Ceglia v. Zuckerberg et al

Filing 224

MEMORANDUM IN SUPPORT re 223 MOTION Order re 41 Text Order Referring Case to Magistrate Judge,,,,, Notice of Motion for Order Prohibiting Defendants from Reliance on Argument that Ceglia Zuckerberg email exchanges in Amended Complaint are Frauds in any dispositive motion MOTION Order re 41 Text Order Referring Case to Magistrate Judge,,,,, Notice of Motion for Order Prohibiting Defendants from Reliance on Argument that Ceglia Zuckerberg email exchanges in Amended Complaint are Frauds in any dispositive motion byPaul D. Ceglia. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Certificate of Service)(Boland, Dean)

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CURRICULUM VITAE Gerald R. Grant Jr. 170 Downsview Drive Rochester, NY 14606 585-739-4337 - Cell grantj@frontiernet.net - E-Mail PROFESSIONAL SUMMARY A professional computer forensic expert and systems analyst with over 25 years of experience involving forensics, computer automation and programming. Mr. Grant is a Certified AccessData Forensic Examiner. Mr. Grant is the currently a Computer Forensic Investigator for the Western District of New York Federal Public Defender’s Office. He was previously the Computer Systems Administrator for the NYW Offices, as well as the Acting Chief, National IT LAN Application and Policy Support Team for the Administrative Office of the United States Courts - Office of Defender Services. He performs forensic investigations on all electronic evidence involved in Federal Criminal Cases. He oversees the NYW automation program and is involved in national IT support for the Federal Defender Organization local area networks. He is based out of the Western District of New York, Federal Public Defender’s Office but travels frequently around the country. He is involved with many committees related to forensics, litigation support and automation. Mr. Grant is also a successful computer consultant specializing in computer forensics, cell phone forensics, cell tower/site analysis, system installation and training. He lectured and conducted training programs for many large groups at various companies. He is a graduate of Bryant and Stratton Business Institute with an AS Degree in computer programming. He is also the recipient of many certificates in forensics, specialized computer training and programming. He has extensive knowledge of PCs, cell phones and cell towers/sites. He has been involved in forensic computer examinations, cell phone forensics, cell site analysis and litigation support for many federal cases. Mr. Grant has lectured at a number of national and local conferences on the subject of computer forensic examinations, cell phone forensics, cell site analysis, computer investigations, computer automation and litigation support. EDUCATION • A.A.S. : Bryant & Stratton Business Institute PRE/POST EDUCATIONAL TRAINING • • • • • Computer Programming Course: B.O.C.E.S. Genesee County Computer Crime Seminar: Medaille College Yearly Training in the Areas of Computer Forensics, Computer Automation, and Computer Related Litigation Support AccessData FTK (Forensic Tool Kit) BootCamp Course AccessData PRTK (Password Recovery Tool Kit) BootCamp Course EXHIBIT B Gerald R. Grant Jr. • • CURRICULUM VITAE Page 2 AccessData Windows Forensics Course Certified Access Data Forensic Examiner (ACE) ACADEMIC AND PROFESSIONAL SKILLS / INTERESTS • • • • • • • • • • • • Over 25 years of experience with data extraction / computer forensics Programming skills in multiple computer languages Web page design / development Computer repair / troubleshooting Experience in all aspects of personal computers Extensive knowledge of DOS and all versions of Windows Operating System Extensive knowledge and experience with popular software applications Extensive knowledge of computer hardware and configurations Extensive knowledge with the technical workings of a computer hard drive Extensive knowledge on cell site information and cell phone forensics Spoke at a number of local and national conferences in regard to computer forensics, cell phone forensics, data recovery, and computer file structures. Lectured on numerous technical subjects including DOS and Windows file systems, architecture and the boot process, DOS and Windows examination techniques and procedures, recovery of deleted files, date and time stamp definitions / alterations, recovering formatted disks, the process and problems in making duplicate copies of media, file type identification and the use of file viewing applications during examinations, archived files and compressed disks, data format conversion, and the examination of Windows swap and related files. PROFESSIONAL EXPERIENCE Computer Forensics Investigator, Federal Public Defender’s Office, Western District of New York, 2010 - Current. Provides all computer forensics, cell phone forensics and cell tower/site analysis for the Western District of New York Federal Defender Organization. Also provides all forensic support, as needed, for other FPD offices in the U.S. Provides computer forensics, cell