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 G
Page 1
1
2
UNITED STATES DISTRICT COURT
3
WESTERN DISTRICT OF NEW YORK
4
No. 1:10-cv-00569-RJA
5
-----------------------------x
PAUL D. CEGLIA,
6
Plaintiff,
7
vs.
8
MARK ELLIOT ZUCKERBERG,
9
Individually, and
FACEBOOK, INC.,
10
Defendants.
11
-----------------------------x
12
13
14
July 11, 2012
15
10:03 a.m.
16
17
Videotaped deposition of LARRY F.
18
STEWART, held at the offices of Gibson,
19
Dunn & Crutcher LLP, 200 Park Avenue,
20
New York, New York, pursuant to notice,
21
before Cary N. Bigelow, Court Reporter,
22
a Notary Public of the State of New York.
23
24
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A P P E A R A N C E S:
3
BOLAND LEGAL, LLC
4
Attorneys for Plaintiff
5
1475 Warren Road
6
Unit 770724
7
Lakewood, Ohio 44107
8
BY:
DEAN BOLAND, ESQ.
9
10
GIBSON, DUNN & CRUTCHER LLP
11
Attorneys for Defendants
12
200 Park Avenue
13
New York, New York 10166-0193
14
BY:
ORIN SNYDER, ESQ.
15
ALEXANDER H. SOUTHWELL, ESQ.
16
MATTHEW BENJAMIN, ESQ.
17
AMANDA AYCOCK, ESQ.
18
SRIPRIYA NARASIMHAN, ESQ.
19
20
ALSO PRESENT:
PETER TYTELL
21
GERALD LAPORTE
NADER KHORASSANI, Summer Associate,
22
Gibson, Dunn & Crutcher, LLP
(a.m. session)
23
ANNA CHASE, Summer Associate,
Gibson, Dunn & Crutcher, LLP
24
(p.m. session)
DANIEL McCLUTCHY, Videographer
25
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2
3
Q.
But your task was overseeing the
plaintiff's examinations; correct?
4
A.
That's correct.
5
Q.
But you're not aware of what tests he
6
conducted or not; right?
7
8
A.
on the ink to see if he could identify it.
9
10
Q.
But you weren't sure what other tests
he conducted?
11
12
As I mentioned, he conducted the tests
A.
If I can answer that, I will explain
why.
13
When you conduct an ink analysis where
14
you are trying to do an identification, many
15
times you have to do exams on the paper as well,
16
so when you ask the question did he examine the
17
paper, I can't answer that other than to assume
18
that he did when he did the identification of the
19
ink.
20
Q.
As the person tasked with overseeing
21
the plaintiff's examinations didn't you
22
coordinate which tests he would be running and
23
which he wouldn't?
24
A.
Yes.
25
Q.
And did you get the samples he took
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I asked him to identify the ink.
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back?
3
A.
No.
4
Q.
Does he still have them?
5
A.
I don't know.
6
Q.
Let's go back to this concept of peer
7
review.
8
At paragraph 447 you state toward the
9
end of your report that as part of your original
10
tasking on this case you conducted what you call
11
technical review of the work conducted by
12
Mr. Blanco; is that correct?
13
A.
Correct.
14
Q.
And you reviewed his declaration along
15
with the supporting exhibits?
16
A.
Yes.
17
Q.
And you peer-reviewed Mr. Blanco's
18
declaration before or after it was executed?
19
A.
Before.
20
Q.
Did Mr. Blanco himself provide you with
21
the declaration and its exhibits or did someone
22
else?
23
A.
No.
24
Q.
So it's your statement here today under
25
Mr. Blanco did.
oath that you received Mr. Blanco's declaration
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The technique as far as forensics goes
3
is used in many different applications and is
4
reliable.
5
age analysis.
6
7
Q.
And I understand that and we'll get to
that.
8
9
I'm questioning its use here in ink
I'm asking a more general question
which is, on its own GCMS testing itself, you are
10
not offering an opinion that it is unreliable;
11
correct?
12
A.
Across the board, no.
13
Q.
And you also do not offer an opinion
14
there's anything wrong with conducting GCMS
15
testing on ink; correct?
16
17
18
A.
For research no problem, beyond that
there may be a problem.
Q.
19
Okay.
Well, you don't offer any opinion about
20
any GCMS testing that you yourself conducted;
21
right?
