Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
08076.08089 08/04/2009 Bradley Edwards Spencer Kuvin Transcript of Alfredo Rodriguez Joint W/P Priv.
Deposition
08311-08318 05/26/2009 Bradley Edwards Katherine Ezell WPB-Confidential-General- Joint W/P Priv.
Financial Disclosure/Discovery
08319-08324 10/16/2009 Bradley Edwards Amy Ederi WPB-General-Confidential Joint W/P Priv.
08398 09/01/2009 Bradley Edwards Kikka Claudio C.M.A. vs. Epstein, et Joint W/P Priv.
als(File#:281849)
08402 09/17/2009 Bradley Edwards Paul Cassell Report this as a parole violation Joint W/P Priv.
08415 09/16/2009 Bradley Edwards Margaret Berk Scanned document from Joint W/P Priv.
Margaret Berk
08422 08/11/2009 Bradley Edwards Katherine Ezell Subpoena directed to the Joint W/P Priv.
investigators
10060 08/03/2009 Adam Horowitz Jacquie Johnson Epstein-Depo-New York Joint W/P Priv.
10069-10074 08/04/2009 Bradley Edwards Spencer Kuvin RE:Transcript of Alfredo Joint W/P Priv.
Rodriguez Deposition
10077.10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv.
& Epstein vs. Jane doe No. 102
10099-10102 08/27/2009 Bradley Edwards Spencer Kuvin RE: Epstein Depo Joint W/P Priv.
10192 08/11/2009 Adam Horowitz Jacquie Johnson Trump Depo moved 08/18 to Joint W/P Priv.
9/24 in NY
10194.10195 08/11/2009 Jacquie Johnson Kikka Claudio FW: Out of state subpoenas Joint W/P Priv.
10264-10266 08/09/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Letter regarding Joint W/P Priv.
Leslie Wexner
1
EFTA00602835
Privilege Log— Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
10279-10291 08/10/2009 Adam Horowitz Jacquie Johnson RE: Epstein-Notice of production Joint W/P Priv.
from non parties/depo of Jane
Doe
10372-10373 09/17/2009 Bradley Edwards Katherine Ezell RE: Leslie Wexner Joint W/P Priv.
10490-10493 09/21/2009 Bradley Edwards Amy Ederi FW: Epstein Depo Joint W/P Priv.
10592.10593 09/29/2009 Bradley Edwards Katherine Ezell RE: Leslie Wexner Joint W/P Priv.
10604.10620 10/01/2009 Bradley Edwards Katherine Ezell FW:meeting w/ atty fr wexner Joint W/P Priv.
10639-10643 10/06/2009 Bradley Edwards Stuart Mermelstein Meeting w/Leslie Wexner Joint W/P Priv.
10700-10702 10/13/2009 Adam Horowitz Jacquie Johnson Depo Joint W/P Priv.
10724-1073 10/14/2009 Adam Horowitz Jacquie Johnson Epstein-depo of Alan Dershowitz Joint W/P Priv.
10897 10/29/2009 Bradley Edwards Stuart Mermelstein Leslie Wexner Joint W/P Priv.
10992-11005 06/22/2009 Bradley Edwards Amy Ederi RE:Regular Monthly Cong. Call Joint W/P Priv.
11011-11021 06/23/2009 Bradley Edwards Katherine Ezell RE:Regular Monthly Cong. Call Joint W/P Priv.
11026-11032 07/09/2009 Bradley Edwards Spencer Kuvin RE:Epstein commissioner Joint W/P Priv.
appointees
11072.11074 07/28/2009 Bradley Edwards Katherine Ezell Possible witness from Joint W/P Priv.
Switzerland
11166-11169 06/23/2009 Katherine Ezell Bradley Edwards RE:Article:Bear Stearns Joint W/P Priv.
2
EFTA00602836
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
11240-11245 06/22/2009 Katherine Ezell Bradley Edwards Article:Bear Stearns Joint W/P Priv.
11248.11250 06/22/2009 Amy Ederi Bradley Edwards Article:Bear Stearns Joint W/P Priv.
