Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
Team privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
03089-03099 05/03/2009 Attorneys and RE: Setting Depos Work Product;attorney client
Staff privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
13445-13453 08/19/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
12281-12291 07/30/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
09337-09340 08/10/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
09350 10/21/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
09335 08/06/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
11983 08/06/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
11984-11988 08/06/2009 Litigation Strategy . Work Product;attorney client
privilege;irrelevant & reasonably calculated to
29
EFTA00296195
Privile e Lo — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00146 06/29/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00147 06/29/2009 M Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00148 04/22/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00149 04/26/2009 all Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00150 04/24/2009 Litigation Team Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00151-00152 06/26/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
01036-01039 04/26/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
13313-13314 07/30/2009 Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
43
EFTA00296196
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
lead to the discovery of admissible
evidence;protected by privacy rights
13315 08/03/3009 Illa Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
01080-01081 06/22/2009 Jane Doe brother Attorney/Client privilege and/or work product
01077 05/28/2009 1 13 Doe family member Attorney/Client privilege and/or work product
02445-02446 05/05/2009 Jones v. Atlantic asphalt Attorney/Client privilege and/or work product
03049 09/21/2009 New addition to the case Attorney/Client privilege and/or work product
02425-02426 06/17/2009 1 Jane Doe v. Dukenik Attorney/Client privilege and/or work product
02669 09/24/2009 Subpoena fo Attorney/Client privilege and/or work product
02647 08/06/2009 1 Samantha Lee Rivera info Attorney/Client privilege and/or work product
03688-03691 04/03/2009 I . Case number assignments Attorney/Client privilege and/or work product
03692-03693 05/06/2009 11. Case list Attorney/Client privilege and/or work product
15678.15680 09/29/2009 1 Subpoena fo Attorney/Client privilege and/or work product
15689 10/01/2009 I I I
Client information Attorney/Client privilege and/or work product
02546-02547 09/22/2009 I Client communication Attorney/Client privilege and/or work product
02809-02810 09/28/2009 I Client communication Attorney/Client privilege and/or work product
02262 07/23/2009 Discussion re: client/victim Attorney/Client privilege and/or work product
personal information
02807-02808 10/01/2009 Client communication Attorney/Client privilege and/or work product
03760-03828 04/01/2009 Client names/types of action/ Attorney/Client privilege and/or work product,
client information privacy right privilege, not relevant
03759 04/01/2009 Conflict Check for Attorney/Client privilege and/or work product
files
08358-08359 09/14/2009 Client info Attorney/Client privilege and/or work product
44
EFTA00296197
Privilege Log — Dated 2-23-2011
il lralailni
BATES DATE TO FROM DESCRIPTION OBJECTION
08364-08368 10/01/2009 l■ Client info Attorney/Client privilege and/or work product
08370 09/14/2009 Client info Attorney/Client privilege and/or work product
'
08374.08375 10/01/2009 I Client info Attorney/Client privilege and/or work product
03878 06/12/2009 I' Curtis Rivera Attorney/Client privilege and/or work product
02955 04/20/2009 1 • . Juskowich Attorney/Client privilege and/or work product
02932 07/17/2009 II Jane Doe v. Roe Attorney/Client privilege and/or work product
11544-11545 09/28/2009 1I Client info Attorney/Client privilege and/or work product
07432-07435 09/25/2009 New addition to the case Attorney/Client privilege and/or work product
06906-06909 07/17/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product
06913-06914 06/22/2009 . Jane Doe v. Roe Attorney/Client privilege and/or work product
06030-06031 05/04/2009 I • Espina — Walmart case Attorney/Client privilege and/or work product
05646 07/08/2009 I' Client meeting Attorney/Client privilege and/or work product
05573 09/18/2009 1 Client meeting Attorney/Client privilege and/or work product
05540 07/31/2009 Client info Attorney/Client privilege and/or work product
05273-05276 07/28/2009 7 1I Client info Attorney/Client privilege and/or work product
05264 07/27/2009 tt I Client info Attorney/Client privilege and/or work product
05267.05270 07/27/2009 I Client info Attorney/Client privilege and/or work product
02933 06/17/2009 --;
I
Jane Doe v. Roe Attorney/Client privilege and/or work product
I
1--
01292 09/18/2009 Epstein article Attorney/Client privilege and/or work product
01068.01070 04/02/2009 All Staff Current case list of Attorney/Client privilege and/or work product
01054-01055 04/02/2009 All Staff Updated case list for Attorney/Client privilege and/or work product
01033 05/06/2009 case list Attorney/Client privilege and/or work product
01030-01031 04/03/2009 Case number assignments Attorney/Client privilege and/or work product
45
EFTA00296198
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
01118-01120 09/22/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product
I
01986-01989 04/02/2009 Conflict check Attorney/Client privilege and/or work product
I I
01984-01985 04/02/2009 Conflict check Attorney/Client privilege and/or work product
25925 09/30/2009 All Staff Conflict check Attorney/Client privilege and/or work product
25874 09/30/2009 All Staff Additional name added to Attorney/Client privilege and/or work product
conflict check
08356-08357 09/16/2009 Client Meeting Attorney/Client privilege and/or work product
16760.16761 09/23/2009 New Client Attorney/Client privilege and/or work product
08005 06/05/2009 New Client Attorney/Client privilege and/or work product
06915.06920 06/17/2009 MG Jane Doe v. Roe Attorney/Client privilege and/or work product
08360-08363 09/16/2009 Client Meeting Attorney/Client privilege and/or work product
04101-04107 09/28/2009 ■ Jane Doe v. Roe Attorney/Client privilege and/or work product
04708.04710 09/18/2009 Epstein Article Attorney/Client privilege and/or work product
06910-06912 06/17/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product
07909 08/10/2009 Jane Doe Same silver car tag Attorney/Client privilege and/or work product
07637-07642 09/10/2009
06795-06799 08/19/2009
III Interview Attorney/ Client Privilege
Anthony P Client Meeting Attorney/Client privilege and/or work product
06542-06548 09/15/2009 Client Meeting Attorney/Client privilege and/or work product
06404-06408 09/10/2009 III • Interview Attorney/Client privilege and/or work product
08338-08339 09/16/2009 New Client Attorney/Client privilege and/or work product
08505 09/14/2009 New Client Meeting Attorney/Client privilege and/or work product
02241-02242 05/28/2009 Confidential Other Rape Victims W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02243-02244 07/07/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02238-02240 05/28/20009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02204 07/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
46
EFTA00296199
Privilege Log - Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
02298-02299 07/08/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02291 06/04/2009 IIIIIIMI Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
02442-02443 08/17/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02440-02441 10/02/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04318-04321 09/24/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05111 06/02/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05152 06/03/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05164 06/03/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05166 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05169-05170 06/03/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05173-05174 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05212-05213 06/23/2009 Confidential Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to
Source Providing New Witnesses discovery of admissible evidence
05215.05217 06/23/2009 Confidential Secret Plea Deal of Epstein W/P Priv.; not reasonably calculated to lead to
Source providing new witnesses discovery of admissible evidence
05175-05189 07/02/2009 I li Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05194-05196 06/23/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05204-05206 06/23/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
47
EFTA00296200
Privilege Log — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
05227-05228 07/08/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
05230-05231 07/08/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
05303 08/06/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05344-05346 06/23/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05408 07/06/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05425.05429 05/28/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05433-05436 05/29/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05433-05436 05/29/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05446 07/07/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05452-05464 05/29/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05535-05536 07/30/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
05538.05539 07/30/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05550-05551 08/11/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05577-05578 08/22/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05619.05620 09/18/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05650 08/06/200 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05688-05689 0/28/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
48
EFTA00296201
Privilege Log — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
05693-05695 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05698 08/21/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05706-05709 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05720-05721 05/29/2O09 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05738.05739 05/29/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05743-05745 05/29/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05754 08/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05759.05762 06/01/2O09 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05765-05768 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05771-05773 06/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05777.05779 06/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05784.05786 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05791-05794 06/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05803 07/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05836-05837 07/08/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05842-05843 07/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
