Ceglia v. Zuckerberg et al

Filing 543

MEMORANDUM in Opposition re 521 Ninth MOTION to Compel And For Other Relief filed by Paul D. Ceglia. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Certificate of Service)(Boland, Dean)

Spurious claim of documents we have not produced.
Dean Boland <[e-mail]>
Thu, Sep 6, 2012 at 10:27 AM
To: Alexander Southwell <[e-mail]>, Paul Argentieri <[e-mail]>
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.