22
A.
23
24
25
I did not conduct GCMS tests in this
case.
Q.
In fact you conducted no ink testing in
this case; correct?
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A.
No.
I did physical analysis on the ink
3
and decided at that point to hold off doing any
4
chemical analysis and I still have the ink
5
samples today, I have not tested them.
6
7
8
9
Q.
And why did you hold off on doing the
chemical analysis?
A.
Because once we -- once I determined
that the ink was degraded, I agree at that point
10
that you're very limited what you can do
11
chemically to analyze that ink and held off at
12
that point doing any additional tests so I would
13
not lose the sample that I had.
14
Q.
Did you explain that in your report
15
that you have those ink samples and you decided
16
not to do any ink testing?
17
A.
No.
18
Q.
Any particular reason why you didn't
19
20
explain that in your report?
A.
I'm not asked questions in the report,
21
I am only putting in the report what I found.
22
I didn't do a test I didn't find anything.
23
24
25
Q.
If
You explain in the report that you took
ink samples from the document, do you not?
A.
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Yes, I do.
I still have them.
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the general analysis of the document, the
3
indentations and the interlineation, I examined
4
the document in general, I looked to see if the
5
two pages were together, bound together, or if
6
they came from two different sources; I also
7
looked at the staple, I also looked at the
8
interlineations and then I addressed the ink
9
issues.
10
directed sending the paper out for testing.
11
Q.
12
13
I also did the toner analysis and
Right.
And Mr. Speckin, he has got a GCMS
machine; right?
14
A.
Yes, he does.
15
Q.
And he does PE ink-dating testing;
16
right?
17
A.
He has in the past.
That's not the
18
direction that I would have had him go in this
19
case if we had chosen to do ink-age determination.
20
Q.
Did he do ink-age determination?
21
A.
I don't know if he did in this case or
23
Q.
Did you ask him?
24
A.
No, because his connection to me in
22
25
not.
this case involving what he did and didn't do has
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been disconnected the past number of months, so I
3
don't have a current connection with him on this
4
case.
5
6
7
Q.
What exactly do you mean by that, your
connection to him has been disconnected?
A.
Once we decided that ink-age analysis
8
wasn't feasible, then it wasn't important for him
9
to issue any additional work in the case, so we
10
continued at that point with Mr. Blanco and
11
myself doing the lion's share of the forensic
12
work.
13
14
Q.
analysis wasn't feasible.
15
16
17
18
Who's we?
A.
Well, on our side I decided, on your
side Mr. Lyter decided.
Q.
19
20
You testified that we decided ink-age
I'm asking who is we.
You said we decided that ink-age
analysis wasn't feasible.
21
Who is we?
22
A.
It would have been myself when I was --
23
Q.
You decided that?
24
A.
I shouldn't have included Lyter in
25
that, it should have been just me.
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Q.
3
Okay.
And as you said before, I think,
4
Mr. Speckin apparently told you that it was --
5
well, let me ask you this:
6
you that he had come to any conclusions about ink
7
dating?
8
9
A.
Did Mr. Speckin tell
He told me that he had come to
conclusions about ink analysis and identification,
10
and when he told me he could not identify the ink
11
because of its deterioration that is, I believe,
12
the end of the work that he did.
13
to ask the lawyers for further information;
14
that's the last I know of.
15
16
17
Q.
You would have
So you didn't interact with him anymore
after that?
A.
I have on other cases.
I have not
18
interacted with him about his findings in this
19
case.
20
21
Q.
Is everything you did as part of your
examination spelled out in your report?
22
A.
I doubt it.
23
Q.
Are all the tests that you ran detailed
24
25
in your report?
A.
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The tests that yielded a finding are
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Q.
How many paper blanks did you take?
3
A.
For that particular document?
4
Q.
How many paper blanks did you take of
5
the Work For Hire contract document?
6
A.
Looks like 16 from page 1 and then 16
7
from page 2 and then an additional 20 from page 1
8
and an additional 20 from page 2.
9
10
11
12
Q.
And what vials were those paper blanks
A.
That would be vial 1, vial 2, vial 7
in?
and vial 9.
13
Q.
14
vials?
15
A.
They were paper-only samples.
16
Q.
And of those samples you gave the
17
18
entirety of vials 7 and 9 to Mr. Rantanen?
A.
19
20
Those were all paper blanks in those
I believe so.
