Ceglia v. Zuckerberg et al

Filing 422

DECLARATION signed by Paul Ceglia filed by Paul D. Ceglia Regarding Plaintiff's Expert Reports. (Boland, Dean)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
PAUL D. CEGLIA,

Civil Action No. : 1:10-cv-00569-RJA

Plaintiff.,

DECI,ARATION
OF PAUL CEGLIA

v.

MARK ELLIOT ZUCKERBERG, Individually, and
FACEBOOK, INC.
Defendants.

DECLARANT, submits this declaration and hereby declares under penalty of

perjury and pursuant to 28 U.S.C. 1746 and under the laws of the United States
that the following is true and correct:

1. I make this declaration

upon personal knowledge.

2.

I located the Facebook Contractl on or about June 27ih 2010.

3.

I located the Facebook Contract in my house in Wellsville, New York.

4.

The document was found within a Hope Chest on the North wall of my spare
room.

5.

In that Hope chest were a series of other documents dating to the same time.

6.

During the Winters of 2003 through 2008 I closed down my house in Wellsville
New York.

7. I shut off the electricity at the main breaker and ieft the house for extended
periods of time during freezing New York Winter conditions.

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To eliminate any confusion, the Facebook Contract designates the two page document presented to Defendants'experts for evaluation in July of2A71.

8.

For at least five months before, during and after the winter of 2003-2004, five
months during and after the winter of 2004-2005, five months before, during
and after the winter of 2005-2006, six months before, during and after the win-

ter of 2006-2007 and four months before and during winter of 2A07-2008, my
house

in Wellsville New York, along with all of its contents, were subject to

freezing and subfreezing temperatures.

9.

During the winter of 2008-2009 I lived in my home. My home was heated with
a wood stove and a gas fireplace as

it

has no central heating.

10. During the winter of 2008-2009, I kept my spare room closed off to keep the
heat in the lived in rooms of my home.

11. During the winter of 2009-2010 I heated my home with a wood stove and a pellet stove. I still had no central heating and kept my spare room closed off from
the rest of the house to conserve heat.

12. The winteizing of my

house

in Wellsville, New York included draining

the

water lines and pipes to prevent ruptures from frozen water.

13. Almost

every year that effort was

still unsuccessful and I would regularly have

to repiace lengths of copper piping each spring from ruptures caused by frozen
pipes.

14. I did not heat

my home whiie absent at the times listed above.

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I

hereby declare under penalty of perjury and pursuant to 28 U.S.C. 1746 and

under the laws of the United States that the foregoing is true and correct:

DATED: June 2,2012

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