Epstein Secrets

nagement, 201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Circ. 1979

cope of permissible questioning during same. Mr. Zinoview’s deposition is presently scheduled to be taken

d supporting Zinoview's Motion for Protective Order. The court found that an order completely prohibiting the deposition from going forward is rare, Salter v. Upiohn co., 593 F.2d 649, 651 (5th Cir. 1979), and that Zinoview's conclusory affidavit in which he denies knowledge of the facts giving rise to

ment 535 Entered on FLSD Docket 04/28/2010 Page 4 of 9 Motion for Protective Order seeking to prevent the deposition of Third Party witness Igor Zinoview despite the fact that Mr. Zinoview was employed by Epstein post-dates giving rise to the facts alleged in these actions. This was the case even thou

Cir. 1989). An order completely prohibiting a deposition from going forward, however, is rare, and only resorted to in extraordinary circumstances. Salter v. Upjohn Co., 593 F.2d 649, 651 (5 Cir. 1979)(noting that it is very unusual for trial court to th prohibit the taking of a deposition altogether,

is before the Court on Third Party Witness, Igor Zinoview’s, Motion for Protective Order (D.E. #402). For the following reasons, Third Party Witness Zinoview’s Motion for Protective Order is denied. By this Motion Third Party Witness Zinoview, who has been employed by Defendant Epstein as a driver and body