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016.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
055.pdf
This document is a Motion for Protective Order filed on November 9, 2009, by Igor Zinoviev, a third-party witness and Jeffrey Epstein's driver/bodyguard since November 2005. Zinoviev seeks to prevent or limit his deposition, arguing he has no knowledge relevant to the civil cases as his employment with Epstein began after the alleged events, and he has not discussed Epstein's criminal or civil cases with him. The motion cites legal precedents on the scope of discovery and includes a list of attorneys involved in various related cases.
080.pdf
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.
DOJ-OGR-00021053.jpg
This document is a 'Table of Authorities' page from a legal filing dated February 28, 2023. It lists various legal precedents (case law) cited in the main brief, including 'Doe v. Indyke et al.,' which directly references Darren Indyke, a known associate and executor for Jeffrey Epstein. The document bears a Department of Justice Bates stamp.
DOJ-OGR-00021117.jpg
This document is page 55 (PDF page 70) of a legal brief filed on February 28, 2023, in Case 22-1426. The text presents a legal argument regarding the 'Landgraf test' and statutory interpretation, specifically arguing that the Child Abduction Prevention Act of 2003 (H.R. 1104) was not intended to apply retroactively because Congress explicitly rejected a proviso that would have allowed it to cover conduct predating the enactment. The page relies on various Supreme Court and Circuit Court citations to support the argument that rejected legislative proposals are significant indicators of congressional intent.
HOUSE_OVERSIGHT_016501.jpg
This document is page 14 of a legal brief or motion arguing for the unsealing of appellate briefs related to Jeffrey Epstein's classification as a level three sex offender. The text draws a parallel to Manhattan DA Cyrus Vance's failure to prosecute Harvey Weinstein in 2015, arguing that the public has a right to scrutinize how the justice system handles 'rich and well-connected' sex offenders to ensure no impropriety or undue deference occurred. It cites legal precedents emphasizing that public access to court proceedings is essential for analyzing judicial reasoning and ensuring fairness.
HOUSE_OVERSIGHT_016486.jpg
This document is a 'Table of Authorities' page (page ii) from a legal filing, likely a brief or motion. It lists various legal precedents (case law) primarily focused on media, public access to court records, and sealing orders (e.g., NY Times v. US, Globe Newspaper v. Superior Court). Crucially, it cites 'People v. Epstein' (2011) as a key authority used 'passim' (throughout) the main document, suggesting the filing relates to the legal proceedings involving Jeffrey Epstein, possibly regarding the unsealing of records. The document bears a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was part of a Congressional investigation.
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This document is a page from the Federal Register, dated August 30, 2011, containing a legal argument against a new National Labor Relations Board (NLRB) rule. The author contends that the NLRB exceeded its statutory authority by mandating that employers post a notice of employee rights, arguing that Congress did not delegate this specific 'gap-filling' power and that failure to post does not constitute an 'unfair labor practice' under the existing framework of the National Labor Relations Act (NLRA). The document cites numerous court cases and legislative history to support the position that the NLRB's rule is an overreach.
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