EFTA00104265

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23 PRIVILEGE LOG Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "CORR RE GJ 6(e) P-000001 SUBPOENAS" containing correspondence Work Product thru related to various rand jury subpoenas and P-000039 attorney handwritten notes Box #1 Operation Leap Year Grand Jury Log 6(e) P-000040 containing subpoenas OLY-01 through OLY-81, Work Product thru correspondence and research related to Contains documents subject P-000549 enforcement of same, documents produced in to investigative privilege response to some subpoenas; and attorney Also contains documents ( handwritten notes subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Ritz Compact Flash SW" 6(e) P-000550 containing copies of a sealed search warrant Contains information subject thru application, warrant, and supporting documents to investigative privilege P-000621 Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "PNY Technologies Compact 6(e) P-000622 Flash SW" containing copies of a sealed search Contains information subject thru warrant application, warrant, and supporting to investigative privilege P-000693 documents Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "JE Corporations" containing Work Product P-000694 attorney research on Epstein-owned corporations Contains information subject thru and prior litigation to investigative privilege P-000781 Box #1 File folder entitled "Capital One" 6(e) P-000782 containing subpoena and correspondence thru P-000803 Box #1 File folder entitled "DTG Operations/Dollar 6(e) P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and thru documents information subject to P-000854 investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Page 1 of 23 EFTA00104265 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 2 of 23 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "JP Morgan Chase" 6(e) P-000855 containing subpoena, correspondence, and Contains documents and thru responsive documents information subject to P-000937 investigative privilege Box #1 File folder entitled "Washington Mutual" 6(e) P-000938 containing subpoena, correspondence, and Contains documents and thru responsive documents information subject to P-000947 investigative privilege Box #1 File folder entitled "Computer Search &" Work Product P-000948 containing legal research on computer search and Attorney-Client thru handwritten notes on indictment preparation Contains information subject P-000982 to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Attorney Notes from Work product P-000983 Document Review" containing typed and 6(e) thru handwritten attorney ( ) notes, target Contains information subject P-001007 letters, correspondence re grand jury subpoena to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Notes from Fed Ex Records" Work Product P-001008 containing handwritten and typed attorney 6(e) thru ) notes and screen shots of FedEx Contains information subject P-001056 subpoena response electronic file to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Colonial Bank Records" 6(e) P-001057 containing records received in response to grand Contains information subject thru jury subpoena to investigative privilege P-001959 Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e) P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject Thru numbered OLY-51 through OLY-81 with related to investigative privilege. P-002089 correspondence Also contains information subject to privacy rights of victims who are not parties to this litigation Page 2 of 23 EFTA00104266 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "Epstein Corporate Records: 6(e) P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and Thru subpoenas, records received in response to documents subject to P-002169 subpoenas, and related correspondence investigative privilege Box #1 File folder entitled "Colonial Bank" containing 6(e) P-002170 subpoenas, correspondence related to subpoenas, Contains information and Thru records received in response to subpoenas documents subject to P-002246 investigative privilege Box #1 File folder entitled "JEGE & Hyperion from 6(e) P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and Thru documents received in response to subpoenas documents subject to P-002265 investigative privilege Box #1 Indictment preparation binder containing: Work product P-002266 Grand jury subpoena log, evidence/activity 6(e) Thru summary chart witness/victim names and contact Contains information and P-002386 list, attorney ( D handwritten notes, 302s, documents subject to 'lions of state investigative file, attorney investigative privilege. Also ) typed notes, of individuals listed as contains information and "Additional victims" documents subject to privacy rights of victims who are not parties to this litigation Box #1 Indictment preparation binder containing: Work product P-002387 Grand jury subpoena log, evidence/activity 6(e) Thru summary charta_witness/victim names and contact Contains information and P-002769 list, attorney ( handwritten notes, 302s, documents subject to as of state investigative file, attorney investigative privilege. Also ( D typed notes, relevant pieces of grand contains information and jury materials, telephone records/flight records documents subject to privacy analysis charts, victim/witness photographs, rights of victims who are not DAVID records, NCICs, and related materials for parties to this litigation persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Box #1 Indictment preparation binder containing: Work product P-002770 witness/victim list with identifying information, 6(e) Thru sexual activity summ telephone call summary Contains information and P-003211 chart, attorney handwritten notes, documents subject to 3CSsfions of state investigative file, attorney investigative privilege. Also ( typed notes, relevant pieces of grand contains information and jury materials, telephone records/flight records documents subject to privacy analysis charts, victim/witness photographs, rights of victims who are not DAVID records, NCICs, and related materials for parties to this litigation persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 Page 3 of 23 EFTA00104267 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23 Bates Range Description Privilege(s) Asserted Box #1 Indictment preparation binder containing meta- Work product P-003212 analysis charts of telephone/flight/grand jury 6(e) Thru information for a number of victim/witnesses, Contains information and P-003545 , and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 FBI Reports of March 2008 interviews of Work product P-003546 additional witness/victim located in New York 6(e) Thru Contains information and P-003552 documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 Printout of filenames from Federal Express Work product P-003553 subpoena response with Attorney notations 6(e) Thru P-003555B Box #1 Document entitled "Identified Numbers" with Work product P-003556 accompanying handwritten attorney list compiled 6(e) Thru from grand jury materials and attorney analysis of Contains information subject P-003562 records to investigative privilege Box #1 Folder entitled "Flight Manifests" containing 6(e) P-003563 manifests received pursuant to grand jury Contains information and Thru subpoena documents subject to P-003629 investigative privilege Box #1 File folder entitled "Recent Attottes" Work product P-003630 containing handwritten attorney ) notes 6(e) Thru regarding document review and case strategy Investigative privilege P-003633 Deliberative process Box #1 File folder bearing victim name containing FBI Work product P-003634 interview report from May 2008, telephone Attorney-client privilege Thru activity report with attorney ( ) 6(e) P-003646 handwritten notes, related grand jury material Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 4 of 23 EFTA00104268 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "Summary of Sexual Activity" Work product P-003647 containing chart bearing handwritten title "Sexual 6(e) Thru Activity — Summary" with meta-analysis of Investigative privilege P-003651 information, sorted by name of each Deliberative process victim/witness, including name and identifying Also contains information and information of each victim/witness documents subject to privacy rights of victims who are not parties to this liti ation Box #1 File folder entitled "Victim Civil Suits" Not privileged. P-003652 Produced to counsel for Thru Petitioners P-003663 Box #1 File folder entitled "Research re JE Websites" Work product P-003664 containing attorney research Thru P-003678 Box #1 File folder entitled ' Y. AUSA)" Work product P-003679 containing attorney ( handwritten notes Thru P-003680 Box #1 File folder entitled "Dr. ' containing Work product P-003681 attorney ( ) memo to expert witness and Investigative privilege Thru handwritten attorney notes P-003687 Box #1 File folder entitled "I[] G[] Interview" containing Work product P-003688 attorney handwritten notes of interview, and Investigative privilege Thru attorney handwritten notes regarding potential Also contains information P-003693 charges subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Research re Travel for Work product P-003694 Prostitution" containing attorney ( ) 6(e) Thru handwritten notes regarding grand jury Investigative privilege P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and House" with handwritten notes, Message Pad documents subject to privacy meta-analysis chart, summary of evidence related rights of victims who are not to one victim/witness, and relevant grand jury parties to this litigation information Box #1 Empty file folder bearing name of victim/witness Investigative privilege P-003712 Also contains information subject to privacy rights of victim who is not a party to this liti ation Page 5 of 23 EFTA00104269 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23 Bates Range Description Privilege(s) Asserted Box #1 File folder entitled "T[] M[]" containing grand 6(e) P-003713 jury subpoenas, motion and order to compel Documents under seal Thru testimony, and correspondence regarding same pursuant to court order P-003746 Box #1 File folder entitled ' ' containing 6(e) P-003747 subpoena and correspondence regarding