its proxy's, and by proximate cause did not have authorization to access the plaintiffs
stored communications i.e. property; and thereby obtained, altered, and prevented the plaintiffs Mark S. Buza's authorized access to his electronic communications while the plaintiffs electronic information was on Yahoo! Inc. servers in which all content mentioned was previously located at the URL's of http://eroups.vahoo.com/~roup/NPSM/, and http://www.eeocities.com/freudian~ladiatorI966. Whereupon limiting the power of NPSM, and its founder, and leader Mark S. Buza by suppressing NPSM's essence from public view, and erasing all copies of the plaintiffs property.
14. The plaintiff has an interest in the following legal doctrine 42 USC I985(3) since the censorship of
the National Psychoanalpic Socialist Movement site from the Yahoo servers most likely did not involve only one individual working at Yahoo! Inc therefore at this time be referenced as "doe" defendants I- m. There an interest in pursuing a contract of adhesion claim if Yahoo! Inc. states that any National Psychoanalytic Socialist Movement site material violated any Yahoo Inc's terms of service (See exhibit one, and paragraph three). I would also like the court to keep in mind California civil code section 5 1.
-5-
DAMAGES
The defendant(s) conduct as alleged above was the only factor in actually, and proximately causing the plaintiffs harm, and was malicious, oppressive, and in total disregard of the plaintiffs rights therefore entitling plaintiff to damages.
WHEREFORE, the plaintiff respectfully requests this court to entitle

plaintiff too:
Exemplary damages for the defendant(s) Yahoo! Inc.'s willful acts of malicious, oppressive, fraudulen wanton, and grossly reckless conduct towards the plaintiff Mark S. Buza.
Actual damages for real damages incurred to compensate for the loss that has actually occurred.
Statutory damages for intellectual property infringement by the defendant Yahoo! Inc.
Zompensatory damages for the injury suffered as a result of the unlawful conduct of the defendant Yahoo [nc.
[ncidental damages compensation for commercially reasonable expenses incurred as a result of the defendant Yahoo! Inc.'s breach.
Zonsequential damages as a consequence of the initial act by the defendant Yahoo! Inc.
Treble damages
Pro Se legal fees
All damages in the amount of twenty-million dollars.

-6-
"I declare under penalty o f perjury that the foregoing is true and correct"
Dated this
8th
day o f
Tulv
,201 I
San Francisco, Ca
Mark S. Buza Plaintiff, Pro Se Advocate
-7-
EXHIBITS
Exhibit A-1
On Sat, 10/25/08, Yahoo! Customer Care <mail-no-reply@cc.yahoo-inc.com>
wrote:
From: Yahoo! Customer Care <mail-no-reply@cc.yahoo-inc.com> Subject: Transcript of your chat To: "Mark Buza" <buzamark@yahoo.com> Date: Saturday, October 25, 2008, 1:56 PM
General Info Chat start time Chat end time Oct 25, 2008 4:40:11 PM EST
Oct 25, 2008 4:54:24 PM EST 00:14:12
Duration (actual chatting time) Operator Sean
Chat Transcript info: Please wait for a Yahoo! agent to respond. info: You are now chatting with Sean Mark Buza: http://groups.yahoo.com/group/NPSM/ Sean: Hi! Welcome to our Yahoo! Mail Live Chat service. I'm glad you've joined us. Sean: Thank you for providing us the details of your issue. Mark Buza: ok Sean: As I understand, the Psychoanalytic Socialist Movement Yahoo! Group has been removed and you want it restored. Am I right? Mark Buza: yes the sooner the better
EXHIBITS
- A-1
'
1
2 3
4
Sean: I a p o l o g i z e f o r t h e i n c o n v e n i e n c e t h i s may h a v e c a u s e d y o u . R e s t a s s u r e d t h a t I
w i l l t r y my b e s t t o h e l p you.
Mark Buza: I would l i k e t o know t h e r e a s o n t h i s i s t h e s e c o n d g r o u p t h a t h a s b e e n d e l e t e d by Yahoo Sean: TO b e a b l e t o h e l p you,

