Ceglia v. Zuckerberg et al

Filing 106

MEMORANDUM in Opposition re 95 Cross MOTION to Compel, 91 MOTION to Compel Defendant Zuckerberg's Compliance with the Court's Order of July 1, 2011 filed by Paul D. Ceglia. (Attachments: # 1 Affidavit, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Affidavit, # 6 Exhibit A, # 7 Exhibit B, # 8 Exhibit C, # 9 Exhibit D, # 10 Exhibit E, # 11 Exhibit F, # 12 Exhibit G, # 13 Exhibit H, # 14 Affidavit, # 15 Exhibit A, # 16 Exhibit B, # 17 Exhibit C, # 18 Certificate of Service)(Lake, Jeffrey)

BIO
Larry F. Stewart was born in Asheville, North Carolina. He has earned an Associate of
Arts degree from Florida Technological University in Orlando, a Bachelor of Science in Forensic
Science degree from the University of Central Florida, also in Orlando and a Master of Forensic
Sciences degree from Antioch University in Yellow Springs, Ohio. Mr. Stewart has worked for
the U.S. Government as a forensic scientist for over 25 years. During that time he has worked on
many notable cases to include; the Unabomber, the John Wilkes Booth diary, numerous accused
Nazi war criminals, e.g. John Demanjuk, a.k.a. Ivan the Terrible, the reinvestigation of the Dr.
Martin Luther King murder, the reinvestigation of the Kennedy assassination/CIA conspiracy
theory, the Quedlinburg Treasure, the Jon Benet Ramsey murder investigation, the 9/11 terrorist
attacks and the DC Sniper investigation. He has testified as an expert witness in state, federal
and military courts of law, as well as testified or been deposed in foreign court systems to
include; Austria, Australia, Canada, Germany, Sri Lanka, and Thailand. He has also testified at
The Hague in the Netherlands and three times before the U.S. Congress. Mr. Stewart most
recently held the position of Laboratory Director and Chief Forensic Scientist for the United
States Secret Service. In that role, he managed up to 120 scientists, technicians, and support staff
in the areas of document analysis, handwriting, fingerprints, trace evidence, audio and video
analysis, photography, toolmarks, computer evidence and counterfeit analysis. In 2005, Mr.
Stewart began the independent forensic consulting and investigative firm known as Stewart
Forensic Consultants, LLC and its subsidiary, Global Investigative & Intelligence Services.
RESUME
Larry F. Stewart
Occupation:
Chief Forensic Scientist and President – Stewart Forensic Consultants, LLC
San Luis Obispo, California
Education:
Associate of Arts Degree - Received June 1976
Florida Technological University
Orlando, Florida
Bachelor of Science in Forensic Science Degree - Received August 1979
University of Central Florida
Orlando, Florida

Master of Forensic Sciences Degree - Received June 1983
Antioch University
Yellow Springs, Ohio
Pertinent Specialized Courses:
Forensic Microscopy Course - March 1978
McCrone Research Institute
Chicago, Illinois
Atomic Absorption Spectrophotometry - April 1979
Perkin-Elmer Corporation
Gaithersburg, Maryland
Gas Chromatography Course - December 1979
Virginia Polytechnic Institute and State University
Gaithersburg, Maryland
Advanced Gas Chromatography - March 1980
Perkin-Elmer Corporation
Advanced High Pressure Liquid Chromatography Course - January 1981
Virginia Polytechnic Institute and State University
Washington, DC (course location)
Ink and Paper Analysis Seminar - January 1981
U.S. Air Force
Office of Special Investigations
Washington, DC
High Pressure Liquid Chromatography/Mass Spectrometry - July 1981
U.S. Justice Department, F.B.I.
Quantico, Virginia
High Pressure Liquid Chromatography/Computer Operation - March 1984
Perkin-Elmer Corporation
Rockville, Maryland

Questioned Document Course - February 1985
U.S. Secret Service
Washington, DC
Fourier Transform Infrared Spectroscopy Course - June 1986
Nicolet Analytical Instruments
Lanham, Maryland
Scanning Electron Microscopy - September 1994
Philips Electronic Instruments
Mahwah, New Jersey
ASCLD/LAB Inspector Training Course – January 2000
Portland, Oregon
Work Experience:
December 1975 through March 1979
Laboratory Technician
University of Central Florida
March 1979 through September 1979
Internship
Bureau of Alcohol, Tobacco and Firearms
September 1979 through July 1982
Forensic Chemist
Bureau of Alcohol, Tobacco and Firearms
July, 1982 through June, 2005 (retired)
Counterfeit Specialist
Questioned Document Examiner
Lead, Instrumental Analysis Section
Lead, Instrumental and Computer Analysis Section
Senior Document Examiner/National Expert for the United States Secret Service
Chief, Questioned Document Branch
Assistant Laboratory Director
Laboratory Director/Chief Forensic Scientist