same Thru P-003751 Box #1 File folder entitled "PBPD Investigative File" 6(e) P-003752 obtained via subpoena Investigative privilege Thru Also contains information and P-004295 documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder bearing name of victim/witness Work product P-004296 containing meta-analysis chart showing telephone 6(e) Thru calls, travel, and grand jury materials relevant to Investigative privilege P-004350 possible charges Also contains information and documents subject to privacy rights of victims who are not arties to this liti ation Box #1 File folder entitled ' Documents Work product P-004351 53909-004" containing attorney research related Thru to bias issue P-004381 Box #1 File Folder entitled "FEDEX" containing 6(e) P-004382 documents obtained via subpoena Investigative privilege Thru P-004478 Box #1 File Folder entitled "State of Delaware Records" 6(e) P-004479 containing documents obtained in preparation for Investigative privilege Thru indictment Work product P-004551 Box #1 File folder entitled "Jet Blue Records" containing 6(e) P-004552 documents obtained via subpoena Work product Thru Investigative privilege P-004555 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege P-004556 RECORDS" containing FDLE records on targets Work product Thru and witnesses obtained at attorney request P-004560 Page 6 of 23 EFTA00104270 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23 Bates Ran e Descri tion Privile s Asserted Box #1 Filed folder entitled ' Work product P-004561 containing attorney ( handwritten notes Investigative privilege Thru of interview P-004565 Box #1 File folder entitled' 6(e) P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product Thru documents obtained via subpoena Investigative privilege P-004716 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled ' Work product P-004717 containing attorney research regarding witness Investigative privilege Thru P-004722 Box #1 File folder entitled "BEAR STEARNS Work Product P-004723 RESEARCH" containing attorney research Investigative privilege Thru regarding potential witness and subpoena P-004725 recipient Box #1 File folder entitled "LAWSUITS INVOLVING Work Product P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege Thru regarding Epstein's past personal and business P-004819 litigative practices Box #1 Filed folder entitled "SEC RECORDS" Work Product P-004820 containing attorney research regarding Epstein Investigative privilege Thru financial relationships P-004959 Box #1 File folder entitled "Message Pads" containing Work Product P-004960 selected items from evidence obtained via 6(e) Thru subpoena Investigative privilege P-005059 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder bearing name of victim/witness Work Product P-005060 containing correspondence with counsel for 6(e) Thru victim/witness, attorney witness outline with Investigative privilege P-005081 attorney handwritten notes, attorney handwritten Also contains information and notes regarding witness reports and case documents subject to privacy preparation rights of victims who are not parties to this litigation Box #1 File folder entitled "New York Trip" containing Work product P-005082 attorney notes re witness interview Investigative privilege Thru P-005083 Page 7 of 23 EFTA00104271 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23 Bates Range Description Privilege(s) Asserted P-005084 thru P-005107 are non responsive documents and have been removed Box #1 File folder entitled' ' containing Work product P-005108 attorney research on select expert, use of experts Investigative privilege Thru at trials in child exploitation cases, and additional P-005193 research materials on offenders and victims Box #1 File folder entitled "Extra Copies" containing Work product P-005194 meta-analysis chart and 302's of victim/witnesses 6(e) Thru used in preparing indictment package Investigative privilege P-005300 Also contains information and documents subject to privacy rights of victims who are not arties to this liti ation Box #1 File folder entitled ' 6(e) P-005301 STATEMENT' containing transcript obtained via Investigative privilege Thru subpoena P-005331 Box #1 File folder entitled' ' containing Work product P-005332 attorney research on select expert, including Investigative privilege Thru attorney handwritten notes P-005341 Box #1 File folder entitled "Info re Planes" containing 6(e) P-005342 correspondence regarding subpoenas and Investigative privilege Thru documents received in response to subpoenas P-005387 Box #1 File folder entitled "Police Reports & PC Work product P-005388 Affidavit" containing portions of police reports 6(e) Thru with attorney notes, related phone records, a list Investigative privilege P-005442 entitled "Victims" with identifying information Also contains information and and attorney handwritten notes, photographs and documents subject to privacy DAVID information, and additional attorney rights of victims who are not research regarding Epstein sexual activity parties to this litigation Box #1 File folder entitled "[Victim name] Transcript of 6(e) P-005443 Interview & GI