49
EFTA00296202
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
05848 07/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05852-05853 07/29/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05857-05858 07/31/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05952-05953 08/25/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06192-06197 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06198-06201 06/24/2009 Confidential Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
06203 07/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06401 09/23/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06643-06651 09/17/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06788.06789 09/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06942-06943 09/26/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
06953 08/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06955-06957 10/02/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06959-06961 08/11/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06963-06980 08/11/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06986.06989 10/03/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07010-07014 10/04/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
50
EFTA00296203
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
07017.07018 09/04/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
07143-07144 10/01/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
07147-07150 09/18/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
075089- 10/13/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
07513 Source discovery of admissible evidence
07605-07615 09/07/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07646-07647 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07674.07697 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08376 10/04/2009 Confidential = Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
08380 09/18/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08427-08430 09/24/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08450 05/17/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08507 10/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
10092.10098 08/31/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01610 06/03/3009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01612 06/04/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01451-01458 05/27/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
51
EFTA00296204
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
01608 07/03/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01606 07/02/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01510 08/25/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01506 08/24/2009 Confidential Other Rape Victims W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01493 08/10/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01488 08/03/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01486 07/28/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01483 07/28/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
01479 07/22/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01449 05/22/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01433 10/20/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
15207-15208 08/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
19716-19719 09/25/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
19730-19731 10/02/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01683 08/06/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01693 08/21/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source I discovery of admissible evidence
03011 09/17/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
52
EFTA00296205
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
Epstein Molestations discovery of admissible evidence
01755-01756 10/02/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
01756 06/22/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01770 10/08/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03126 09/18/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Strategy discovery of admissible evidence
02006 06/23/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02060 09/23/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03487-03494 09/19/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02269 08/26/2009 Confidential Other Rape Victims W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02322-02323 10/16/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02595-02596 09/07/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02866.02867 09/25/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02895 08/31/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
02901 09/16/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03032 09/18/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03057 10/13/2009 ,11. Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03070 07/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
53
EFTA00296206
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
03081-03082 09/21/2009 Confidential Source Providing Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03144 10/08/2009 Confidential Providing Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03189.03190 10/14/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Strategies discovery of admissible evidence
04015 09/08/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02913 09/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02956-02957 08/31/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02975 10/21/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
04031.04055 08/12/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
04057 08/11/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
04060 08/12/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02979-02980 10/02/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
02998 07/21/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05626 10/12/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05630-05631 10/12/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05664-05665 10/12/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07976 08/14/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
06655 06/09/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
54
EFTA00296207
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
Source discovery of admissible evidence
19986-19987 09/28/2009 Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
04905-04906 07/15/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04946.04951 10/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05148 05/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05151 05/26/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05161 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05203 06/23/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05207-05208 06/23/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05220-05221 06/23/2009 Confidential Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05224.05225 06/24/2009 Confidential Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05239 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05277-05278 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05324.05325 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05368-05369 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05387-05388 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02811-02812 10/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
55
EFTA00296208
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
01280-01288 09/18/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
01131-01134 10/08/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
00988 04/25/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10163-10167 08/12/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10181-10188 08/12/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10245-10251 09/08/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10364-10367 09/17/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
10586-10591 09/24/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
10625-10632 10/02/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
10698-10699 10/13/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
10718.10719 10/13/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10927-10937 05/28/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10945-10954 05/29/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10964-10978 06/02/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
10991 06/22/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
11006.11010 06/23/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
56
EFTA00296209
n alloalik l na
2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
Epstein Molestations to discovery of admissible evidence.
11075.11076 07/29/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
11080-11082 07/31/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
11085-11097 09/04/2009 Confidential Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11123-11136 09/17/2009 Confidential Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11140-11142 10/04/2009 Confidential Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11150.11151 10/12/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
10390-10393 09/19/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
11157-11165 10/25/2009 Confidential Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11170.11174 06/23/2009 Confidential Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11184.11185 05/27/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11188-11195 05/28/2009 Confidential Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11198-11200 05/28/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11208-11214 05/29/2009 Confidential Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11223-11236 06/01/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11260-11266 06/24/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11320-11325 07/30/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
57
EFTA00296210
Privilege Log — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
11372-11373 08/11/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11380-11383 08/12/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11438-11442 09/17/2009 Confidential Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11549-11550 10/01/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
source to discovery of admissible evidence.
