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

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

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

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

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

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