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)

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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., 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 2 CASE NO. 11-20427-WILLIAMS/TURNOFF DATED: January 18, 2012 By: /s/ Roderick M. Thompson Roderick M. Thompson (admitted pro hac vice) Email: rthompson@fbm.com Andrew Leibnitz (admitted pro hac vice) Email: aleibnitz@fbm.com Anthony P. Schoenberg (admitted pro hac vice) Email: tschoenberg@fbm.com Deepak Gupta (admitted pro hac vice) Email: dgupta@fbm.com Janel Thamkul (admitted pro hac vice) Email: jthamkul@fbm.com FARELLA BRAUN + MARTEL LLP 235 Montgomery St. San Francisco, CA 94104 Telephone: 415.954.4400 Telecopy: 415.954.4480 And /s/ Janet T. Munn Janet T. Munn, Fla. Bar No. 501281 Email: jmunn@rascoklock.com Rasco Klock 283 Catalonia Avenue, Suite 200 Coral Gables, Fl 33134 Telephone: 305.476.7101 Telecopy: 305.476.7102 And /s/Valentin Gurvits Valentin Gurvits (admitted pro hac vice) Email: vgurvits@bostonlawgroup.com BOSTON LAW GROUP 825 Beacon Street, Suite 20 Newton Center, MA 02459 Telephone: 617.928.1800 Telecopy: 617.928.1802 Counsel for Defendants Hotfile Corporation and Anton Titov 3 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: karen.stetson@gray-robinson.com 1211 Brickell Avenue Suite 1600 Miami, FL 33131 Telephone: 305.416.6880 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: 818.935.5812 Email: Karen_Thorland@mpaa.org Steven B. Fabrizio (Pro Hac Vice ) Email: sfabrizio@jenner.com Duane C. Pozza (Pro Hac Vice ) Email: dpozza@jenner.com Luke C. Platzer (Pro Hac Vice ) Email: lplatzer@jenner.com JENNER AND BLOCK, LLP 1099 New York Ave, N.W. Suite 900 Washington, DC 20001 Telephone: 202.639.6000 Telecopy: 202.639.6066 4

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