phone forensics, cell tower/site analysis and automation support for the CJA, (Criminal Justice Act), panel of lawyers on Federal Cases. Experienced in the latest computer and cell phone forensic tools including; Forensic Tool Kit (FTK), EnCase, Mobile Phone Examiner, Neutrino Mobile Phone Examiner, Paraben Device Seizure, BitPIM, NetAnalysis, HstEx, Mount Image PRO, Event Log Explorer, Gargoyle Investigator, VMWare, Adroit Photo Forensics and SafeBack. Computer Systems Administrator, Federal Public Defender’s Office, Western District of New York, 1994 - 2010. Provided computer forensics, cell phone forensics, cell tower/site analysis and all automation for the Western District of New York Federal Defender Organization. Involved locally in all factors involving automation equipment as it relates to the offices. Provided computer forensics, cell phone forensics, cell tower/site analysis and automation support for the CJA, (Criminal Justice Act), panel of lawyers on Federal Cases. Acting Chief, National IT LAN Application and Policy Support Team , Office of Defender Services, Federal Public Defender’s Office - Western District of New York, 1999 - 2007. Provided automation and computer forensic support / management for the EXHIBIT B Gerald R. Grant Jr. CURRICULUM VITAE Page 3 entire Federal Defender Organization. Involved nationally in all factors involving automation equipment as it relates to the offices. Provided computer forensics, cell phone forensics, cell tower/site analysis and automation support for the CJA, (Criminal Justice Act), panel of lawyers on Federal Cases Nationally. Set all national automation standards for the entire Federal Defender Program. Spoke at a number of National and local conferences involving forensic, technical and legal subjects related to computers. Computer Consultant, J.R. Computer Consulting, 1990 - Current. Independent Computer Consultant dealing with a large array of computer related problems, configurations and installations. Involved with small to large network configurations and installations involving both Novell and Microsoft products. Primarily involved with computer forensics, cell phone forensics, cell tower/site analysis and data recovery utilizing the latest techniques and software. Corporate Computer Sales, CompuAdd Computers, 1988 - 1990. Involved with Major Corporate Accounts dealing with all factors of computer systems in the Western District of New York. PROFESSIONAL MEMBERSHIPS, HONORS AND AWARDS Monroe County Bar Association: • 1999 Presidents Award for development of the MCBA Web Site Administrative Office if the U.S. Courts - Office of Defender Services • 2005 Recognition for Effort and Support of National E-Mail Project Team • 2007 Recognition for Commitment and Accomplishments of National Work SEMINARS LECTURED AT / OTHER APPEARANCES Date Seminar Topic 09/26/2001 Monroe County Bar Association Computers and Ethics: Security and Privacy Issues 10/30/2001 Federal Public Defender’s Office NYW - Federal Criminal Defense Practice Seminar Computer Enhanced Presentation of Evidence 04/05/2002 Greater Rochester Association of Women Attorneys Computers and Ethics: Security and Privacy Issues 08/12/2002 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 12/06/2002 Federal Public Defender’s Office NYW - Federal Criminal Defense Practice Seminar Update on Courtroom Technology 07/22/2003 New York State Defenders Association Computer Forensics in Child Pornography Cases EXHIBIT B Gerald R. Grant Jr. CURRICULUM VITAE Page 4 Date Seminar Topic 09/22/2003 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 11/13/2003 Western New York Chapter of The Women’s Bar Association Ethics and Technology 11/15/2003 New York State Defenders Association Computers and Ethics: Security and Privacy Issues 06/30/2004 Monroe County Bar Association Obtaining and Working with Electronic Evidence 09/01/2004 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 03/30/2005 Federal Judicial Center Investigators and Paralegal Specialists Seminar Computer Search Warrants: Fourth Amendment Issues and Litigation Strategies 06/22/2005 Administrative Office of the U.S. Courts - ODS Training Branch Trial Advocacy Workshop Introduction to PowerPoint and Trial Director 08/31/2005 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 09/07/2005 Monroe County Bar Association Overview of Computer Forensics 10/21/2005 New York State Court of Claims Legal Ethics & Technology Computer Forensics 04/19/2006 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 04/26/2006 Federal Judicial Center Investigators and Paralegal Specialists Seminar Technology and the Fourth Amendment: Current Issues in Criminal Litigation - Computer Forensics 06/08/2006 Monroe County Bar Association Ethics and the Internet: A Technical View 07/27/2006 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 09/07/2006 Administrative Office of the U.S. Courts - ODS Training Branch Complex Litigation Seminar EXHIBIT B Computer Search Warrants: Fourth Amendment Issues and Litigation Strategies Gerald R. Grant Jr. CURRICULUM VITAE Page 