073.pdf
237 KB
Extraction Summary
12
People
7
Organizations
3
Locations
4
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal pleading (response to motion for protective order)
File Size:
237 KB
Summary
This document is a legal response filed on November 28, 2009, by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) in her civil case against Jeffrey Epstein. The filing opposes a motion by third-party witness Igor Zinoview—Epstein's driver, bodyguard, and trainer since November 2005—who sought to avoid being deposed by claiming he had no knowledge of relevant facts. The Plaintiff argues that Zinoview must be deposed because he worked for Epstein during the active Palm Beach Police investigation (2005-2006) and likely possesses knowledge regarding activities at the Epstein residence, especially since Epstein himself invoked the Fifth Amendment.
People (12)
| Name | Role | Context |
|---|---|---|
| Carolyn M. Andriano | Plaintiff |
Filing response as Jane Doe No. 2 against Jeffrey Epstein.
|
| Jeffrey Epstein | Defendant |
Employer of Igor Zinoview; accused of sexual misconduct with minors.
|
| Igor Zinoview | Third Party Witness |
Epstein's driver, bodyguard, and trainer since Nov 2005. Seeking to avoid deposition.
|
| Jack Scarola | Attorney |
Counsel for Plaintiff, Searcy Denney Scarola Barnhart & Shipley, P.A.
|
| Jack P. Hill | Attorney |
Counsel for Plaintiff, Searcy Denney Scarola Barnhart & Shipley, P.A.
|
| Sarah Kellen | Defendant (Related Case) |
Represented by Bruce Reinhart.
|
| Stuart S. Mermelstein | Attorney |
Counsel for Plaintiffs in related cases.
|
| Brad Edwards | Attorney |
Counsel for Plaintiff in related case.
|
| Bruce Reinhart | Attorney |
Counsel for Defendant Sarah Kellen.
|
| Paul G. Cassell | Attorney |
Co-counsel for Plaintiff Jane Doe.
|
| Jack Alan Goldberger | Attorney |
Counsel for Defendant Jeffrey Epstein.
|
| Spencer T. Kuvin | Attorney |
Counsel for Plaintiff in related case.
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where case is filed.
|
|
| Palm Beach Police Department |
Conducted investigation into Epstein from March 2005 to Feb 2006.
|
|
| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm representing the Plaintiff.
|
|
| Garcia Law Firm, P.A. |
Law firm on service list.
|
|
| Rothstein Rosenfeldt Adler |
Law firm on service list.
|
|
| Podhurst Orseck, P.A. |
Law firm on service list.
|
|
| Leopold, Kuvin, P.A. |
Law firm on service list.
|
Timeline (4 events)
2005-03-15
Start of Palm Beach Police Department investigation into Jeffrey Epstein.
Palm Beach, FL
2005-11
Igor Zinoview begins employment as Epstein's driver, bodyguard, and trainer.
Epstein Residence
2006-02
End of Palm Beach Police Department investigation period cited in document.
Palm Beach, FL
Locations (3)
| Location | Context |
|---|---|
|
Location of police investigation and law firms.
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|
|
Location of Plaintiff's counsel.
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|
|
Implied location where Zinoview worked as driver/bodyguard.
|
Relationships (3)
Employed as driver, bodyguard, and trainer since November 2005.
Case caption: Jane Doe No. 2 (Carolyn M. Andriano) vs. Jeffrey Epstein.
Service list lists Bruce Reinhart as 'Counsel for Defendant Sarah Kellen'.
Key Quotes (4)
"Mr. Zinoview has been employed by Defendant, Jeffrey Epstein, as his 'driver, bodyguard, and trainer' since November of 2005."Source
073.pdf
Quote #1
"Mr. Zinoview certainly might have direct knowledge about what was going on in and around the Epstein residence during the time period in which he was employed by Defendant Epstein"Source
073.pdf
Quote #2
"Given the Defendant’s voracious invocation of his Fifth Amendment privilege, the plaintiffs have consistently been denied the opportunity to seek any relevant information directly from Defendant Epstein himself."Source
073.pdf
Quote #3
"Mr. Zinoview’s opinions and beliefs about the factual matters surrounding plaintiffs’ claims are relevant to exploring any potential bias and prejudice in favor of his employer"Source
073.pdf
Quote #4
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