Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
171
MEMORANDUM of Law re 165 Plaintiff's MOTION FOR ONE ADDITIONAL EXAMINATION DAY FOR RULE 30(b)(6) DEPOSITION OF DEFENDANT HOTFILE CORPORATION of Defendants Hotfile Corporation and Anton Titov In Opposition to Plaintiffs' Motion to Depose Anton Titov Individually and as Hotfile's Rule 30(b)(6) Witness For Over Four Days and Defendants' Cross-Motion for Protective Order Limiting the Depositions of Hotfile Witnesses Including Mr. Titov by Hotfile Corp., Anton Titov. (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit B)(Munn, Janet)
EXHIBIT 9
Leibnitz, Andrew (21) x4932
From:
Sent:
To:
Cc:
Subject:
Attachments:
Pozza, Duane [DPozza@jenner.com ]
Thursday, September 29, 2011 8:57 PM
Thompson, Rod (27) x4445; Leibnitz, Andrew (21) x4932; Schoenberg, Tony (28) x4963;
Gupta, Deepak (22) x4419; Thamkul, Janel (28) x4467; Janet Munn;
vgurvits@bostonlawgroup.com
Fabrizio, Steven B; Platzer, Luke C
Disney Enterprises, Inc. v. Hotfile Corp. -- Plaintiffs' Notice of Depositions
Plaintiffs' Notice of Deposition of Andrei lanakov.pdf; Plaintiffs' Notice of Deposition of Atanas
Vangelov.pdf; Plaintiffs' Notice of Deposition of Deian Chuburov.pdf; Plaintiffs' Notice of
Deposition of Rumen Stoyanov.pdf; Plaintiffs' Notice of Deposition of Stanislav Manov.pdf
Counsel,
Please see the attached notices of deposition. We have specified dates•here as required by the Federal Rules, but we
are willing to work with the witnesses' schedules to find other dates if these are not convenient. That said, until we can
reach agreement on alternative dates, these dates should be considered operative. Please do advise us immediately if
defendant Hotfile Corp. does not intend to voluntarily produce any of these witnesses in Miami for any reason, and if so,
the bases on which they will not be produced, so that we can file any motion to compel as appropriate.
Regards,
Duane
Duane Pozza
Jenner & Block LLP
1099 New York Avenue, N.W.
Suite 900
Washington, DC 20001-4412
Tel (202) 639-6027
Fax (202) 661-4962
DPozzaAjenner.com
www.ienner.com
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