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

Filing 190

MEMORANDUM in Opposition re 184 Plaintiff's MOTION to Compel Deposition of [REDACTED] Defendants' Memorandum of Law In Opposition to Plaintiffs' Motion to Compel the Deposition of Andrei Ianakov by Hotfile Corp., Anton Titov. (Attachments: # 1 Exhibit 1, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit 2)(Munn, Janet)

EXHIBIT A

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09:34 Q. Is Mr.Ianakov employed by Hotfile Corporation?

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09:34 A. He's employed by Blue Ant elemented but works for

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09:35

Hotfile Corporation.

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09:36 Q. Does anybody else have responsibility for general

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09:36

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09:36 A. At a certain point, gStanislav Marnov.

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09:36 Q. And that's'S'IANIELAVMANOV?

operations of Hotfile?

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09:36 A.

Exactly.

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09:36 Q.

When did Mr. Marnov assume responsibilities for general

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09:36

operations?

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09:36 A:

He started helping Andre Yanakov in spring ten,

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09:37

I believe.

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09:37 Q.

So prior to spring of 2010 it was just Mr.

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09:37

handling operations?

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09:37 A.

I'm not sure of what your definition of operations is,

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09:37

he was handling communications with users and, again

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09:37

DMCA take down notice the.

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Ianakov

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14:14 Q.

As between Chubarov, Kolev and Ianakov, do you consider

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14:14

any of them managers in that they supervise the others?

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14:15 MR. THOMPSON: Objection, vague.

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14:15 A.

I don't think so.

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15:01 Q. Does Mr. Stoyanov supervise Mr. Chubarov, Mr. Kolev and

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15:01

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15:01 A. Chubarov Kolev and Ianakov, yes.

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15:01 Q. And Mr. Stoyanov supervises those gentlemen?

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15:01 A. Yes, he does.

Mr. Ianakov as well?

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