11255-11259 06/23/2009 Katherine Ezell Bradley Edwards USAO Chose Bradley Edwards Joint W/P Priv.
conversation
11269-11281 06/30/2009 Stuart Bradley Edwards RE:Epstein Depo;possible Joint W/P Priv.
Mermelstein deponents
11316.11319 06/28/2009 Katherine Ezell Bradley Edwards Discussion about possible Joint W/P Priv.
witness from Switzerland
11332-11336 08/04/2009 Spencer Kuvin Bradley Edwards FW:Transcript of Alfrefo Joint W/P Priv.
Rodriguez Depo and Copperfeild
and Clinton's whereabouts
11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vs.Jane Doe No.101 & Joint W/P Priv.
Estrada 102
11348-11358 08/06/2009 Adam Horowitz Bradley Edwards RE:Motion for protective Joint W/P Priv.
order/discussion
11430-11434 08/27/2009 Spencer Kuvin Bradley Edwards Discussion RE:Wexner Joint W/P Priv.
involvement
11443 09/17/2009 Katherine Ezell Bradley Edwards Wexner served subpoena OH Joint W/P Priv.
11541-11542 09/29/2009 Katherine Ezell Bradley Edwards RE:Leslie Wexner & Bob Joint W/P Priv.
11551-11559 10/01/2009 Spencer Kuvin Bradley Edwards RE:Meeting w.Stanely Arkin Joint W/P Priv.
11585.11586 10/14/2009 Adam Horowitz Bradley Edwards RE:Epstein;Larry Visoski Joint W/P Priv.
confirmed
11675-11676 10/29/2009 Stuart Bradley Edwards RE:Leslie Wexner attorney info Joint W/P Priv.
Mermelstein
3
EFTA00602837
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
15981-15988 08/04/2009 Spencer Kuvin Jacquie Johnson Attachment:Kellen & Trump Joint W/P Priv.
subpoena
15999.16007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv.
16057-16065 08/06/2009 Mercedes Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv.
Estrada
15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in Joint W/P Priv.
NY & OH
16066-16069 08/06/2009 Adam Horowitz Jacquie Johnson Maxwell,Trump, Wexner convo Joint W/P Priv.
RE:Depo dates
16095-16098 08/11/2009 Adam Horowitz Jacquie Johnson Maxwell,Trumo,Wexner Convo Joint W/P Priv.
RE:Depo dates cont..
15813.15814 10/29/2009 Stuart Bradley Edwards Wexler Lawyer's info Joint W/P Priv.
Mermelstein
15856 08/03/2009 Adam Horowitz Jacquie Johnson Epstein Depo-NY:2 Attachments Joint W/P Priv.
15866-15881 08/03/2009 Adam Horowitz Jacquie Johnson Epstein Depos 08/14,17,18 in Joint W/P Priv.
NY&OH/PDF of
Notice of Videotaped Depo
15893-15901 08/03/2009 Kikka Claudio Jacquie Johnson Depo &subpoena notice for Joint W/P Priv.
Trump
15360-15363 09/01/2009 Jacquie Johnson Mercedes Estrada RE:Alan Dershowitz;Harvard Law Joint W/P Priv.
Info
15394-15397 09/09/2009 Jacquie Johnson Katherine Ezell RE:E stein-De os of Joint W/P Priv.
&
15413.15428 09/10/2009 Adam Horowitz Jacquie Johnson RE:Esptein-Notice of Prodcution Joint W/P Priv.
from Non Parties
15434-15437 09/10/2009 Jacquie Johnson Katherine Ezell Notice Of Production from Non- Joint W/P Priv.
Parties discussion
4
EFTA00602838
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
15454-15475 09/15/2009 Adam Horowitz Jacquie Johnson Critton's notice of depo;Epstein Joint W/P Priv.
notice of hearing,Mark Epstein
notice of depo
01465 07/13/2009 Katherine Ezell Bradley Edwards Epstein Joint W/P Priv.
15485-15492 09/17/2009 Jacquie Johnson Mercedes Estrada RE:Epstein Depo Joint W/P Priv.
15493.15500 09/18/2009 Jacquie Johnson Katherine Ezell RE:Deposition of Jean Luc Joint W/P Priv.
