Disney Enterprises, Inc. et al v. Hotfile Corp. et al
Filing
420
NOTICE by Hotfile Corp., Anton Titov of Filing PUBLICLY FILED REDACTED Version of the Declaration of Janel Thamkul Filed In Support of Memoranda In Support of Motions for Summary Judgment (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)(Munn, Janet)
EXHIBIT 10
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Fabrizio, Steven 8[SFabrizio@jenner.coml
. Sunday, June 05, 2011 8:14 AM
Leibnitz, Andrew (21) x4932; Pozza, Duane; Thompson, Rod. (27) x4445
Schoenberg, Tony (28) x4963; Platzer, luke C
Re: Hotfile - individuals listed in response to Interrogatory No.1
Andy,
We. have not' made final.decisions as to who· we might depose and likely will only. make those
'determination 5 after reviewing defendants' documents_ However ,wi thout prejudice, you' can
assume that we would depose Chuburov, IanakoV,1IIIIIIIII and Manov. Yaucan also assume
that, once we have defendants' consent to voluntarily produce these witnesses in Bulgaria
(assuming that i:s where they are reside)' pursuant to the Federal Rules, we will make proper
arrangements with the Bulgarian auti10ri ties so no one's sovereignty will be insulted ... Having
defendants' consent and stipulation undoubtedly will ~o a long way towards facilitating
.
. arrangements with the consulate. You.can also assume that we will coor·dinate times with an
... concerned so the dates are reasonably convenience for everyone .
As for bringing the .witnesses to theUS, we can of course agree that we wiJl not use their
presence on us soil to serve them with process or otherwise prejudice them (much like we did
whenmeet:i.ng Titov in .Florida for our settlement conference) . . As for the cost issue; we'll
have to check witl1 our clients .. However. for purpose of answering our. questions. assume that
we would reach a mutually agreeable arrangement.on costs, since (despite our mutual desire to
· explore Bulgaria) taking these .depositions in the US would save both our >
Date: Fri j 3 Jun 21311 18:25':55 -135ee'
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· To: Duane Pozza >, Steven
Fabrizio
www.jenner. com '
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