Ceglia v. Zuckerberg et al
DECLARATION signed by Alexander H. Southwall re 521 Ninth MOTION to Compel And For Other Relief filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Snyder, Orin)
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
PAUL D. CEGLIA,
MARK ELLIOT ZUCKERBERG and
Civil Action No. 1:10-cv-00569-RJA
ALEXANDER H. SOUTHWELL
I, ALEXANDER H. SOUTHWELL, hereby declare under penalty of perjury that the
following is true and correct:
I am an attorney licensed to practice law in the State of New York and admitted to
practice before this Court. I am a partner in the New York office of the law firm of Gibson,
Dunn & Crutcher LLP (“Gibson Dunn”), counsel of record for Mark Elliot Zuckerberg and
Facebook, Inc. (“Facebook”) in the above-captioned matter. I make this Declaration in Support
of Defendants’ Ninth Motion to Compel and for Other Relief. I have personal knowledge of the
information set forth herein based upon my direct involvement in the matters at issue and upon
my review of the documents referenced below.
This declaration describes Defendants’ good-faith efforts to resolve disputes
regarding Plaintiff’s failure to comply with this Court’s Orders dated July 1, 2011 (Doc. Nos. 83,
84) before filing Defendants’ Ninth Motion to Compel, in compliance with Western District of
New York Local Rule 7(d)(4).
Attached hereto as Exhibit A is a true and correct copy of a letter dated September
4, 2012 from me to Dean Boland in which I requested that Ceglia produce to Defendants all hard
copies of the purported contract created before June 30, 2010, including those hard copies
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