Ceglia v. Zuckerberg et al

Filing 541

DECLARATION signed by Jason Holmberg re 540 Response in Opposition to Motion filed by Paul D. Ceglia filed by Paul D. Ceglia. (Boland, Dean)

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK PAUL D. CEGLIA, Civil Action No. : 1:10-cv-00569-RJA Plaintiff, v. DECLARATION OF JASON HOLMBERG 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 was present at some meetings in which lawyers from the Kasowitz firm were also present. 2. The Kasowitz lawyers cautiously did not discuss potentially privileged information while I was present in any of those meetings. 3. I was asked to leave meetings at which Kasowitz lawyers were present so that a discussion of privileged information could occur. 4. I never discussed the subject matter of the Kasowitz lawyers declining to represent Paul Ceglia with any person, including not with any Kasowitz lawyer. 5. Therefore, I have never discussed with anyone the subject matter of why or under what circumstances the Kasowitz lawyers declined to represent Paul 1 Ceglia. 6. I also never saw nor was I ever aware of the Street Fax digital images until they were publicly released in court filings. I hereby declare 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: DATED: September 14, 2012. Jason Holmberg 2