Ceglia v. Zuckerberg et al

Filing 241

DECLARATION signed by Alexander H. Southwell re 237 Response in Opposition to Motion,,,, filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Snyder, Orin)

EXHIBIT B

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

1

Description of Relevant Materials

March 3, 2004 email from Paul Ceglia to his attorney
Jim Kole, Esq.

Source File Path

IL170\D\Documents and Settings\Owner\Local Settings\Application
Data\Identities\{520682BF-0796-481A-AAB44E13F899C96E}\Microsoft\Outlook Express\Sent Items.dbx

Folder Containing Item

Privilege Log

Confidential Log

1

Attorney-client
privileged pursuant to
N.Y. C.P.L.R. 4503

Confidential

Confidential

2

Page 1 of signed and dated "Street Fax" contract
IL170\D\Documents and Settings\Owner\Local Settings\Application
between Mark Zuckerberg and Paul Ceglia. Attachment Data\Identities\{520682BF-0796-481A-AAB4to item 1.
4E13F899C96E}\Microsoft\Outlook Express\Sent Items.dbx

3

IL170\D\Documents and Settings\Owner\Local Settings\Application
Data\Identities\{520682BF-0796-481A-AAB44E13F899C96E}\Microsoft\Outlook Express\Sent Items.dbx

March 3, 2004 email from Paul Ceglia to his attorney
Jim Kole, Esq.

2
Attorney-client
privileged pursuant to
N.Y. C.P.L.R. 4503

Confidential

3
Confidential

4
5
6
7
8
9
10
11

12

13

14

Page 2 of signed and dated "Street Fax" contract
between Mark Zuckerberg and Paul Ceglia. Attachment
to item 2.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
Unsigned Microsoft Word version of "Work For Hire"
Contract document.
WPS file containing what appears to be correspondence
between Paul Ceglia and Jeff Kazen dated August 18,
2003; August 19, 2003; August 21, 2003; and August 22,
2003.
WPS file containing what appears to be correspondence
between Paul Ceglia and Jeff Kazen dated August 18,
2003; August 19, 2003; August 21, 2003; and August 22,
2003.
TXT file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated September 1 and
September 2, 2003.

Prepared on 2011-07-27

IL170\D\Documents and Settings\Owner\Local Settings\Application
Data\Identities\{520682BF-0796-481A-AAB44E13F899C96E}\Microsoft\Outlook Express\Sent Items.dbx

4
Confidential

FL03J\(1) PAUL_3_23_11\paul ciglia\work for hire SF template.doc
FL03J\(1) PAUL_3_23_11\paul ciglia\Copy1_work for hire SF
template.doc

5

FL03J\(1) PAUL_3_23_11\paul ciglia\Copy1_XWRL0003.TMP

7

FL03J\(1) PAUL_3_23_11\paul ciglia\Work for Hire ContractMZ.doc

8

FL03J\(1) PAUL_3_23_11\paul ciglia\XWRL0004.TMP
FL03J\(1) PAUL_3_23_11\paul ciglia\Copy1_Work for Hire
ContractMZ.doc

9
10

IL94\SFWebWorkForHireMZ.doc

11

Confidential
6
Confidential
Confidential
Confidential
Confidential
Confidential
Confidential

FL03I\(4) HOTBURN_JUL22_04\emails with mark and jeff\emails with
mark and jeff.rtf.wps

12
Confidential

FL03I\(3) HOTBURN_JUL22_03\emails with mark and jeff\emails with
mark and jeff.rtf.wps

13
Confidential

FL03J\(1) PAUL_3_23_11\paul ciglia\mark email 090103.txt

14

Page 1 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

17

TXT file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated September 1 and
September 2, 2003.
DOC file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated August 28 and August
29, 2003.
DOC file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated August 28 and August
29, 2003.