United States Secret Service
June 2005 to present
Chief Forensic Scientist and President
Stewart Forensic Consultants, LLC
Instructor:
Bureau of Alcohol, Tobacco and Firearms
Rockville, Maryland
United States Air Force, Office of Special Investigations
Special Investigator's Course
Washington, DC
United States Secret Service
Washington, DC
Federal Law Enforcement Training Center
Glynco, Georgia
Drug Enforcement Agency
Washington, DC
International Law Enforcement Academy
Budapest, Hungary
Naval Criminal Investigative Service
Washington, DC
Rochester Institute of Technology
Rochester, New York
Cuesta College
San Luis Obispo, California
California Polytechnic University
San Luis Obispo, California

Guest Speaker:
Montgomery College
October 1980
Rockville, Maryland
Antioch School of Law
November 1980 and February 1981
Washington, DC
Montgomery College
Ink and Paper Analysis/Instrumental Techniques - February 1982
Rockville, Maryland
DocSec'85
Document Security - May 1985
Washington, DC
George Washington University
Ink and Paper Analysis - February 1986
Washington, DC
Inspector Generals Office - Health and Human Services
Tri-regional Conference - January 1991
Mt. Pocono, Pennsylvania
Bolling Air Force Base
Joint Basic Computer Forensic Workshop - September 1993
Washington, DC
Virginia Military Institute
The Uses of Chemistry and Biology in the Forensic Sciences - April 1994
Lexington, Virginia
UCLA
Forensic Examination of Financial and Identity Documents – August 1998
American Society of Questioned Document Examiners meeting

Los Angeles, California
Catholic University
Science Under Oath – February 2000
Washington, DC
GATF Conference
Security Printing, Computers and the Forensic Scientist – August 2000
Pittsburgh, PA
Fraud Prevention Workshop
Security Printing – October 27, 2000
U.S. Department of State
Ft. Lauderdale, Florida
International Association for Identification
Forensic Science and Fraudulent Documents – May 2004
Sacramento, California
San Luis Obispo Criminal Bar Association
Getting the Most from Forensic Technology in Criminal Investigations – December 13, 2006
San Luis Obispo, California
California Association of Licensed Investigators
Counterfeits Are All Around Us! – February 2, 2007
Palm Springs, California
California Association of Licensed Investigators
Leveling The Playing Field - December 4, 2008
Pismo Beach, California
Specialized Tours/Training:
Crane-Weston Paper Mill
Dalton, Massachusetts - July 28, 1982
Philadelphia Mint
Philadelphia, Pennsylvania - July 29, 1982

Bureau of Engraving and Printing
Washington, DC - July 30, 1982
Visa International
San Francisco, California - January 3-6, 1984
Malco Plastics
Garrison Park, Maryland - January 1985
BIS CAP International, Ink Jet Printing Conference
Boston, Massachusetts - September 17-19, 1990
Achievements:
Participated as a "referee" in the 1980 Crime Laboratory Proficiency Training Program Forensic
Sciences Foundation, Colorado Springs, Colorado
Testified in May of 1989 and 1990 before the Subcommittee on Oversight and Investigations of
the Committee on Energy and Commerce, U. S. House of Representatives. These matters
concerned the investigation of fraud in science.
Certified by the US Secret Service as an accredited Examiner of Questioned Documents,
February 1, 1991.
Recipient of the Health and Human Services Inspector General's Integrity Award, 1991.
Appointed Chairman of A.S.T.M. task groups (1991) concerned with developing standards for
performing "Writing Ink Comparisons" and "Writing Ink Identifications."
United States Delegate at the 14th European Meeting on Currency Counterfeiting, The Hague,
The Netherlands, October 9-11, 1991 and the First International Conference on Fraudulent
Documents, Ottawa, Canada, April 27- May 1, 1992.
United States Delegate at the 6th European Conference for Police and Government Experts,
London, United Kingdom, October 2-4, 1996. Presented a paper on Ink Dating, Relative and
Absolute: New Approaches to Old Problems.

