Epstein Secrets

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

x [email protected] Co-counsel/or Plaintiff Jane Doe Isidro M. Qarcia, Esq. Garcia Law Firm, P.A. 2

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

fected them emotionally and psychologically. See ~-, Exhibit "D", Affidavit of Richard C.W. Hall, outlining the psychological issues experienced by Jane Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As such, Plaintiffs should not, once again, be able to "handpic

THIRD PARTY WITNESS, IGOR ZINOVIEW'S, MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LA ,v Third Paiiy Witness, Igor Zinoview's, ("Mr. Zinoview") by and through his undersigned attorney, moves this Court pursuant to Fed. R. Civ. P. 26(c) for a protective order regarding his deposition and a

Hae Vice' 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected]. utah. ed u Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm) P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia@be

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

T OF FLORIDA CASE NO: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,

tion to File Reply to Response to Motion to Compel filed May 18, 2009 (D.E. #109 in Case #08-80380 and D.E. #61 in Case #08- 80993); (3) Third Party Zinoview's Motion for Protective Order filed November 9, 2009 (D.E. #149 in Case #08-80380; D.E. #151 in Case #08-80811; D.E. #99 in Case #08- 80993; D.E. #1

Entered on FLSD Docket 12/17/2009 Page 1 of 4 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

and, D.E. #49 in Case #08-80994); (8) Third Party Zinoview's Motion for Protective Order filed November 9,

Entered on FLSD Docket 12/17/2009 Page 1 of 4 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend