Ceglia v. Zuckerberg et al
Filing
397
MEMORANDUM IN SUPPORT re 396 MOTION for Discovery Notice of Motion For Discovery of Harvard emails byPaul D. Ceglia. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Certificate of Service)(Boland, Dean)
5/30/12
Gmail ‑ Discovery
Dean Boland
Discovery
Dean Boland
Tue, May 22, 2012 at 4:49 PM
To: Alexander Southwell , Oren Snyder , Paul Argentieri
Bcc: Paul Ceglia
Alex:
The Harvard email production that Defendants' provided appears deficient in two respects:
1. The earliest dated email provided is from June 2, 2003.
As you know, our clients signed an agreement on April 28, 2003. Your client found my client's posting via
craigslist before that date. Our clients undoubtedly corresponded via email before and after April 28, 2003
leading up to June 2, 2003. It is not believable that your client and mine did not correspond via email before
June 2, 2003. Also, there are no emails from your client to my client after November 2003. As you know, there
is significant work that Zuckerberg did for my client well into 2004.
2. Several emails have within their body threads of previous emails and those previous emails are not provided
themselves in native msg format.
For example, but by no means the only example, Defendants provided two msg files, emails, dated November
19, 2003. Both are supposedly sent from my client to Zuckerberg. One was supposedly sent at 1:49 AM and
the other at 11:53 am.
In the 1:49 AM email, the body contains a prior email sent by Zuckerberg to Ceglia at 1:44 am with content. That
1:44 am email was not provided in the Defendants' production as required by the court's order Doc. No 83.
In the 11:53 AM email, the body contains a prior email sent by Zuckerberg to Ceglia at 3:23 am. That 3:23 am
email was not provided in the Defendants' production as required by the court's order Doc. No 83.
These are only two examples of many such concealed or deleted emails by Zuckerberg. Please remedy this
apparently deficient production by noon on Thursday, May 24, 2012. This is our attempt to meet and confer on
this matter. The Thursday deadline is necessary because of our June 3, 2012 deadline to submit expert reports.
Dean Boland.
Dean Boland
Owner/Member
Boland Legal, LLC
1475 Warren Road
Unit 770724
Lakewood, Ohio 44107
216.236.8080 ph
866.455.1267 fax
dean@bolandlegal.com
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 2162368080.
EXHIBIT A
https://mail.google.com/mail/?ui=2&ik=b614a0d4c7&view=pt&q=southwell emails&qs=true&search=que…
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