Disney Enterprises, Inc. et al v. Hotfile Corp. et al

Filing 141

REPLY to Response to Motion re 108 Plaintiff's MOTION to Compel RESPONSES TO SUBPOENA TO THIRD PARTY LEMURIA COMMUNICATIONS, INC. filed by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc.. (Attachments: # 1 Exhibit 1-Declaration of Duane C. Pozza in Support of Reply Memorandum in Support of Motion to Compel from Lemuria, # 2 Exhibit A to Declartion of Duane C. Pozza, # 3 Exhibit B to Declaration of Duane C. Pozza)(Stetson, Karen)

EXHIBIT 1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20427-JORDAN

DISNEY ENTERPRISES, INC.,
TWENTIETH CENTURY FOX FILM CORPORATION,
UNIVERSAL CITY STUDIOS PRODUCTIONS LLLP,
COLUMBIA PICTURES INDUSTRIES, INC., and
WARNER BROS. ENTERTAINMENT INC.,

Plaintif,
v.

HOTFILE CORP., ANTON TITOV, and
DOES 1-10.
Defendants.

/

REPL Y DECLARATION OF DUANE C. POZZA IN SUPPORT OF PLAINTIFFS'
REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL RESPONSES TO
SUBPOENA TO THIRD PARTY LEMURIA COMMUNICATIONS, INC.
I, Duane C. Pozza, hereby declare as follows:
1. I am a partner at the law firm of Jenner & Block LLP, and counsel to the plaintiffs

Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios
Productions LLLP, Columbia Pictures Industries, Inc., and Warner Bros. Entertainment Inc.
Plaintiffs' Motion to Compel Responses to

("plaintiffs"). I submit this declaration in support of

Subpoena to Third Party Lemuria Communications, Inc ("Lemuria"). The statements made in
this declaration are based on my personal knowledge.
2. Attached hereto as Exhibit A is a redacted copy of an email bates labeled

Webazilla 0664, produced by Webazilla, LLC ("Webazila"). This document has been
the Protective Order entered in this case.

designated as "Confidential" according to the terms of

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The unredacted version of the document has been designated as "Confidential" according to the
terms of

the Protective Order entered in this case, but counsel for Webazilla has consented to

plaintiffs publicly filing this document with the indicated redactions.
3. Attached hereto as Exhibit B is a redacted copy of a document bates labeled

Webazila 0076-77, produced by third party Webazilla. The unredacted version of the document
has been designated as "Confidential" according to the terms of the Protective Order entered in

this case, but counsel for Webazila has consented to plaintiffs publicly fiing this document with
the indicated redactions.

I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.

Executed on September 9, 2011, at Washington, D.C.

D'-~j~

Duane C. Pozza

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