Case 9:08-cv-80380-KAM Document 153 Entered on FLSD Docket 11/28/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA JANE DOE NO. 2. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF, RESPONSE TO THIRD PARTY WITNESS, IGOR ZINOVIEW'S, MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW Plaintiff, by and through her undersigned counsel, hereby files her Response Third Party Witness, Igor Zinoview's, Motion For Protective Order and Incorporated Memorandum of Law (D.E. 402), and in support thereof states as follows: 1. Third party witness, Igor Zinoview, seeks to have this Court enter an order preventing his deposition from going forward at all, or, in the alternative, limiting the scope of permissible questioning during same. Mr. Zinoview's deposition is presently scheduled to be taken on December 18, 2009. 2. Mr. Zinoview has been employed by Defendant, Jeffrey Epstein, as his "driver, bodyguard, and trainer" since November of 2005. See Affidavit of Igor Zinoview EFTA02741379