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)

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11/25/11 Gmail - Motion for TRO Dean Boland <deanboland@gmail.com> Motion for TRO 1 message Dean Boland <dean@bolandlegal.com> Wed, Nov 23, 2011 at 10:13 PM To: Oren Snyder <osnyder@gibsondunn.com>, Alexander Southwell <asouthwell@gibsondunn.com>, Paul Argentieri <paul.argentieri@gmail.com>, lsimpson <lsimpson@orrick.com>, mcooper@orrick.com Bcc: Paul Ceglia <paulceglia@gmail.com> To All: This correspondence is an attempt to resolve the issue of preserving the forensic copies of the computers in the ConnectU case without the need of additional motion practice. If satisfactory steps are taken and communicated to me in writing no later than Friday, November 25, 2011 at noon, insuring the preservation of that evidence until further order of THIS court, there may well be no need for Plaintiff to file a motion for a TRO. If there is no sufficient response by that time detailing what steps were taken by Defendants or Defendant's counsel to preserve that evidence, Plaintiff will be forced to seek the court's intervention to preserve that evidence. It is my hope that further motions before the court and a request for an expedited hearing on this issue will not be necessary. I look forward to your response that provides sufficient assurance that evidence in the possession of Parmet and Associates, Defendants from the ConnectU case and any other as yet undisclosed parties, will be preserved until further order of the court in the Western District of New York. Dean Boland. -Dean Boland Owner/Member Boland Legal, LLC 18123 Sloane Avenue Lakewood, Ohio 44107 216.236.8080 ph 866.455.1267 fax dean@bolandlegal.com 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 L https://mail.google.com/mail/?ui=2&ik=b614a0d4c7&view=pt&q=parmet&qs=true&search=query&th=13… 1/2

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