November 01, 2009
Filing of Third Party Witness, Igor Zinoviev's Motion for Protective Order and Incorporated Memorandum of Law.
| Name | Type | Mentions | |
|---|---|---|---|
| Igor | person | 34 | View Entity |
| Jack Alan Goldberger | person | 199 | View Entity |
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.
Events with shared participants
Seminar-POWER
Date unknown • Unknown
Deposition scheduled but canceled due to an incident involving Jeffrey Epstein and the plaintiff.
2009-09-17 • Florida Science Foundation (implied)
Attempted deposition of Epstein. Epstein and his driver, Igor Zinoviev, exited in a separate elevator to leave the building. Epstein intended to exit through the front entrance to go home and watch the deposition via video feed.
2009-09-17 • Deposition location
Videotaped Deposition of Bradley J. Edwards
2010-03-23 • 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida
Scheduled deposition of Igor Zinoview.
2009-12-18 • Unspecified
Start of Igor Zinoview's employment with Jeffrey Epstein.
2005-11-01 • Epstein residence
Epstein and his driver, Igor Zinoviev, exited the building via separate elevators after the deposition was assumed to have started. Epstein saw two women, one he thought might be Jane Doe No. 4, and avoided interaction.
2009-09-16 • Building containing deposition room, front door, garage.
Igor Zinoview began working for Jeffrey Epstein.
2005-11-01 • Palm Beach, FL
Scheduled deposition of Igor Zinoview (which he sought to prevent).
2009-12-18 • Unknown
Lobby Incident / Confrontation
2009-09-16 • Lobby of 250 Australian Avenue South
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