Ceglia v. Zuckerberg et al

Filing 91

MOTION to Compel Defendant Zuckerberg's Compliance with the Court's Order of July 1, 2011 by Paul D. Ceglia. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Text of Proposed Order, # 8 Certificate of Service)(Lake, Jeffrey)

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Exhibit “B” Case 1:10-cv-00569-RJA -LGF Document 88 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ------------------------------------ x : PAUL D. CEGLIA, : : Plaintiff, : : v. : : MARK ELLIOT ZUCKERBERG and : FACEBOOK, INC., : : Defendants. ------------------------------------ x Filed 07/15/11 Page 1 of 2 DECLARATION OF PAUL D. CEGLIA Civil Action No. 1:10-cv-00569RJA I, Paul D. Ceglia, being over the age of 21, and pursuant to this Court’s Order regarding Expedited Discovery dated July 1, 2011, hereby declare under penalty of perjury: 1. I am the Plaintiff (“Plaintiff”) in the above captioned matter and make this Declaration pursuant to this Court’s Order regarding Expedited Discovery dated July 1, 2011. 2. As required by the Court’s July 1, 2011 Order, I hereby identify all computers and electronic media in my possession, custody or control, including without limitation and the electronic assets listed in Paragraph 6 of the Declaration of John H. Evans, dated June 17, 2011 as follows: A. As currently possessed by the Sylint Group in Sarasota, Florida i. One (1) Seagate 120GB internal hard drive SN: 3JT1JQF6 ii. One (1) Maxtor 300GB external USB drive SN: L42PMZBG iii. Five (5) 3.5” floppy disks iv. Twelve (12) CD/DVDs B. As currently possessed by the Project Leadership Associates, Chicago i. One (1) Toshiba laptop SN: 69500395Q ii. 169 3.5” floppy disks Case 1:10-cv-00569-RJA -LGF Document 88 Filed 07/15/11 Page 2 of 2 iii. 1075 CD/DVDs iv. An electronic image of a one (1) Seagate 120GB internal hard drive SN: 3JT1JQF6 C. As currently possessed by Paul Argentieri, Esq. in Buffalo, New York i. One Compaq SR5000 computer SN: 3CR8190BXZ with Samsung hard drive, SN: S19JJ1DQ400135. 3. I hereby certify that all such computers and electronic media are being produced for inspection to Defendants on July 15, 2011and that such computers and electronic media contain all the electronic communications I have had with Defendants regarding the claims set forth in the First Amended Complaint for this matter filed on April 11, 2011. I hereby certify and declare under penalty of perjury that the foregoing is true and accurate. DATED: July 15, 2011 /s/ Paul D. Ceglia__ Paul D. Ceglia 2

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