069.pdf
1.14 MB
Extraction Summary
21
People
11
Organizations
15
Locations
4
Events
15
Relationships
3
Quotes
Document Information
Type:
Legal motion / court document
File Size:
1.14 MB
Summary
This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.
People (21)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 2 | Plaintiff |
Lead plaintiff in the case
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| Jeffrey Epstein | Defendant |
Defendant in the civil case
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| Igor Zinoviev | Third Party Witness, Driver, Bodyguard |
Works for Jeffrey Epstein, subject of the motion for protective order.
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| L.M. | Witness |
Plaintiff's counsel has questioned this witness in depositions.
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| E.W. | Witness |
Plaintiff's counsel has questioned this witness in depositions.
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| Judge Linnea Johnson | Judge |
Issued an Omnibus Order on October 28, 2009, regarding discovery scope.
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| Jack Alan Goldberger | Counsel for Defendant Jeffrey Epstein |
Signed the motion and certificate of service.
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| Stuart S. Mermelstein | Counsel for Plaintiffs |
Listed on the service list for related cases.
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| Adam S. Horowitz | Counsel for Plaintiffs |
Listed on the service list for related cases.
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| Richard Horace Willits | Counsel for Plaintiff |
Listed on the service list for related case No. 08-80811.
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| Jack Scarola | Counsel for Plaintiff, C.M.A. |
Listed on the service list.
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| Jack P. Hill | Counsel for Plaintiff, C.M.A. |
Listed on the service list.
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| Bruce Reinhart | Counsel for Defendant Sarah Kellen |
Listed on the service list.
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| Brad Edwards | Counsel for Plaintiff |
Listed on the service list for related case No. 08-80893.
|
| Paul G. Cassell | Co-counsel for Plaintiff Jane Doe |
Listed on the service list.
|
| Isidro M. Garcia | Counsel for Plaintiff |
Listed on the service list for related case No. 08-80469.
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| Robert C. Josefsberg | Counsel for Plaintiffs |
Listed on the service list for related cases Nos. 09-80591 and 09-80656.
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| Katherine W. Ezell | Counsel for Plaintiffs |
Listed on the service list for related cases Nos. 09-80591 and 09-80656.
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| Sarah Kellen | Defendant |
Defendant in a related case, represented by Bruce Reinhart.
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| Theodore J. Leopold | Counsel for Plaintiff |
Listed on the service list for related case No. 08-08804.
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| Spencer T. Kuvin | Counsel for Plaintiff |
Listed on the service list for related case No. 08-08804.
|
Organizations (11)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA |
Court where the case is filed.
|
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| Atterbury Goldberger & Weiss, P.A. |
Law firm of Jack Alan Goldberger, counsel for Jeffrey Epstein.
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| Mermelstein & Horowitz, P.A. |
Law firm representing plaintiffs.
|
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| Richard H. Willits, P.A. |
Law firm representing a plaintiff.
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| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm representing plaintiff C.M.A.
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| Bruce E. Reinhart, P.A. |
Law firm representing defendant Sarah Kellen.
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| Rothstein Rosenfeldt Adler |
Law firm representing a plaintiff.
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| Garcia Law Firm, P.A. |
Law firm representing a plaintiff.
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| Podhurst Orseck, P.A. |
Law firm representing plaintiffs.
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| Leopold, Kuvin, P.A. |
Law firm representing a plaintiff.
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| Food Lion, Inc. v. United Food & Commercial Workers Intern. Union |
Cited legal precedent.
|
Timeline (4 events)
2005-09
Allegations directed to Mr. Epstein in pending civil cases do not extend beyond this date, according to the motion.
Unknown
2009-10-28
Judge Linnea Johnson issued Omnibus Order (DE #377) regarding the scope of discovery.
Court
2009-11-09
Third Party Witness, Igor Zinoviev's Motion for Protective Order and Incorporated Memorandum of Law filed.
Southern District of Florida Court
Locations (15)
| Location | Context |
|---|---|
|
Location of Mermelstein & Horowitz, P.A.
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Location of Richard H. Willits, P.A.
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Location of Atterbury Goldberger & Weiss, P.A., Searcy Denney Scarola Barnhart & Shipley, P.A., Bruce E. Reinhart, P....
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Location of Rothstein Rosenfeldt Adler.
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Location of Paul G. Cassell.
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Location of Leopold, Kuvin, P.A.
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Address of Mermelstein & Horowitz, P.A.
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Address of Richard H. Willits, P.A.
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Address of Searcy Denney Scarola Barnhart & Shipley, P.A.
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Address of Bruce E. Reinhart, P.A. and Atterbury Goldberger & Weiss, P.A.
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Address of Rothstein Rosenfeldt Adler.
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Address of Paul G. Cassell.
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Address of Garcia Law Firm, P.A.
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Address of Podhurst Orseck, P.A.
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Address of Leopold, Kuvin, P.A.
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Relationships (15)
Works for Defendant, Jeffrey Epstein as a driver and bodyguard; first employed in November 2005.
Counsel for Defendant Jeffrey Epstein
Counsel for Plaintiffs
Counsel for Plaintiffs
Counsel for Plaintiff in Related Case No. 08-80811
Counsel for Plaintiff, C.M.A.
Counsel for Plaintiff, C.M.A.
Counsel for Defendant Sarah Kellen
Counsel for Plaintiff in Related Case No. 08-80893
Co-counsel for Plaintiff Jane Doe
Counsel for Plaintiff in Related Case No. 08-80469
Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656
Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656
Counsel for Plaintiff in Related Case No. 08-08804
Counsel for Plaintiff in Related Case No. 08-08804
Key Quotes (3)
""[w]hile the scope of discovery is broad, it is not without limits.""Source
069.pdf
Quote #1
"'[w]hile the standard of relevancy [in discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter (sic) which does not presently appear germane on the theory that it might conceivably become so.'"Source
069.pdf
Quote #2
""[a] party or any person from whomn discovery is sought may move for a protective order in the court where the action is pending.... The court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following: (A) forbidding the disclosure or discovery;""Source
069.pdf
Quote #3
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