18

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated August 22, 2003; August 23, 2003;
August 25, 2003; August 27, 2003; August 28, 2003;
August 29, 2003; September 1, 2003; September 2,
2003; September 3, 2003; September 15, 2003;
FL03I\(4) HOTBURN_JUL22_04\emails with mark and jeff\emails with
September 16, 2003; and September 17, 2003.
mark and jeff 091803 incl email list.doc

19

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated August 22, 2003; August 23, 2003;
August 25, 2003; August 27, 2003; August 28, 2003;
August 29, 2003; September 1, 2003; September 2,
2003; September 3, 2003; September 15, 2003;
FL03I\(3) HOTBURN_JUL22_03\emails with mark and jeff\emails with
September 16, 2003; and September 17, 2003.
mark and jeff 091803 incl email list.doc

15

16

Folder Containing Item

Privilege Log

Confidential Log

Confidential

IL94\mark email 090103.txt

15
Confidential

FL03I\(4) HOTBURN_JUL22_04\emails with mark and jeff\mark emails
082903.doc

16
Confidential

FL03I\(3) HOTBURN_JUL22_03\emails with mark and jeff\mark emails
082903.doc

17
Confidential

18
Confidential

19
Confidential

20

21

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated September 22, 2003; September
29, 2003; October 2, 2003; October 7, 2003; October
10, 2003; October 11, 2003; and October 12, 2003.
IL93\emails with mark and jeff 102003.doc
DOC file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated August 28, 2003 and
August 29, 2003.
IL93\mark emails 082903.doc

Prepared on 2011-07-27

20
Confidential

21

Page 2 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

Folder Containing Item

Privilege Log

Confidential Log

Confidential

22

RTF file containing what appears to be correspondence
between Jeff Kazen, Paul Ceglia, and Mark Zuckerberg
dated July 16, 2003; July 20, 2003; July 22, 2003; July
25, 2003; July 28, 2003; July 31, 2003; August 1, 2003;
August 5, 2003; August 7, 2003; August 8, 2003; August
13, 2003; August 15, 2003; August 16, 2003; August 17,
2003; August 18, 2003; and August 21, 2003.
IL93\emails with mark and jeff\emails with mark and jeff 082503.rtf

22
Confidential

24

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
Jeff Kazen, and Paul Ceglia dated August 22, 2003;
August 23, 2003; August 25, 2003; August 27, 2003;
August 26, 2003; August 30, 2003; August 28, 2003;
August 29, 2003; September 1, 2003; September 2,
2003; September 3, 2003; September 15, 2003;
IL93\emails with mark and jeff\emails with mark and jeff 091803 incl
September 17, 2003; and September 16, 2003.
email list.doc
WPS file containing what appears to be correspondence
between Paul Ceglia and Jeff Kazen dated August 18,
2003; August 19, 2003; August 21, 2003; and August 22,
2003.
IL93\emails with mark and jeff\emails with mark and jeff.rtf.wps

25

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated July 29, 2003; August 25, 2003;
August 26, 2003; August 28, 2003; September 22, 2003;
September 27, 2003; September 28, 2003; September
29, 2003; September 30, 2003; October 2, 2003;
October 7, 2003; October 2, 2003; October 10, 2003;
October 11, 2003; October 12, 2003; October 13, 2003;
October 14, 2003; October 17, 2003; and October 20, FL03I\(4) HOTBURN_JUL22_04\emails with mark and jeff\emails with
2003.
mark and jeff 102003.doc

23

23
Confidential

24
Confidential

Prepared on 2011-07-27

25

Page 3 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

Folder Containing Item

Privilege Log

Confidential Log

Confidential

26

27

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated July 29, 2003; August 25, 2003;
August 26, 2003; August 28, 2003; September 22, 2003;
September 27, 2003; September 28, 2003; September
29, 2003; September 30, 2003; October 2, 2003;
October 7, 2003; October 10, 2003; October 11, 2003;
October 12, 2003; October 13, 2003; October 14, 2003; FL03I\(3) HOTBURN_JUL22_03\emails with mark and jeff\emails with
October 17, 2003; and October 20, 2003.
mark and jeff 102003.doc
DOC file containing what appears to be correspondence
between Mark Zuckerberg and Paul Ceglia dated July
30, 2003; September 2, 2003; November 22, 2003;
November 28, 2003; November 29, 2003; and
November 30, 2003.
FL03I\(4) HOTBURN_JUL22_04\Mark harvard emails up to Dec.doc

