Ceglia v. Zuckerberg et al

Filing 263

REPLY to Response to Motion re 189 MOTION for Sanctions Memorandum of Law in Support of Motion for Sanctions for Spoliation by Defendants, 188 MOTION for Sanctions Notice of Motion for Sanctions for Spoliation of Evidence by Defendants filed by Paul 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)(Boland, Dean)

July 14, 2011, Partial record of light exposure suffered by Facebook Contract

14:55ish Contract back under bright light
15:13 Bright light off
15:22:25 Tytel turns on bright light again over docs
15:32:19 Lights out in room but bright light over docs still on
15:40:03 Bright light out, room lights back on and Tytel off screen
16:05:21 Blue light on
16:10 Blue light out
16:19:38 Bright light is on again over doc
16:27:50 Bright light off
16:29:27 Uv placed directly on contract
16:39:49 Bright light on and then off
16:42:31 Bright UV light laying directly on contract
16:45:31 UV flare when he takes the UV light off contract
16:46:01 UV light back on now this time it is propped up and not laying directly on
contract
16:49:31 UV light off
16:51:11 Blue light on again
15:51:37 Blue light off
16:53:43 Blue light back on contract
16:54:00 Blue light off
17:00:48 UV light back on
17:02:15 UV light off

EXHIBIT F

17:02:40 UV light on
17:04:01 UV light off
17:04:41 UV light on
17:05 UV light
17:05 Blue light on
17:06:48 demonstrates that one side is exposed to UV and not the other 8 hours
after testing began
17:15ish Bright UV light on again
17:19:17 Bright UV light off
17:19:21 Blue light on
17:20:30 Blue light off and Tytel takes his tie of
17:27:03 Blue light on
17:37:21 Blue light off
17:38:06 Blue light on
17:41:06 Blue light off
17:58:50 Blue light on
17:59:22 UV light on, TNG Tytel
18:00:01 UV light off
18:02:22 Blue light on
18:02:57 Blue light off
18:04:17 Zontini guy uses Hand held UV light and uses welders glasses to protect
his eyes at the same time
18:04:35 Tytel then uses the light and the goggles
18:06:31 UV light on and off

EXHIBIT F

18:07:12 Blue light on
18:09:28 Blue light off
18:09:37 UV light on, Tytel using goggles and still no gloves
18:10:32 Uv light off
18:17:07 Blue light on
18:19:09 Bright UV light on again
18:20:08 UV light off
18:23:34-18:26:05 Blue light back on and Tytel wearing goggles
18:26:09 UV bright light back on
18:26:17 Zontini drops off the box of gloves next to Tytel signaling him to wear them
18:27:53 Tytel comes back over and grabs gloves and puts them on
17:51:16 to 18:27:53 Tytel does not have gloves on and touches contract at least 30
times, Romano touches at least 4 times
18:29:07 UVbright light back on
18:29:47 UVbright light off
18:29:51 Blue light on
18:30:04 Blue light off
18:30:21 UV bright light on
18:32:10 UV bright light off
18:34:20 UV bright light on
18:35:34 UV bright light off
18:35:44 Blue light on
18:36:04 UV bright light on
18:37:22 UV bright light and blue light off

EXHIBIT F

18:42:12 UV bright light on
18:42:36 UV bright light is off and Blue light back on
18:43:28 Blue light off
18:43:42 UV bright light on
18:43:55 UV bright light off
18:44:35 Blue light on
18:44:52 Blue light off
18:45:15 Blue light on
18:46:14 Blue light off
18:46:15 UV bright light on
18:47:16 UV bright taken away from paper and turned off
18:47:54 Bright UV light on
18:52:06 Room light back on

EXHIBIT F