11574-11579 10/13/2009 Confidential Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
BOX 2
BATES DATE TO FROM DESCRIPTION OBJECTION
08029.08032 09/14/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08026-08028 05/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07738-07739 05/13/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07747 09/17/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07758-07759 05/05/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
58
EFTA00296211
Privilege Log — Dated 2-23-2011
BATES DATE Ts FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
07760-07765 09/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07766 10/11/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07767.07784 05/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07785-07790 06/26/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07791 04/04/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07792-07793 04/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07794.07841 04/04/2009 Full draft of motion to stay W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07842.07848 06/16/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
59
EFTA00296212
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
05320-05323 07/30/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05312.05313 07/22/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05306-05307 07/22/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05302 07/22/2009 Attorney at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05281 08/03/2009 Review of litigation materials W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05282-05283 04/09/2009 Jane Doe v. Us W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05288-05291 07/22/2009 Dr. Swan W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05292 07/22/2009 Attorneys at. RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
63
EFTA00296213
Privilege Log — Dated 2-23-2011
BATES DATE IQ FROM DESCRIPTION • BJE I • N
privacy rights
05295-05297 07/23/2009 Attorneys at RE: Epstein Conference Room W/P; Attorney Client Privilege; Irrelevant and
Reserved not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05298 08/03/2009 Discussion of Epstein strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05261 07/23/2009 Victim Psychological Assessment W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18358-18359 07/24/2009 Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04431-04432 08/14/2009 RE: Epstein-Maxwell Subpoena W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04419-04420 04/09/2009 RICO Statement W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04403.04416 10/17/2009 Punitive Damages W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04387-04402 08/19/2009 Victim Complaints, Forensic W/P; Attorney Client Privilege; Irrelevant and
accountants, & Epstein's not reasonably calculated to lead to the
Fraudulent Transfers discovery of admissible evidence; protected by
privacy rights
64
EFTA00296214
Privilege Log — Dated 2-23-2011
BATES RATE iv FROM DESCRIPTION OBJECTION
04202-04206 09/08/2009 Epstein's attorneys & Bob W/P; Attorney Client Privilege; Irrelevant and
Josephsberg have filed several not reasonably calculated to lead to the
motions on limits of the no discovery of admissible evidence; protected by
contact order privacy rights
O4207-04215 09/04/2009 Attorneys at. Letter to Critton RE: ProtectiveW/P; Attorney Client Privilege; Irrelevant and
Order not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04191-04193 09/04/2009 Finding out who is protected by W/P; Attorney Client Privilege; Irrelevant and
the order not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04194-04195 09/04/2009 Attorneys at Seek Court Intervention W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04196.04199 09/08/2009 Finding out who is protected by W/P; Attorney Client Privilege; Irrelevant and
the order not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25937 10/25/2009 Epstein's house staff W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25923 09/09/2009 Attorneys at. Maribel Matiska legal opinion RE: Epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25832-25838 06/01/2009 contact Information re: who is W/P; Attorney Client Privilege; Irrelevant and
pertinent to the case not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25825-25826 10/05/2009 Trial Prep Epstein W/P; Attorney Client Privilege; Irrelevant and
67
EFTA00296215
Privilege Lo — Dated 2-23-2011
ll !I ll fi l l ! ' flip I I I
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19856 10/17/2009 I Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20888 09/12/2009 a = Potential New witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20946 05/11/2009 Attorneys at Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05807-05810 07/23/2009 Attorneys at Conference room reserved W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05262-05263 07/22/2009 Investigator information W/P; Attorney Client Privilege; Irrelevant and
not reasonably cakulated to lead to the
discovery of admissible evidence; protected by
privacy rights
25829 05/11/2009 Motion to unseal criminal records W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25830-25831 05/11/2009 Attorneys at Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25811-25813 05/11/2009 Attorneys at Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
72
EFTA00296216
e alMit l ina
2-23-2011
BATES DATE TO FROM PESCRIPTION OBJECTIQN
discovery of admissible evidence; protected by
privacy rights
25815-25822 06/01/2009 Depo information W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18358-18359 07/24/2009 Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05382 09/12/2009 Potential new witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08033-08070 10/23/2009 Attorneys at a Legal Research RE: Causes of W/P; Attorney Client Privilege; Irrelevant and
action against Epstein not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25997 10/23/2009 Legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and
action against Epstein not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26741-26763 10/23/2009 Attorneys at Legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and
action against Epstein not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25774-25777 05/12/2009 Filed Motions W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18177-18179 08/24/2009 Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
73
EFTA00296217
Privilege Loa — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
privacy rights
18174-18176 08/24/2009 Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
El
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18172-18173 08/24/2009 IIII Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18170 08/24/2009 Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy ri hts
03106 06/03/3009 Epstein Case Info W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02593-02594 05/13/2009 Discussion with secretary W/P; Attorney Client Privilege; Irrelevant and
regarding client information not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08014 Undated Unknown Staff Miscellaneous case info W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
27494 10/23/2009 Attorneys at ■ Legal Research RE: Causes of W/P; Attorney Client Privilege; Irrelevant and
IIII
action against Epstein not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18166.18167 08/04/2009 Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
74
EFTA00296218
Privilege Log — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16795-16796 10/01/2009 ism Trump Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16455-16759 09.10/2009 Depo Dates W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16436-16437 09/09/2009 Dershowitz Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16400-16404 09/02/2009 Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16394-16395 08/31/2009 Depo Dates W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01046 08/25/2009 Computer information W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01048-01050 07/28/2010 Hard drive of Plaintiffs computer W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01052 09/09/2009 Attorneys at ■ Maribel Matiska legal Opinion RE: Epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
76
EFTA00296219
Privile e Lo — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
01100 10/19/2009 Dershowitz Involvement W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01105 08/11/2009 Potential New Witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01111 05/13/2009 Legal research W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01112.01117 05/12/2009 Dr. Swan W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01139-01142 04/29/2009 Staff Epstein Depo revised W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01151 09/11/2009 Motion for protective order final W/P; Attorney Client Privilege; Irrelevant and