26
Confidential

27
Confidential

28

29

DOC file containing what appears to be correspondence
between Mark Zuckerberg and Paul Ceglia dated
January 1, 2004; January 5, 2004; January 6, 2004;
January 13, 2004; January 16, 2004; February 2, 2004;
February 3, 2004; February 4, 2004; February 6, 2004;
and February 7, 2004.
FL03I\(4) HOTBURN_JUL22_04\mark feb emails.doc
DOC file containing what appears to be correspondence
between Mark Zuckerberg and Paul Ceglia dated April 6,
2004 and July 22, 2004.
IL93\mark harvard site\Mark emails july04.doc

28
Confidential
29
Confidential

30

31

32

DOC file containing what appears to be correspondence
between Mark Zuckerberg and Paul Ceglia dated
January 1, 2004; January 5, 2004; January 6, 2004;
January 13, 2004; January 16, 2004; February 2, 2004;
February 3, 2004; February 4, 2004; February 6, 2004;
and February 7, 2004.
IL93\mark harvard site\mark feb emails.doc
DOC file containing what appears to be correspondence
between Mark Zuckerberg and Paul Ceglia dated July
30, 2003; September 2, 2003; November 22, 2003;
November 28, 2003; November 29, 2003; and
November 30, 2003.
IL93\mark harvard site\Mark harvard emails up to Dec.doc
DOC file containing what appears to be correspondence
between Mark Zuckerberg and Paul Ceglia dated April 6,
2004 and July 22, 2004.
FL03I\(4) HOTBURN_JUL22_04\Mark emails july04.doc

Prepared on 2011-07-27

30
Confidential

31
Confidential
32

Page 4 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

33

34

Description of Relevant Materials

TXT file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated September 1 and
September 2, 2003.
TXT file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated September 1 and
September 2, 2003.

Source File Path

Folder Containing Item

Privilege Log

Confidential Log

Confidential
FL02\D\Documents and Settings\Owner\Desktop\New Folder\mark
email 090103.txt

33
Confidential

FL02\D\Documents and Settings\Owner\Desktop\New
Folder2\sptimesadLEGAL\mark email 090103.txt

34
Confidential

35

36

RTF file containing what appears to be correspondence
between Mark Zuckerberg, Jeff Kazen, and Paul Ceglia
dated July 16, 2003; July 18, 2003; July 22, 2003; July
23, 2003; July 25, 2003; July 28, 2003; July 30, 2003;
July 31, 2003; August 1, 2003; August 5, 2003; August 7,
2003; August 8, 2003; August 13, 2003; August 15,
2003; August 16, 2003; August 17, 2003; August 18,
2003; and August 21, 2003.
WPS file containing what appears to be correspondence
between Paul Ceglia and Jeff Kazen dated August 18,
2003; August 19, 2003; August 21, 2003; and August 22,
2003.

FL02\D\Documents and Settings\Owner\Desktop\New Folder2\emails
w mark and jeff\emails with mark and jeff\emails with mark and jeff
082503.rtf

35
Confidential

FL02\D\Documents and Settings\Owner\Desktop\New Folder2\emails
w mark and jeff\emails with mark and jeff\emails with mark and
jeff.rtf.wps

36
Confidential

37

38

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated July 29, 2003; August 25, 2003;
August 26, 2003; August 28, 2003; September 22, 2003;
September 27, 2003; September 28, 2003; September
29, 2003; September 30, 2003; October 2, 2003;
October 7, 2003; October 10, 2003; October 11, 2003;
October 12, 2003; October 13, 2003; October 14, 2003;
October 17, 2003; and October 20, 2003.
DOC file containing what appears to be correspondence
between Mark Zuckerberg and
[e-mail] dated August 28 and August
29, 2003.

