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 KK

Attachments:

responsetoSouthwell09_04_12.pdf; ResponsetoSouthwell9_4_12.doc;
ResponsetoSouthwell9_4_12.pages

From: Dean Boland
Sent: Thursday, September 06, 2012 10:24:29 AM (UTC-05:00) Eastern Time (US & Canada)
To: Southwell, Alexander H.; Paul Argentieri
Subject: Response to 8/30 Stewart production

Alex:
Attached is a detailed, ten page response from Larry Stewart to your fourth demand for the same
information. Mr. Stewart has now completely answered your requests for documents on more than one
occasion. He has no further documents to provide. Despite your threat to file a motion on this issue, there can
be no sensible order that compels Mr. Stewart to produce items he has repeatedly told you he does not
have. Our agreement was to provide you documents that he relied on in forming his opinions. He has done so,
completely.
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.

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