draft not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01167 09/11/2009 Epstein MPO W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01216 05/21/2009 Immunity for testimony about W/P; Attorney Client Privilege; Irrelevant and
prostitution not reasonably calculated to lead to the
discovery of admissible evidence; protected by
EFTA00296220
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
privacy rights
01247 09/30/2009 Therapy Notes W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01268-01269 10/22/2009 Epstein meeting W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01293 08/19/2009 Epstein Assets W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01299 04/21/2009 Order denying the motion to W/P; Attorney Client Privilege; Irrelevant and
reassign or transfer not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01305 08/24/2009 Epstein Computers W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01313 09/02/2009 Attorneys at Epstein Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01333 08/03/3009 Epstein Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01335 08/03/2009 Investigation into Epstein planes W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
78
EFTA00296221
Privilege Log - Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
01337 08/10/2009 Epstein Depo list W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01363 09/08/2009 Motion to freeze assets W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01414-01416 98/18/2009 Epstein Potential Witness List W/P; Attorney Client Privilege; Irrelevant and
& not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01417 08/24/2009 Potential Witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01429 09/09/2009 Attorneys at. Epstein telephone conference W/P; Attorney Client Privilege; Irrelevant and
today not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01431 07/31/2009 Epstein case info W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01432 09/15/2009 New Victims W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01434 10/19/2009 Epstein Evidence W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01461 04/27/2009 Epstein Info W/P; Attorney Client Privilege; Irrelevant and
79
EFTA00296222
Privilege
r i - Datec 2-23-2011
i s Log
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01466 07/31/20009 Epstein Presentation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01471 07/18/2009 Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01480 07/22/2009 Attorneys at al Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01482 07/24/2009 Investigation into Epstein planes W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01491 08/10/2009 Investigative fees W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01492 08/10/2009 ME The Mar-a-Lago Club Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01495 08/11/2009 Potential Witness W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01498 08/17/2009 Legal opinion re:Epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
80
EFTA00296223
Privile e Lo — Dated 2-23-2011
BATES DATE • FROM DESCRIPTION OBJECTION
01628 06/15/2009 Investigations W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01635 05/21/2009 Personal Conversation W/P; Attorney Client Privilege; Irrelevant and
le
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01636 06/23/2009 Motion to unseal W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01638 06/29/2009 Litigation Strategy RE: Motion to W/P; Attorney Client Privilege; Irrelevant and
unseal not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01644 07/06/2009 Confidential Request for admission W/P; Attorney Client Privilege; Irrelevant and
Source not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01646 07/06/2009 Confidential Secret Plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and
Source not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01648 07/11/2009 Investigating Epstein's planes W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01650 07/13/2009 Epstein's Assets W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01658-01659 07/18/2009 DOJ W/P; Attorney Client Privilege; Irrelevant and
83
EFTA00296224
Privilege Log — Dated 2-23-2011
at
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
01692 09/12/2009 Proposal for settlement W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01698 05/05/2009 IMI Epstein Victim Depos W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01702 09/17/2009 Epstein Depos W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01705 05/14/2009 Statutory Rape W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01711 04//01/2009 Third party subs W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01737 07/14/2009 Facebook/Myspace W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01564 05/11/2009 Attorneys at ■ Investigation Epstein's planes W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01603 10/15/2009 Adam Horowitz Testimony RE: Vehicles W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
85
EFTA00296225
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
04237-04242 06/15/2009 Epstein secret plea deal with W/P; Attorney Client Privilege; Irrelevant and
Bear Stearns not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04246 06/15/2009 Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and
Stearns not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04250 06/15/2009 Epstein Victims W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04255-04256 06/15/2009 Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and
Stearns not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04260 06/15/2009 Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and
Stearns not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04523 05/14/2009 Investigating Epstein's planes W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05088-05090 10/27/2009 Attorneys at Epstein's assets W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05108 04/01/2009 Victims employment W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
87
EFTA00296226
Privile e Lo. — Dated 2-23-2011
11 &
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08/04/2009 Spencer Kuvin Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
02728.02729
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02746 07/22/2009 Adam Steinberg Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02813.02814 08/26/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02817-02826 08/04/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02827-02832 05/12/2009 Attorneys at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02833-02835 08/23/2009 Other Rape Victims W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02874.02876 05/23/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02887-02888 08/26/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
89
EFTA00296227
Privile e Lo — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03050-03052 10/16/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03053 10/17/2009 a Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03054 10/13/2009 Attorneys at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03056 09/04/2009 Other Rape Victims W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03072 06/22/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03073 09/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03074-03075 10/28/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03100 10/15/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
93
EFTA00296228
Privilege Lori— Dated 2-23-2011
BATES DATE 11
Q ROM DESCRIPTION OBJECTION
03197-03199 08/14/2009 Attorneys at., Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03205-03211 09/13/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03212 08/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03213 10/28/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03214-03218 10/27/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03223.03232 04/15/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03233-03242 09/28/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03245 06/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03251-03252 09/24/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
96
EFTA00296229
Privilege Log — Dated 2-23-2011
i~iii&
BATES DATE IQ FROM DESCRIPTION OBJECTION
privacy rights
03524 09/04/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03525-03530 09/05/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03532 08/24/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03536 07/19/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03539-03540 08/26/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03541-03544 10/12/2009 Attorneys at ■ Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03545.03547 06/26/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03548.03549 04/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
99
EFTA00296230
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
