oke, with the benefit of hindsight, about Jeffrey 4 Epstein and others like him from her office in Madison, Wisconsin. | _ “Consider a car,” says Dr. Salter. “There’s a motor, and there "are brakes. We all have sexual impulses we don’t think it would bea good idea to act on. Most of us have good control o

e spoke, with the benefit of hindsight, about Jeffrey _ Epstein and others like him from her office in Madison, Wisconsin. “Consider a car,” says Dr. Salter. “There’s a motor, and there "are brakes. We all have sexual impulses we don’t think it would be a good idea to act on. Most of us have good control

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

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,

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