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)

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EXHIBIT 6 Highly Confidential Page 1 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 11-20427-WILLIAMS/TURNOFF 2 3 4 5 6 7 8 DISNEY ENTERPRISES, INC., TWENTIETH CENTURY FOX FILM CORPORATION, UNIVERSAL CITY STUDIOS PRODUCTIONS LLLP, COLUMBIA PICTURES INDUSTRIES, INC., and WARNER BROS. ENTERTAINMENT, INC., 9 Plaintiffs, 10 v. 11 . 12 13 HOTFILE CORP., ANTON TITOV, and DOES 1-10 Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 14 15 16 17 HIGHLY CONFIDENTIAL (Pursuant to protective,order, the following transcript has been designated highly confidential) 18 19 20 21 30(B)(6) DEPOSITION OF ANTON TITOV LOS ANGELES, CALIFORNIA THURSDAY, NOVEMBER 17, 2011 22 23 24 25 REPORTED BY: Alejandria E. Kate CSR NO. 11897, HI 448, RPR, CLR JOB NO.: 44003 TSG Reporting - Worldwide 800-702-9580 Highly Confidential Page 22 1 it's not on the record. I'm sorry. MR. FABRIZIO: It's all right. We'll just try 2 3 again. 4 07:33 07:33 07:33 MR. THOMPSON: Mr. Fabrizio, how about the 07:33 5 reporter reads back what she got so Mr. Titov can then 07:33 6 fill in. 07:33 7 MR. FABRIZIO: 8 (Record read.) 07:33 9 THE WITNESS: Okay. First, is the second word 07:33 That makes sense. 07:33 10 "started"? Because I believe I said "studied" or 07:33 11 "discussed" or something like that, not "started." 07:33 12 MR. FABRIZIO: I think he did. 07:34 13 THE WITNESS: And there's some pretty big 07:34 14 organizations and you -- encounter that will just use a 07:34 15 couple IP of addresses to -- the users will -- 07:34 16 (Reporter clarification.) 07:34 17 THE COURT REPORTER: Okay. I'm sorry -- 07:34 18 MR. FABRIZIO: Hold it. Okay. A couple of IP 07:34 19 addresses. 20 07:34 THE COURT REPORTER: I can't keep doing this 07:34 21 because it's going to be so choppy, it's not going to -- 07:34 22 it's making it difficult. If we use the interpreter -- 07:34 23 MR. FABRIZIO: No. 07:34 24 THE COURT REPORTER: -- it would be so much 07:34 25 cleaner. 07:34 TSG Reporting - Worldwide 800-702-9580

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