080.pdf
1.14 MB
Extraction Summary
23
People
12
Organizations
6
Locations
2
Events
4
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 third-party witness Igor Zinoviev, requesting a protective order to prevent his deposition in the case Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, who worked as a driver and bodyguard for Epstein since November 2005, argues he has no relevant information for the civil cases as his employment began after the alleged events and he never discussed the criminal or civil cases with Epstein.
People (23)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 2 | Plaintiff |
Plaintiff in the case against Jeffrey Epstein
|
| Jeffrey Epstein | Defendant |
Defendant in the case, employer of Igor Zinoviev
|
| Igor Zinoviev | Third Party Witness |
Moves for a protective order, worked as a driver and bodyguard for Jeffrey Epstein since November 2005
|
| L.M. | Witness |
Mentioned in depositions
|
| E.W. | Witness |
Mentioned in depositions
|
| Judge Linnea Johnson | Judge |
Issued Omnibus Order on October 28, 2009, regarding scope of discovery
|
| Jack Alan Goldberger | Counsel for Defendant Jeffrey Epstein |
Attorney for Jeffrey Epstein, signed the motion and certificate of service
|
| Stuart S. Mermelstein | Counsel for Plaintiffs |
Attorney for plaintiffs in related cases
|
| Adam S. Horowitz | Counsel for Plaintiffs |
Attorney for plaintiffs in related cases
|
| Richard Horace Willits | Counsel for Plaintiff |
Attorney for plaintiff in related case 08-80811
|
| Richard H. Willits | Counsel for Plaintiff |
Attorney for plaintiff in related case 08-80811
|
| Jack Scarola | Counsel for Plaintiff, C.M.A. |
Attorney for plaintiff C.M.A.
|
| Jack P. Hill | Counsel for Plaintiff, C.M.A. |
Attorney for plaintiff C.M.A.
|
| Bruce Reinhart | Counsel for Defendant Sarah Kellen |
Attorney for Sarah Kellen
|
| Bruce E. Reinhart | Counsel for Defendant Sarah Kellen |
Attorney for Sarah Kellen
|
| Brad Edwards | Counsel for Plaintiff |
Attorney for plaintiff in related case 08-08993
|
| Paul O. Cassell | Co-counsel for Plaintiff Jane Doe |
Attorney for Plaintiff Jane Doe
|
| Isidro M. Garcia | Counsel for Plaintiff |
Attorney for plaintiff in related case 08-80469
|
| Robert C. Josefsberg | Counsel for Plaintiffs |
Attorney for plaintiffs in related cases 09-80591 and 09-80656
|
| Katherine W. Ezell | Counsel for Plaintiffs |
Attorney for plaintiffs in related cases 09-80591 and 09-80656
|
| Theodore J. Leopold | Counsel for Plaintiff |
Attorney for plaintiff in related case 08-08804
|
| Spencer T. Kuvin | Counsel for Plaintiff |
Attorney for plaintiff in related case 08-08804
|
| Sarah Kellen | Defendant |
Mentioned as a defendant for whom Bruce Reinhart serves as counsel
|
Organizations (12)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA |
Court where the case is filed
|
|
| Mermelstein & Horowitz, P.A. |
Law firm representing plaintiffs
|
|
| Richard H. Willits, P.A. |
Law firm representing a plaintiff
|
|
| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm representing a plaintiff
|
|
| Bruce E. Reinhart, P.A. |
Law firm representing defendant Sarah Kellen
|
|
| Rothstein Rosenfeldt Adler |
Law firm representing a plaintiff
|
|
| Garcia Law Firm, P.A. |
Law firm representing a plaintiff
|
|
| Podhurst Orseck, P.A. |
Law firm representing plaintiffs
|
|
| Leopold, Kuvin, P.A. |
Law firm representing a plaintiff
|
|
| Atterbury Goldberger & Weiss, P.A. |
Law firm representing defendant Jeffrey Epstein
|
|
| Brown & Williamson Tobacco |
Cited in legal precedent (Washington v. Brown & Williamson Tobacco)
|
|
| United Food & Commercial Workers Intern. Union |
Cited in legal precedent (Food Lion, Inc. v. United Food & Commercial Workers Intern. Union)
|
Timeline (2 events)
2005-11
Igor Zinoviev began employment with Jeffrey Epstein as a driver and bodyguard.
2009-10-28
Judge Linnea Johnson issued an Omnibus Order (DE #377) regarding the scope of discovery.
Court
Locations (6)
| Location | Context |
|---|---|
|
Address for Mermelstein & Horowitz, P.A. (18205 Biscayne Boulevard, Suite 2218, Miami, FL 33160)
|
|
|
Address for Richard H. Willits, P.A. (2200 10th Avenue North, Suite 404, Lake Worth, FL 33461)
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Addresses for Searcy Denney Scarola Barnhart & Shipley, P.A. (2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33...
|
|
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Address for Rothstein Rosenfeldt Adler (401 East Las Olas Boulevard, Suite 1650, Fort Lauderdale, FL 33301)
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Address for Paul O. Cassell (332 South 1400 E, Room 101, Salt Lake City, UT 84112)
|
|
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Address for Leopold, Kuvin, P.A. (2925 PGA Blvd., Suite 200, Palm Beach Gardens, FL 33410)
|
Relationships (4)
Igor Zinoviev worked for Jeffrey Epstein as a driver and bodyguard since November 2005.
Jane Doe No. 2 is the plaintiff in the case against Jeffrey Epstein.
Jack Alan Goldberger is Counsel for Defendant Jeffrey Epstein.
Bruce Reinhart is Counsel for Defendant Sarah Kellen.
Key Quotes (3)
""[w]hile the scope of discovery is broad, it is not without limits.""Source
080.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
080.pdf
Quote #2
""[a] party or any person from whom 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
080.pdf
Quote #3
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