Testified on July 22, 1999 before the House Judiciary Committee, Subcommittee on Immigration
and Claims, U.S. House of Representatives. This matter concerned detection and prevention of
counterfeit documents.
Classified as an “Inspector” for the American Society of Crime Laboratory Directors.
Elected to the Board of Directors for the American Society of Crime Laboratory Directors,
September 14, 2000.
Elected to the Board of Directors for the Document Security Alliance, December, 2003.
Appointed as the forensic consultant for the United Nations, tasked with developing and
implementing a successful forensic laboratory in Nigeria, Africa, 2007.
Elected to the Board of Directors for The Academy, June, 2007.
Certified Forensic Consultant, American College of Forensic Examiners Institute, October, 2007.
Appointed as a forensic consultant for the US Department of State, Bureau of International
Narcotics and Law Enforcement Affairs in Yerevan, Armenia, January, 2008 (ongoing
assignment).
Appointed as a forensic consultant for the US Department of State, Bureau of International
Narcotics and Law Enforcement Affairs in Tbilisi, Georgia, May, 2008.
Elected to the Board of Directors for the American Board of Forensic Examiners, February,
2009.
Original Research Publications/Presentations:
"Detection of Volatile Accelerants in Fire Debris. 1. A Comparative Evaluation... " Richard A.
Strobel, Richard A. Tontarski, Larry F. Stewart, Philip Wineman presented at the American
Academy of Forensic Sciences, New Orleans, Louisiana, February 1980, and the Mid-Atlantic
Association of Forensic Scientists, combined meeting, Louisville, Kentucky, May 1980.
"Artificial Aging of Documents," L.F. Stewart. Published in the Journal of Forensic Sciences,
Vol. 27, No. 2, April 1982.

"Ballpoint Ink Age Determination by Volatile Component Comparison," L.F. Stewart, Presented
at the American Academy of Forensic Sciences meeting, Orlando, Florida, February 1982, and
Mid-Atlantic Association of Forensic Scientists/Northeastem Association of Forensic Scientists
joint meeting, Harrisburg, Pennsylvania, April 1982.
Published in the Journal of Forensic Sciences, April 1985.
"The Role of the Secret Service in Counterfeit Deterrence," L.F. Stewart. Presented at the MidAtlantic Association of Forensic Scientists meeting, Baltimore, Maryland, April 1983.
"The Forensic Analysis of Printing Inks," Larry F. Stewart. Presented at the American Society of
Questioned Document Examiners, Lake Tahoe, Nevada, September 1983.
"Counterfeit Credit Card Deterrence," Larry F. Stewart. Presented at the American Society of
Questioned Document Examiners/Canadian Society of Forensic Scientists annual meeting,
Montreal, Quebec, Canada, September 1985.
"Detection of Counterfeit Currency," Larry F. Stewart. Presented at the International Association
of Identification conference, Arlington, Virginia, August 1987.
"Identification of United States Currency Security Fibers by Fourier Transform Infrared
Spectroscopy," J.E. Brown and L.F. Stewart. Presented at the Canadian Society of Forensic
Scientists annual meeting, Toronto, Ontario, Canada, October, 1988.
"U.S. Secret Service Ink Identification System," J.W. Hargett, J.E. Brown and L.F. Stewart.
Presented at the Canadian Society of Forensic Scientists annual meeting, Toronto, Ontario,
Canada, October 1988.
"Use of Enlargement Ratios of Negatives and/or Printing Plates to Characterize Counterfeit
Currency," L.F. Stewart, R.L. Outland and J.E. Brown. Presented at the Canadian Society of
Forensic Scientists annual meeting, Toronto, Ontario, Canada, October 1988.
"Current Status of Ink Age Determination," L.F. Stewart and S.L Guertin. Presented at the Ninth
INTERPOL Forensic Science Symposium, INTERPOL Headquarters, Lyon, France, December
12, 1989. Published in INTERPOL International Criminal Police Review, March-April, 1991.
"A.S.T.M. Standard for Writing Ink Comparisons," L.F. Stewart and J.L. Becker