Transcript" Investigative privilege Thru Also contains information and P-005496 documents subject to privacy rights of victims who are not parties to this litigation Box #1 File folder entitled "Bear Stearns Subpoena 6(e) P-005497 Resp." containing material received in response Investigative privilege Thru to subpoena P-005556 Page 8 of 23 EFTA00104272 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23 Bates Range Description Privilege(s) Asserted Box #1 U.S. Attorney's Office Criminal Case File Jacket Work product P-005557 containing file opening documents, expert Deliberative process Thru witness payment documents P-005576 Box #1 U.S. Attorney's Office Asset Forfeiture Case File Work product P-005578 Jacket containing file opening and file closing Deliberative process Thru documents P-005583 Box #1 File folder entitled "6001 Immunity Request" 6(e) P-005584 containing internal memoranda seeking witness Work product and Thru immunity and correspondence with counsel for deliberative process (as to P-005606 witness regarding same internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "MASTER PHONE Work product P-005607 RECORDS" containing meta-analysis of all 6(e) Thru phone, travel, and grand jury data for all Investigative privilege P-005914 victim/witnesses for indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder bearing name of victim/witness Work product P-005915 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-005977 indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder bearing name of victim/witness Work product P-005978 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-006050 indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder bearing name of victim/witness Work product P-006051 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-006065 indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 9 of 23 EFTA00104273 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 10 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "JANE DOE #4" containing Work product P-006066 meta-analysis of all phone, travel, and grand jury 6(e) Thru data related to that victim/witness for indictment Investigative privilege P-006220 preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled 'JANE DOE #12" containing Work product P-006221 meta-analysis of all phone, travel, and grand jury 6(e) Thru data related to that victim/witness for indictment Investigative privilege P-006222 preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "CORRECTED PHONE Work product P-006223 RECORDS 5/31/07" containing meta-analysis of 6(e) Thru all phone, travel, and grand jury data related to all Investigative privilege P-006522 victims/witnesses for indictment preparation Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "[Victim Name] Phone Work product P-006523 Records" containing telephone records received 6(e) Thru in response to subpoena Investigative privilege P-006802 Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #2 File folder entitled "Lists of Identified Phone Work product P-006803 Numbers" containing charts of information culled 6(e) Thru from grand jury materials, interviews, and other Investigative privilege P-006860 investigation, with attorney handwritten notes, Also contains information and and information to issue follow-up grand jury documents subject to privacy subpoena rights of victims who are not parties to this litigation Box #2 File folder entitled "EPSTEIN, CELL Work product P-006861 PHONE RECORDS" containing documents 6(e) Thru received via subpoena with attorney handwritten Investigative privilege P-007785 notes and highlighting Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 10 of 23 EFTA00104274 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 11 of 23 Bates Range Description Privilege(s) Asserted Box #2 Folder entitled "OLY GRAND JURY LOG: Work product P-007786 OLY-01 THROUGH OLY-50" containing 6(e) Thru subpoenas, correspondence regarding same, 6(e) Investigative privilege P-008120 letters, attorney handwritten notes regarding Also contains information and records received in response to subpoenas documents subject to privacy rights of victims who are not parties to this litigation Box #2 Handwritten flight logs received in response to 6(e) P-008121 subpoena Investigative privilege Thru P-008139 Box #2 Grand jury presentation folder containing Work product P-008140 attorney handwritten notes, typed outline with 6(e) Thru additional handwritten notes, complete indictment Investigative privilege P-008298 package dated 2/19/2008, victim list with Also contains information and identifying information, photographs, and documents subject to privacy summary of activity rights of victims who are not parties to this litigation Box #2 File folder entitled "FINAL AGREEMENTS" P-008299 containing subfolder entitled "Agrmts Filed in Thru State Court" (P-008300-P-008327 [not being P-008363 withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, lii I . gg . st es r tive portion of 12/19/2007 (P-008328-P- 008343 [not . mg wit e as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanchez Ltr" containing unredacted copies of that letter (P- 