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)

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EXHIBIT AA From: Dean Boland Sent: Thursday, August 23, 2012 1:43:30 PM (UTC-05:00) Eastern Time (US & Canada) To: Southwell, Alexander H.; Paul Argentieri Subject: Regarding Requested Information from Larry Stewart Alex: As I have told you in the past, we have already submitted the requested items to you during the October 2011 submission based on the Court order. Mr. Stewart maintained a duplicate of the CDRom he FedExp'd to Orin Snyder on 10/24/11. In that CD there is a subdirectory called "072511images." That subdirectory contains images Mr. Stewart captured of the FB contract during his examination on 7/25/11. Specific scans were made in order to document where he had taken the plugs of ink, toner and paper. In those images, you can see small holes that correspond to where he took the plugs. The documents were scanned front and back, so some of the images are of the back side of a page and clearly show the removed plugs. The specific images of interest that he previously sent to Mr. Snyder on 10/24/11 are the following: q1_004.pdf q1.tif q1_0001.tif q1_0002.tif q1_0003.tif In addition, after he completed taking samples opposing counsel immediately received a photocopy of the front and back side of each of the 2 pages of the FB contract, again depicting where he had taken his samples. Defendants' counsel were provided those photocopies on-site in Chicago at the end of his examination on 7/25/11. In addition, Defendants' counsel were provided scanned images of the notes he took on 7/25/11 which describe the number of plugs and location of where he removed plugs of ink, toner and paper from the FB contract. In addition, Defendants' counsel were provided a TLC Worksheet Form showing the toner analysis he conducted and again outlining where the specific samples tested were removed from the FB contract. He will re-scan each of these documents and separately email them to me in a YouSendIt file as their sizes are large. I will, in turn, send those files to you using the same large file transfer system this afternoon. Mr. Stewart has kept copies of all of the submissions made to opposing counsel over the past year. He can document that you have received in the past the items we are now sending you again. You and your experts may not have understood what you had, but you definitely have been sent everything. I will re-send the pertinent documents to you via yousendit again in a few minutes. -Dean Boland Owner/Member Boland Legal, LLC 1475 Warren Road 1 Unit 770724 Lakewood, Ohio 44107 216.236.8080 ph 866.455.1267 fax dean@bolandlegal.com 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. 2

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