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This legal document, dated March 31, 2008, is a motion for a protective order filed by the law firm Herman & Mermelstein, P.A. on behalf of 'Witness Y. Doe'. The motion requests that the court order the witness's deposition for an unspecified criminal case and the civil case 'Jane Doe No. 3 v. Jeffrey Epstein' to be conducted simultaneously. The stated purpose is to prevent potential harassment of the witness by the defendant, Jeffrey Epstein.

This legal document, dated March 31, 2008, is a request for a protective order filed by the law firm Herman & Mermelstein on behalf of 'Witness Y. Doe'. The motion asks the court to require that depositions for a criminal case and a civil case, 'Jane Doe No. 3 v. Jeffrey Epstein', be conducted at the same time to prevent harassment of the witness by Defendant Epstein. The filing states that counsel for the State and for Epstein were contacted about this request but have not responded.