Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
390
NOTICE by Hotfile Corp., Anton Titov Defendants' Notice of Filing the Publicly Filed Redacted Version of the Declaration of Andrew Leibnitz and Exhibits Thereto, Filed in Support of Defendants' Opposition to Plaintiffs' Motion for Summary Judgment and Exhibits Thereto (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34, # 36 Exhibit 35, # 37 Exhibit 36, # 38 Exhibit 37)(Munn, Janet)
EXHIBIT 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
DISNEY ENTERPRISES, INC.,
TWENTIETH CENTURY FOX FILM
CORPORATION, UNIVERSAL CITY
STUDIOS PRODUCTIONS LLLP,
COLUMBIA PICTURES INDUSTRIES,
INC., and WARNER BROS.
ENTERTAINMENT INC.,
Plaintiffs,
vs.
CASE NO. 11-20427-WILLIAMS-TURNOFF
HOTFILE CORP., ANTON TITOV,
and DOES 1-10,
Defendants.
__________________________
AND RELATED CROSS-ACTION.
_______________________________________________________
HIGHLY CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
VIDEOTAPED DEPOSITION OF LANCE R. GRIFFIN, ESQUIRE
PURSUANT TO FEDERAL RULE 30(b)(6)
Los Angeles, California
Thursday, December 22, 2011
Reported by:
LORI SCINTA, RPR
CSR No. 4811
Job No. 178940
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
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UNITED STATES DISTRICT COURT
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12/22/2011
SOUTHERN DISTRICT OF FLORIDA
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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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Plaintiffs,
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vs.
CASE NO. 11-20427-WILLIAMS-TURNOFF
HOTFILE CORP., ANTON TITOV,
and DOES 1-10,
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Defendants.
__________________________
AND RELATED CROSS-ACTION.
______________________________________________________
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HIGHLY CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
Videotaped deposition of LANCE R. GRIFFIN,
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ESQUIRE, pursuant to Federal Rule 30(b)(6), taken on
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behalf of Defendants and Counterclaimant Hotfile Corp.,
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at 633 West Fifth Street, Suite 3600, Los Angeles,
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California, beginning at 9:47 A.M. and ending at
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4:49 P.M. on Thursday, December 22, 2011, before
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LORI SCINTA, RPR, Certified Shorthand Reporter No. 4811.
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LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
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12/22/2011
APPEARANCES:
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For Plaintiffs:
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JENNER & BLOCK LLP
BY: STEVEN B. FABRIZIO
Attorney at Law
1099 New York Avenue, NW, Suite 900
Washington, D.C. 20001-4412
202.639.6000
Email: sfabrizio@jenner.com
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-- and -9
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THE WALT DISNEY COMPANY
BY: GORDON GOLDSMITH
Attorney at Law
500 South Buena Vista Street
Burbank, California 91521-0641
818.560.7893
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For Defendants and Counterclaimant Hotfile Corp.:
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FARELLA BRAUN + MARTEL LLP
BY: ANTHONY SCHOENBERG
Attorney at Law
235 Montgomery Street
San Francisco, California 94104
415.954.4400
Email: tschoenberg@fbm.com
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Videographer:
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VONYARN MASON
SARNOFF COURT REPORTERS
20 Corporate Park, Suite 350
Irvine, California 92606
877.955.3855
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3
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
12:36
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not certain.
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BY MR. SCHOENBERG:
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filtering technology the fact that it has populated with
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its fingerprints any particular -- let me rephrase this
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to utilize a digital fingerprinting preupload filtering
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technology, how would I know which vendor to go to to
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ensure that I was filtering Disney's fingerprints?
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THE WITNESS:
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could ask the vendor.
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BY MR. SCHOENBERG:
12:37
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testimony, calls for speculation.
THE WITNESS:
Q
No, I'm -- I'm just saying I'm
And preupload filtering -- let me -- let me
rephrase this question.
Does Disney communicate to users of preupload
question.
If I ran a -- if I ran a website and I wanted
MR. FABRIZIO:
Objection.
Incomplete
hypothetical.
Q
My understanding is that you
Does Disney communicate that information to the
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LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
03:35
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03:35
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MR. SCHOENBERG:
03:35
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MR. FABRIZIO:
03:35
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THE WITNESS:
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response to the interrogatory.
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BY MR. SCHOENBERG:
03:35
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Q
Other than the response to the interrogatory?
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A
I'm not aware.
03:35
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MR. FABRIZIO:
03:35
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THE WITNESS:
03:35
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03:35
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03:35
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A
Yes.
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Q
Did Disney ever communicate anything to Hotfile
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regarding the use of preupload filtering to control
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infringement other than what might be in that
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interrogatory response?
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03:36
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recommendations regarding a repeat infringer policy?
MR. FABRIZIO:
I take it, Counsel, you're
speaking of before this litigation began.
At any time.
Objection.
Vague as to time.
Well, I know that we have this
Same objections.
I'm not aware.
BY MR. SCHOENBERG:
Q
Okay.
And the first thing you mentioned was
preupload filtering.
MR. FABRIZIO:
Same objection as to vague as to
pre- or post-complaint.
164
LANCE R. GRIFFIN, ESQ. 12/22/2011
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
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ERRTA SHEET
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~Sarnoft 208
877.955.3855
LANCE R. GRIFFIN, ESQ.
HIGHLY CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
12/22/2011
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I, the undersigned, a Certified Shorthand
Reporter of the State of California, do hereby certify:
That the foregoing proceedings were taken
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before me at the time and place herein set forth; that
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any witnesses in the foregoing proceedings, prior to
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testifying, were duly sworn; that a record of the
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proceedings was made by me using machine shorthand
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which was thereafter transcribed under my direction;
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that the foregoing transcript is a true record of the
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testimony given.
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Further, that if the foregoing pertains to
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the original transcript of a deposition in a Federal
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Case, before completion of the proceedings, review of
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the transcript [X] was [ ] was not requested.
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I further certify I am neither financially
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interested in the action nor a relative or employee
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of any attorney or party to this action.
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IN WITNESS WHEREOF, I have this date
subscribed my name.
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Dated: 12/29/2011
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________________________________
LORI SCINTA, RPR
CSR No. 4811
209
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