Ceglia v. Zuckerberg et al

Filing 179

DECLARATION signed by Dean Boland re 176 Response in Opposition to Motion, 177 Memorandum in Opposition to Motion, 178 Affidavit in Support of Motion filed by Paul D. Ceglia. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Boland, Dean)

Connors & Vilardo, LLP
Description of Document
Street Fax List of Products and Services
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
Scan of printed email between
[e-mail] and
[e-mail], dated September
22, 2003
Scan of printed email between
[e-mail] and
[e-mail], dated September
2, 2003
Scan of printed email between
[e-mail] and
[e-mail], dated December
19, 2003
Scan of printed email between
[e-mail] and
[e-mail], dated February
16, 2004
Scan of printed email between
[e-mail] and
[e-mail], dated August 29,
2003

Type of Document
PDF
PDF

Privilege Claimed
None
None

PDF

None

PDF

None

PDF
PDF

None
None

PDF

None

PDF

None

PDF

None

PDF

None

EXHIBIT A

Scan of printed email between
[e-mail] and
[e-mail], dated August 28,
2003
Scan of printed email between
[e-mail] and
[e-mail], dated June 19, 2003
Scan of printed email between
[e-mail] and
[e-mail], 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

None

PDF

None

PDF

None

PDF

None

PDF

None

PDF

None

PDF

None

PDF

None

PDF

None

Kasowitz, Benson, Torres & Firedman LLP
Description of Document

Type of Document

EXHIBIT A

Privilege Claimed

Portion of Lawsuit Overview

PDF

Work Product Privilege/Attorney-client
Privilege (N.Y. C.P.L.R. 4503) and see
submitted memorandum to the court.
Unredacted portions already submitted to
Defendants. In accordance with
Fed.R.Civ.P. 26(b)(5)(A)(ii) and
Fed.R.Civ.P. 26(e)(1)(A) the description of
the content of the redacted pages is as
follows: Attorney client communication and
attorney analysis derived from that
communication along with strategy
considerations and an analysis of facts in
this case used in the past by Mr. Ceglia for
consideration of retention of additional
counsel.

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
None

Powerpoint

None

Speckin Forensic Laboratories

EXHIBIT A

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
None

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
None

For every document where the “Privilege Claimed” column says “none” Stroz Friedberg has been directed to release those documents
to Defendants.

THIS PRIVILEGE LOG SUPERSEDES THE PRIOR PRIVILEGE LOG THAT WAS DOC. NO. 156-2

EXHIBIT A