03550-03574 09/09/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03575-03588 10/19/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03589-03604 04/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03605-03606 10/16/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03607-03610 10/16/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03611-03612 10/16/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03613.03615 10/29/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03616-03618 10/01/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03628-03637 09/15/2009 I Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
100
EFTA00296231
Privilege Log — Dated 2-23-2011
BATES DATE 11
Q FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03638-03641 09/08/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08454 10/23/2010 Attorneys at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08118-08123 10/23/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08124-08156 10/23/2009 Attorneys at Steven Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02411-02413 05/12/2009 Attorneys at I Jane Doe II v. Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01913-01914 06/15/2009 I I Activity in case 9:08-cv-80893- Work product; attorney/client privilege;
KAM Doe v. Epstein Motion to irrelevant and not reasonably calculated to lead
Dismiss to the discovery of the admissible evidence;
protected by privacy rights
01918- 01919 04/15/2009 Attorneys at I Activity In case 9:08-cv-80893- Work product; attorney/client privilege;
KAM Doe v. Epstein Motion to irrelevant and not reasonably calculated to lead
Compel to the discovery of the admissible evidence;
protected by privacy rights
01920-01924 05/20/2009 I. Activity in case 9:08-cv-80994- Work product; attorney/client privilege;
KAM Jane Doe No. 6 v. Epstein irrelevant and not reasonably calculated to lead
101
EFTA00296232
Privilege Log — Dated 2-23-2011
BATES DATE 12 FROM DESCRIPTION OBJECTION
Motion to Strike to the discovery of the admissible evidence;
protected by privacy rights
01925 08/26/2009 I Surveillance/Interview Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01928-01929 08/03/2009 I Alfredo Rodriguez address Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01930 09/05/2009 I I Client info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01940 09/10/2009 I. Witness Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01944-01952 04/10/2009 I Epstein assets Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01969 05/04/2009 I I Call from sources of information Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01971.01972 05/13/2009 Attorneys at I Draft Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01973-01974 07/23/2009 I vs. Epstein — new Work product; attorney/client privilege;
investigator info irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
102
EFTA00296233
Privilege Log — Dated 2-23-2011
St
BATES PATE IQ FROM DESCRTTJal OBJECTION
02023 05/14/2009 Attorneys at. I deposition of Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02045-02046 09/04/2009 Attorneys at Doe v. Epstein — Letter Work product; attorney/client privilege;
from Bob Critton irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02049-02053 09/04/2009 Doe v. Epstein — Letter Work product; attorney/client privilege;
from Bob Critton irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02063-02064 05/19/2009 1 I. Epstein — Confirming Dialin Work product; attorney/client privilege;
Telephone Conference for irrelevant and not reasonably calculated to lead
Monday , 6/8/09 at 2:00 p.m. to the discovery of the admissible evidence;
protected by privacy rights
02089.02090 09/17/2009 I Epstein hearing Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02091.02092 06/16/2009 Attorneys at I. Epstein — Monthly Call in Work product; attorney/client privilege;
Telephone Conference irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02106-02108 04/29/2009 I I Epstein — Telephone Conference Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02109 05/13/2009 I. Epstein info — List of Plaintiff Work product; attorney/client privilege;
lawyers irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02110-02111 09/15/2009 1 Epstein - Cancelling depositions Work product; attorney/client privilege;
104
EFTA00296234
Privilege Log — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
in New York for the following irrelevant and not reasonably calculated to lead
week to the discovery of the admissible evidence;
protected by privacy rights
02112-02116 09/10/2009 Epstein — Yearbook picture of Work product; attorney/client privilege;
Epstein rape victims irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02117-02118 10/23/2009 I
Epstein (AUSA) Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02119-02121 09/08/2009 S. I Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02130-02137 05/26/2009 I I Epstein cases- depositions in Work product; attorney/client privilege;
federal cases irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02138-02139 08/04/2009 I Epstein depo — New York Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02143-02146 09/28/2009 I Epstein Depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02229 05/05/2009 I Epstein Depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02236-02337 05/20/2009 Attorneys at I Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
105
EFTA00296235
Privilege Log- Dated 2-23-2011
&
Rau Rag ILR -----
FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
02256-02257 07/22/2009 Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02260-02261 07/22/2009 I Epstein — coordinating meetings Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02263-02265 07/23/2009 Attorneys at. Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02266 07/30/2009 I Epstein — Video Deposition oM Work product; attorney/client privilege;
in NY irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02273.02276 09/18/2009 I Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02278-02279 07/23/2009 Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02284-02855 05/11/2009 I I Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01769 10/30/2009 I Barbara Berg info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
106
EFTA00296236
Privilege Log— Dated 2-23-2011
BATES pATt TO FROM DESCRIPTION OBJECTION
protected by privacy rights
01780 09/14/2009 I Discussion of belief that Epstein Work product; attorney/client privilege;
is transferring assets to avoid irrelevant and not reasonably calculated to lead
judgments to the discovery of the admissible evidence;
protected by privacy rights
01787-01788 09/04/2009 I 1. Accountants 2. Motion for IME Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01799-01801 10/14/2009 I Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
KAM Doe v. Epstein Notification irrelevant and not reasonably calculated to lead
of ninety days expiring to the discovery of the admissible evidence;
protected by privacy rights
01804-01805 09/04/2009 S. I Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
KAM Doe v. Epstein — Order on irrelevant and not reasonably calculated to lead
motion for Medical Exam to the discovery of the admissible evidence;
protected by privacy rights
01806.01807 09/09/2009 I Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
KAM Doe v. Epstein — Motion for irrelevant and not reasonably calculated to lead
protective order to the discovery of the admissible evidence;
protected by privacy rights
01808-01809 09/10/2009 I Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
KAM Doe v. Epstein - Order on irrelevant and not reasonably calculated to lead
Motion for Extension of Time to to the discovery of the admissible evidence;
File Response/Reply/Answer protected by privacy rights
01810-01816 09/09/2009 Attorneys at 1 1 Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
KAM Doe v. Epstein — Response irrelevant and not reasonably calculated to lead
to Motion to the discovery of the admissible evidence;
protected by privacy rights
01817-01818 06/11/2009 I Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
KAM Doe v. Epstein — Response irrelevant and not reasonably calculated to lead
to motion to the discovery of the admissible evidence;
protected by privacy rights
107
EFTA00296237
Privilege Log — Dated 2-23-2011
BATES DATE :EQ FROM DESCRIPTION OBJECTION
01840-01841 07/16/2009 IIIIIIIIII I Activity in case 9:08-cv-80119-Work product; attorney/client privilege;
la KAM Doe v. Epstein — Order on irrelevant and not reasonably calculated to lead
Motion to Stay to the discovery of the admissible evidence;
protected by privacy rights
01867-01868 09/28/2009 I. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
la KAM Doe v. Epstein — Notice irrelevant and not reasonably calculated to lead
(Other) to the discovery of the admissible evidence;
protected by privacy rights