I w i l l n e e d t o r e d i r e c t you t o o u r Yahoo! Groups t e a m
5
6
7 8
s i n c e t h e y h a v e t h e r i g h t t o o l s t o h e l p you w i t h y o u r i s s u e . Sean: L e t me p r o v i d e you t h e l i n k where you c a n c o n t a c t them d i r e c t l y . Sean: P l e a s e c l i c k h e r e t o c o n t a c t o u r Yahoo! Groups team. Mark Buza: ok b u t t h e y d i d n t d o a n y t h i n g t h e l a s t t i m e Sean: I u n d e r s t a n d . B u t , t h e y a r e t h e r i g h t d e p a r t m e n t t o a s s i s t you w i t h y o u r i s s u e . Mark Buza: I a l r e a d y s e n t them a e m a i l t o d a y Sean: T h i s a v e n u e o f s u p p o r t i s f o r Yahoo! M a i l i s s u e s a n d i n q u i r i e s o n l y . Mark Buza: c h a t would b e b e t t e r Sean: T h a t i s o u t o f o u r e x p e r t i s e . Mark Buza: i s t h e r e a phone number Sean: U n f o r t u n a t e l y , YouMark Buza: ok Sean: I n t h e meantime, i s t h e r e a n y t h i n g e l s e I c a n h e l p you w i t h r e g a r d i n g y o u r Yahoo! M a i l a c c o u n t ? Mark Buza: o h i f o r g o t t h e y d e l e t e d my e m a i l a c c o u n t Mark Buza: npsm~high~command@yahoo.com Sean: P l e a s e g i v e me two t o t h r e e m i n u t e s t o c h e c k o n t h a t a n d s e e what I c a n d o t o h e l p you. Mark Buza: ok Mark Buza: t h a t was t o d a y a l s o Sean: I ' m s o r r y f o r t h e d e l a y . I ' l l b e w i t h you a s s o o n a s I c a n . Mark Buza: ok EXHIBITS - A-1 you c a n o n l y r e a c h them t h r o u g h t h e l i n k t h a t I h a v e p r o v i d e d
9 10
1 1
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Sean: Sorry to keep you waiting. Are you able to login using that account? Mark Buza: no Sean: Are you receiving any error message when you tried to access that account? Mark Buza: no error message Sean: Thank you for the confirmation. Mark Buza: ok Sean: Since you are unable to login to that account, I will need you to contact our Abuse team since they have the right tools to assist you further with your issue. Sean: Let me provide you the link where you can contact them. Mark Buza: ok Sean: Please click here to contact our Abuse team. Mark Buza: ok Sean: I would suggest that you contact our Yahoo! Groups and Abuse team so that they can help you resolve your issue as soon as possible. Sean: Would there be anything else I may assist you with? Mark Buza: right now Mark Buza: that should do it Sean: If you won't mind, it would be much appreciated if you can complete a short survey to give us your comments/suggestion on how we did today. Sean: All you need to do is click on the word "Close" at the top right of the chat window. Sean: Thank you for using Yahoo! Mail. If you have any other questions, please feel
free to come back and chat with us at any time. Sean: Thanks so much for visiting. Please be in touch any time. We're always here! Sean: Take care. Sean: Goodbye.
EXHIBITS
- A-1 -
TRANSMISSION VERIFICATION REPORT

I
Exhibit A-2
: 118/28/2610 1 4 : SWORDS : 4152524790 FAX TEL : 4152524788 SER. # : C85632789

