Ceglia v. Zuckerberg et al

Filing 50

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)

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EXHIBIT B 1 EXHIBIT B Style Markers in QUESTIONED vis-à-vis KNOWN-Zuckerberg 1. 2. 3. 4. 5. Spelling: Spelling: Spelling: BACKEND INTERNET CANNOT 6. 7. 8. 9. 10. Syntax: Syntax: Syntax: Syntax: Syntax: RUN-ON SENTENCES SINGLE-WORD SENTENCE OPENERS SENTENCE-INITIAL "SORRY" [similarity] DISTANT OR AMBIGUOUS PRONOUN-REFERENT NO COMMA AFTER IF-CLAUSE 11. 1. Punctuation: APOSTROPHES Punctuation: SUSPENSION POINTS Discourse: MESSAGE-FINAL "THANKS!" [similarity] Punctuation: APOSTROPHES Apostrophes indicating contraction and possession are sometimes absent in QUESTIONED, but always present in KNOWN-Zuckerberg. Questioned 010604Z doesnt 010604Z parents [parents'] 020604Z sites [site's = site is] 020604Z sites [site's = possessive] Known-Zuckerberg All apostrophes in contractions and possessives are present. 2. 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 words. Questioned 073003Z . . . I’ve been tweaking the search engine today 010104Zb I’ll just get this site online as quickly as I can ...” Known-Zuckerberg So let me know... (3x) boxes...there (3x) 2 3. Spelling: BACKEND 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. Questioned 010104Z the back end of the site Known-Zuckerberg backend (6x) frontend (5x) 4. Spelling: INTERNET The word "internet" starts with a small-i in the QUESTIONED writing but with a capital-I in KNOWN-Zuckerberg. Questioned 090203Z internet Known-Zuckerberg Internet (2x with cap I) 5. Spelling: CANNOT The word "cannot" appears as two words in the QUESTIONED writing but appears multiple times as a single word in KNOWN-Zuckerberg. Questioned 020604Z can not [2 words] Known-Zuckerberg cannot [1 word] (6x) 6. 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. Questioned 073003Z I’d like to --- Face Book], I think it will really help 090203Z I have been away --- internet, during that time I revised 010604Z you would be seriously violating --- by doing so, I have done 010604Z Please do not contact them --- issue, they would probably just 020204Z Paul, I have --- to discuss with you, according to --- I owe you 020404Z ‘thefacebook.com’ opened --- today, when you get a chance take a 020604Z Sorry it’s --- to respond, (sic) Now that --- live I feel I must 020604Z I don’t care about --- right now, I just want to see if people 3 072204Z I still don’t have --- build our site, I understand that I Known-Zuckerberg No run-on sentences 7. 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. Questioned 090203Z Further, 090203Z Additionally, 010104Z Thus, 010604Z Again[,] 020204Z First[,] 020204Z Mostly though 040604Z Paul, Known-Zuckerberg Okay And Anyhow, (2x) Also, But But regardless, Then However, 8. Syntax: SENTENCE-INITIAL "SORRY" [similarity] Both the QUESTIONED and the KNOWN-Zuckerberg writings demonstrate sentence-initial apologies starting with "Sorry". Questioned 020604Z Sorry Known-Zuckerberg Sentence-initial "Sorry" in Known-Zuckerberg (4x) 9. 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. 4 Questioned 090203Z ... 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 detail. 090203Z 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] remains unresolved. 010104Z 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 contract. 020204Z 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 .... Known-Zuckerberg [No too-distant pronoun referents in KNOWN-Zuckerberg] 10. 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. Questioned 112203Z if you could send another $1000 for --- project _ it would allow 010104Z if there is any way you can --- funding _ I believe we will be 020604Z If I had the rest --- that extra work I did _ I wouldn’t even Known-Zuckerberg Comma present 13x before or after if-clause in KNOWN-Zuckerberg Comma absent 2x before or after if-clause in KNOWN-Zuckerberg 11. Discourse: MESSAGE-FINAL "THANKS!" [similarity] Both sets of writings contain an example of "Thanks!" used to conclude the writing. Questioned 073003Z Thanks! Known-Zuckerberg Thanks! (1x)

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