03662-03663 08/10/2009 Attorneys at. la I. Meeting with clients Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03664.03668 09/18/2009 I. Litigation strategy and Work product; attorney/client privilege;
preparation irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08166-08168 10/28/2009 ■- I. Weds filing Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08169-08170 08/06/2009 Wexner deposition for 14th Work product; attorney/client privilege;
1
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08190-08196 04/07/2009 I: Motion to unseal/Motion to stay Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08265-08300 09/04/2009 Attorneys at ■ I Witness Information Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08377-08378 10/02/2009 Zorro Trust research info. Work product; attorney/client privilege;
I
108
EFTA00296238
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08441-08446 10/05/2009 Attorneys at Trial Prep Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03672-03673 06/26/2009 Brunel information Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03706-03718 08/05/2009 Cf. Response to Motion to File Work product; attorney/client privilege;
Epstein Affidavit irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03737 08/25/2009 Computers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03746-03753 08/02/2009 Computers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02335-02338 05/08/2009 Litigation strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02360-02361 06/09/2009 Hearing to Un-seal- Criminal Plea Work product; attorney/client privilege;
Transcript irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02368-02373 10/14/2009 Igor Zinoview depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
110
EFTA00296239
Privilege Log — Dated 2-23-2011
BATES DATE IQ FROM DESCRIPTION OBJECTION
protected by privacy rights
02376-02392 10/14/2009 Igor Zinoview depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02401-02410 05/08/2009 Jane Doe II v. Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02414-02419 05/12/2009 Attorneys at. Jane Doe II v. Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03669-03670 10/08/2009 Epstein house arrest monitor Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02288-02289 05/26/2009 Motion date Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02292-02293 05/19/2009 Pimp and His Game Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
023O4-O2308 09/17/2009 Forensics/Investigations Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02313-02316 07/01/2009 Confidential Agreement Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
111
EFTA00296240
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
02331-02334 05/08/2009 Critton order Transcript Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02173 09/04/2009 Attorneys at. Epstein Juan Alessi Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02187 07/26/2009 Epstein matter Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02195-02197 09/17/2009 Epstein Order Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02199-02203 09/18/2009 Epstein Order Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02211-02214 07/01/2009 Epstein v. State of Florida- Work product; attorney/client privilege;
Emergency Petition for Writ of irrelevant and not reasonably calculated to lead
Certiorari to the discovery of the admissible evidence;
protected by privacy rights
02224 07/28/2009 Witness of Epstein rapes from Work product; attorney/client privilege;
Switzerland irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10787-10799 10/19/2009 Witness List Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10901-10902 05/11/2009 RICO Enterprise Work product; attorney/client privilege;
112
EFTA00296241
Privilege Log — Dated 2-23-2011
BATES DATE 12 FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10904-10905 05/11/2009 Attorneys at RICO Enterprise Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10908-10909 05/11/2009 Attorneys at RICO Enterprise Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10912.10913 05/11/2009 Attorneys at. RICO Enterprise Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10955-10963 06/01/2009 Plaintiff's Witness list Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10979.10981 06/03/2009 Serve Subpoenas Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11022-11025 06/26/2009 Info on 2 MC2 Workers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11036.11037 07/21/2009 Serve Subpoenas Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11039-11071 07/21/2009 Retainer from the Firm Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
113
EFTA00296242
Privilege Log — Dated 2-23-2011
BATES DATE 12 FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
11083-11084 09/04/2009 Attorneys at. Witness info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11105-11110 09/09/2009 Disseminate letter from Wexner Work product; attorney/client privilege;
attorney irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11137-11139 10/03/2009 Zorro Trust research info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11143-11146 10/04/2009 11/28 Discovery Cutoff Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11155-11156 10/18/2009 Attorneys at. New Property Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11175-11183 04/27/2009 Epstein Case info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11196-11197 05/28/2009 Jail Visitors Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11205.11207 05/28/2009 Litigation strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence; i
114
EFTA00296243
Privilege Log — Dated 2-23-2011
BATES DATE 12 RIPKA DESCRIPTION OBJECTION
11359.11362 08/10/2009 Epstein depos Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11366-11371 08/11/2009 Trump depo info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11377-11379 08/12/2009 Issuing Subpoenas Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11390-11395 08/17/2009 Witness depos Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11400-11415 08/18/2009 Subpoenas for pilots Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11420-11426 08/24/2009 Attorneys at Serving Alan Dershowitz Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11428-11429 08/26/2009 Attorneys at Witness info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11568 10/07/2009 Meeting with Leslie Wexner Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11587 10/23/2009 Visoski Depo Work product; attorney/client privilege;
116
EFTA00296244
Privilege Log — Dated 2-23-2011
BATES DATE 12 FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11861.11865 10/23/2009 Attorneys at Witness List Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11870-11871 08/24/2009 Attorneys at Epstein info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11874 08/24/2009 Confidential info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11876 08/24/2009 Attorneys at Confidential Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11967-11972 10/29/2009 Subpoenas for Epstein's Work product; attorney/client privilege;
Attorneys irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08072-08075 07/22/2009 Total counts for Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08090.08091 10/05/2009 Trial Prep Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08114-08117 08/18/2009 Updated Witness List Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
117
EFTA00296245
Privilege Log — Dated 2-23-2011
BATES PATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08157-08159 06/03/2009 Vanity Fair Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08499.08501 08/24/2009 Attorneys at. Witness List Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10063.10068 08/03/2009 Confidential Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10090-10091 08/31/2009 Attorneys at Witness Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10103-10104 08/27/2009 Attorneys at Witness Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10106-10137 08/24/2009 Attorneys at Meetings/ Confidential Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
12569 07/30/2009 Epstein Sex Abuse Litigation Work product; attorney/client privilege;
Forum irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15827.15837 07/22/2009 Retainer for Investigator Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
118
EFTA00296246
Privilege Log— Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
protected by privacy rights
15820-15822 10/29/2009 Subpoenas for Epstein's Work product; attorney/client privilege;
Attorneys irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15401-15412 09/09/2009 Disseminate the letter from Work product; attorney/client privilege;
wexner atty irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15356-15359 08/26/2009 Attorneys at Witness info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
14934-14950 07/22/2009 Investigator Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
13413-13414 08/06/2009 Epstein information Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
