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

Filing 195

Plaintiff's MOTION To Substitute Newly Redacted Versions of Motion to Compel the Deposition of Andrei Ianakov in Place of Publicly Filed Versions re 184 Plaintiff's MOTION to Compel Deposition of [REDACTED] by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc.. (Attachments: # 1 Exhibit Attachment A, # 2 Exhibit Attachment B, # 3 Exhibit Attachment C, # 4 Exhibit Attachment D, # 5 Exhibit Attachment E, # 6 Exhibit Attachment F, # 7 Exhibit Attachment G, # 8 Exhibit Attachment H, # 9 Exhibit Attachment I, # 10 Text of Proposed Order)(Stetson, Karen)

ATTACHMENT D

EXHIBIT A

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 11-20427-WILLIAMS/TURNOFF
- - - - - - - - - - - - - - - - - - - - - - - - - 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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Plaintiff,
v.
HOTFILE CORP., ANTON
TITOV, and DOES 1-10,

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Defendants.

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HOTFILE CORP.,
Counterclaimant,
v.
WARNER BROS ENTERTAINMENT
INC.,
Counterdefendant.
- - - - - - - - - - - - - - - - - - - - - - - - VOLUME I
H I G H L Y C O N F I D E N T I A L
(Pursuant to protective order, the following
transcript has been designated highly confidential)
30(b)(6) DEPOSITION OF ANTON TITOV
Radisson Blu Hotel
Sofia, Bulgaria
Monday, December 5, 2011
Job Number: 44174
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A.

General operations would be -- begin once the site

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starts operating.

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development, in my understanding.

Everything else before that is

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Q.

Okay.

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A.

Do you agree?

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Q.

That's fair enough.

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A.

So, from the beginning or almost from the beginning,

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Andre Ianakov would be responsible for communications

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with users, and handling DMCA takedown notices.

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Q.

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MR. THOMPSON:

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Is Mr. Ianakov a manager?
Objection, vague.

Calls for a legal

conclusion.

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BY MR. FABRIZIO:

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Q.

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Let me ask it this way:

Does Mr. Ianakov have a title

at Hotfile?

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A.

I don't think anybody at Hotfile really has a title.

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Q.

Is Mr. Ianakov employed by Hotfile Corporation?

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A.

He's employed by

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but works -- he does

work for Hotfile Corporation, yes.
Q.

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To your knowledge, does he perform work for any other
company?

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A.

I am not aware of any.

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Q.

And you said communicates with users and DMCA takedown

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notices.

Does Mr. Ianakov have any other general
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operations responsibilities?
A.

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I don't think anything else would be -- could be defined
as his responsibility.

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Q.

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A.

He started helping Andre Ianakov in spring 2010,
I believe.

Q.

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assume responsibilities for general

operations?

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When did Mr.

So prior to spring of 2010, it was just Mr. Ianakov
handling operations?

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I'm not sure of what your definition of "operations" is.

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He was handling communications with users and, again,

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DMCA takedown notices.

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Q.

Did Mr. Ianakov report to anybody else?

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MR. THOMPSON:

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A.

Objection, vague.

I don't think he -- we have strictly defined reporting

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structure, but it is my impression that he would

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normally report to

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technical problems would be reported to me.

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Q.

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MR. THOMPSON:

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A.

And of course

BY MR. FABRIZIO:

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Professionally, you were Mr. Ianakov's superior?
Objection, vague and ambiguous.

I consider myself superior to Mr. Ianakov.

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BY MR. FABRIZIO:

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Q.

If you gave him instructions about things to do with

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Hotfile, you would expect him to carry them out because

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you told him to, correct?

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MR. THOMPSON:

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A.

Objection, overbroad.

I would expect so.

But to the extent if he thinks that

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instruction I'm giving him he's considering unimportant,

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he show choice, he would probably ask if I conferred

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with

and probably

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BY MR. FABRIZIO:

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Q.

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Okay.

Other than Mr. Ianakov and eventually Mr.

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has anybody else worked on the general operations of

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Hotfile?

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MR. THOMPSON:

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A.

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Objection, vague.

It really depends what you -- how you define "general
operations."

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BY MR. FABRIZIO:

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Q.

Well, how do you define "general operations"?

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A.

This is my first time defining general operations, but

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I would say things that had to be done day to day.
Q.

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All right.
and

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With that definition, other than Mr. Ianakov

, was there anybody else?

To the extent that Hotfile servers require and required

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maintenance, and that we would be needing off on

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provisioning of new servers at first, I was dealing with

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these tasks.

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Hotfile Corp., and the more he -- he started performing

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most of the these duties.

And since

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started working for

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