Ceglia v. Zuckerberg et al
DECLARATION signed by Gerald R. McMenamin re 44 MOTION to Expedite - Notice of Motion for Expedited Discovery filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Snyder, Orin)
Style Markers in QUESTIONED vis-à-vis KNOWN-Zuckerberg
SINGLE-WORD SENTENCE OPENERS
SENTENCE-INITIAL "SORRY" [similarity]
DISTANT OR AMBIGUOUS PRONOUN-REFERENT
NO COMMA AFTER IF-CLAUSE
Punctuation: SUSPENSION POINTS
MESSAGE-FINAL "THANKS!" [similarity]
Apostrophes indicating contraction and possession are sometimes absent in QUESTIONED,
but always present in KNOWN-Zuckerberg.
sites [site's = site is]
sites [site's = possessive]
All apostrophes in contractions and possessives are present.
Punctuation: SUSPENSION POINTS
Suspension points appear in threes and are spaced in QUESTIONED. Three suspension
points appear in KNOWN-Zuckerberg but are never spaced between each other or away from
. . . I’ve been tweaking the search engine today
010104Zb I’ll just get this site online as quickly as I can ...”
So let me know... (3x)
The technical term "backend" is written as two words in QUESTIONED. "Backend" and its
parallel "frontend" are always written as one word in KNOWN-Zuckerberg and appear as one
word multiple times.
the back end of the site
The word "internet" starts with a small-i in the QUESTIONED writing but with a capital-I in
Internet (2x with cap I)
The word "cannot" appears as two words in the QUESTIONED writing but appears multiple
times as a single word in KNOWN-Zuckerberg.
can not [2 words]
cannot [1 word] (6x)
Syntax: RUN-ON SENTENCES (2 sentences with no separating-punctuation)
Run-on sentences constitute a strong and relatively frequent pattern in the QUESTIONED
writings. The even more extensive sample of KNOWN-Zuckerberg writings does not
demonstrate run-on sentences.
I’d like to --- Face Book], I think it will really help
I have been away --- internet, during that time I revised
you would be seriously violating --- by doing so, I have done
Please do not contact them --- issue, they would probably just
Paul, I have --- to discuss with you, according to --- I owe you
‘thefacebook.com’ opened --- today, when you get a chance take a
Sorry it’s --- to respond, (sic) Now that --- live I feel I must
I don’t care about --- right now, I just want to see if people
I still don’t have --- build our site, I understand that I
No run-on sentences
Syntax: SINGLE-WORD SENTENCE OPENERS
It has been shown that words introducing sentences (sentence openers) group as a habituallyused set for individual writers. The set of sentence openers present in the QUESTIONED
writings is wholly distinct from that of the KNOWN-Zuckerberg writings.
Syntax: SENTENCE-INITIAL "SORRY" [similarity]
Both the QUESTIONED and the KNOWN-Zuckerberg writings demonstrate sentence-initial
apologies starting with "Sorry".
Sentence-initial "Sorry" in Known-Zuckerberg (4x)
Syntax: DISTANT OR AMBIGUOUS PRONOUN-REFERENT
A pronoun2 will refer back to a noun1 previously used, as in, I painted the door1 because it2
needed attention. If there is more than one preceding noun, the pronoun will refer back to one
of those, one which cannot be too far back, as in, I painted the door and my nails, and they
needed attention. However, sentences like the latter or sentences with a too-distant nounreferent can result in awkward ambiguity: I painted the door and the table, which really needed
attention. This type of problematic ambiguous or too-distant reference occurs in the
QUESTIONED writings but not in the KNOWN-Zuckerberg writings.
... during that time I revised the business plan for the Harvard
site. I would like to talk to you on the phone about it in
As you mentioned last week, the issue we must resolve is how to
produce a revenue stream from the users. My conclusion this past
week is .... With this in mind, ... we could ... expand to other
colleges. Further, since the plan involves more than one
college, the name can’t have Harvard in it and [no pronoun]
Thus, I am requesting a written waiver on your part
exempting me from the obligation to give you additional
ownership in the project that is outlined in our original
First I want to say that I think that is completely unfair
because I did so much extra work for you on your site that
caused those delays ....
[No too-distant pronoun referents in KNOWN-Zuckerberg]
Syntax: NO COMMA AFTER IF-CLAUSE
A long if-clause is separated from its preceding or following main clause by a comma. Such a
comma is absent in the QUESTIONED writings, but most often present in the KNOWNZuckerberg writings.
if you could send another $1000 for --- project _ it would allow
if there is any way you can --- funding _ I believe we will be
If I had the rest --- that extra work I did _ I wouldn’t even
Comma present 13x before or after if-clause in KNOWN-Zuckerberg
Comma absent 2x before or after if-clause in KNOWN-Zuckerberg
Discourse: MESSAGE-FINAL "THANKS!" [similarity]
Both sets of writings contain an example of "Thanks!" used to conclude the writing.
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