008344-P-008363 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit Box #2 File folder entitled ' Immunity Request" 6(e) P-008364 containing internal memoranda, Justice Work Product Thru Department documentation, and subpoena Deliberative Process P-008382 regarding immunity request Investigative privilege Box #2 File folder containing March 18, 2008 grand jury Work product P-008383 presentation materials, including "Operation Leap 6(e) Thru Year Revised Indictment Summary Chart (by Investigative privilege P-008516 victim)," grand jury materials, draft indictments, Deliberative process victim reference list, grand jury subpoena log Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Page 11 of 23 EFTA00104275 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 12 of 23 Bates Ran e Descri tion Privile e s Asserted Box #2 6/25/2007 Letter from to P-008517 and Thru [pursuant to Court's Order, not being withheld as P-008535 privileged — will be produced to opposing counsel upon lift of stay by 11'" Circuit] Box #2 Handwritten attorney notes to prepare for Work product P-008536 interview of Jane Doe #2 Investigative Privilege Thru Contains information subject P-008542 to privacy rights of victims who are not parties to this suit Box #2 Handwritten attorney notes regarding May 8, Work product P-008543 2007 grand jury presentation 6(e) Thru Investigative privilege P-008549 Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "Most Recent Indictment & Work product P-008550 Good Cases" containing draft indictment and 6(e) Thru legal research Investigative privilege P-008615 Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "FBI Summary Charts" Work product P-008616 containing chart prepared at direction of AUSA, Attorney-Client Privilege Thru containing victim names, identifying information, 6(e) P-008686 summary of activity, and other information Investigative privilege relevant to indictment Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #4" Work product P-008687 containing phone records and meta-analysis of all 6(e) Thru phone, travel, and grand jury data related to that Investigative privilege P-008776 victim/witness for indictment preparation Contains information and documents subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #5" Work product P-008777 containing handwritten notes and meta-analysis 6(e) Thru of all phone, travel, and grand jury data related to Investigative privilege P-008808 that victim/witness for indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Page 12 of 23 EFTA00104276 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 13 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "[Victim name]/Jane Doe #6" Work product P-008809 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008847 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #7" Work product P-008848 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008862 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #8" Work product P-008863 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-008890 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "Certified Copy of State Case" P-008891 containing certified copy of Epstein state criminal Thru cases and change of plea transcript [not being P-009103 withheld as privileged — copy provided to opposing counsel] Box #2 File folder entitled "Meeting Timeline" Work product P-009104 containing typed notes summarizing Deliberative process Thru meetings with o osin counsel prepared at P-009111 request of with handwritten correction and t d uideline estimate Box #2 11/2 2008 Email from to P-009112 and re Jeffrey Epstein Thru (work release) P-009113 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of lid Circuit] Box #2 7/3/2008 Email from to M - P-009114 at PBSO re Epstein work release with Thru attachment [not being withheld as privileged — P-009115 produced to o osin counsel] Box #2 12/6/2007 Letter from to P-009116 re Jeffrey Epstein (victim notification) Thru [pursuant to Court's Order, not being withheld as P-009125 privileged — will be produced to opposing counsel upon lift of stay by 1 l th Circuit]) Page 13 of 23 EFTA00104277 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 14 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "[Victim name]/Jane Doe #9" Work product P-009126 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009134 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe Work product P-009135 #13" containing meta-analysis of all phone, 6(e) Thru travel, and grand jury data related to that Investigative privilege P-009141 victim/witness for indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe Work product P-009141A #12" containing meta-analysis of all phone, 6(e) Thru travel, and grand jury data related to that Investigative privilege P-009141C victim/witness for indictment preparation Contains information subject to privacy rights of victims who are not arties to this suit Box #2 File folder entitled ' Work product P-009142 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that individual for Investigative privilege P-009152 indictment preparation Contains information subject to privacy rights of victims