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)

EXHIBIT 6

Highly Confidential

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20427-WILLIAMS/TURNOFF

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

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

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HIGHLY CONFIDENTIAL
(Pursuant to protective,order, the following
transcript has been designated highly confidential)

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30(B)(6) DEPOSITION OF ANTON TITOV
LOS ANGELES, CALIFORNIA
THURSDAY, NOVEMBER 17, 2011

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REPORTED BY:
Alejandria E. Kate
CSR NO. 11897, HI 448, RPR, CLR
JOB NO.: 44003
TSG Reporting - Worldwide 800-702-9580

Highly Confidential

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it's not on the record. I'm sorry.
MR. FABRIZIO: It's all right. We'll just try

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again.

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07:33
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MR. THOMPSON: Mr. Fabrizio, how about the

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reporter reads back what she got so Mr. Titov can then

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fill in.

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MR. FABRIZIO:

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(Record read.)

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THE WITNESS: Okay. First, is the second word

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That makes sense.

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"started"? Because I believe I said "studied" or

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"discussed" or something like that, not "started."

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MR. FABRIZIO: I think he did.

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THE WITNESS: And there's some pretty big

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organizations and you -- encounter that will just use a

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couple IP of addresses to -- the users will --

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(Reporter clarification.)

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THE COURT REPORTER: Okay. I'm sorry --

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MR. FABRIZIO: Hold it. Okay. A couple of IP

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addresses.

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THE COURT REPORTER: I can't keep doing this

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because it's going to be so choppy, it's not going to --

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it's making it difficult. If we use the interpreter --

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MR. FABRIZIO: No.

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THE COURT REPORTER: -- it would be so much

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cleaner.

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TSG Reporting - Worldwide 800-702-9580