Ceglia v. Zuckerberg et al

Filing 555

DECLARATION signed by Alexander H. Southwell re 553 MOTION for Discovery 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, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, # 27 Exhibit AA, # 28 Exhibit BB, # 29 Exhibit CC, # 30 Exhibit DD, # 31 Exhibit EE, # 32 Exhibit FF, # 33 Exhibit GG, # 34 Exhibit HH, # 35 Exhibit II, # 36 Exhibit JJ, # 37 Exhibit KK, # 38 Exhibit LL, # 39 Exhibit MM, # 40 Exhibit NN)(Snyder, Orin)

EXHIBIT P

From:
Sent:
To:
Cc:
Subject:

Dean Boland <[e-mail]>
Friday, July 20, 2012 6:12 PM
Southwell, Alexander H.
[e-mail]; Benjamin, Matthew; Aycock, Amanda; Narasimhan, Sripriya
Re: Letter re Stewart docs

Alex:
I am reviewing the list of items you indicate you still haven't received. Without waiving any objection to your
request for materials from Mr. Stewart, I will review this and get back to you.
Mr. Stewart is not coming to New York to be deposed again. He is coming to New York to assist me with the
deposition of your witness Gerald LaPorte. I am not agreeing to any deposition of Larry Stewart during that
timeframe. I will need to confer with him both before and after all depositions set for next week as I have
planned.
If you believe you are entitled to depose him for more than the seven hours you have already consumed, please
advise as to your basis for exceeding the seven hours provided for in the rules.
If your basis is the additional materials we have provided you, please know that we are not waiving any
objection to the propriety of your request for additional materials, but merely provided materials in the interest
of civil cooperation amongst attorneys.
Dean Boland.
On Wed, Jul 18, 2012 at 9:24 PM, Southwell, Alexander H. <[e-mail]> wrote:
Mr. Boland:

Please provide us by tomorrow the materials from Mr. Stewart discussed in our July 16th letter (attached again, without
the enclosure). We may want to resume his deposition if he is here next Thursday.

Alex

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.

1