who are not arties to this suit Box #2 File folder entitled' Work product P-009153 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that individual for Investigative privilege P-009156 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #1" Work product P-009157 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009208 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "[Victim name]/Jane Doe #2" Work product P-009209 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009213 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Page 14 of 23 EFTA00104278 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 15 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "[Victim name]/Jane Doe #3" Work product P-009214 containing meta-analysis of all phone, travel, and 6(e) Thru grand jury data related to that victim/witness for Investigative privilege P-009271 indictment preparation Contains information subject to privacy rights of victims who are not parties to this suit Box #2 File folder entitled "Purpose of Travel Cases" Work product P-009272 containing attorney research and handwritten Thru notes P-009354 Box #2 File folder entitled "Interstate Commerce Cases" Work product P-009355 containing attorney research and handwritten Thru notes P-009403 Box #2 File folder entitled "Attorney Conflict Research" Work product P-009404 containing attorney research and handwritten Thru notes P-009536 Box #2 File folder entitled "Mann Act/Travel to Have Work product P-009537 Sex w/Minor" containing attorney research and Thru handwritten notes P-009574 Box #2 File folder entitled "Travel Act" containing Work Product P-009575 attorney research and handwritten notes Thru P-009603 Box #2 File folder entitled "Florida Work Product P-009604 Prostitution/Lewdness Statutes" containing Thru attorney research and handwritten notes P-009711 Box #2 Booklet entitled "Attorney General Guidelines for P-009712 Victim and Witness Assistance" [not being Thru withheld as privileged — produced to opposing P-009819 counsel] Box #2 File folder entitled "Corporate Liability Rsrch" Work Product P-009820 containing attorney research and handwritten Thru notes P-009965 Box #2 File folder entitled "Research re Knowledge of Work Product P-009966 Age Unnecessary" containing attorney research 6(e) Thru and handwritten notes and copy of grand jury P-010096 subpoena Page 15 of 23 EFTA00104279 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 16 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "Money Laundering" Work Product P-010097 containing attorney research and handwritten Thru notes P-010276 Box #2 File folder entitled "1960 & Aiding/Abetting" Work Product P-010277 containing attorney research and handwritten Thru notes P-010394 Box #2 File folder entitled "18 USC § 2255 Cases" Work Product P-010395 containing attorney research and handwritten Thru notes P-010488 Box #2 File folder entitled "Research re Overt Acts & Work Product P-010489 Witness Testimony" containing attorney research Thru and handwritten notes P-010509 Box #2 File folder entitled "Extradition" containing Work Product P-010510 attorney research and handwritten notes Thru P-010525 Box #2 File folder entitled "Rsrch re Crime Victims Work Product P-010526 Rights" containing attorney research, handwritten Deliberative Process Thru notes, draft victim notification letter and draft P-010641 correspondence to (Also contains a November 28 2007 letter from Kenneth Starr to • and a November 29 2007 letter from to 1. (P-010528 thru P-010537and P-010556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by 11th Circuit) Box #2 File folder entitled "Immunity" containing Work Product P-010642 attorney research on granting immunity to Thru witnesses P-01650 Box #2 File folder entitled "Research re G.J. Transcript" Work Product P-010651 containing attorney research and draft pleadings 6(e) Thru re compelling production of grand jury transcript Deliberative process P-010659 with sub na Box #2 File folder entitled "Research re GJ Transcript" Work Product P-010660 containing grand jury subpoena, 6(e) letters, 6(e) Thru attorney research and correspondence related to P-010757 subpoena Page 16 of 23 EFTA00104280 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 17 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "Original Proposed Ind." Work Product P-010758 containing draft indictment 6(e) Thru Deliberative process P-010793 Box #2 File folder entitled "Epstein" containing sample Work Product P-010794 indictments and attorney research re potential Thru charges with attorney notes P-010829 Box #2 File folder entitled "1591 & Money Laundering" Work Product P-010830 containing attorney research and handwritten Thru notes P-010853 Box #2 File folder entitled "18 USC 2425" containing Work Product P-010854 attorney research and handwritten notes Thru P-010876 Box #2 File folder entitled "Knowledge of Age" Work Product P-010877 containing attorney research and handwritten Thru notes P-010920 Box #2 File folder entitled "2423(b) Constitutionality and Work Product P-010921 Purpose of Travel" containing attorney research Thru and handwritten notes P-011049 Box #2 