Epstein Secrets

OHNSON JANE DOE N0. 2. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _________________________________

ld not go forward as scheduled because Defendant Epstein has never discussed nor attempted to discuss wit

s well as counsel for all of the other victims of Jeffrey Epstein, are entitled to question and challenge Mr

or information related to any legal matters that Mr. Epstein is involved in does not give rise to requisite “e

ition should not go forward as scheduled because Defendant Epstein has never discussed nor attempted to discuss wit

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

14 15 16 17 18 19 20 21 22 23 24 25 157 ,; '~ .. \i A O~i 1 Q, And I'm just asking you if you did have '. '· 'tt .} knowledge that Jeffrey Epstein.was having sex will) {_·_ liltle girls either on the plane or al a place that you i were laking him to or from on a daily basis, thal's what t he di

ed them as witnesses to assume ce1iain facts about which they have no knowledge, and he then asks their opinions about certain facts. See Exhibit B ~Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions. 4. There is no information which Mr. Zinoview has relating to the fa

ein and in terms of being able to name 13 not to answer any question that goes to his opinion 13 somebody that you would say you've observed with Jeffrey 14 of someone else's motivation or the truth of facts 14 Epstein and would classify that person as Jeffrey 15 to which he has no knowledge, 15

bit A, he works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did not know Mr.

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

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469

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 bodyguard since 2005, seeks an order preventing the taking of his deposition on the basis that his employment with Epstein post-dates

cases and that “at not time has he discussed with Mr. Epstein any issues involving Mr. Epstein’s criminal case

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

010 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ---------------~/ Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,

I Response To Plaintifrs, Jane Doe No.: 4, Motion for Protective Order {DE 534), With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby files his Response In Opposition to Plaintiffs', Jane Doe's Motion for Protectiv

0 Phone 561/253-0164 Fax (Counsel for Defendant Jeffrey Epstein) Certificate of Service Jane Doe No. 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

9 Page 1 of 4 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTH

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

Case 9:08-cv-80119-KAM Document 440 Entered on FLSD Docket 12/17/2009 Page 1 of 4 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON ---------------·' Related cases: 08-

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