Bruhnel
15501.15555 09/18/2009 Jacquie Johnson Adam Horowitz RE:Epstein Depo Joint W/P Priv.
15556-15564 09/22/2009 Jacquie Johnson Margaret Berk Epstein Depos Joint W/P Priv.
15565.15575 09/25/2009 Jacquie Johnson Lisa Rivera FW:Deposition of Jean Luc Joint W/P Priv.
Bruhnel
15687.15688 10/01/2009 Jacquie Johnson Lisa Rivera Depo of David Hart Rogers Joint W/P Priv.
15692-15707 10/01/2009 Jacquie Johnson Katherine Ezell FW:Meeting w/Sranley Arkin Joint W/P Priv.
15708-15709 10/06/2009 Jacquie Johnson Mercedes Estrada RE:Jane Does 2-8v. Epstein-Cross Joint W/P Priv.
Nod's of Oct 6.8 depos
15033-15032 08/05/2009 Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for 8/17 Joint W/P Priv.
15087.15093 08/06/2009 Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for 8/17 Joint W/P Priv.
15094-15100 08/06/2009 Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv.
15109-15112 08/10/2009 Jacquie Johnson Adam Horowitz RE:Epstein Depositions for Joint W/P Priv.
8/14,17,18 in NY & OH
5
EFTA00602839
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
15122-15125 08/11/2009 Jacquie Johnson Kikka Claudio RE: Ms. Maxwell Depo Joint W/P Priv.
rescheduled
15142-15158 08/11/2209 Bradley Edwards Kikka Claudio FW:out of state subpoenas Joint W/P Priv.
15166-15170 08/11/2009 Jacquie Johnson Kikka Claudio RE:out of state subpoenas Joint W/P Priv.
15171-15172 08/11/2009 Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv.
15178-15182 08/12/2009 Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv.
15306.15355 08/25/2009 Jacquie Johnson Kikka Claudio FW:Epstein Depo Notices & Subs Joint W/P Priv.
14951-14952 08/03/2009 Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv.
14954-14972 09/16/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Depo of Mark Epstein Joint W/P Priv.
on 9/21 in NY will take place as
scheduled
14979-14981 08/03/2009 Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv.
14983-15015 08/04/2009 Jacquie Johnson Adam Horowitz RE:Epstein Depositions 8/14.17, Joint W/P Priv.
&18 in NY & 01-I
16501-16519 09/15/2009 Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv.
16520-16547 09/09/2009 Spencer Kuvin Jacquie Johnson RE:Epstein-Deposition of Jane Joint W/P Priv.
Doe-9/30/2009
16355-16384 08/24/2009 Adam Horowitz Jacquie Johnson Epstein Depo Notices and Subs Joint W/P Priv.
16554.16568 09/16/2009 Kikka Claudio Jacquie Johnson RE:Epstein Depo Joint W/P Priv.
6
EFTA00602840
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
16574.16577 09/17/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv.
16396-16398 09/01/2009 Margaret Estrada Jacquie Johnson Alan Dershowitz Joint W/P Priv.
16578-16581 09/17/2009 Katherine Ezell Jacquie Johnson RE:Depo Joint W/P Priv.
16582-16585 09/18/2009 Adam Horowitz Jacquie Johnson RE:Deposition of Jean Luc Joint W/P Priv.
Bruhnel
16585-16611 09/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv.
16612-16439 09/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo of Mark Epstein Joint W/P Priv.
16440 08/18/2009 Spencer Kuvin Jacquie Johnson RE:Epstein Sub to Bear Steam Joint W/P Priv.
16740-16753 09/22/2009 Margaret Berk Jacquie Johnson RE:Epstein Depos Joint W/P Priv.
16443-16452 09/09/2009 Katherine Ezell Jacquie Johnson RE:Epstein-Depos of Joint W/P Priv.
&
16777-16786 09/30/2009 Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv.
16793-16794 10/01/2009 Lisa Rivera Jacquie Johnson RE:Depo of David Hart Rogers Joint W/P Priv.
16462-16477 09/10/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
16802-16823 10/02/2009 Margaret Berk Jacquie Johnson RE:Epstein depos Joint W/P Priv.
