Ceglia v. Zuckerberg et al

Filing 232

MEMORANDUM IN SUPPORT re 231 MOTION for Temporary Restraining Order Notice of Motion MOTION for Sanctions Notice of Motion byPaul D. Ceglia. (Attachments: # 1 Certificate of Service, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M)(Boland, Dean)

11/25/11

Gmail - Steps taken to preserve evidence

Dean Boland <[e-mail]>

Steps taken to preserve evidence
1 message
Dean Boland <[e-mail]>
Wed, Nov 23, 2011 at 6:09 PM
To: Alexander Southwell <[e-mail]>, Oren Snyder
<[e-mail]>, lsimpson <[e-mail]>, [e-mail]
To All:
As of approximately an hour ago, all of you have been informed in detail, by email, of the
need to take all necessary steps to preserve the evidence currently in the possession of
Parmet and Associates related to the ConnectU litigation against your clients, Mark
Zuckerberg and Facebook.
I anticipate a response by no later than Friday at noon, given the holiday tomorrow, of the
steps you have taken to preserve the evidence. Despite the lack of a need for a litigation
hold to trigger a duty of a lawyer to preserve evidence, a litigation hold letter was in fact sent
to and its receipt acknowledged by Ms. Simpson early on in this litigation. It is Plaintiff's
expectation that you all intend to honor that duty and all other duties to preserve evidence in
this case.
Please advise.
Dean Boland.
-Dean Boland
Owner/Member
Boland Legal, LLC
18123 Sloane Avenue
Lakewood, Ohio 44107
216.236.8080 ph
866.455.1267 fax
[e-mail]
Please note, I typically only review my emails once daily. If there is something urgent in any
email, please do not hesitate to contact my office at 216-236-8080.

EXHIBIT J, PAGE 1
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