Presented at the Mid-Atlantic Association of Forensic Scientists 1991 meeting, Bethesda,
Maryland, May 31, 1991.
"Standard Guide For Test Methods For Forensic Writing Ink Comparisons," L.F. Stewart (Task
Group Chairman). Published in the American Society For Testing and Materials (ASTM),
Standard Designation number E-1422-91, November 1991.
"Counterfeit Documents Produced by Color Copier Systems," L.F. Stewart, Presented at
INTERPOL Headquarters, Lyon, France, December 11-19, 1991.
"Sentence Insertions Detected Through Ink, ESDA and Line Width Analysis," S.L. Fortunato and
L.F. Stewart. Published in the Journal of Forensic Sciences, November 1992.
"Status of U.S.S.S. Ink Dating Program," J.W. Hargett and L.F. Stewart. Presented at the
Humboldt University, Berlin, Germany, April 2, 1993. Published in Kriminalistik und
Forensische Wissenschaften, No. 82, 1994.
"U.S.S.S. International Ink Library and Bulletin Board System," L.F. Stewart. Presented at the
Mid-Atlantic Association of Forensic Scientists meeting, Baltimore, Maryland, May 20, 1993.
"Standard Guide For Test Methods For Forensic Writing Ink Identifications," L.F. Stewart (Task
Group Chairman). Published in the American Society For Testing and Materials (ASTM),
Standard Designation number E-1422, 1995.
"The Government Response to Ink Age Determination," L.F. Stewart, J.L. Becker. Presented at
the American Academy of Forensic Sciences meeting, Seattle, Washington, February 17, 1995.
Published in the International Criminal Police Review - INTERPOL, Spring, 1996.
“Distinguishing Between Relative Ink Age Determination and the Accelerated Aging
Technique,” L.F. Stewart and S.L. Fortunato. Published in the International Journal of Forensic
Document Examiners, January/March, 1996.
“Forensic Examination of Financial Crimes Documents,” L.F. Stewart and J.W. Hargett.
Presented at the 6th European Conference for Police and Government Document Experts,
London, United Kingdom, October 2-4, 1996 and the GFS Conference, Luzerne, Switzerland,
September 9-12, 1997.

“Unusual Document Examination Approaches and Their Relationship to the Daubert Challenge,”
L.F. Stewart. Presented at the American Board of Forensic Document Examiners meeting, Las
Vegas, NV, June 23, 2002 and the American Society of Questioned Document Examiners
meeting, San Diego, CA, August 14, 2002.
“Forensic Science – Fake Fingerprints?,” L.F. Stewart, Published in the Forensic Expert Witness
Association, Fall, 2007.
"Leveling The Playing Field," L.F. Stewart. Presented at the California Association of Licensed
Investigators, Central Coast meeting, Pismo Beach, California, December 4, 2008.
“Crime Scene Investigation,” L.F. Stewart, on-line course developed for and published by the
American College of Forensic Examiners Institute, January 2009.
“Identity Theft,” L.F. Stewart, A-Z Literary Book Publisher, 2009.
“Document Examination,” L.F. Stewart, A-Z Literary Book Publisher, 2009.
“Forensic Science – Fake Fingerprints?,” L.F. Stewart, Published in the HG Experts Legal
Experts Directory on-line publication, Spring, 2010.
“Forensic Science - The Good and the Bad,” L.F. Stewart, Published in the HG Experts Legal
Experts Directory on-line publication, Spring, 2010.
“Forensic Science - Erroneous Handwriting Opinions,” L.F. Stewart, Published in the HG
Experts Legal Experts Directory on-line publication, Spring, 2010.
Professional Affiliations:
American Academy of Forensic Sciences - Fellow
Canadian Society of Forensic Scientists (past member)
American Society of Crime Laboratory Directors
Document Security Alliance (past member)
Mid-Atlantic Association of Forensic Scientists (past member)
California Association of Licensed Investigators
Forensic Expert Witness Association
American College of Forensic Examiners Institute
American Chemical Society

Association For Intelligence Officers
Business Espionage Controls & Countermeasures Association
Offices Held:
Mid Atlantic Association of Forensic Scientists
Secretary/Treasurer
November 1981 to October 1984.
American Society of Crime Laboratory Directors
Board of Directors
September 14, 2000 to September, 2003
Document Security Alliance
Board of Directors
December 2003 to November 2004
The Academy
Board of Directors
June, 2007 to present
American Board of Forensic Examiners
Board of Directors
January, 2009 to December, 2009
Contact Information:
Physical Address:
Stewart Forensic Consultants, LLC
570 Peach Street, #30
San Luis Obispo, California 93401
Mailing Address:
Stewart Forensic Consultants, LLC
793A East Foothill Boulevard, Suite 200
San Luis Obispo, California 93405
Tel/Fax: [phone], Cell: [phone]
Email: [e-mail]

Website: http://www.stewartforensicconsultants.com