Ceglia v. Zuckerberg et al

Filing 398

DECLARATION signed by Paul Ceglia re 397 Memorandum in Support, 396 MOTION for Discovery Notice of Motion filed by Paul D. Ceglia. (Boland, Dean)

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK PAUL D. CEGLIA, Civii Action No. : 1:10-cv-00569-RJA Plaintiff-, NECI,ARATION OF PAUL CEGLIA V. MARK ELLIOT ZUCKERBERG, Individually, and FACEBOOK, INC. Defendants. DECLARANT, submits this declaration and hereby declares under penalty of perjury and pursuant to 28 U.S.C. 1746 and under the laws of the United States that the following is true and correct: 1. I make this declaration upon personal knowledge. 2. On or about January or February of 2003 I posted an advertisement on Craigslist New York for a computer programmer. 3. The advertisement did not include my phone number. 4. I accepted applications, including the one from Mark Zuckerberg, via email only. 5. On or about February or March of 2003 I selected Mark Zuckerberg as the contractor. 6. Throughout February, March and April of 2003 time I exchanged multiple emails with Mark Zuckerberg to begin to explain in greater detail the work I wanted completed and to explain my need for a search engine. Dozens of emails were exchanged with Mark Zuckerberg in those three months. 7. Those emails included drafts of what became the eventual Facebook Contract that we signed on April 28,2003 in Boston. 8. We both arranged a meeting in Boston for April 28,2003 to sign an agreement, now known as the Facebook Contract. 9. After our meeting and signing in Boston we discussed via email the concerns that Mark had over specific areas of the build in the weeks leading up to the official start date of May 24, t}i'e day after Mark's classes at Harvard ended for the semester. 10. During the week of May 24 through May 31, 2003, countless emails were exchanged as continual issues arose that required my input. 11. I continued to both correspond by email and occasionally speak to Mark Zuckerberg on the phone about the ongoing project. 12. In November of 2003 Mark Zuckerberg and I again began to communicate regularly via email. 13. Mark Zuckerberg sent me numerous emails between November 2003 and December 31, 2003. That email communication continued into 2004. I hereby declare under penalty of perjury and pursuant to 28 U.S.C. 1746 under the laws of the United States that the following is true and correct: DATED: May 30, 2012. and.