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

Filing 228

Unopposed MOTION Defendants' Unopposed Motion to Unseal the Recording of the Hearing Held Before United States Magistrate Judge William C. Turnoff on January 13, 2012 and to Permit Transcription of a Written Transcript by Hotfile Corp., Anton Titov. (Attachments: # 1 Exhibit A)(Munn, Janet)

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.,
Plaintiffs,
v.
HOTFILE CORP., ANTON TITOV,
and DOES 1-10.
Defendants.
/
DEFENDANTS’ UNOPPOSED MOTION TO UNSEAL THE RECORDING
OF THE HEARING HELD BEFORE UNITED STATES MAGISTRATE JUDGE
WILLIAM C. TURNOFF ON JANUARY 13, 2012 AND TO PERMIT
TRANSCRIPTION OF A WRITTEN TRANSCRIPT
Defendants Hotfile Corp. and Anton Titov (“Defendants”), move for an order of this
Court to unseal the transcript of the hearing held before United States Magistrate Judge
William C. Turnoff on January 13, 2012 and to allow the U.S. District Court’s court reporter to
prepare a written transcript of the hearing.
1.

On January 13, 2012, a status conference and hearing on various discovery

motions was held before United States Magistrate Judge William C. Turnoff.
2.

Counsel for Defendants has been informed by the court reporter’s office that

because some of the motions were filed under seal, Magistrate Judge Turnoff’s chambers has

CASE NO. 11-20427-WILLIAMS/TURNOFF
instructed the court reporter not to prepare a written transcript of the hearing without an order
from the Court permitting such transcription.
3.

Counsel for Defendants needs to review the written transcript of the hearing in

order to evaluate whether Defendants should file objections to any of the rulings by the Court.
4.

A proposed Order granting Defendants’ unopposed motion to unseal the tapes for

the purpose of permitting the court reporter to prepare a written transcript of the hearing is
attached hereto as Exhibit “A”.
CONCLUSION
On the basis of the foregoing, Defendants respectfully request that this Court grant
Defendants’ unopposed motion to unseal the recording of the hearing held on January 13, 2012,
before United States Magistrate Judge William C. Turnoff, in order to allow the court reporter to
transcribe the recording of the hearing and create a written transcript of the hearing.
CERTIFICATE OF GOOD FAITH CONFERENCE
I hereby certify that counsel for the movant, Janet T. Munn, Esq., conferred with all
parties or non-parties who may be affected by the relief sought in this motion, including
Plaintiffs’ counsel, Karen Stetson, Esq., in a good faith effort to resolve the issues and Plaintiffs’
counsel has advised that Plaintiffs do not oppose the motion.
/s/ Janet T. Munn
Janet T. Munn

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CASE NO. 11-20427-WILLIAMS/TURNOFF
DATED: January 18, 2012

By: /s/ Roderick M. Thompson
Roderick M. Thompson (admitted pro hac vice)
Email: [e-mail]
Andrew Leibnitz (admitted pro hac vice)
Email: [e-mail]
Anthony P. Schoenberg (admitted pro hac vice)
Email: [e-mail]
Deepak Gupta (admitted pro hac vice)
Email: [e-mail]
Janel Thamkul (admitted pro hac vice)
Email: [e-mail]
FARELLA BRAUN + MARTEL LLP
235 Montgomery St.
San Francisco, CA 94104
Telephone: [phone]
Telecopy: 415.954.4480
And
/s/ Janet T. Munn
Janet T. Munn, Fla. Bar No. 501281
Email: [e-mail]
Rasco Klock
283 Catalonia Avenue, Suite 200
Coral Gables, Fl 33134
Telephone: [phone]
Telecopy: 305.476.7102
And
/s/Valentin Gurvits
Valentin Gurvits (admitted pro hac vice)
Email: [e-mail]
BOSTON LAW GROUP
825 Beacon Street, Suite 20
Newton Center, MA 02459
Telephone: [phone]
Telecopy: 617.928.1802
Counsel for Defendants Hotfile Corporation
and Anton Titov

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CASE NO. 11-20427-WILLIAMS/TURNOFF

CERTIFICATE OF SERVICE
I hereby certify that on January 18, 2012, the foregoing document was served on all
counsel of record or pro se parties identified below either via transmission of Notices of
Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or
parties who are not authorized to receive electronically Notices of Electronic Filing.
By: /s/Janet T. Munn
Janet T. Munn

Karen L. Stetson, Fla. Bar No.: 742937
GRAY-ROBINSON, P.A.
Email: [e-mail]
1211 Brickell Avenue
Suite 1600
Miami, FL 33131
Telephone: [phone]
Telecopy: 305.416.6887

Karen R. Thorland, Esq. (Pro Hac Vice)
Senior Content Protection Counsel
Motion Picture Association of America, Inc.
15301 Ventura Boulevard Building E
Sherman Oaks, CA
Telephone: [phone]
Email: [e-mail]

Steven B. Fabrizio (Pro Hac Vice )
Email: [e-mail]
Duane C. Pozza (Pro Hac Vice )
Email: [e-mail]
Luke C. Platzer (Pro Hac Vice )
Email: [e-mail]
JENNER AND BLOCK, LLP
1099 New York Ave, N.W.
Suite 900
Washington, DC 20001
Telephone: [phone]
Telecopy: 202.639.6066

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