5 Date Seminar Topic 09/13/2006 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 09/21/2006 National Defender Investigator Association Technology and the Fourth Amendment: Current Issues in Criminal Litigation - Search Warrants / Computer Forensics 10/06/2006 Southern Federal Defender Program- ALS - CJA Panel Training Computer Forensics: How to Address Issues in Pornography Cases 02/09/2007 Administrative Office of the U.S. Courts - ODS Training Branch National CJA Winning Strategies Seminar Computer Forensics: Issues in Pornography Cases 04/19/2007 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 05/03/2007 Federal Public Defender’s Office PAE - CJA Panel Training Technology and the Fourth Amendment: Current Issues in Criminal Litigation 05/04/2007 Federal Public Defender’s Office NYW - Federal Criminal Defense Practice Seminar Technology and the Fourth Amendment: Current Issues in Criminal Litigation - Search Warrants / Computer Forensics 06/29/2007 Federal Public Defender’s Office SD/ND - Remote Seminar Computer Forensics / Cell Site Information / Cell Phone Forensics 07/26/2007 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 08/28/2007 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 11/17/2007 New York State Association of Criminal Defense Lawyers Computer Forensics: Technical Issues in Criminal Cases 11/30/2007 Federal Public Defender’s Office NYW - Federal Criminal Defense Practice Seminar Technology and the Fourth Amendment: Current Issues in Criminal Litigation - Cell Site Information / Cell Phone Forensics 01/15/2008 Digital Rochester - Knowledge Upgrade Series v18 EXHIBIT B Getting the Evidence: Computer Forensics Gerald R. Grant Jr. CURRICULUM VITAE Page 6 Date Seminar Topic 02/02/2008 New York State Association of Criminal Defense Lawyers Computer Forensics / Cell Site Information / Cell Phone Forensics 02/11/2008 Rochester Institute of Technology Forensic Investigation, Laws and Technology 04/03/2008 Judge Feldman’s Chambers Visitors from Russia Forensic Investigation, Information and Demonstration 04/23/2008 WXOV AM Radio - New Rochelle, NY - Don’t Worry Murray Show Computer Forensics / Cell Phone Forensics / Cell Site Analysis 06/12/2008 Administrative Office of the U.S. Courts - ODS Training Branch National CJA Winning Strategies Seminar Technology and the Law: Computer Forensics 07/21/2008 New York State Defenders Association Technology Issues In Criminal Defense (Computer and Cell Phone Forensics) 04/06/2009 Monroe County Bar Association Computer Technology - Defending Child Enticement Cases - Social Sites / IM / Forensics 07/30/2009 Judge Feldman’s Chambers Visitors from Russia Forensic Investigation, Information and Demonstration 10/10/2009 Monroe County Public Defender’s Office / New York State Defenders Association / Easton Thompson Kasperek & Shiffrin Technology Based Evidence: How to Find It and Use It to Your Advantage 10/30/2009 New York State Association of Criminal Defense Lawyers Computer Forensics / Cell Site Information / Cell Phone Forensics 11/4/2009 Monroe County Bar Association / Greater Rochester Association for Women Attorneys Cyberstalking and the Potential for Privacy Intrusion the Electronic Way 02/11/2010 Monroe County Public Defender’s Office Technology Based Evidence Practicing In The New Age - Part 1 02/19/2010 Monroe County Public Defender’s Office Technology Based Evidence Practicing In The New Age - Part 2 04/24/2010 New York State Defenders Association - Family Court Practitioners / Adult Representation in Family Court Admissibility of text Messages, EMails, and Social Networking Sites 07/22/2010 Judge Feldman’s Chambers Visitors from Russia EXHIBIT B Forensic Investigation, Information and Demonstration Gerald R. Grant Jr. CURRICULUM VITAE Page 7 Date Seminar Topic 09/23/2010 Administrative Office of the U.S. Courts - ODS Training Branch National Techniques in Electronic Case Management Workshop Introduction to Adobe Acrobat, ISYS Indexer, Lexis/Nexis CaseMap Suite 10/13/2010 Queens County Bar Association CLE Technology Based Evidence Practicing In The New Age Computer Forensics / Cell Phone Forensics / Cell Site Analysis 11/05/2010 Federal Public Defender’s Office NYW - Federal Criminal Defense Practice Seminar eDiscovery - Issues and Solutions for the Modern Case 01/20/2011 Administrative Office of the U.S. Courts - ODS Training Branch Law & Technology Workshop Introduction to PowerPoint and Trial Director 04/07/2011 Federal Public Defender’s Office TXW - El Paso CJA Seminar Investigation Tools “Technology & Litigation Based Evidence” 09/22/2011 Administrative Office of the U.S. Courts - ODS Training Branch National Techniques in Electronic Case Management Workshop Introduction to Adobe Acrobat, ISYS Indexer, Lexis/Nexis CaseMap Suite 10/29/2011 NYSACDL - Annual Fall Syracuse CLE Seminar Overview and Introduction to Electronic Evidence Presentation and Trial Preparation 11/05/2011 Annual El Paso Criminal Law Seminar Investigation Tools “Technology & Litigation Based Evidence” EXHIBIT B

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