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)

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
[e-mail]
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.

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