TIME
NAME
DATE, T I ME FAX NO. /NAME DURATION PAGE (S) RESULT MODE
16/20 14:51 14083493301 00: 00: 20 02 OK STANDARD
ECM
1060Howard Street
San Francisco, CA '94103 Te1: (415) 252-4788 Fax: (415) 252-4790
TO:
'
FU:
D: *
GQ~) 34($-3301
L~rao7/0
Re:
cc:
Yahoo! Inc. &karst Avjenue Sunnyvale, CA 94089 Tel: (408) 349-3300 Fax: (408) 349-3301 3reetings Yahoo! :
EXHIBITS
rhis is a letter concerning that your company Yahoo! inc. is in violation of the civil rights of Mark Buza and his medium the political group the National Psychoanalytic Socialist Movement. This matter encompasses violations in which your company Yahoo! inc. participate in by deleting two NPSM sites from your servers at Yahoo! One NPSM site http:/~www.rzeocities.com/freudiangladiatorl966 terminated near the date of 10/17/08 and was the main NPSM site http://groups.yahoo.com/gro-up/NPSM/ deleted on 10/25/2008. This was action violates Mark Buza's well-established rights of free speech, equal protection, and fieedon ~f discrimination under the United States and California Constitutions. [I.] Some of the same issues have previously has been addressed by the courts of the United States, which the courts have decided that a ban on protest of speech violates First Amendment rights. See Tinker v. Des Moinei Independent Community School District, 393 U.S. 503 (1969) In that Ease, the U.S. Supreme Court ruled 7-2 against the school and in favor of the students wearing armbands seeing that their actions andlor speech did not interfere with school work or the rights ~f others in the schools classrooms. A prohibition against expression of opinion, without any zvidence that the rule is necessary to avoid substantial interference with school discipline or the rights of others, is not permissible under the First and Fourteenth Amendments of the United States Constitution. Pp. 507-5 14. See also Texas v. Johnson, 491 U.S. 397 (1989), Johnson participated in a political protest ~utside 1984 Republican National Convention in Dallas, Texas. At the end of the protest the Johnson poured kerosene on an American flag and set it on fire. Several witnesses not participating in the protest were offended at Johnson's actions. At the time Texas had a statute which made it a crime to desecrate a state or national flag. Johnson was charged and convicted under this Texas state law. After the finding he appealed, arguing that the law was a unconstitutional infringement on his First Amendment rights. The U.S. Supreme Court ruled in favor of Johnson in this case. The Court in a 5-4 ruling said that the Texas law did violate the First Amendment as applied to Johnson's act since it determined that the prosecution of Johnson was directly related to expression. Jarrar v. Harris et al. On Aug. 12, 2006, Transportation Security Administration officials and JetBlue Airways personnel prevented Raed Jarrar from boarding a flight at John I?. Icemedy Airport until he agreed to cover his T-shirt, which read "We Will Not Be Silent" in English and Arabic. Jarrar that day was waiting to board a JetBlue flight from the east coast to his home in Oakland, Calif., when he was suddenly approached by two TSA officials. One of the officials told Jarrar that he needed to remove his shirt because other passengers were not comfortable wit the Arabic script, telling him that wearing a shirt with Arabic writing on it to an airport was like "wearing a T-shirt at a bank stating, 'I am a robber." On Aug. 9, 2007, the American Civil
EXHIBITS
1
2
3
4
Liberties Union and the New York Civil -o in filed a civil rights lawsuit on Jarrar's &&atir&e U.S. District Court for the Eastern District of New York. The complaint charged that TSA and JetBlue officials violated Jarrar's civil rights under the First and Fifth Amendme ts and federal, state and city anti-discrimination laws. -TSA and JetBlue agreed in December 200 to give a monetary reward to Jarrar to settle the lawsuit out of court.
I am requesting Yahoo! inc. only to reconsider, renounce it's wrongdoing and pay a fine which will be defined by Mark Buza payable to Mark Buza for numerous civil rights, power, time 10s and other legal violations. This application of settlement applying to the previously stated guidelines that Yahoo's! course changed after being informed that such conduct violates I urge you to take this step above and resolve this matter amicably. If you do not, you may incu larger business financial liability, given the well-established nature of the law governing individual rights in these circumstances. See 28 U.SC. $ 1983.
Because legal action is approaching rapidly, please respond to this letter as soon as possible indicating that Yahoo! inc. will change it's course and do what is right in this matter correcting the wrong that was put upon Mark Buza and his political group. If I do not hear from you soor will have to assume that you are standing by your previous position and actions, notwithstandir our having called your attention to the law set forth in this letter, and we will proceed accordingly. This letter is not intended to set forth all of the facts relating to this matter or all of the rights or remedies available to Mark Buza under the present circumstances, or the bases thereof, all of which are expressly reserved.
16
:
I
17
Thank you for your attention to this matter. All correspondence should be mailed or emailed tc the following addresses. Mark Buza 1060 Howard st. San Francisco, Ca 94 103 Email address: markbuza@gmail.com
22
I I With anticipation;
I U.S. Const. , amend. 1 (protecting "freedom of speech" as well as expressive association); U.S.Const., amend. XJV (guaranteeing rights of "equal 1 protection of the laws," "liberty" and intimate association); CALIFORNIA CONSTSTUTION ARTICLE 1 DECLAlL4I'ION 0 : RIGKI'S states SECTION I . All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending lire and liberty, ncquiring, possessing, and protecting property, and pursuing and obtaining safety, happiness, and privacy, SEC. 2. (a) Every person may rreely speak, write and publish his or her sentiments on all subjects, being responsible for the abuse orthis right. A law may not restraln or abridge liberty of speech press. SEC. 3. (a)l'he people have the right to instruct their representatives, petition government for redress of grievances, and assemblc lieely to COW
II
EXHIBITS
TRANSMISSIOPJ VERIFICATION REPORT