Prepared on 2011-07-27

FL02\D\Documents and Settings\Owner\Desktop\New Folder2\emails
w mark and jeff\emails with mark and jeff\emails with mark and jeff
102003.doc

37
Confidential

FL02\D\Documents and Settings\Owner\Desktop\New Folder2\emails
w mark and jeff\emails with mark and jeff\mark emails 082903.doc

38

Page 5 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

Folder Containing Item

Privilege Log

Confidential Log

Confidential

46

DOC file containing what appears to be correspondence
between Mark Zuckerberg, [e-mail],
and Jeff Kazen dated August 22, 2003; August 23, 2003;
August 25, 2003; August 27, 2003; August 28, 2003;
August 29, 2003; September 1, 2003; September 2,
2003; September 3, 2003; September 15, 2003;
September 16, 2003; and September 17, 2003.
DOC file that appears to test the results of modifying a
Microsoft Word document.
DOC file that appears to test the results of modifying a
Microsoft Word document.
DOC file that appears to test the results of modifying a
Microsoft Word document.
DOC file that appears to test the results of modifying a
Microsoft Word document.
DOC file that appears to test the results of modifying a
Microsoft Word document.
DOC file that appears to test the results of modifying a
Microsoft Word document.
Partially recoverable copy of page 2 of signed and dated
Street Fax contract.

47

Metadata of overwritten deleted file with the same
name as items 15, 33, and 34.

48

Metadata of overwritten deleted file with the same
name as items 16, 17, 21, and 38.

49

Metadata of overwritten deleted file with the same
name as items 12, 13, 24, and 36.

50

Metadata of overwritten deleted file with the same
name as items 22 and 35.

51

Metadata of overwritten deleted file with the same
name as items 22 and 35.

52

Metadata of overwritten deleted file with the same
name as items 16, 17, 21, and 38.

39
40
41
42
43
44
45

Prepared on 2011-07-27

FL02\D\Documents and Settings\Owner\Desktop\New Folder2\emails
w mark and jeff\emails with mark and jeff\emails with mark and jeff
091803 incl email list.doc
FL03I\(4) HOTBURN_JUL22_04\worktocopyinto\text to copy over to
the test doc.doc
FL03I\(4) HOTBURN_JUL22_04\work to pasteoutof\doc to paste
into.doc
FL03I\(4) HOTBURN_JUL22_04\beginning folder\folderholdsdoc\test
doc2.doc
FL03I\(4) HOTBURN_JUL22_04\beginning folder\folderholdsdoc\test
doc.doc
FL03I\(3) HOTBURN_JUL22_03\beginning folder\folderholdsdoc\test
doc4.doc
FL03I\(2) HOTBURN_JUL22_02\beginning folder\folderholdsdoc\test
doc3.doc

39
Confidential
40
Confidential
41
Confidential
42
Confidential
43
Confidential
44
Confidential
45
Confidential

IL170\D\Recovered Folders\Scan0002.tif

IL94\mark email 090103.txt

IL93\mark emails 082903.doc

IL93\emails with mark and jeff.rtf.wps

IL93\emails with mark and jeff 082503.rtf

IL93\emails with mark and jeff 082503.rtf

IL93\mark emails 082903.doc

46
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Page 6 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

53

Metadata of overwritten deleted file with the same
name as items 16, 17, 21, and 38.

54

Metadata of overwritten deleted file with the same
name as items 20, 25, 26, and 37.

55

Metadata of overwritten deleted file with the same
name as items 29 and 32.

56

Metadata of overwritten deleted file with the same
name as items 29 and 32.

57

Metadata of overwritten deleted file with the same
name as items 27 and 31.

58

Metadata of overwritten deleted file with the same
name as items 27 and 31.

59

Metadata of overwritten deleted file with the same
name as items 27 and 31.

60

Metadata of overwritten deleted file with the same
name as items 20, 25, 26, and 37.

61

Metadata of overwritten deleted file with the same
name as items 18, 19, 23, and 39.

62

Metadata of overwritten deleted file with the same
name as items 18, 19, 23, and 39.

63

Metadata of overwritten deleted file with the same
name as items 20, 25, 26, and 37.

64

Metadata of overwritten deleted file with the same
name as items 20, 25, 26, and 37.

65

Metadata of overwritten deleted file with the same
name as items 27 and 31.

66

Metadata of overwritten deleted file with the same
name as items 27 and 31.

