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

Filing 461

NOTICE by Hotfile Corp., Anton Titov of Filing Publicly Filed Redacted Version of the Declaration of Anthony Schoenberg and Exhibits Thereto, Filed in Support of Defendants' Brief in Support of Motion to Strike Reply Declaration of Dr. Ian Foster in Support of Plaintiffs' Motion for Summary Judgment (Attachments: # 1 Exhibit A, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4)(Munn, Janet)

EXHIBIT “A”

PUBLIC VERSION
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 11-CIV-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.
____________________________________/

DECLARATION OF ANTHONY SCHOENBERG IN SUPPORT OF
DEFENDANTS’ BRIEF IN SUPPORT OF MOTION TO STRIKE REPLY
DECLARATION OF DR. IAN FOSTER IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT

26501\3027469.1

FILED UNDER SEAL
I, Anthony Schoenberg, declare as follows:
1.

I am an attorney at Farella Braun + Martel LLP, counsel for defendants Hotfile

Corporation and Anton Titov. I have personal knowledge of the matters stated herein and, if
called and sworn as a witness, I could and would competently testify to the facts set forth herein.
2.

Attached hereto as Exhibit 1 is a true and correct copy of the Rule 26(a)(2)(B)

Report of Dr. Ian Foster, dated November 18, 2011.
3.

Attached hereto as Exhibit 2 is a true and correct copy of the Rule 26(a)(2)(B)

Rebuttal Report of Dr. Ian Foster, dated January 6, 2012.
4.

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

Plaintiffs' Third Supplemental Interrogatory Responses, Schedule B, dated October 11, 2011.
5.

Attached hereto as Exhibit 4 is a true and correct copy of excerpts from the

deposition of Warner Bros' 30(b)(6) witness, David Kaplan, taken December 14, 2011 in the
above-captioned case.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed on this 12 th of April 2012, at San Francisco, California.
day

Anthony S. oenberg

26501\3027469.1