Epstein Secrets

11/09/2009 Page 4 of 26 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite

Notary P\lblic, State of Florida ~squire Deposition Sc1·vices West Po.l1n Bench Of(ice Job ~127542 2 APPEARANCES: On behalf of the Plaintiff: BRADLEY J. EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Suite 1660 Fort Lauderdale, Florida 33394 On behalf of the Defendant: ROBERT

CRITTON: Let me put on there, for the -- 12 lf this deposition ls not typed - and We request 13 ii - I'd like at least this portion where 14 Mr. Edwards' last question back about five pages 15 worth, so Just if you could mark it from this 16 page back about five pages. l 7 If nobody requests the

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

80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfel

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

, FL 33401-5012 561-659-8300 Fax: 561-835-8691 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos

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