D. Plaintiff and his counsel hid no information.

Blake Horwitz

Zane Seipler

In the September 14, 2011 deposition of Mr. Seipler, Mr. Horwitz specifically asked Mr. Seipler clear, direct questions as to whether he uploaded the information onto the offending website.

Mr. Sotos admits that the answers were clear. (Sotos TR. at 969.)

Even though Defendants seeks sanctions regarding this deposition (Dkt No. 384, pg. 8, allegations 14-15), it is clear that Plaintiff was deliberate and straightforward in his answers.

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Part 13 tomorrow.