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

Filing 424

NOTICE by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc. re 423 Plaintiff's MOTION to Strike >PLAINTIFFS' MOTION AND MEMORANDUM OF LAW TO STRIKE PORTIONS OF DECLARATIONS OF PROFESSOR JAMES BOYLE, DR. ANDREW CROMARTY AND ANTON TIVO IN SUPPORT OF DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTIO >NOTICE OF FILING PUBLIC REDACTED VERSION OF DECLARATION OF JENNIFER V. YEH IN SUPPORTT OF PLAINTIFFS' MOTION TO STRIKE< (Attachments: # 1 Affidavit Declaration of Jennifer V. Yeh in Support of Plaintiffs' Motion to Strike, # 2 Exhibit 1 to Declaration of J. Yeh, # 3 Exhibit 2 to Declaration of J. Yeh, # 4 Exhibit 3 to Declaration of J. Yeh, # 5 Exhibit 4 to Declaration of J. Yeh)(Stetson, Karen)

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.,
Counterdefendant.
/
DECLARATION OF JENNIFER V. YEH IN SUPPORT OF PLAINTIFFS’
MOTION TO STRIKE PORTIONS OF DECLARATIONS OF PROFESSOR JAMES
BOYLE, DR. ANDEW CROMARTY, AND ANTON TITOV IN SUPPORT OF
DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR SUMMARY
JUDGMENT

PUBLIC REDACTED VERSION

I, Jennifer V. Yeh, declare as follows:
1.

I am an attorney at the law firm of Jenner & Block LLP, and counsel to the plaintiffs

Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios
Productions LLLP, Columbia Pictures Industries, Inc., and Warner Bros. Entertainment Inc. The
statements made in this declaration are based on my personal knowledge including on
information provided to me by colleagues or other personnel working under my supervision on
this case. If called to testify, I would testify as follows:
2.

Attached hereto as Exhibit 1 is a true and correct copy of excerpts of the deposition of

Professor James Boyle, taken on Dec. 21, 2011 and Jan. 19, 2012 in the above-captioned case.
3.

Attached hereto as Exhibit 2 is a true and correct copy of excerpts of the deposition of

Scott Zebrak, taken on Dec. 20, 2011 and Jan. 20, 2012 in the above-captioned case.
4.

Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the deposition of

defendant Anton Titov, in his personal capacity and as Fed. R. Civ. P. 30(b)(6) representative of
defendant Hotfile Corp., taken from Dec. 5 to Dec. 8, 2011 in the above-captioned case.
5.

Attached hereto as Exhibit 4 is a true and correct copy of Defendants’ Responses to

Plaintiffs’ First Set of Requests for Production, served on May 5, 2011.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 16, 2012.

_____________________________
Jennifer V. Yeh