Ceglia v. Zuckerberg et al
Filing
381
Sixth MOTION to Compel And For Other Relief by Facebook, Inc., Mark Elliot Zuckerberg.(Snyder, Orin)
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
-----------------------------------PAUL D. CEGLIA,
Plaintiff,
v.
MARK ELLIOT ZUCKERBERG and
FACEBOOK, INC.,
Defendants.
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NOTICE OF DEFENDANTS’
SIXTH MOTION TO COMPEL
AND FOR OTHER RELIEF
Civil Action No. 1:10-cv-00569RJA
PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law, the
undersigned move this Court to compel Plaintiff to produce immediately the Kasowitz Letter, as
described in the accompanying Memorandum of Law, and all attachments and/or embedded
images to Defendants. Alternatively, the undersigned move this Court to compel Plaintiff to
produce immediately the Kasowitz Letter (and all attachments to the Letter) for in camera
inspection and file with the Court evidentiary support justifying his privilege claims with a copy
of any such filing served on Defendants.
PLEASE TAKE FURTHER NOTICE that, pursuant to Local Civil Rule of Procedure
7 of this Court, Defendants request oral argument and state their intention to file and serve reply
papers.
Dated:
New York, New York
May 24, 2012
Respectfully submitted,
Thomas H. Dupree, Jr.
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, NW
Washington, DC 20036
(202) 955-8500
/s/ Orin Snyder
Orin Snyder
Alexander H. Southwell
GIBSON, DUNN & CRUTCHER LLP
200 Park Avenue, 47th Floor
New York, NY 10166-0193
(212) 351-4000
Terrance P. Flynn
HARRIS BEACH PLLC
726 Exchange Street
Suite 1000
Buffalo, NY 14210
(716) 200-5120
Attorneys for Defendants Mark Zuckerberg and Facebook, Inc.
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