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This legal document, a Memorandum of Law, discusses the denial of a protective order sought by plaintiffs in a case (9:08-cv-80119-KAM). The motion aimed to prevent a named party, Epstein, from attending depositions and to exclude him from all depositions of the plaintiffs. The court finds that the plaintiffs failed to demonstrate "extraordinary circumstances" and that the motion does not meet the necessary burden for Jane Does 2, 3, 4, 5, 6, or 7.

This document is a legal argument from a court filing, asserting that a specific document should be inadmissible as evidence. The core argument is that the document is not a reliable business record because it was created specifically in anticipation of litigation against Mr. Epstein, not in the ordinary course of business. The text cites several legal precedents to support this position and outlines the stringent requirements for a document to qualify under the business records exception to the hearsay rule.