Ceglia v. Zuckerberg et al

Filing 219

DECLARATION signed by Alexander H. Southwell re 216 MOTION to Strike 212 Declaration and for Sanctions filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A)(Snyder, Orin)

EXHIBIT A

Neutral Third Party confirms Facebook damaging of Ceglia’s
Contract
Posted by Dean Boland
In a stunning continuation of evidence supporting Mr. Ceglia’s claims, a new declaration has been filed
supporting Mr. Ceglia’s claim that Facebook’s experts recklessly damaged the Facebook Contract during
their examination of it.

As was noted in a prior post, there is video evidence demonstrating that when Facebook’s experts
received Ceglia’s and Zuckerberg’s authentic contract, it was in pristine condition, i e. two white pieces of
paper with original signatures in ink. The videos in that post show that when the document is finally
unveiled after Facebook’s experts’ examination, it is noticeably discolored and has been damaged by
Facebook’s experts.

Today, one of the neutral witnesses to the entire document examination by Facebook’s experts, was the
videographer hired by BOTH parties to document Facebook’s experts’ examination. That disinterested
neutral third party ran the video camera of the entire examination. He also viewed the Facebook Contract
at the first moments it was first presented to the Facebook experts to examine. He is off camera during
the video where the Facebook Contract is being opened in front of the Facebook Experts for the first time.
The video shows the contract as two white pieces of paper.

His sworn declaration, filed just today in support of Ceglia’s motion for sanctions against Facebook and
Zuckerberg for damaging the Facebook Contract, clearly states what he saw with his own eyes, not
through the video camera. t confirms Ceglia’s claim and devastates Facebook’s murky, meandering,
unsupported defenses. The videographer confirms the document was white when it was given to
Facebook’s experts.

That declaration states in part:

“8. My role in this case was that of a disinterested third party documenting the events on video.

9. I was retained by both parties in this case, with half of my fee paid by each party, to document on video
the examination of the Facebook Contract at the offices of Harris Beach law firm in Buffalo New York,
from July 14, 2011 through July 19, 2011 .

12. Paul Argentieri spoke to me the morning of July 14, 2011 before the documents were removed from
the envelope that he had in his possession.

13. Paul Argentieri said to me as he placed the two documents on the table of the conference room words
to the effect of ‘this is the two page document’ and then, ‘this is the six page document.’

14. I was standing approximately three feet from the documents as they were laid out on the conference
room table.

15. I observed the documents both with my eyes unaided by the video camera and through the lens of the
video camera.

16. I did not notice anything out of the ordinary regarding the documents.

17. They looked like white documents, eight total white pages.”

The entire filed sworn declaration can be downloaded here.