Ceglia v. Zuckerberg et al

Filing 79

MOTION to Continue Hearing by Paul D. Ceglia. (Attachments: # 1 Affidavit Declaration of Jeffrey A. Lake in Support of Motion to Continue)(Lake, Jeffrey)

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK PAUL D. CEGLIA, Plaintiff, vs. MARK ELLIOT ZUCKERBURG and FACEBOOK, INC., Defendants. x : : : : : : : : : : x CIVIL ACTION NO. 10-CV-00569(RJA) DECLARATION OF JEFFREY A. LAKE IN SUPPORT OF PLAINTIFF’S MOTION FOR A CONTINUANCE I, Jeffrey A. Lake, hereby declare as follows: 1. I am an attorney with the law firm of Lake, A.P.C., counsel for Plaintiff, Paul D. Ceglia. I am licensed to practice law before the courts of the state of California and the District Court for the Western District of New York. 2. I make this declaration in support of this motion for a continuance upon personal knowledge. 3. On June 28, 2011, DLA Piper LLP, formerly counsel of record for Mr. Ceglia, filed a Notice of Substitution of Counsel (Doc. No. 75) substituted me and my law firm into this case as Mr. Ceglia’s new counsel of record. 4. At this time, Mr. Ceglia is interviewing law firms in order to obtain additional new counsel to appear in this case. 5. As a result of my recent retention, I have not had time to prepare adequately for the hearing scheduled on June 30, 2011 because of my short time as counsel of record in this case. 6. At approximately 1:40 p.m. EST, I personally called Orin Snyder, Esq., counsel of record for Defendants Mark Zuckerberg and Facebook, and requested that he stipulate to continue the subject hearing for three weeks for the reasons set forth herein. Mr. Snyder refused to enter into the proposed stipulation. I declare under penalty of perjury that the foregoing is true and correct. Executed this 29th day of June, 2011. JEFFREY A. LAKE, A.P.C. By: s/ Jeffrey A. Lake___________ 835 5th Avenue, Suite 200A San Diego, California 92101 (619) 795-6460 jlake@lakeapc.com Attorneys for Plaintiff Paul Ceglia

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