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 G

EXHIBIT D

HIGHLY CONFIDENTIAL

Page 555
1

2
3

4

5

6

7

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.,

8
9
10
11

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

12
13

Defendants.

14
15
16
17
18

19
20

21

22
23

24

25

HOTFILE CORP.,
Counterclaimant,
v.
WARNER BROS ENTERTAINMENT
INC.,
Counterdefendant.
- - - - - - - - - - - - - - - - - - - - - - - - VOLUME IV
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
Thursday, December 8, 2011
Job #44430
AT: 9:10 a.m.
TSG Reporting - Worldwide

877-702-9580

HIGHLY CONFIDENTIAL

Page 637

3

Q.

Does Hotfile have a Twitter account?

4

A.

I believe so.

5

Q.

Okay.

6

What's the Twitter account name?

What's the

handle?

7

Maybe I can help you, it's not a memory game.

8

Is it

"hotfile_site"?

9

A.

Maybe.

10

Q.

And who tweets through that Hotfile Twitter account?

11

MR. THOMPSON:

Objection, vague.

12

MR. FABRIZIO:

Maybe to you, but undoubtedly not to him.

13

A.

14

BY MR. FABRIZIO:

15

Q.

Anybody else?

16

A.

I don't believe so.

17

Q.

Okay.

I can't remember.

That would be Mr. Ianakov.

And is he -- is that part of -- is that something

18

he's permitted to do as part of his job responsibility

19

for Hotfile?

20

MR. THOMPSON:

21

A.

22

Objection, assumes facts.

I have impression that Mr.

allowed him to do

so, yes.

TSG Reporting - Worldwide

877-702-9580

HIGHLY CONFIDENTIAL

Page 674
1

complaint --

2

MR. THOMPSON:

Okay.

3

MR. FABRIZIO:

-- with the court ECF stamp on top.

4

BY MR. FABRIZIO:

5

Q.

Mr. Titov, is exhibit 167 a true and correct copy of the

6

Hotfile FAQ web page from the time period of

7

around February 2011?

8

A.

Actually there's a time stamp at the bottom indicating

10

Q.

Oh.

Oh, there we go.

So this is a true and correct

11

copy of the Hotfile FAQ page as it appeared on the

12

Hotfile website in the July 2010 timeframe?

13

MR. THOMPSON:

Objection, calls for a legal conclusion, and

14

I assume you mean excluding the court stamps and the

15

like?

16

MR. FABRIZIO:

17

A.

18

BY MR. FABRIZIO:

19

Q.

20

Yes.

I don't have any reasons to believe it is not.

Okay.

Are you aware that the -- strike that.

Did the FAQ page change between July of 2010

21

and February of 2011?

22

MR. THOMPSON:

23

A.

24

BY MR. FABRIZIO:

25

Q.

Objection, overbroad and vague.

I don't know.

Okay.

If you look at the third page of the exhibit,

TSG Reporting - Worldwide

877-702-9580

HIGHLY CONFIDENTIAL

Page 675
1

it's the one in the upper right marked "Page 4 of 5"

2

there, under the question -- well, first of all, who

3

wrote the questions and answers to the Hotfile FAQ?

4

A.

I believe it would be Andre Ianakov.

5

Q.

Did you review them?

6

A.

No, I did not.

7

Q.

Okay.

8

A.

No.

9

Q.

He was perfectly within his rights to write these and

10
11

put them up on the website?
MR. THOMPSON:

12
13

Did you have to approve them?

Objection, vague and ambiguous, calls for

a legal conclusion.
A.

You mean since he's the one who is responding to the

14

query in the email, he's really the person who would

15

know what frequently questions are in reality, so

16

I think he was being given this task.

TSG Reporting - Worldwide

877-702-9580