Ceglia v. Zuckerberg et al

Filing 279

REPLY to Response to Motion re 231 MOTION for Temporary Restraining Order Notice of Motion MOTION for Sanctions Notice of Motion filed by Paul D. Ceglia. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Certificate of Service)(Boland, Dean)

Dean Boland <[e-mail]>

Resolution
Dean Boland <[e-mail]>
Tue, Dec 27, 2011 at 2:28 PM
To: Alexander Southwell <[e-mail]>, Paul Argentieri
<[e-mail]>
Bcc: Paul Ceglia <[e-mail]>
Alex:
I am writing to you to offer a resolution of the pending motion for sanctions for fraud against
yourself, Mr. Snyder, The Orrick Law Firm and your clients.
My client has authorized me to offer that if you and your clients agree to submit a forensically
sound copy of all the copies of the computers currently in the possession of Parmet and
Associates to the court, the motion for sanctions for the fraud already committed will be
withdrawn.
Please advise on this offer to attempt to streamline the issues of this case and remove an
item from the judge's docket as well.
Dean
-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 C

Dean Boland <[e-mail]>

Resolution
Southwell, Alexander <[e-mail]>
Wed, Dec 28, 2011 at 4:09 PM
To: Dean Boland <[e-mail]>, Paul Argentieri <[e-mail]>
Cc: "Snyder, Orin" <[e-mail]>

Mr.$Boland:
$
Once$again,$your$request$is$at$odds$with$the$expedited$discovery$orders.$$As$you$certainly
know,$and$as$we$repeatedly$have$communicated,$there$is$no$basis$for$your$request$for
access$to$“all$the$copies$of$the$computers$currently$in$the$possession$of$Parmet$and
Associates”$or$your$request$that$copies$of$these$assets$be$submitted$to$the$Court.$$You
are$not$entitled$to$the$assets$and$we$reject$your$“offer”$of$a$purported$“resolution.”$$Your
motion$for$sanctions$is$absolutely$baseless$and$vexatious.$$If$you$wish$to$reduce$the
burden$on$the$Court,$you$should$remove$the$“item”$from$the$Judge’s$docket$by
withdrawing$your$frivolous$motion.$
Alex
$
From: Dean Boland [mailto:[e-mail]]
Sent: Tuesday, December 27, 2011 2:29 PM
To: Southwell, Alexander; Paul Argentieri
Subject: Resolution
[Quoted text hidden]

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EXHIBIT C