Let me check.
Q.
Sir, if you don't mind, if you'd leave
21
that out, I could just have a quick copy made of
22
that.
23
24
25
A.
Okay.
I just want to make sure I get
it back in the right place.
Q.
212-279-9424
Is that just that one page?
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A.
That's all you've asked for.
3
Q.
Well, is there anything else that you
4
5
6
7
haven't produced provided to us?
A.
10
11
12
13
You say you
didn't have it, but I did provide it to you.
Q.
8
9
I provided that to you.
Okay.
Is there anything else that you have
that you haven't provided to us?
A.
I provided you everything.
I don't
know whether you have everything.
Q.
And what did you do with the rest of
the paper blanks?
14
A.
I have them.
15
Q.
Did you do anything with them?
16
A.
I used some for the toner analysis and
17
18
19
20
I have the rest in my laboratory.
Q.
How did you use them for the toner
analysis?
A.
As a paper blank to subtract any
21
influence from the paper from the results of the
22
toner.
23
Q.
24
25
You ran those before you ran the TLC of
the toner, the TLC analysis on the toner?
A.
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No.
You run them at the same time.
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Q.
How?
3
A.
In my notes that were taken at the desk
4
as I was doing the examination.
5
Q.
Did you measure them?
6
A.
Yes, I did.
7
Q.
What were the measurements?
8
A.
Reading from my notes it says there
9
were two slightly wider areas on both pages on
10
top edges about 1/2 inch in from left on page 1
11
and one inch from right on page 1.
12
They are -- and this is not in my
13
notes, but just my recollection, they are
14
amorphous in size so that you cannot do an
15
accurate measurement of exactly how big they
16
were.
17
18
Q.
your notes in the case.
19
Can you just hold those up, please?
20
21
And what are you -- you're reading from
A.
Yes.
It was provided to you, it's got
Staples at the top from a Staples --
22
Q.
And how many pages?
23
A.
Just one page.
24
Q.
And how do you know it was provided to
25
us?
Did you provide it to us?
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A.
Yes.
3
Q.
You did?
4
A.
Yes.
5
Q.
How?
6
A.
It's my recollection it was provided to
7
you back in November and it was provided to you
8
again on Mr. Southwell's request last week when
9
you got that file.
10
Q.
And you provided it to us directly?
11
A.
No.
I don't deal with you directly.
12
provided it to the lawyers on Mr. Ceglia's side
13
I
and they provided it to you.
14
Q.
How do you know they provided it to us?
15
A.
You are showing me some of them, so I
16
17
assume that they did.
Q.
Do you want to look through here,
18
because those notes are not in here, those notes
19
were not provided to us.
20
21
22
A.
If you want me to look through there, I
will.
Q.
23
Can I make a copy of those notes?
Let's look at the TLC worksheet form
24
that you just provided to us today and which we
25
have made a copy of.
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staple holes?
3
4
A.
any photographs.
5
6
Q.
MR. SOUTHWELL:
8
10
And you understand that someone who
is -- that it is possible to --
7
9
I took scans on site, I did not take
Q.
Strike that.
Let me actually hand you back your
notes here and if we could have this marked as
Defendants' Exhibit 27.
11
(Defendants' Exhibit 27, photocopy of
12
one page of handwritten notes by Mr.
13
Stewart, marked for identification, as of
14
this date.)
15
Q.
16
Defendants' Exhibit 27 is the notes we
were just referring to?
17
A.
Yes, sir.
18
Q.
Yes?
19
So if you refer to that, can you
20
identify what Q1 and Q2 on Defendants' Exhibit 26
21
is?
22
A.
23
I will try.
There I'm calling Q2 the six-page
24
document.
25
you look at the worksheet, you'll see that
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I believe what is going on there, if
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there's two pages listed for Q1, two pages listed
3
for Q2, and I just doubled my sampling because at
4
the time of the analysis we were asked -- we were
5
allowed to do additional plugs and so I'm using
6
the same name twice, it appears.
7
Q.
8
9
10
Well, let's discuss this.
So Defendants' 27 are your notes from
the date of the inspection July 25th, 2011;
correct?
11
A.
That's correct.
12
Q.
Those are your contemporaneous notes of
13
what you did; yes?
14
A.
That's correct.
15
Q.
And Q1 is the two-page document that
16
we've been referring to as the Work For Hire
17
document; yes?
