Ceglia v. Zuckerberg et al

Filing 484

DECLARATION signed by Paul Argentieri re 481 Response in Opposition to Motion filed by Paul D. Ceglia. (Boland, Dean)

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

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

Plaintiff,
DECLARATION
OF PAUL ARGENTIERI

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 am counsel for Paul D. Ceglia in this matter.
3. Paul Ceglia sent an email to me on June 27, 2010 with an attachment.
4. The attachment to that June 27, 2010 email was a scan of the Facebook
Contract made by Paul Ceglia.
5. On June 28th and 29th of 2010, I prepared the first complaint and the Order
to Show Cause papers.
6. The preparation of that complaint required me to attach a printed copy of the
Facebook Contract as an exhibit.
7. While preparing the court filings, the attachment noted in number 4 above
was printed on an office printer to be attached as the exhibit noted in number
6 above.

8. The filing in New York State court, including copies needed for service,
required me to create an original of the complaint and all attachments and
then copy that complete filing for service on various parties.
9. To make the documents noted in number 8 above the printout of the
attachment was inserted into a copy machine and multiple copies of that
printout were made.
10. To make the contract more legible, I changed the settings on the copy
machine to cause the copy machine output copies to be as dark as possible to
enable them to be as legible as possible.
11. The copy machine I used for this purpose was an inexpensive model that
regularly required the darkening of documents as the default settings on the
copier resulted in poor quality copies.
12. Therefore, the copy of the Facebook Contract attached to the complaint was a
darkened copy of a printout from a scan of the Facebook Contract received as
an attachment via email from Paul Ceglia.
13. I have since spoken to Paul Ceglia about how the scan he attached to the
email referenced in Number 3 above was created.
14. Approximately June 2010, Paul Ceglia took the original Facebook Contract
that was examined in July 2011 by Defendants experts, and copied it on a
grocery store copier near his home in Wellsville, New York.

15. Paul Ceglia took that photocopy from the grocery store copier and scanned
that copy converting it to an electronic file that was then attached to the
email sent to me that is referenced in number 3 above.

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 following is true and correct:
DATED: August 20, 2012.

/s/ Paul Argentieri
Paul Argentieri