Ceglia v. Zuckerberg et al

Filing 523

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)

EXHIBIT B

From: Dean Boland
Sent: Thursday, September 06, 2012 10:27:47 AM (UTC-05:00) Eastern Time (US & Canada)
To: Southwell, Alexander H.; Paul Argentieri
Subject: Spurious claim of documents we have not produced.

Alex:
Your claim that Mr. Argentieri's recent declaration establishes undisclosed documents is false. Plaintiff and his
counsel are well aware of the ongoing duty to supplement discovery. There are no documents in Plaintiff or his
counsel's possession, custody or control that have not already been produced. As with Mr. Stewart, no sensible
order can be requested which orders Plaintiff or his counsel to produce documents that either have already been
produced or are not within our possession, custody or control. This is Defendants' wishful thinking sighing
expedition.
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.

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