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 - Motion for TRO

Dean Boland <[e-mail]>

Motion for TRO
1 message
Dean Boland <[e-mail]>
Wed, Nov 23, 2011 at 10:13 PM
To: Oren Snyder <[e-mail]>, Alexander Southwell
<[e-mail]>, Paul Argentieri <[e-mail]>, lsimpson
<[e-mail]>, [e-mail]
Bcc: Paul Ceglia <[e-mail]>
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
[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 L
https://mail.google.com/mail/?ui=2&ik=b614a0d4c7&view=pt&q=parmet&qs=true&search=query&th=13…

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