File folder entitled "Mistake not a Work Product P-011050 Defense" containing attorney research and Thru handwritten notes P-011212 Box #2 File folder entitled "Research re `Pandering— Work Product P-011213 containing attorney research and handwritten Thru notes P-011237 Box #2 File folder entitled "Research re Grand Jury Work Product P-011238 Instructions" containing attorney research and 6(e) Thru handwritten notes P-011319 Box #2 File folder entitled "Telephone = Facility of Work Product P-011320 Commerce" containing attorney research and Thru handwritten notes P-011361 Box #2 File folder entitled "Def of Prostitution" Work Product P-011362 containing attorney research and handwritten Thru notes P-011374 Page 17 of 23 EFTA00104281 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 18 of 23 Bates Range Description Privilege(s) Asserted Box #2 File folder entitled "Relevant Florida Statutes" Work Product P-011375 containing attorney research and handwritten Thru notes P-011456 Box #2 File folder entitled "Unit of Prosecution Work Product P-011457 Research" containing attorney research and Thru handwritten notes P-011626 Box #3 File folder entitled "Attorney Notes" containing Work Product P-011627 attorney handwritten and typed notes Thru P-011662 Box #3 File folder entitled "Drafts" containing draft 6(e) P-011663 indictments with attorney handwritten notes, draft Work Product Thru internal memoranda, relevant witness interview Deliberative Process P-011698 and reports and grand jury material and attorney Investigative Privilege P-012189 thru handwritten notes Contains information subject P-012361 to privacy rights of victims (gap was who are not parties to this scanning error) Box #3 File folder entitled "6/9/09 Signed Indictment" 6(e) P-011699 containing signed indictment package dated Work product Thru 6/9/2009 with corrections Deliberative process P-011777 Box #3 File folder entitled "6/12/09 Victim Notif. Log" Work product P-011778 containing chart with victim contact information Thru and attorney notes regarding dates and type of P-011788 contacts Box #3 File folder entitled "Breach Memo" containing Work product P-011789 memorandum analyzing breach of Non- Deliberative process Thru Prosecution Agreement with attachments P-011879 Box #3 File folder entitled "Overt Act Lists" containing Work product P-011880 handwritten notes cross-checking all overt acts Attorney-client privilege Thru alleged in draft indictment by victim and typed Deliberative process P-011922 overt act summary charts for indictment 6(e) preparation Page 18 of 23 EFTA00104282 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 19 of 23 Bates Range Description Privilege(s) Asserted Box #3 Folder entitled "Responses to Arguments from JE Work product P-011923 Counsel" containing: Deliberative process Thru ■ 7/13/2007 letter from 6(e) P-011966 to with handwritten Attorney-Client Privilege attorney ( I notes- • 6/25/2007 letter from to g , and with handwritten attorney ( i• ■ 6/25/2007 email from to and entitled "Thoughts on letter" Handwritten and typed attorney I I notes regarding main themes raised by Epstein counsel Box #3 Composition book entitled "Operation Leap Work product P-011967 Year" containing attorney handwritten notes Investigative privilege Thru regarding investigation and case strategy 6(e) P-012016 Contains information subject to privacy rights of victims who are not parties to this litigation Box #3 Motion of Jeffrey Epstein to Intervene and to 6(e) P-012017 Quash Grand Jury Subpoenas and Incorporated Thru Memorandum of Law P-012055 Box #3 Affidavit of Esq. in Support of 6(e) P-012056 Motion of Jeffrey Epstein to Intervene and to Thru Quash Grand Jury Subpoenas P-012088 Box #3 United States' Response to Motion of Jeffrey 6(e) P-012089 Epstein to Intervene and to Quash Grand Jury Thru Subpoenas and Cross-Motion to Compel P-012129 Box #3 Declaration of 6(e) P-012130 Thru P-012150 Box #3 Ex Parte Declaration Number One in Support of 6(e) P-012151 United States' Response to Motion to Quash Investigative Privilege Thru Subpoenas Also contains information P-012167 subject to privacy rights of victims who are not parties to this litigation Page 19 of 23 EFTA00104283 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 20 of 23 Bates Range Description Privilege(s) Asserted Box #3 Ex Parte Declaration Number Two in Support of 6(e) P-012168 United States' Response to Motion to Quash Investigative Privilege Thru Subpoenas P-012170 Box #3 Supplement to Ex Parte Declaration Number One 6(e) P-012171 in Support of United States' Response to Motion Investigative Privilege Thru to Quash Subpoenas Also contains information P-012173 subject to privacy rights of victims who are not parties to this litigation Box #3 Draft of Se • tember 2009 letter from Work Product P-012174 to regarding breach of Non Attorney-Client Privilege Thru Prosecution Agreement with handwritten attorney Deliberative Process P-012176 notes Box #3 Undated handwritten attorney notes Work Product P-012177 regarding negotiations and allegations Attorney-Client Privilege Thru Deliberative Process P-012178 Box #3 File Folder entitled "FBI