Ceglia v. Zuckerberg et al

Filing 296

DECLARATION signed by Alexander H. Southwell re 294 Fifth MOTION to Compel and For Other Relief filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M)(Snyder, Orin)

EXHIBIT C

Ex. A

#

334

Description of Relevant Materials

Privilege Claim, if Any

December 4, 2010 email from
[e-mail] to
[e-mail] with
Attorney client
subject "Re: letter" discussing, among communication other things, a hushmail account.
Privileged.

360

First attachment to February 24, 2011
email from [e-mail] to
[e-mail] with subject
"Summaries". Document concerning
Paul Argentieri's summary of Paul
Ceglia's action.
February 15, 2007 email from
[e-mail] to
[e-mail] and CC'ed to
[e-mail] with subject
"FW: Paul D. Ceglia".
March 17, 2011 email from
[e-mail] to
[e-mail] with
subject "file for DLA" with two files
attached.

373

December 12, 2010 email from
[e-mail] to
[e-mail] and
[e-mail] and CC'ed Attorney client
to [e-mail] with subject communication "FW: Zuck signature".
Privileged.

379

April 19, 2011 email from
[e-mail] to
[e-mail] with subject
"Fwd: Follow-up" containing emails
with [e-mail],
[e-mail],
[e-mail], and
[e-mail] with
attachments.

337

348

Attorney Work Product,
Case Analysis provided to
client.

Attorney client
communication Privileged.
Attorney client
communication with
Attorney's agent Privileged.

Attorney client
communication Privileged.

400

December 2, 2010 email from
[e-mail] to
[e-mail] and
[e-mail] and Attorney client
CC'ed to [e-mail] communication with subject "RE: Zuck signature".
Privileged.

402

December 8, 2010 email from
[e-mail] to
[e-mail] with
subject "Re: Zuck signature".
December 8, 2010 email from
[e-mail] to
[e-mail] with subject
"RE: Zuck signature".

403

December 17, 2010 email from
[e-mail] to
Attorney client
[e-mail] with communication subject "Re: Zuck signature".
Privileged.

405

December 2, 2010 email from
[e-mail] to
[e-mail] and CC'ed
to [e-mail] and
Attorney client
[e-mail] with communication subject "Zuck signature".
Privileged.

401

Attorney client
communication Privileged.
Attorney client
communication Privileged.

Ex. B

From: Dean Boland
Sent: Friday, February 10, 2012 10:58:41 AM (UTC-05:00) Eastern Time (US & Canada)
To: Southwell, Alexander; Paul Argentieri
Subject: Supplemental Declaration Request from Defendants regarding Mr. Holmberg

Alex:
Mr. Ceglia has no personal knowledge regarding what files Jason Holmberg has retained or is retaining
regarding this matter. Moreover, those files have been produced to Stroz Friedberg after your
communication. Mr. Ceglia could not produce a declaration "from personal knowledge" as declarations appear
to require, regarding this issue. If you are seeking a declaration that is not from Mr. Ceglia's personal
knowledge, i.e. restates hearsay he has been provided about Mr. Holmberg's file retention, please advise and we
will consider it.
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.

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