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 C Jo- Rough Transcript Page 16 2 08:42 Q. Well my question was not do you know whether he did 3 08:42 enlist other people, my question was whether he was 4 08:42 authorized by Hotfile to do so if he thought that was i 5 08:42 the best interests of Hotfile? 6 08:42 MR. THOMPSON: Same objections and now asked and answered. 7 08:43 Q. I am not aware if Hotfile permit him to do so. , ti LIWPAJF.A. TSG Reporting - Worldwide 800-702-9580 Rough Transcript Page 55 Li 9 A 10:28 Q. Could those four gentlemen Mrs. Chubarov Kolev Ianakov 10 10:28 or Manov have changed the price at a Hotfile charges for 11 10:28 prey- subsubscription services without consulting with 12 10:28 the shareholders? 13 10:28 MR. THOMPSON: Same objections. 14 10:28 A. No really but I was talking about if there is a currency 15 10:29 conversion bug or something, they might fix it, but not 16 10:29 change the price. 17 10:29 BY MR. FABRIZIO: 18 10:29 Q. Okay, could they change the benefits that Hotfile offers 19 10:29 to premium subscribers has opposed to free subscribers 20 10:29 without consulting with the shareholders? 21 10:29 MR. THOMPSON: General, object, calling for speculation, 22 10:29 23 10:29 A. I don't believe so. overbroad and compound. ‘dr 11.01 TSG Reporting - Worldwide 800-702-9580

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