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)
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EXHIBIT B
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08:16 Q. Maybe I should put it this way, while he was there,
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08:16
Mr. Manov and through the the period, Mr. Ianakov, were
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they empowered by Hotfile to exercise their direction
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discretion in answering user correspondence?
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08:16 MR. THOMPSON: Objection, vague and calls for a legal
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conclusion.
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08:16 A. I would say to a certain extent.
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08:16 BY MR. FABRIZIO:
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08:16 Q. To a certain extent? What do that mean?
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08:16 MR. THOMPSON: Objection, vague.
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08:17 A. Probably there would be problems that they will address
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to Rumen or to me and if they want me to tell them how
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to solve this problem, they would generally get the idea
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that this is the way that these problems should be
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solved.
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(877) 702-9580
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Page 61
REDACTED
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11:18 A.
No, he is not to does he have any ownership interests
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Hotfile Corporation?
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11:18 A.
No, he does not.
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11:18 Q.
Does he have an ownership interest in Hotfile Ltd?
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11:18 A.
No.
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11:18 Q.
E, he does not.
TSG Reporting - Worldwide
(877) 702-9580
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Page 62
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11:19 Q.
Does Mr. Ianakov receive any portion or percentage of
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Hotfile profits?
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11:19 MR. THOMPSON: Same objection.
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11:20 A.
I don't know for a fact, but I don't believe so.
iii6DAirt ED
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(877) 702-9580
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Page 151
L
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16:48 Q. Is Mr. Ianakov vested with authority to set policy for
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16:48
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16:48 MR. THOMPSON: Objection, vague.
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16:48 A. No, he's not.
Hotfile?
tz. 6ait; tr . ED
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(877) 702-9580
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