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

Filing 336

NOTICE by Hotfile Corp., Anton Titov Notice of Defendants Hotfile Corporation and Anton Titov of Scrivener's Error In the Motion and Memorandum of Law of Defendants to Strike the Declaration of Jennifer V. Yeh Filed In Support of Plaintiffs' Motion for Summary Judgment and to Strike Any References In Plaintiffs' Motion for Summary Judgment or Statement of Facts to the Yeh Declaration and Its Attachments (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.
____________________________________/
HOTFILE CORP.,
Counterclaimant,
v.
WARNER BROS. ENTERTAINMENT INC.,
Counter-Defendant.
____________________________________/
NOTICE OF DEFENDANTS HOTFILE CORPORATION AND
ANTON TITOV OF SCRIVENER’S ERROR IN THE MOTION
AND MEMORANDUM OF LAW OF DEFENDANTS TO
STRIKE THE DECLARATION OF JENNIFER V. YEH FILED
IN SUPPORT OF PLAINTIFFS’ MOTION FOR SUMMARY
JUDGMENT AND TO STRIKE ANY REFERENCES IN PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT OR STATEMENT OF
FACTS TO THE YEH DECLARATION AND ITS ATTACHMENTS

CASE NO. 11-20427-WILLIAMS-TURNOFF

Defendants, Hotfile Corporation and Anton Titov (collectively “Defendants”), hereby
give notice of a scrivener’s error in their Motion to Strike the Declaration of Jennifer V. Yeh
Filed in Support of Plaintiffs’ Motion for Summary Judgment and to Strike Any Reference in
Plaintiffs’ Motion for Summary Judgment or Statement of Facts to the Yeh Declaration and its
Attachments. The Certificate of Good Faith Attempt to Resolve the Motion was unintentionally
omitted from the filed version of the Motion to Strike, filed March 7, 2012. Undersigned
counsel apologizes for the error and requests that the Court accept the attached Certificate of
Good Faith Attempt to Resolve that is attached hereto as Exhibit “A.”

DATED: March 8, 2012

Respectfully submitted,

s/ Janet T. Munn
Janet T. Munn, Esq. Fla. Bar No. 501281
Email: [e-mail]
RASCO KLOCK
283 Catalonia Avenue, Suite 200
Coral Gables, Fl 33134
Telephone: [phone]
Telecopy: 305.476.7102
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 March 8, 2012, a true and correct copy of 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.
Karen L. Stetson, Esq.
GRAY-ROBINSON, P.A.
Email: [e-mail]
1221 Brickell Avenue
Suite 1600
Miami, FL 33131
Telephone: [phone]
Telecopy: 305.416.6887

Karen R. Thorland, Esq. (admitted pro hac vice)
Senior Content Protection Counsel
Email: [e-mail]
Motion Picture Association of America, Inc.
15301 Ventura Boulevard, Building E
Sherman Oaks, CA 91403-5885
Telephone: [phone]

Steven B. Fabrizio, Esq. (admitted pro hac vice)
Email: [e-mail]
Duane C. Pozza, Esq. (admitted pro hac vice)
Email: [e-mail]
Luke C. Platzer, Esq. (admitted 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
By: /s/ Janet T. Munn
Janet T. Munn

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CASE NO. 11-20427-WILLIAMS-TURNOFF

EXHIBIT “A”

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CASE NO. 11-20427-WILLIAMS-TURNOFF

CERTIFICATE OF GOOD FAITH ATTEMPT TO RESOLVE
Pursuant to Local Rule 7.1(a)(3)(A), I hereby certify that on March 5, 2012, prior to
filing this motion, as counsel for the movant, I, N. Andrew Leibnitz, Esq., conferred with Duane
Pozza, Esq., counsel for Plaintiffs, in a good faith effort to resolve the issues raised in this
motion, but was unable to resolve the issues and that Plaintiffs oppose this motion.
s/ N. Andrew Leibnitz
N. Andrew Leibnitz, Esq.

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