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)

Download PDF
EXHIBIT F From: Sent: To: Cc: Subject: Southwell, Alexander Sunday, July 08, 2012 10:19 AM Dean Boland (dean@bolandlegal.com) paul.argentieri@gmail.com; Benjamin, Matthew J.; Aycock, Amanda M. Stewart materials Mr. Boland: With regard to the Stewart materials, you have provided a series of apparent digital photographs of portions of documents and other materials without any explanation. For many of the photographs, it is not apparent what the item purports to be or whether it is responsive at all to any request made by Defendants. Additionally, you appear not to have provided the following from our June 13, 2012 letter: 1. List of . . . all documents, reports, filings, declarations, videos, handwriting exemplars, or other material reviewed [by Stewart] prior to the submission of their reports; 6. . . . identification of the samples provided to Mr. Rantanen (including detail on the contents of each vial provided, e.g., how many samples each vial contained; from which document, page, and location the samples were taken; the size of the samples; and any other source or identifying information); 7. The materials Mr. Stewart claims in his Report were produced in discovery, on which he relies for the assertion that a Defendants’ expert had knowledge of Stewart’s findings related to the markings at the top of each page of the Work for Hire Document and the dull corner on the back of page 1 under ultra-violet examination (which in fact were not produced in discovery) (see Doc. No. 416, ¶ 195); 8. The results, data, captured images or pictures, in electronic of hard-copy form, or thin layer chromatography plates resulting from Mr. Stewart’s “chemical analysis of the toner” (Doc. No. 416, ¶ 89), and other “testing methods, [which] included microscopy and thin layer chromatography” (Doc. No. 416, ¶ 93); 9. Details of the contents and sources of Mr. Stewart’s “library of standard toners,” including any catalogue, index, directory, log, or similar information (see Doc. No. 416, ¶ 98-99). Please provide these materials immediately, or explain what you believe has already been provided or cannot be provided, and provide clarifying information about the photographs you provided. With regard to the amended Grant declaration, please provide clarification as to the date and circumstances of this document. The declaration is dated June 8, 2012, prior Mr. Grant’s deposition, yet it appeared that he created this list after his deposition since you had not provided it in advance. Thanks Alex Alexander H. Southwell Partner GIBSON DUNN Gibson, Dunn & Crutcher LLP 200 Park Avenue, New York, NY 10166-0193 1

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?