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Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 1 of 26

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, 08-083 80, 08-803 81, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,

______________
09-80591,09-80656,09-80802,09-81092
_;/

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 as grounds therefore would state:

1. As reflected on the affidavit of Igor Zinoview, attached as Exhibit A, he

works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did

not know Mr. Epstein before November of 2005. He first became employed by Mr.

Epstein in November of 2005.

2. Additionally, Mr. Zinoview would testify as set forth on his affidavit, that

at no time has he discussed with Mr. Epstein any issues involving Mr. Epstein's criminal

case nor any of the cases or issues involved with civil plaintiffs.
Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 2 of 26

3. In many of the depositions, counsel for L.M. and E.W., has asked them as

witnesses to assume ce1iain facts about which they have no knowledge, and he then asks

their opinions about certain

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