Ceglia v. Zuckerberg et al

Filing 476

DECLARATION signed by Alexander H. Southwell re 474 MOTION for Protective Order filed by Facebook, Inc., Mark Elliot Zuckerberg. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Snyder, Orin)

Download PDF
EXHIBIT G From: Dean Boland Sent: Tuesday, August 07, 2012 2:22:14 PM (UTC-05:00) Eastern Time (US & Canada) To: Southwell, Alexander H.; Paul Argentieri Subject: Discovery related to Motion to Dismiss for Statute of Limitations Alex: I have reviewed your letter. You are past your due date to provide these responses to us. We graciously gave you until Friday of this week to respond. And, that delay in time was merely for you to draft a letter finding that Plaintiff has not constructed a single interrogatory or document request that complies with the court's order, which is your opinion. You have refused to comply with any of the interrogatories or requests for production of documents related to our right of discovery responding to Defendants' statute of limitations motion to dismiss. Each of these interrogatories were carefully crafted to obtain information related to the court's discovery order: "Plaintiff is thus permitted discovery under Rule 56(d), limited to serving, within 60 days, interrogatories and document requests directly concerning (1) assuming, arguendo, the Work for Hire contract dated August 28, 2003 is authentic, what were Plaintiff’s intellectual property rights and other ownership interests under the contract’s language providing that Plaintiff, in exchange for helping fund Zuckerberg’s development of FaceBook, would own “a half interest (50%) in the software, programming language and business interests derived from the expansion of that service to a larger audience....” We expect answers to each of our interrogatories by Friday as well as the production of documents requested. Thank you. 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 216-236-8080. 1

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?