Ceglia v. Zuckerberg et al

Filing 225

DECLARATION signed by Paul Ceglia 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, 224 Memorandum in Support,, filed by Paul D. Ceglia. (Boland, Dean)

TINITED STA|ES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
PAUL D'

CEGLIA'

civlActionNo.:1:10-cv-00569-R.rA

Plaintiff'

DECLARATT.N

oF pnul cecr-r.t rN supponr

V.

or

MOTION TO PROHIBIT
DEFENDANTS' RELTANCE ON

MARK ELLIOT ZUCKERBERG, Individually, and
FACEBOOK,INC.
Defendants.

PAUL CEGLIA, submits this declaration and hereby declares under penalty of perjury
and pursuant to 28 U.S.C

. 1746 and under the laws of the United

States that the

following is true

and correct:

1.

I make this declaration upon personal knowledge.

2.

I am the Plaintiff in this matter.

3.

Included with the Amended Complaint were copies of the text and header information of
emails I exchanged with Mr. Zuckerberg. Doc. No. 39.

4.

I copied the text

and header information from emails that were stored in my MSN webmail

account.

5.

I copied this text and header information in2003 and2004.

6.

MSN webmail routinely deleted email content to maintain user account sizes.

7.

During and just after

I

discontinued regular email communication with Mr. Zuckerberg, I

copied the text and header information from various emails between us and pasted that
content into a Microsoft Word document.

8.

I saved those files to floppy disks.

9.

Those emails include various discussions about the terms and effect of the Facebook Contract that was attached as an exhibit to the original complaint.

10.

Those emails also include discussions between myself and Mr. Zuckerberg where we ex-

I

panded the concepts of the Facebook's original idea.
1

1.

In those emails it was clearly established that Mark was to use the search engine I had developed to quickly implement start up of Facebook.

12.

Shortly after the filing of the amended complaint, I provided those floppy disks containing
the Word documents with the contents of the email exchanges to computer forensics expert
Jerry Grant.

I hereby

and hereby declare under penalty of perjury and pursuant to 28 U.S.C. 1746 and

under the laws of the United States that the following is true and correct:

DAIED:

November17,20Tl