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

Filing 174

MEMORANDUM of Law re 165 Plaintiff's MOTION FOR ONE ADDITIONAL EXAMINATION DAY FOR RULE 30(b)(6) DEPOSITION OF DEFENDANT HOTFILE CORPORATION Corrected Memorandum of Law 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 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 CONFIDENTIALITY WARNING: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). Any unauthorized use or disclosure of this communication is prohibited. If you believe that you have received this email in error, please notify the sender immediately and delete it from your system. 1

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