Ceglia v. Zuckerberg et al

Filing 156

DECLARATION signed by Alexander H. Southwell re 154 Third MOTION to Compel and for Other Relief filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Snyder, Orin)

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EXHIBIT B Connors & Vilardo, LLP Description of Document Street Fax List of Products and Services Type of Document PDF Street Fax List of Products and Services; Street Fax Sales Representative Potential Customers for Region Photograph Additions to Street Fax “Photobase” in Florida Street Fax Confidential Private Placement Memorandum Street Fax List of Products PDF Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated September 22, 2003 Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated September 2, 2003 Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated December 19, 2003 Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated February 16, 2004 PDF PDF PDF PDF Privilege Claimed Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Cumulative/Equally Available to Defendants PDF Cumulative/Equally Available to Defendants PDF Cumulative/Equally Available to Defendants PDF Cumulative/Equally Available to Defendants Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated August 29, 2003 Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated August 28, 2003 Scan of printed email between mzuckerb@fas.harvard.edu and paulceglia@msn.com, dated June 19, 2003 Scan of printed email between mzuckerb@fas.harvard.edu and kpmonsterus@yahoo.com, dated September 22, 2003 Unexecuted Unanimous Written Consent in Lieu of First Meeting of the Board of Directors of US Data Basics, Inc. Action by Written Consent of the Incorporator of US Data Basics, Inc., signed by Jack Berberian, dated June 5, 2002 Unexecuted StreetDelivery.com, Inc. Promissory Note Unexecuted StreetDelivery.com Loan Agreement Memorandum of Understanding from StreetDelivery.com, Inc. v. U.S. Data Basics, Inc. and Paul Ceglia et al. (Civ. No. 03-10590, D. Mass. 2003) StreetDelivery.com, Inc. Independent Contractor Agreement with no indication of execution PDF Cumulative/Equally Available to Defendants PDF Cumulative/Equally Available to Defendants PDF Cumulative/Equally Available to Defendants PDF Cumulative/Equally Available to Defendants PDF Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret PDF Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret PDF Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret PDF PDF PDF Irrelevant/Outside Scope of August 18, 2011 Order/Trade Secret Kasowitz, Benson, Torres & Firedman LLP Description of Document Portion of Lawsuit Overview Type of Document PDF Privilege Claimed Work Product Privilege/Attorney-client Privilege (N.Y. C.P.L.R. 4503)/Outside Scope of August 18, 2011 Order Edelson McGuire, LLP Description of Document Multiple enhanced scans of portions of “„Work for Hire‟ Contract” executed by Paul Ceglia and Mark Zuckerberg, dated April 28, 2003 Multiple Powerpoints of portions of “„Work for Hire‟ Contract” executed by Paul Ceglia and Mark Zuckerberg, dated April 28, 2003 Type of Document PDF Privilege Claimed Work Product Privilege Powerpoint Work Product Privilege Speckin Forensic Laboratories Description of Document Multiple enhanced scans of portions of “„Work for Hire‟ Contract” executed by Paul Ceglia and Mark Zuckerberg, dated April 28, 2003 Type of Document PDF Privilege Claimed Work Product Privilege Stewart Forensic Consultants, LLC Description of Document Multiple enhanced scans of portions of “„Work for Hire‟ Contract” executed by Paul Ceglia and Mark Zuckerberg, dated April 28, 2003 Type of Document TIFF Privilege Claimed Work Product Privilege

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