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Case 9:09-cv-80591-KAM Document 86 Entered on FLSD Docket 11/28/2009 Page 1 of 8
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA/JOHNSON
JANE DOE N0. 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, 09-80802, 09-81092
PLAINTIFF, CAROLYN M. ANDRIANO’S, RESPONSE TO THIRD PARTY WITNESS,
IGOR ZINOVIEW’S, MOTION FOR PROTECTIVE ORDER AND INCORPORATED
MEMORANDUM OF LAW
Plaintiff, Carolyn M. Andriano, by and through her undersigned counsel, hereby
files her Response Third Party Witness, Igor Zinoview’s, Motion For Protective Order
and Incorporated Memorandum of Law (D.E. 402), and in support thereof states as
follows:
1. Third party witness, Igor Zinoview, seeks to have this Court enter an order
preventing his deposition from going forward at all, or, in the alternative, limiting the
scope of permissible questioning during same. Mr. Zinoview’s deposition is presently
scheduled to be taken on December 18, 2009.
2. Mr. Zinoview has been employed by Defendant, Jeffrey Epstein, as his
“driver, bodyguard, and trainer” since November of 2005. See Affidavit of Igor Zinoview
Case 9:09-cv-80591-KAM Document 86 Entered on FLSD Docket 11/28/2009 Page 2 of 8
(D.E. 402) dated November 9, 2009. Mr. Zinoview argues that his deposition should not
go forward as scheduled because Defendant Epstein has never discussed nor
attempted to discuss with him “any facts or information related to any legal matters in
which he [Jeffrey Epstein] is involved.” Id. From Mr. Zinoview’s vague assertion springs
the bold yet erroneous argument that “Mr. Zinoview cannot possibly have any
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