18
A.
The six-page document, yes.
19
Q.
Q1 is the two-page document that we
20
referred to as the Work For Hire document on your
21
notes, Defendants' Exhibit 27?
22
23
24
25
A.
I'm sorry.
Yes, Q1 is the Work For
Hire document.
Q.
Q2 is the six-page document titled
"StreetFax Back-End" dot, dot, dot, that we
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referred to as the specifications document; yes?
3
A.
That's correct.
4
Q.
And if you look in your report at
5
paragraph -- page 12, you refer to, again, Q1 is
6
the Work For Hire contract, Q2 is the Street Fax
7
back-end technical specification; yes?
8
A.
That's correct.
9
Q.
Now, the TLC form that we were
10
referring to as Defendants' Exhibit 26 is also a
11
contemporaneously dated document from July 25,
12
2011, when you conducted this examination;
13
correct?
14
A.
That's correct.
15
Q.
And there vials 1 through 6 reflect
16
your document here, your log reflects that those
17
samples were taken from Q1 and your log reflects
18
that vials 7 through 10 were taken from Q2;
19
correct?
20
A.
That's what that says, yes, and I'm
21
trying to explain that to you.
22
the videotape, you'll see where the analysis was
23
taken from.
24
additional plugs and I renamed it.
25
unfortunately used the same name there that I
212-279-9424
If you look at
I was given the authority to take
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then used in the report, but you could see that
3
those are both two-page documents and it's just
4
reiteration of the same analysis.
5
Q.
So your testimony is that this
6
inventory is inaccurate with respect to -- well,
7
your inventory uses a different nomenclature than
8
your contemporaneous notes of the same day,
9
that's what you're testifying to?
10
A.
That's not my testimony.
I would have
11
made it clearer to you reading it now if I'd used
12
an A or some other name that I didn't use in the
13
report, so, again, I could have probably
14
clarified it, but it's very clear from reading
15
the worksheet that it's a two-page document in
16
what I did there.
17
Q.
And so you are absolutely certain that
18
vials 7 to 10 which are denominated Q2 are not
19
actually the specs document?
20
A.
Right.
You can see from the pieces of
21
plugs that it's yellow on one side; the specs
22
document was not.
23
Q.
And if we go back and check the
24
videotape do you think that that's going to
25
support your opinion?
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A.
I recall that name being used.
I don't
3
recall seeing the document, I was just told what
4
I could do.
5
Q.
And you recall that in fact you were
6
allowed to take only 20 plugs from the Work For
7
Hire document?
8
9
10
11
A.
I don't recall the number, I would have
to go back and look.
Q.
But your testimony here is that you
were allowed to take additional plugs.
12
Are you sure that wasn't later when you
13
had access, exclusive access to the documents
14
that was not part of the authorized examination?
15
16
17
18
19
20
21
A.
No.
My analysis as far as taking plugs
was only done in Chicago.
Q.
So did you send plugs from the
specifications document to Mr. Rantanen?
A.
No.
I sent him only the document, the
Work For Hire document.
Q.
Now, it's your position that the
22
physical document that was used to create the
23
copy that was attached to the complaint of the
24
Work For Hire document is the same physical
25
document as the one produced to experts in this
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Do you have a document that identifies
3
what the lanes on this TLC plate Defendants'
4
Exhibit 28 is?
5
A.
6
7
I'm looking.
Yes.
It was provided to you, it has 10
lanes described on the left column.
8
Q.
What are you referring to?
9
A.
Another TLC worksheet that you were
10
provided in that package.
11
Q.
Can you hold that up, please?
12
A.
It says "Plate 1" in the upper left and
13
the upper right "Plugs taken from those removed
14
7/25."
15
Q.
16
that refer to the different plates?
17
18
And how many sheets do you have here
You just have this one sheet that
refers to plate 1?
19
A.
Yes, one plate and one sheet.
20
Q.
You only did one plate and you have one
21
22
sheet that corresponds?
A.
Right.
The next page that you've got
23
is the back side of that sheet, the handwritten
24
notes beginning with I-706 in the top part.
25
Q.
212-279-9424
I don't think we have that.
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Could I make a copy of that?
3
It might be easier if you just give us
4
the whole file and then we can make sure we have
5
a copy of everything.
6
number of documents that have not been provided.
7
A.
