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 G

From: Dean Boland
Sent: Thursday, July 12, 2012 7:28:02 PM (UTC-05:00) Eastern Time (US & Canada)
To: Southwell, Alexander H.
Cc: Benjamin, Matthew; Paul Argentieri; Aycock, Amanda
Subject: RE: Rantanen Deposition on for Monday

Alex:
Blanco can do any of the three days I mentioned. So, lets set it up so he is the first day, the 24th, and the other
two depositions are the next two days. Then the existing two depositions do not have to be moved at all.
How's that? I know you want to depose him first and that's fine.
Dean Boland
On Jul 12, 2012 6:04 PM, "Southwell, Alexander H." <[e-mail]> wrote:
We are not agreeing to put off Rantanen without setting Blanco to occur prior to our document experts’
depositions. We can do Blanco on the 23rd, or possibly the 24th if the depositions scheduled for the 25th and 26th get
bumped back a day. You mentioned that Blanco had trial on the 23rd, but those dates often move, so please see if
Blanco can do the 23rd.

Tytell is scheduled to be deposed by you in the afternoon of the 25th in our offices.

From: Dean Boland [mailto:[e-mail]]
Sent: Thursday, July 12, 2012 2:40 PM
To: Southwell, Alexander H.; Paul Argentieri
Subject: Rantanen Deposition on for Monday

Alex:

Mr. Rantanen and I just spoke. He will be at your offices at 10:00 am on Monday, July 16, 2012 for his
deposition.

His daily rate for his deposition is $3150.00. He is advised to retain travel receipts and to provide those to me
within 30 days of his deposition for reimbursement of those.
1

Finally, he is gathering the responses to the items you wanted more information about. Those should be
provided today for email to you.

As to Blanco's deposition, we have two deposition (the Stroz Friedberg folks) set for Wednesday and Thursday
of the following week, Albert Lyter and Gerald LaPorte. I may have a conflict with July 27th. I should know
one way or another on that by tomorrow.

Therefore, we need to discuss further about Mr. Blanco's revised deposition date.

Finally, I do not have a date on my calendar for Mr. Tytell's deposition although he was noticed along with your
other experts. If I have overlooked a date we agreed to for his deposition, please advise. Otherwise, please
suggest dates for his deposition within the 60 day period expiring August 4, 2012.

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.

This message may contain confidential and privileged information. If it has been sent to you in error, please
reply to advise the sender of the error and then immediately delete this message.
2

3