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 HH

From: Dean Boland
Sent: Thursday, August 30, 2012 4:28:46 PM (UTC-05:00) Eastern Time (US & Canada)
To: Southwell, Alexander H.; Paul Argentieri
Subject: Stewart Documents

Alex:
Orin Snyder was originally sent everything the Court Order requested back on October 24/25, 2011. He said
during Mr. Stewart's deposition that one of the "Worksheets" I was referring to hadn't been sent to Defendants,
so he was given a copy at that time. Thus, the mysterious 2 worksheets. I am sending you via a "YouSendIt"
file a copy of every document and image Mr. Stewart has that is responsive to the Gibson Dunn and Court
Order requests. He have nothing else. We are providing the two TLC worksheets again (I think for the 3rd
time) now.
As information, pgs 13 and 18 of 55 from the file named, "doc083012a.pdf" are the two worksheets. Pg 20 of
the same file is a page of handwritten notes describing the sampling of the WFH document. Pgs 21-42 of the
same file show "before and after" sampling pictures as well as locations of sampling areas. Mr. Stewart is
still maintaining the untested samples in case they are needed.
To date, you have been provided files responsive to the Court Order (10/25/11) along with additional files on
06/13/12 based on their request for new materials. In addition, you were provided files you said you hadn't
received at the 07/11/12 deposition (These files were provided on-site at the deposition to you). Next, based on
your inference that you hadn't received all of the material requested, I resubmitted the previously provided
material on 08/23/12. Due to the continued insistence that you haven't been provided all of the requested the
files, today Mr. Stewart photocopied all printed documents responsive to the Court and defendants requests and
has provided that to me. I am, in turn, providing that to you along with all of the image files. This has all been
previously provided (actually on multiple occasions), but to be certain, we are providing everything again.
Mr. Stewart has nothing else to provide responsive to your requests.
The "YouSendIt" file follows as 3 separate files (due to the size).
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]

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