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)

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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

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