I
EXHIBITS
Exhibit A-5
TIIvlE NAME FAX TEL
: : : :
12/'29/26EI13 16:
SWORDS
4152524790 4152524788
DATE, TIf4E F&X NU. /I.4At~,lE DLIR&TI ObI FAGE(S) EESLLT NODE
12/29 16:49 14083493301 00:BB: 4 9

'
84 OK STANDARD ECM
1060.Haward Street San Francisco, CA 94103. I Tel: (415) 252-4780 Fax; (415) 252-4790
~ e :
.-.
P
-
pages:
CC:
Urgent
CI 'Fix R w K w
.-.
CJP k ,
Reply
D Please R.K
.--.
EXHIBITS
- ."-. .
Yahoo! Inc. 01 First Avenue $hibit y 6 unnyva e, CA 94089 Tel: (408) 349-3300 Fax: (408) 349-3301 Greetings Yahoo!:
EXHIBITS
Mark S. Buza the owner of the National Psychoanalytic Socialist Movement has previously requested for your company Yahoo! inc. to reconsider, renounce its wrongdoing, reinstate both National Psychoanalytic Socialist Movement sites, and pay a fine after being informed that your companies conduct is in violation of the law, and the United States Constitution for Yahoo's deletion of two NPSM sites. O n e N P S M site ~~ttp://www.~eocities.con~/freu~-iin~~~1ndiator1~~ was terminated near the date of 10/1~/08, and the main NPSM site htt p://Kroups.yxhoo.cc!~n/Rroup/NPSM/ was deleted on 1o/zy/zoo8 from the Yahoo! servers. Accordingly since there has not been a response by Yahoo! from the prior demand letter sen a n 12/29/2009 via fax to (408) 349'3301. I shall start the final process of drafting an action against Yahoo! for the purpose of imposing through legal means what will be just in this circumstance. These two political sites were not for children to tamper with, and seeing t h Yahoo! is a large company well defined in the internet industry one could assume that a company of this magnitude would not do sometliing so blatant, and irresponsible upon the United States Constitution, and to a figure of stature such as the owner, founder and soon tl be plaintiff in this matter against Yahoo!. Yahoo! has shown through its actions against the National Psychoanalytic Socialist Movement, and its founder, and leader Mark S. Buza of tampering, and erasing the history of a entity of NPSM's large magnitude is no more than censorship, and Look burning and thus your company Yahoo! should pay a very steep price for it's illegal intrusion onto history.
Marlc S. Buza
EXHIBITS
- A-6 -

