Ceglia v. Zuckerberg et al

Filing 120

MEMORANDUM in Support re 118 MOTION to Stay re 117 Order, Terminate Motions filed by Paul D. Ceglia. (Attachments: # 1 Affidavit, # 2 Affidavit, # 3 Exhibit A, # 4 Certificate of Service)(Lake, Jeffrey)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
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:
PAUL D. CEGLIA,
:
:
Plaintiff,
:
:
v.
:
:
MARK ELLIOT ZUCKERBERG and
:
FACEBOOK, INC.,
:
:
Defendants.
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Civil Action No. 1:10-cv-00569RJA

DECLARATION OF JEFFREY A. LAKE
I, Jeffrey A. Lake, Esq., submit this Declaration in support of Plaintiff’s Motion to Stay
Discovery (Motion to Stay) and hereby declare:
1.

I am an attorney licensed to practice law in the State of California and duly

admitted to practice before the United States District Court for the Western District of New
York. I am counsel of record for Plaintiff Paul D. Ceglia in the above-captioned matter. I make
this declaration based upon personal knowledge.
2.

Pursuant to the Court’s July 1, 2011 Order (Doc. No. 83) (July 1, 2011 Order)

Plaintiff already produced extensive electronic media in Plaintiff’s possession, custody, and
control, including a laptop, a desktop, two hard drives, a forensic image of one of those hard
drives, 174 floppy discs, and 1,087 CDs/DVDs.
3.

Pursuant to the July 1, 2011 Order, Plaintiff already produced the original contract

for extensive ink and paper testing by both parties.
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4.

Although Plaintiff has requested expedited transcripts of the August 17, 2011 and

August 18, 2011 hearings, nothing has been received as of the time of this filing.

I hereby certify and declare under penalty of perjury that the foregoing is true and accurate.
DATED: August 22, 2011
s/ Jeffrey A. Lake

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