Ceglia v. Zuckerberg et al

Filing 396

MOTION for Discovery Notice of Motion by Paul D. Ceglia.(Boland, Dean)

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK PAUL D. CEGLIA, Civil Action No. : 1:10-cv-00569-RJA Plaintiff, v. NOTICE OF MOTION FOR DISCOVERY REGARDING HARVARD EMAILS MARK ELLIOT ZUCKERBERG, Individually, and FACEBOOK, INC. Defendants. PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law, Mr. Ceglia will move this Court, at a date and time to be set by the Court, for an order: 1. An order from this court authorizing a subpoena to be issued to Harvard University for all backup tapes of the Harvard email server from 2003-2004 containing or potentially containing the email account of Defendant Zuckerberg. 2. An order authorizing Plaintiff's computer forensics expert to acquire all native format email messages from Defendant Zuckerberg's computers used during 2003-2004 forensic copies of which are currently in the possession of Parmet and Associates. Pursuant to Local Civil Rule of Procedure 7 of this Court, Plaintiff requests an oral argument and states his intention to file and serve a reply to Defendants’ response to this motion. 1 Respectfully submitted, /s/Dean Boland Paul A. Argentieri 188 Main Street Hornell, NY 14843 607-324-3232 phone 607-324-6188 paul.argentieri@gmail.com Dean Boland 18123 Sloane Avenue Lakewood, Ohio 44107 216-236-8080 phone 866-455-1267 fax dean@bolandlegal.com 2

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