Ceglia v. Zuckerberg et al

Filing 310

RESPONSE in Opposition re 294 Fifth MOTION to Compel and For Other Relief filed by Paul D. Ceglia. (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)(Boland, Dean)

Dean Boland <[e-mail]>

Recent letter regarding claimed non-compliance
Dean Boland <[e-mail]>
Fri, Feb 17, 2012 at 10:19 PM
To: Alexander Southwell <[e-mail]>, Paul Argentieri <[e-mail]>
Bcc: Paul Ceglia <[e-mail]>
Alex:
I am working on a response to your complaints about our privilege designations. I will modify those privilege claims as
appropriate following my review of those items and the applicable case law. I will have this response to you next week.
Following your receipt of that information, I suggest a phone call to resolve any lingering matters more efficiently than the back
and forth emails.
I am available most of next week to schedule that call. Please provide two good dates and times after Wednesday to discuss.
This communication is obviously part of my duty to continue to meet and confer to resolve our issues which we are doing in
good faith at this point.
I appreciate the urgency of your demands to get responses to you as it reflects your sincere interest in complying with the
court's order about the 16(b) conference and getting prepared for trial. Now that a trial in this matter is a certainty, it has finally
created an environment where we can both pull in the same direction, i.e. reasonable discovery and then a trial. I don't know
what your experience is, but I find it's always good to actually try cases on a regular basis to keep those skills sharp, get out of
the office slogging away with paper and such. Anyhow, please review the proposed ESI protocol and preservation letter and
give me a date and time next week you would be available for a call about that.
Have a great weekend. Talk to you soon.
Dean.
-Dean Boland
Owner/Member
Boland Legal, LLC
18123 Sloane Avenue
Lakewood, Ohio 44107
216.236.8080 ph
866.455.1267 fax
[e-mail]

EXHIBIT D

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.