G.J. Log" containing 6(e) P-012179 copy of FBI rand jury subpoena log with Work Product Thru attorney ( handwritten notes Investigative Privilege P-012188 Also contains information subject to privacy rights of victims who are not parties to this litigation Box #3 File folder entitled "Key Documents" containing 6(e) P-012362 correspondence between AUSA and case agent Work Product Thru regarding indictment prep questions, victim Attorney-Client privilege P-012451 identification information, corrections to draft Investigative Privilege indictment, indictment preparation timeline, key Also contains information grand jury material subject to privacy rights of victims who are not parties to this litigation Box #3 File folder entitled "Victim List" containing list Work Product P-012451 of victims with dates of birth and age information Investigative Privilege Thru Also contains information P-012452 subject to privacy rights of victims who are not parties to this litigation Page 20 of 23 EFTA00104284 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 21 of 23 Bates Range Description Privilege(s) Asserted Box #3 Complete indictment package marked "Originals Work-product P-012453 12/12/07" Deliberative process Thru 6(e) P-012623 Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 Folder entitled "(Victims) Additional 302's" Investigative Privilege P-012624 containing reports of interviews conducted in Also contains documents Thru June 2007, October 2007, and March 2008. subject to privacy rights of P-012653 victims who are not parties to this litigation Box #3 3-ring binder entitled "Child Molesters: A Work-product P-012654 Behavioral Analysis" with attorney Ma) Thru handwritten notes P-012864 Box #3 Indictment preparation binder containing: Work Product P-012865 witness/victim list with identifying information, Deliberative Process Thru sexual activity subilephone call summary 6(e) P-013226 chart, attorney handwritten notes, Also contains documents 302s of state investigative file, attorney subject to investigative ( D typed notes, relevant pieces of grand privilege jury materials, telephone records/flight records Also contains documents analysis charts, victim/witness photographs, subject to privacy rights of DAVID records, NCICs, and related materials for victims who are not parties to persons identified as Jane Does #9, 10, 11, 12, 13, this litigation 14 Box #3 April 23, 2008 Memo from to Privacy Act P-013227 Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Box #3 April 21, 2008 Letter from to Privacy Act P-013226 Office of Professional Responsibility re Self Thru Reporting P-013230 Box #3 April 22, 2008 Letter from to Privacy Act P-013231 Office of Professional Responsibility re Self- Thru Report of Allegation of Conflict of Interest P-013239 Page 21 of 23 EFTA00104285 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 22 of 23 Bates Range Description Privilege(s) Asserted Box #3 April 21, 2008 Letter from to Privacy Act P-013240 Office of Professional Responsibility re Self Thru Reporting with attachments P-013247 Box #3 Emails between Assistant Attorney-Client Privilege P-013248 General Counsel, Executive Office for United Thru States Attorneys, and First P-013251 Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated Au ust 24 and Au ust 29 2011 Box #3 Emails between Assistant Attorney-Client Privilege P-013252 General Counsel, Executive Office for United Thru States Attorneys, and First P-013253 Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, Au ust 3, and Au ust 24 2011 Box #3 Emails between Assistant Attorney-Client Privilege P-013254 General Counsel, Executive Office for United Thru States Attorneys, and First P-013257 Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated Au ust 24 and Au ust 29 2011 Box #3 Emails between Assistant Attorney-Client Privilege P-013258 General Counsel, Executive Office for United Thru States Attorneys, and First P-013259 Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3 2011 Box #3 Email from , Assistant General Attorney-Client Privilege P-013260 Counsel, Executive Office for United States Thru Attorneys, to Wifredo Ferrer (U.S. Attorney, P-013262 SDFL Robert O'Neill (U.S. Attorney, MDFL i , (FAUSA, SDFL), and El (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated Au ust 24 2011. CC's ODAG), USAEO SABO), USAEO , (USAEO) Page 22 of 23 EFTA00104286 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 23 of 23 Bates Ran e Descri lion Privile s Asserted Box #3 ' Emails between Assistant Attorney-Client Privilege P-013263 General Counsel, Executive Office for United Deliberative Process Thru States Attorneys, and First Work Product P-013271 Assistant U.S. Attorney, Southern District of Florida, regarding recusal of Southern District of Florida, dated July 29. 2011 with attached memorandum from to summarizing Jeffrey Epstein Investigation Box #3 Emails between Executive Office Attorney-Client Privilege P-013272 for United States Attorneys, and Thru Southern District of Florida, seeking advice P-013278 regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from ■ to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 EFTA00104287