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)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK

PAUL D. CEGLIA,
Plaintiff,
vs.
MARK ELLIOT ZUCKERBURG and
FACEBOOK, INC.,
Defendants.

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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
[phone]
[e-mail]
Attorneys for Plaintiff Paul
Ceglia