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

Filing 69

Joint MOTION for Extension of Time to bring discovery motions JOINT MOTION OF THE PARTIES FOR STIPULATED EXTENSION OF TIME TO BRING DISCOVERY MOTIONS by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Hotfile Corp., Anton Titov, Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc.. Responses due by 6/13/2011 (Attachments: # 1 Text of Proposed Order PROPOSED ORDER)(Stetson, Karen)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 1:11-CIV-20427-JORDAN
DISNEY ENTERPRISES, INC.,
TWENTIETH CENTURY FOX FILM CORPORATION,
UNIVERSAL CITY STUDIOS PRODUCTIONS LLLP,
COLUMBIA PICTURES INDUSTRIES, INC.,
and WARNER BROS. ENTERTAINMENT INC.,
Plaintiffs,
vs.
HOTFILE CORP., ANTON TITOV, and
DOES 1-10.
Defendants.
______________________________________________/
JOINT MOTION AND MEMORANDUM OF LAW OF THE PARTIES FOR
STIPULATED EXTENSION OF TIME TO BRING DISCOVERY MOTIONS
Plaintiffs Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal
City Studios Productions LLLP, Columbia Pictures Industries, Inc., and Warner Bros.
Entertainment Inc. (collectively, “Plaintiffs”) jointly with Defendants Hotfile Corporation and
Anton Titov (collectively, “Defendants”) (Plaintiffs and Defendants are together the “Parties”),
pursuant to Fed. R. Civ. P. 29 and the Local Rules of this Court, hereby stipulate to and jointly
respectfully move for an extension of time to bring discovery motions under Local Rule 26.1(h).
The grounds supporting this Joint Motion are as follows.
MEMORANDUM OF LAW
Pursuant to Local Rule 26.1(h) a party is required to file discovery motions “within thirty
(30) days of the occurrence of grounds for the motion.” See S.D. Fla. L.R, 26.1(h). Plaintiffs’
counsel and Defendants’ counsel have engaged in significant discussions to attempt to resolve

Case No. 1:11-CIV-20427-JORDAN
the parties’ discovery issues prior to bringing motions to the Court, and both believe that the
additional 30 days will assist the parties in fully attempting to reach agreement on discovery
issues in this case and thereby avoid unnecessary motion practice. Therefore, the Parties jointly
request that they be permitted to have sixty (60) days from the date of the occurrence of the
grounds for a discovery motion to file their discovery motions in this action, rather than the
customary thirty (30) days afforded under Local Rule 26.1(h).
To avoid any disruption of the Court’s pre-trial and trial schedule in this case (which has
not yet been set), the Parties request that this additional time for filing discovery motions apply
to those discovery motions filed by the parties, to and including ninety (90) days before the
commence of the trial. The Parties are respectfully proposing that any discovery motions filed
after that deadline would need to comply with the Court’s pre-trial and/or trial order and the
Local Rule time limits.
CONCLUSION
On the basis of the foregoing, the Parties respectfully request that they be given an
extension of time of sixty (60) days to file discovery motions in this case, as a modification of
the thirty (30) day limit imposed by Local Rule 26.1(h), except for any discovery motions that
would be filed less than ninety (90) days prior to the date set for trial of this action. Motions that
are filed less than ninety (90) days prior to trial would be subject to the Court’s pre-trial and/or
trial orders and the Local Rules of this Court. A proposed Order is attached to this Joint Motion
as Exhibit “A” and will also be submitted to the Court by email.
Respectfully submitted,
Dated: May 27, 2011

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Case No. 1:11-CIV-20427-JORDAN
By:
/s/ Karen L. Stetson
Karen L. Stetson, Fla. Bar No. 742937
GRAY-ROBINSON, P.A.
1221 Brickell Avenue
Suite 1600
Miami, FL 33131
Telephone: [phone]
Telecopy: [phone]
Steven B. Fabrizio (Pro Hac Vice)
Duane C. Pozza (Pro Hac Vice)
Luke C. Platzer (Pro Hac Vice)
JENNER & BLOCK LLP
1099 New York Ave., N.W.
Suite 900
Washington, DC 20001
Telephone: [phone]
Telecopy: [phone]
Karen R. Thorland (Pro Hac Vice)
MOTION PICTURE ASSOCIATION
OF AMERICA, INC.
15301 Ventura Blvd.
Building E
Sherman Oaks, CA 91403
Telephone: [phone]
Telecopy: [phone]

By:
/s/ Janet T. Munn
Janet T. Munn, Fla. Bar No. 501281
RASCO KLOCK
283 Catalonia Avenue, Suite 200
Coral Gables, Fl 33134
Telephone: [phone]
Telecopy: 305.476.7102
Roderick M. Thompson (admitted pro hac vice)
Andrew Leibnitz (admitted pro hac vice)
Deepak Gupta (admitted pro hac vice)
Janel Thamkul (admitted pro hac vice)
FARELLA BRAUN + MARTEL LLP
235 Montgomery St.
San Francisco, CA 94104
Telephone: [phone]
Telecopy: 415.954.4480
Valentin Gurvits (admitted pro hac vice)
BOSTON LAW GROUP, PC
825 Beacon Street, Suite 20
Newton Centre, MA 02459
Telephone No.: 617.928.1804
Telecopy No.: 617.928.1802
Attorneys for Defendants

Attorneys for Plaintiffs

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