Ceglia v. Zuckerberg et al

Filing 519

DECLARATION signed by Alexander H. Southwell re 517 MOTION for Attorney Fees And For Recovery Of Expenses filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S)(Snyder, Orin)

EXHIBIT A

From: Dean Boland <[e-mail]>
Date: June 19, 2012 9:33:53 AM EDT
To: Alexander Southwell <[e-mail]>, Paul Argentieri <[e-mail]>, Neil
Broom <[e-mail]>, Jim Blanco <[e-mail]>, Larry Stewart <[e-mail]>,
Jerry Grant <[e-mail]>
Subject: Broom deposition and other witnesses
Alex:
Mr. Broom's deposition for next week is a conflict. Also, since you noticed him for deposition
away from his office location, I wanted to be clear that Defendants are paying not only his travel
expenses to attend his eventual deposition in New York, but also his time spent traveling, billed
at a flat $2,000 per day. Please confirm that and lets talk about a date the following week for his
deposition.
I would like to arrange convenient dates to depose Defendants experts instead of just noticing
them with demand dates. I would like to depose your tech experts the same day, in the
afternoon, that we will eventually have Broom's depo. This allows both experts to attend the
other's depo which I assume you planned anyhow.
Same idea for the paper experts, Blanco and Stewart. Depose Blanco in the morning, then
Tytell, Lesnevich or LaPorte in the afternoon. Depose Stewart in the morning and then one of
your other paper experts in the afternoon. I won't need more than two hours with each of your
experts, so we can actually handle deposing two of your paper experts in a single afternoon.
Let's keep working on this. I am sure we can accommodate each others' schedules. If we can't
work out the dates, then we can mutually approach the court for some additional days. I am
confident we can work it out.

Dean.
-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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