Ceglia v. Zuckerberg et al
Filing
556
DECLARATION signed by Amanda M. Aycock 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)(Snyder, Orin)
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EXHIBIT I
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
No. 1:10-cv-00569-RJA
_______________________
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PAUL D. CEGLIA,
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Plaintiff,
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vs.
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MARK ELLIOT ZUCKERBERG,
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Individually, and
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FACEBOOK, INC. ,
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Defendants.
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_______________________
Gibson, Dunn & Crutcher
200 Park Avenue
New York, New York
10166-0193
July 16, 2012
10:06 A.M.
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VIDEOTAPED DEPOSITION OF
Walter John Rantanen, II
Reported by:
DEBRA SAPIO LYONS, RDR, CRR, CCR, CPE
212-279-9424
VERITEXT REPORTING COMPANY
www.veritext.com
212-490-3430
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July 16, 2012
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Videotaped deposition of Walter
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John Rantanen, II, held at the offices of
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Gibson, Dunn & Crutcher, 200 Park Avenue,
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New York, New York
10166-0193, before
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Debra Sapio Lyons, a Registered Diplomat
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Reporter, a Certified Realtime Reporter, a
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Certified LiveNote Reporter, an Approved
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Reporter of the United States District
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Court for the Eastern District of
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Pennsylvania, a Certified Court Reporter
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of the State of New Jersey, a Notary
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Public of the States of New Jersey, New
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York and the Commonwealth of Pennsylvania.
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212-279-9424
VERITEXT REPORTING COMPANY
www.veritext.com
212-490-3430
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APPEARANCES:
BOLAND LEGAL
BY:
DEAN BOLAND, ESQUIRE
1475 Warren Road #770724
Lakewood, Ohio
44107
216.236.8080
dean@bolandlegal.com
Counsel for Paul D. Ceglia
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GIBSON, DUNN & CRUTCHER
BY:
MATTHEW BENJAMIN, ESQUIRE
ALEXANDER H. SOUTHWELL, ESQUIRE
AMANDA AYCOCK, ESQUIRE
200 Park Avenue
New York, New York
10166-0193
212.351.4079
212.351.3981
212.351.2347
mbenjamin@gibsondunn.com
asouthwell@gibsondunn.com
aaycock@gibsondunn.com
Counsel for Mark Elliot
Zuckerberg, Individually, and
Facebook, Inc.
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ALSO PRESENT:
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JAMES THOMPSON
Gibson Dunn
DEVERELL WRITE, Videographer
Veritext New York
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212-279-9424
VERITEXT REPORTING COMPANY
www.veritext.com
212-490-3430
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Walter J. Rantanen, II
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recollection of the samples other than
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generally what was on the request form
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and what was in the report.
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A.
Yes.
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Q.
So you don't know who
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extracted the samples or when or how or
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anything like that; right?
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A.
Not for certain.
I -- I
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guess I would assume that Mr. Stewart
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would have.
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Q.
I...
But that's just an
assumption; right?
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A.
Yes.
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Q.
Okay.
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Was there any ink on
the samples?
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A.
Not that I recall.
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Q.
Was there any toner
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printing?
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A.
Not that I recall.
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Q.
And your report doesn't
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indicate that the samples were anything
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other than plain white paper; right?
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A.
Yes.
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Q.
You have no reason to think
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Walter J. Rantanen, II
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that there were any inconsistencies or
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anomalies regarding the color of the
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samples; right?
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A.
No.
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Q.
So the color was consistent
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on both sides of the paper samples;
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right?
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A.
From what I could see with
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the very small piece, but we did notice
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those little specks on one side versus
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the other side.
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Q.
Right.
Other than the
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specks, there was consistent coloration
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on the front and backs of the samples;
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right?
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A.
From what I could tell, yes.
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Q.
Did you examine the
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samples -- you examined the samples
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visually before they were dissolved;
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right?
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A.
Yes.
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Q.
Did you examine them under a
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microscope?
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A.
212-279-9424
Yes.
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Page 236
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Walter J. Rantanen, II
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A.
Yes.
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Q.
Now, here you're noting that
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the paper contains optical brightening
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agents, chemicals used to whiten it;
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right?
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A.
Yes.
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Q.
What does strong mean?
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A.
It came up brightly on
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the -- with the -- when you put the
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lamp over there, it -- basically if
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you've ever seen it, it lights up.
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me it lit up strongly.
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Q.
To
And your report indicates
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strong UV fluorescence in both samples;
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right?
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A.
Yes.
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Q.
No indication that the
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fluorescence differs across the samples
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or from front to back or anything like
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that; right?
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A.
any detectable difference.
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I didn't -- I didn't notice
Q.
In your third sentence you
report, "In the small punch outs
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Walter J. Rantanen, II
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significant fluorescence differences
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were not detected"; right?
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A.
Yes.
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Q.
You say you didn't observe
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any significant fluorescence
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differences.
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A.
Did you observe any?
There may have been some
slight appearance, but I -- to me that
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may not have been.
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dealing with little, little pieces like
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that it's hard to get a good comparison
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on -- on some of them.
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Q.
Right.
It -- when you're
And as I think
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you've testified repeatedly today, you
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didn't observe any difference in the UV
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characteristics across the samples
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front to back, one to the other?
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A.
Not that I could detect, no.
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Q.
Right.
Now, you also noted
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that significant differences were not
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detected, quote, in the small punch
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outs.
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sensible limitation because obviously
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those punch outs came from only certain
212-279-9424
Now, that -- it seems like a
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