That All Depends: But this is all Nonsensical Request as i am an Artist (IA - means Intellectual Art) Or on your terms "Intellectual Property". This is not a Devoice proceedings so get your duplicates case projecting somewhere else Seth Rafkin. Remember your not of the hook for contempt of Court in Bringing a Frivolous Lawsuit. Smart attorney John would help you learn this lesson that you cannot wring the arms of the civil justice system if you choose too it is best to try criminal court. Here is compound Probabilities and your way up hill looking motion 003 Esq for contempt of court right in the eyes - could you imagine if I had come to your beckoning to fight in the snow of NYC in front of 60 Center street? I've like Malicious, vindictive Gildred in Catch and Kill Matrimonial Infidelity and Carolina Hernandez and Orlando Manuel M.D. Psych Garcia - I'll have Motive and Motif. Again it All Depends: In regards to Plaintiff and I having had Sex This Fact is undisputable. If Plaintiff want to deny this fact then take a photo of her Vagina and I would be happy to ID the specific Corners of insertion and or penetration.
Please refer the the Answer - Don't rush take your time and read it through - There in it is all the answers. You are Faking it.
Seth Rafkin Esq you have picked the wrong frivolous case I can't wait to see the results because the Court is going to catch you. 
Your digging in deeper and deeper. Frivolous Professional Plaintiff Case will have its day in Court -Soon!