13908-13911 08/24/2009 Attorneys at Meeting info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10595-10597 09/29/2009 Subpoena for Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10621.10624 10/02/2009 Meeting with Wexner atty Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
119
EFTA00296247
Privilege Log — Dated 2-23-2011
&
BATES DATE TO FROM DESCRIPTION OBJECTION
10633.10638 10/05/2009 Trial Prep Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10681-10692 10/07/2009 Depositions Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10777-10786 10/16/2009 New Evidence of Epstein Work product; attorney/client privilege;
Fraudulent Transfers irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04094-04100 04/07/2009 Draft Motion to Strike Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02915 10/03/2009 Attorneys at Finances Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02971 10/14/2009 Larry Visoski depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02976 09/09/2009 Disseminate the letter from Work product; attorney/client privilege;
wexner irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02995 06/24/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10172-10178 08/12/2009 Trump Depo Work product; attorney/client privilege;
120
EFTA00296248
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10193 08/11/2009 Trump Depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10255 09/09/2009 Depo of Alan Dershowitz Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10259-10263 09/09/2009 Attorneys of. Cooperfield Service Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03876-03877 10/26/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03879-03884 07/13/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03886-03891 07/13/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03905-03920 09/08/2009 . Doe v. Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03937 08/17/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
121
EFTA00296249
Privilege Log — Dated 2-23-2011
BAT€S DATE M FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
04005-04011 05/13/2009 Discovery Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04070-04093 04/07/2009 Motion to Strike Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03754 07/08/2009 Conference Call Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03848-03858 09/09/2009 Cooperfield Service Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03642-03643 09/04/2009 1. Accounts/ 2. Motion for IME Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03657-03661 09/04/2009 Attorneys at Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02475 06/15/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02494.02515 09/20/2009 Mark Epstein Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
122
EFTA00296250
Privilege Log— Dated 2-23-2011
BATES DATE Lo FROM DESCRIPTION OBJECTION
protected by privacy rights
02520-02543 06/06/2009 Memo of Assest Transfers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02548-02553 08/03/2009 Federal Subpoena Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02560-02565 07/31/2009 Federal Subpoena Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02568-02570 10/13/2009 New Times Article Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02578.02583 05/28/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02619-02622 09/09/2009 New client Retainer Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02633-02646 05/01/2009 Response to Motion to Work product; attorney/client privilege;
Consolidate + strategy irrelevant and not reasonably calculated to lead
Memo for Jay to the discovery of the admissible evidence;
protected by privacy rights
07959.07964 09/24/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
123
EFTA00296251
Privilege Log— Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
Visoski depo irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07595-07604 05/20/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07616 07/22/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07530-07549 06/11/2009 Overtime Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07470-07507 07/09/2009 Motion to Compel Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07447-07469 10/13/2009 Attorneys at New Times Article on epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07444-07446 05/01/2009 Response to Motion to Work product; attorney/client privilege;
Consolidate + Strategy irrelevant and not reasonably calculated to lead
Memo for Jay to the discovery of the admissible evidence;
protected by privacy rights
07440 10/18/2009 Attorneys at New Trump Property Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07436 04/11/2009 New cases Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
125
EFTA00296252
Privilege Log — Dated 2-23-2011
BATES DATE m FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06800-06803 09/06/2009 RE: 1. Accountants 2. Motion for Work product; attorney/client privilege;
IME irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06761-06762 08/19/2009 Attorneys at. IME Rules Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06767-06769 09/10/2009 Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06782.06787 04/10/2009 Confidential Detailed Strategy Work product; attorney/client privilege;
Memo on Asset Protection Issues irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06744.06747 05/01/2009 Depo of Jeffrey Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06736-06739 05/01/2009 Asset Protection Issue Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06709.06710 10/14/2009 Igor Zinoview depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
130
EFTA00296253
Privilege Log — Dated 2-23-2011
&
BATES QATE 12 FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05845 07/24/2009 Plane Tail Numbers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05811 06/09/2009 Witness Numbers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05813 08/15/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05748-05749 08/11/2009 Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05711 05/11/2009 Attorneys at. Subpoena Clinton Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05701-05704 04/20/2009 Epstein strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05687 08/21/2009 Alfredo Rodriguez Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05690-05691 05/11/2009 Motion to Unseal Work product; attorney/client privilege;
136
EFTA00296254
Privilege Log— Dated 2-23-2011
BATES DATE IQ FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05680-05682 05/11/2009 Subpoena Clinton Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05676 08/24/2009 Attorneys at. Topics for Meeting Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05648 07/23/2009 Attorneys at Gary Assemble Epstein Litigation Work product; attorney/client privilege;
meeting irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05629 08/03/2009 Law Enforcement cannot release Work product; attorney/client privilege;
juvenile reports irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05621.05622 09/18/2009 Preparing Motion to take an IME Work product; attorney/client privilege;
of Epstein irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05610-05612 04/27/2009 Request for Copies Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05588-05590 08/24/2009 Attorneys at. Travel restrictions Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
137
EFTA00296255
Privilege Log— Dated 2-23-2011
&
BATES DATE IQ FROM DESCRIPTION OBJECTION
05575-05576 08/21/2009 Alfredo Rodriguez Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05582 09/11/2009 Epstein strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05569-05570 08/17/2009 Legal Opinion Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05556-05558 08/14/2009 Attorneys at Communication with legal expert Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05537 07/30/2009 No objections from defense Work product; attorney/client privilege;
counsel regarding depo fora irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
_ protected by privacy rights
05534 07/24/2009 Flight logs for Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05518 07/22/2009 Attorneys at Assemble Epstein Litigation Work product; attorney/client privilege;
meeting irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05512-05513 07/23/2009 Assemble Epstein Litigation Work product; attorney/client privilege;
meeting irrelevant and not reasonably calculated to lead
138
EFTA00296256
Privilege Log — Dated 2-23-2011
&
BATES TO I FROM DESCRIPTION S
05399 10/17/2009 Proposal for settlement Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05399 10/17/2009 Proposal for settlement Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05271-05272 07/22/2009 Depo Dates to take_, and Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05259-05260 07/22/2009 Investigator retainer Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05238 07/14/2009 File a request to produce Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05240-05241 08/24/2009 Attorneys at order on the Epstein Work product; attorney/client privilege;