Prepared on 2011-07-27

Source File Path

IL93\mark emails 082903.doc

IL93\emails with mark and jeff 102003.doc

IL93\Mark emails july04.doc

IL93\Mark emails july04.doc

IL93\Mark harvard emails up to Dec.doc

IL93\Mark harvard emails up to Dec.doc

IL93\Mark harvard emails up to Dec.doc

IL93\emails with mark and jeff 102003.doc

IL93\emails with mark and jeff 091803 incl email list.doc

IL93\emails with mark and jeff 091803 incl email list.doc

IL93\emails with mark and jeff 102003.doc

IL93\emails with mark and jeff 102003.doc

IL93\Mark harvard emails up to Dec.doc

IL93\Mark harvard emails up to Dec.doc

Folder Containing Item

See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".

Privilege Log

Confidential Log

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Page 7 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

67

Metadata of overwritten deleted file with the same
name as items 28 and 30.

68

Metadata of overwritten deleted file with the same
name as items 28 and 30.

69

Metadata of overwritten deleted file with the same
name as items 27 and 31.

70

Metadata of overwritten deleted file with the same
name as items 29 and 32.

71

Metadata of overwritten deleted file with the same
name as items 29 and 32.

72

Metadata of unrecoverable deleted file with the same
name and contemporaneous dating as item 2.

73

Metadata of overwritten deleted file with the same
name and contemporaneous dating as item 2.

Source File Path

IL93\mark feb emails.doc

IL93\mark feb emails.doc

IL93\Mark harvard emails up to Dec.doc

IL93\Mark emails july04.doc

IL93\Mark emails july04.doc

IL170\D\Recovered Folders\Scan0001.tif

IL170\D\Recovered Folders\Scan0001.tif

74

Metadata of unrecoverable file.

75

Metadata of overwritten deleted file with the same
name as item 74.

76

Link file to potentially relevant document on removable
media.
See link file spreadsheet "Link Files.xlsx" in folder named "76-91".

77

Link file to potentially relevant document on removable
media.
See link file spreadsheet "Link Files.xlsx" in folder named "76-91".

78

Link file to potentially relevant document on removable
media.
See link file spreadsheet "Link Files.xlsx" in folder named "76-91".

79

Link file to potentially relevant document on removable
media.
See link file spreadsheet "Link Files.xlsx" in folder named "76-91".

80

Link file to potentially relevant document on removable
media.
See link file spreadsheet "Link Files.xlsx" in folder named "76-91".

Prepared on 2011-07-27

NY02\D\Recovered Folders\My Scans\2009-09 (Sep)\scan0001.jpg

NY02\D\Recovered Folders\My Scans\2009-09 (Sep)\scan0001.jpg

Folder Containing Item

See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See metadata spreadsheet
"Metadata Deleted Files.xlsx" in
folder named "47-75".
See link file spreadsheet "Link
Files.xlsx" in folder named "7691".
See link file spreadsheet "Link
Files.xlsx" in folder named "7691".
See link file spreadsheet "Link
Files.xlsx" in folder named "7691".
See link file spreadsheet "Link
Files.xlsx" in folder named "7691".
See link file spreadsheet "Link
Files.xlsx" in folder named "7691".

Privilege Log

Confidential Log

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Page 8 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

81

Link file to potentially relevant document on removable
media.

82

Link file to potentially relevant document on removable
media.

83

Link file to potentially relevant document on removable
media.

84

Link file to potentially relevant document on removable
media.

85

Link file to potentially relevant document on removable
media.

86

Link file to potentially relevant document on removable
media.

87

Link file to potentially relevant document on removable
media.

88

Link file to potentially relevant document on removable
media.

89

Link file to potentially relevant document on removable
media.

90

Link file to potentially relevant document on removable
media.

91

Link file to scan0001.jpg file referenced in item 74.

92

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers
that were not disclosed to Stroz Friedberg.

93

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers
that were not disclosed to Stroz Friedberg.

