Ceglia v. Zuckerberg et al

Filing 164

MOTION to Stay Proceedings Temporarily by Paul D. Ceglia. (Attachments: # 1 Affidavit, # 2 Exhibit A)(Lake, Jeffrey)

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ------------------------------------ x : PAUL D. CEGLIA, : : Plaintiff, : : v. : : MARK ELLIOT ZUCKERBERG and : FACEBOOK, INC., : : Defendants. ------------------------------------ x 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. I have received permission from Paul Ceglia and Paul Argentieri to withdraw from this case. A true and correct copy of the notice of withdrawal is attached hereto as Exhibit A. 3. However, Paul Ceglia is currently in discussions with several attorneys concerning substitution of new counsel in this case. It is my understanding that these attorneys are diligently coming up to speed with the facts and proceedings in an effort to effectively represent Paul Ceglia in future proceedings. 4. As such, it would most benefit Mr. Ceglia and my law firm if the proceedings were stayed pending substitute of new counsel. I hereby certify and declare under penalty of perjury that the foregoing is true and accurate. DATED: October 17, 2011 s/ Jeffrey A. Lake 2

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