Ceglia v. Zuckerberg et al
MEMORANDUM in Opposition re 525 MOTION for Extension of Time to File Response/Reply in Support of Defendants' Motion to Dismiss (Doc. No. 318) filed by Paul D. Ceglia. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Certificate of Service)(Boland, Dean)
Spurious claim of documents we have not produced.
Thu, Sep 6, 2012 at 10:27 AM
To: Alexander Southwell , Paul Argentieri
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.
Boland Legal, LLC
1475 Warren Road
Lakewood, Ohio 44107
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