It seems that there are a
If it helps you on those type of
8
documents, they were part of a PDF that was sent
9
with the file and there are many pages in the PDF.
10
Q.
I am confident we printed everything
11
that we were provided.
12
reason we were not provided those documents.
13
14
I think that for whatever
I will want to ask you some questions
about that, so you'll have to hold on.
15
Now, with respect to your library of
16
standards, do you have an index to your library
17
of toner standards?
18
19
20
21
A.
I have a logbook that has all of them
in there.
Q.
And have you been asked for that in
other litigations?
22
A.
Yes.
23
Q.
And have you provided that in discovery
24
25
in other litigations?
A.
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No, I have not.
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is that right?
3
4
A.
That's right.
It's a moral agreement
in words that I've had with the industry.
5
Q.
And what specifically is there that is
6
proprietary or confidential about the list of the
7
materials that you have in your library?
8
A.
Composition and formula information.
9
Q.
I'm handing you back your notes.
10
There's some sort of, like, on the -- I
11
see.
12
copy of a back of a page; is that what's going on
13
here?
14
This was the back of -- this is a color
A.
15
Yes, sir.
MR. SOUTHWELL:
Let's just take a real
16
quick break.
17
document.
18
understand that these are documents you have
19
not provided to us previously, so I need the
20
opportunity to look at them.
21
you have travel arrangements, but let me
22
look at them and let me see if we can do
23
that and we will be right back.
24
25
I want to look at this
Mr. Boland, you have to
MR. BOLAND:
I understand
I'm not agreeing that we
haven't provided them, but I understand
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L. Stewart
your position is that we haven't.
3
4
MR. SOUTHWELL:
as we can.
5
6
We'll be back as soon
THE VIDEOGRAPHER:
record.
Going off the
The time is 6:36.
7
(Recess taken.)
8
THE VIDEOGRAPHER:
9
10
11
record.
We are back on the
The time is 6:41.
BY MR. SOUTHWELL:
Q.
Mr. Stewart, referring you to
12
Defendants' Exhibit 26, you did not take any
13
samples of ink; is that right?
14
A.
15
26 is.
16
Q.
I don't know what Defendants' Exhibit
That reflects that you did not take any
17
ink samples; right?
18
inventory sheet?
19
A.
Or is there some other
There should be a different one that
20
has ink on it.
21
paper.
22
Q.
23
A different form, okay.
I see.
Another form that we don't have.
24
25
This one is just for toner and
Does it look like this form, the
worksheet form, but you're saying it includes ink
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samples?
3
A.
Yes.
4
Q.
It should look the same?
5
A.
It should look the same, but it would
6
7
It should --
indicate that there's ink samples.
Q.
You mentioned that when you were doing
8
the hard copy inspection, you used a digital
9
microscope, right, that was your testimony?
10
A.
I believe I recall that I told you that
11
I would have to review the videotape to see, but
12
I think I recall taking one with me and using it.
13
14
15
16
17
Q.
And what manufacturer is your digital
microscope that you used on that day?
A.
I think I took a Pro Scope, but, again,
I would have to look at the videotape.
Q.
And that would have been attached to
18
the computer; right?
19
attached to the computer to capture images; yes?
20
21
A.
If it's digital, it's
It would be attached to a laptop
computer, yes.
22
Q.
And did you capture images using that?
23
A.
If I had they would have been included.
24
I don't know if I did, I would have to look at
25
the videotape.
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very much weight, and we can litigate that
3
opinion, if appropriate.
4
I don't think it contains proprietary
5
information, it lists the different toners
6
and the manufacturers.
7
could explain what's in that index.
8
9
MR. BOLAND:
Maybe Mr. Stewart
Obviously, we have a
difference of opinion.
We say we've given
10
you all of the documents, you say we
11
haven't, that's fine, so if you want to
12
finish out the deposition time, then make a
13
motion.
14
MR. SOUTHWELL:
Mr. Stewart is going to
15
be here for other days, we can simply
16
reconvene with him he's here on a day that
17
we're deposing defendants' experts.
18
MR. BOLAND:
I don't know if he's going
19
to be here on other days, but if he is,
20
certainly, if that's convenient.
21
MR. SOUTHWELL:
So I would ask that you
22
produce the documents either now or after
23
you make your flight and then we arrange to
24
reconvene to review those documents with
25
Mr. Stewart.
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