Buza V Yahoo Complaint

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Buza V Yahoo Complaint

Uploaded by

Copyright:

Available Formats

Case4:11-cv-04422-DMR Document1

Attorneys for Defendant, YAHOO! Inc.

UNITED STATES DISTRICT COURT

5 1331 and is one which may be removed

1441, subdivisions (b) and (c) because it arises

Notice of Removal of Action

5 1331 or, in the

Notice of Removal of Action

Intradistrict Assignment: Pursuant to Local Rule 3-2(C), assignment of this action to

either the Santa Clara or San Francisco Division is appropriate as

Dated: September 6,20 1 1

Respectfully submitted, OVSKY AND POPEO, P.C.

By: Michele Floyd Robert S. Eaton Attorneys for Defendant

Notice of Removal of Action 3

Sari Francisco Superior Court

0CCP 416.1 0 (corporation)

1CCP 416.60 (minor) 0 CCP 416 70 (consenratee)

a CCP 416.90 (authorized person)

other (specify): by personal delivery on (date):

WITHOUT AlTORNEY (Name, Sf

r number, and &real:

1060 Howard St. San Francisco, Ca 94103

Sm F . c o ountv Sumrior Cou

SUPERIOR COURT OF CAUFORNI~COUNTY OF

San Francisco, CA 94102 San Francisco Superior Court

CIVIL CASE COVER SHEET

0 b. 0 nonnmonetary; declaratory or injunctive relief

Intellectual Property, USC 2701

(SIGNATURE OF P A R ~ A ~ R N NFOR PARW R

a y Use ~ u d uCand d Cfdbrnm l c ~ o i [Rev. ~ u ) y1. zm7] a

CIVIL CASE COVER SHEET

SUPERIOR C O U R T FOR THE STATE OF CALIFORNTA

COUNTY OF SAN FRANCISCO

CIVIL ACTION AGAINST YAHOO1 INC.

Civil Action Agairuc Yahoo Inc.

and the second National Psychoanalytic Socialist Movement

Civil Accion Against Yahoo Inc.

FIRST CAUSE OF ACTION

ht~://www.~eocities,com/freudian~ladiatorI966 therefore limiting the power of NPSM, and its founder

Civil Action Against Yahoo Inc.

THlRD CAUSE OF ACTION

FORTH CAUSE OF ACTION

mFTH CAUSE OF ACTION

Civil .kction Against Yahoo Inc

Pro Se legal fees

Al damage%in the amount of twenty-million dollars. l

CIVII Action Against Yalloo lnc.

C I V Actjon Agalnsr Yahoo Inc. I~ -7-

On Sat, 1 0 / 2 5 / 0 8 , Yahoo! Customer Care -ail-no-reply@cc.yahoo-inc.com,

Duration (actual chatting time) Operator Sean

Sean: U n f o r t u n a t e l y , you c a n c n l y r e a c h them t h r o u g h t h e ].ink t h a t I h a v e p r o v i d e d

If you have any other questions, please feel

: 10/2112818 1 4 : : SWORDS : 4152524790

FAX NO. /NME WRATIW

Liberties Union and the New York Civil o n

filed a civil rights lawsuit on Jarrar's

DATE, TIIv1E FAX NU. .i't4&fv1E DURAT1OI.I PAGE ( 5 ) ESLLT FlUDE

1060. Howard Street

San Fra.wisco, CA 94103,

Fax: (915) 252-4790

(Cl TACION JUDICIAL)

San Francisco Superior Court