Prepared on 2011-07-27

Source File Path

Folder Containing Item

See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See link file spreadsheet "Link
Files.xlsx" in folder named "76See link file spreadsheet "Link Files.xlsx" in folder named "76-91".
91".
See spreadsheet "Registry
References to Mass Storage
See spreadsheet "Registry References to Mass Storage Devices.xlsx" in Devices.xlsx" in folder named
folder named "92-112".
"92-112".
See spreadsheet "Registry
References to Mass Storage
See spreadsheet "Registry References to Mass Storage Devices.xlsx" in Devices.xlsx" in folder named
folder named "92-112".
"92-112".

Privilege Log

Confidential Log

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Page 9 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

94

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
that were not disclosed to Stroz Friedberg.
folder named "92-112".

95

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
that were not disclosed to Stroz Friedberg.
folder named "92-112".

96

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
that were not disclosed to Stroz Friedberg.
folder named "92-112".

97

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
that were not disclosed to Stroz Friedberg.
folder named "92-112".

98

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
that were not disclosed to Stroz Friedberg.
folder named "92-112".

99

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
that were not disclosed to Stroz Friedberg.
folder named "92-112".

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
100 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
101 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
102 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
103 that were not disclosed to Stroz Friedberg.
folder named "92-112".

Prepared on 2011-07-27

Folder Containing Item

See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".

Privilege Log

Confidential Log

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Page 10 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
104 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
105 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
106 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
107 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
108 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
109 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
110 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
111 that were not disclosed to Stroz Friedberg.
folder named "92-112".
Registry reference to USB Mass Storage device
identified as having been attached to Ceglia computers See spreadsheet "Registry References to Mass Storage Devices.xlsx" in
112 that were not disclosed to Stroz Friedberg.
folder named "92-112".

113 EnCase Forensic 6.17 Disk View of IL93.

114 Excerpt from System Event Log from IL170.

Prepared on 2011-07-27

See spreadsheet "IL93 Disk View.xlsx" in folder named "113".

See spreadsheet "IL170 System Event Log.xlsx" in folder named "114".

Folder Containing Item

See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "Registry
References to Mass Storage
Devices.xlsx" in folder named
"92-112".
See spreadsheet "IL93 Disk
View.xlsx" in folder named
"113".
See spreadsheet "IL170 System
Event Log.xlsx" in folder named
"114".

Privilege Log

Confidential Log

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Confidential

Page 11 of 12

Gibson Dunn (Facebook)
July 1, 2011 Exepedited Discovery Order- Presummed Relevant Materials/Privilege/Confidential Log - "Confidential Pursuant to
Protective Order"
#

Description of Relevant Materials

Source File Path

Folder Containing Item

Privilege Log

Confidential Log

Confidential

115 Entry from System Event Log from IL170.

See spreadsheet "System Event Log Entry From IL170.xlsx" in folder
named "115".

See spreadsheet "System Event
Log Entry From IL170.xlsx" in
folder named "115".

See spreadsheet "System Restore Points From IL170.xlsx" in folder
named "116-119".

See spreadsheet "System
Restore Points From IL170.xlsx"
in folder named "116-119".

See spreadsheet "System Restore Points From IL170.xlsx" in folder
named "116-119".

See spreadsheet "System
Restore Points From IL170.xlsx"
in folder named "116-119".

See spreadsheet "System Restore Points From IL170.xlsx" in folder
named "116-119".

See spreadsheet "System
Restore Points From IL170.xlsx"
in folder named "116-119".

Confidential

116 Metadata of System Restore Points from IL170.

Confidential

117 Metadata of System Restore Points from IL170.

Confidential

118 Metadata of System Restore Points from IL170.

Confidential

119 Metadata of System Restore Points from IL170.
Forensic artifacts regarding disk location of contract
120 drafts on IL94.

Prepared on 2011-07-27

See spreadsheet "System
See spreadsheet "System Restore Points From IL170.xlsx" in folder
Restore Points From IL170.xlsx"
named "116-119".
in folder named "116-119".
See spreadsheet "Contract Disk
See spreadsheet "Contract Disk Locations on IL94.xlsx" in folder named Locations on IL94.xlsx" in folder
"120".
named "120".

Confidential

Page 12 of 12