probation irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05197-05199 08/24/2009 Attorneys at. Michael info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
140
EFTA00296257
Privilege Log - Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
05155.05156 04/20/2009 Set Epstein's depo duces tecum Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05159.05160 05/28/2009 Right to move to reconsider all Work product; attorney/client privilege;
rulings irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05149-05150 05/27/2009 Epstein filed a motion to Work product; attorney/client privilege;
continue the trial irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05153 08/24/2009 Epstein traveling Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05146-05147 05/26/2009 The response to the motion to Work product; attorney/client privilege;
continue is due 6/8 irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05137-05144 05/20/2009 Attorneys at Epstein litigation strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05133-05136 05/11/2009 Subpoena Clinton and others on work product; attorney/client privilege;
Sid Garcia's witness list irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01749-01751 10/28/2009 Phaedra Xanthos Final affidavit from forensic Work product; attorney/client privilege;
accountant irrelevant and not reasonably calculated to lead
141
EFTA00296258
Privilege Log — Dated 2-23-2011
BATE, DATE IQ FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05054-05065 08/18/2009 Attorneys at Epstein Potential witnesses Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05049-05053 08/18/2009 Subpoenas for potential Work product; attorney/client privilege;
witnesses irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04957-04964 09/04/2009 Juan Alessi statement and Work product; attorney/client privilege;
burglary report irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04952-04953 10/28/2009 Attorneys at. Epstein injunction filing — Work product; attorney/client privilege;
accountant affidavit will be sent irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04955-04956 09/03/2009 Attorneys at Epstein Invoice Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04916-04920 09/11/2009 Updates on # of victims, billing Work product; attorney/client privilege;
amounts, etc. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04899 09/10/2009 Epstein Discovery Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
143
EFTA00296259
Privile e Lo — Dated 2-23-2011
BATES DATE 1g FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
26479-26481 08/19/2009 Attorneys at. Assistance on the Epstein Case Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
27155-27159 10/23/2009 Attorneys at. Steven PACER entries Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
26604-26605 10/27/2009 Phaedra Xanthos Political Work product; attorney/client privilege;
Contributions/advertisement for irrelevant and not reasonably calculated to lead
the rental on Little St. James to the discovery of the admissible evidence;
Island protected by privacy rights
26570 08/13/2009 Discussions about Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04954 10/28/2009 Attorneys at. Creation of another Doe file Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06665.06670 08/12/2009 Epstein Costs Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06675-06676 08/26/2009 Personal convo in regards to Work product; attorney/client privilege;
moving offices irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
150
EFTA00296260
Privilege Loa — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
06679-06682 08/26/2009 Personal convo in regards to Work product; attorney/client privilege;
moving offices irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07590-07594 05/13/2009 Office information Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08451-08453 08/17/2009 Updated Witness List Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08455.08456 06/03/2009 Vanity Fair Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08466-08479 08/26/2009 Attorneys at Witness info that we need to use Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01767 07/06/2009 Info on a guy going to Work product; attorney/client privilege;
boyfriends house irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08379 06/06/2009 Info on Former FHP trooper Work product; attorney/client privilege;
subcontracted by Riley irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08399 07/23/2009 Epstein affidavit to the reply Work product; attorney/client privilege;
memo irrelevant and not reasonably calculated to lead
151
EFTA00296261
Privilege Log — Dated 2-23-2011
BATcS DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08406 10/30/2009 Attorneys at Flying epstein rape survivor to St. Work product; attorney/client privilege;
Louis to see expert irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05697 08/19/2009 Meeting with client Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20330.20334 08/24/2009 Serving Alan Dershowitz Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20327-20329 10/17/2009 Attorneys at. Property purchased by Epstein in Work product; attorney/client privilege;
Palm Beach irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20100.20102 08/24/2009 Attorneys at. Epstein's arrival at his buildingWork product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20283-20326 10/14/2009 Attorneys at Research regarding Mr. Visoski Work product; attorney/client privilege;
and questions to consider during irrelevant and not reasonably calculated to lead
the depo to the discovery of the admissible evidence;
protected by privacy rights
20092.20099 08/24/2009 Attorneys at Epstein travel Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
152
EFTA00296262
Privilege Log — Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
20085.20091 10/15/2009 Questions from accountant Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19996-20084 10/14/2O09 Attorneys at. Visoski Research and Questions Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20217.20218 08/04/2009 Info on Copperfield Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20213-20216 08/03/2009 Attorneys at. Info on Copperfield Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20211-20212 08/03/2009 Pilots depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20207-20210 08/10/2009 List of witness Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20201-20204 08/24/2009 Attorneys at Serving Dershowitz Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
153
EFTA00296263
Privilege Log - Dated 2-23-2011
BATES DATE TO FROM DESCRIPTION OBJECTION
20193-20200 08/24/2009 Attorneys at. Proof of him being out of FL — Work product; attorney/client privilege;
Violation of the agreement irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19982-19985 09/03/2009 Dave Rogers depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19988 10/07/2009 Depositions Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19971-19981 08/24/2009 Attorneys at. Serving Dershowitz Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19969-19970 08/18/2009 Subpoenas for Pilots Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19962.19968 08/03/2009 Working with the FBI to get some Work product; attorney/client privilege;
info irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20190.20192 08/24/2009 Personal emails regarding Work product; attorney/client privilege;
surgery irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20187-20189 08/24/2009 Attorneys at Epstein travel Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
154
EFTA00296264
Privilege Log — Dated 2-23-2011
RATES DATE 12 FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
19959-19961 07/24/2009 Attorneys at Flight logs for Epstein Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
00156-00157 07/09/2009 2255 Problem Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15366-15367 09/04/2009 Attorneys at. Witness info that we need to use Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01003.01005 10/12/2009 Asset movement by Jeffrey Work product; attorney/client privilege;
Epstein irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01013.01014 10/29/2009 Subpoenaing Epstein's attorneys Work product; attorney/client privilege;
for their fees and accompanying irrelevant and not reasonably calculated to lead
documents to the discovery of the admissible evidence;
protected by privacy rights
01042 07/22/2009 New Info that our investigators Work product; attorney/client privilege;
obtained from current FBI agents irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03133-03134 06/09/2009 Personal conversation Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
155
EFTA00296265