16483-16486 09/10/2009 Katherine Ezell Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
7
EFTA00602841
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
16874-16880 10/13/2009 Adam Horowitz Jacquie Johnson Depo Joint W/P Priv.
16904-16905 10/14/2009 Spencer Kuvin Jacquie Johnson RE:Epstein Joint W/P Priv.
16945 10/26/2009 Kikka Claudio Jacquie Johnson RE:Epstein depos on 10/28 Joint W/P Priv.
17033-17034 10/26/2009 Kikka Claudio Jacquie Johnson RE:Epstein depos on 10/28 Joint W/P Priv.
02065-02068 06/08/2009 Bradley Edwards Mercedes Estrada FW:Epstein-Confirming AT&T Joint W/P Priv.
Dial Telephone Conference for
Mon 6/8/09 at 2:00 p.m.
02070 09/02/2009 Jacquie Johnson Spencer Kuvin FW:Epstein-De I os of Joint W/P Priv.
&
02071 08/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns Joint W/P Priv.
02072-02078 09/04/2009 Jacquie Johnson Spencer Kuvin FW:Epstein-De • os of Joint W/P Priv.
&
03466-03468 05/14/2009 Spencer Kuvin Bradley Edwards RE:Actvity in Case 9:08-cv- Joint W/P Priv.
80893-KAM Doe v. Epstein Order
on Motion to Stay
02301.02302 09/09/2009 Paul Cassel Bradley Edwards FW:Epstein Joint W/P Priv.
03122-03123 06/10/2009 Adam Horowitz Bradley Edwards FW: Motion to Dismiss Joint W/P Priv.
02805-02806 05/26/2009 Susan Stirling Katherine Ezell RE:WPB-Confidential-Genereal- Joint W/P Priv.
Financial Disclosure/Discovery
02670-02671 10/21/2009 Bradley Edwards Spencer Kuvin FW:Subpoena Info Joint W/P Priv.
02517-02519 10/02/2009 Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv.
8
EFTA00602842
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
02614.02617 08/05/2009 Bradley Edwards Kikka Claudio FW:Proposal Request Joint W/P Priv.
15702.15704 10/02/2009 Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv.
15581-15585 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv.
15431.15433 09/10/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
15797-15798 10/14/2009 Spencer Kuvin Bradley Edwards RE:Epstein Joint W/P Priv.
11560-11562 10/02/2009 Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv.
Johnson
11444-11448 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv.
05823 09/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv.
05832 09/08/2009 Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv.
05838 09/08/2009 Jacquie Johnson Jack Hill RE:Epstein Joint W/P Priv.
05847 09/09/2009 Jacquie Johnson Katherine Ezell RE:Epstein Joint W/P Priv.
05859 07/23/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05863-05864 07/23/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05886-05887 07/24/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
9
EFTA00602843
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05902.05903 07/28/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05906-05907 07/28/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05912 08/27/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05928-05930 07/28/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05933-05934 09/18/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05936 09/18/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05938 09/18/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv.
05940-05941 09/18/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05951 05/29/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05957-05960 09/09/2009 Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv.
05970-05971 10/21/2009 Jacquie Johnson Margaret Berk RE:Epstein Joint W/P Priv.
05982-05983 10/28/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05993-05994 09/09/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv.
05997 08/06/2009 Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv.
10
EFTA00602844
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01029 10/08/2009 Bradley Edwards Carolyn Edwards Brian Ryalls Joint W/P Priv.
07707 09/03/2009 BradleyEdwards Kikka Claudio RE:Regarding:C.M.A. vs. Epstein. Joint W/P Priv.
Et al.(File# 281849)
07708.07709 06/22/2009 Bradley Edwards Amy Ederi RE:Regular Monthly Cong. Call Joint W/P Priv.
07734 07/24/2009 Bradley Edwards RE:Release Joint W/P Priv.
07218.07219 10/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv.
06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv.
06876.06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv.
06891-06897 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv.
06901 09/11/2009 Bradley Edwards Mercedes Estrada Re:Jane Doe No. 101 & Jane Doe Joint W/P Priv.
No. 102 vs. Epstein-Cross Notice
Of Depos
06902 09/15/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe No.101 & Jane Doe Joint W/P Priv.
NO.102 vs. Epstein
06903 09/04/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe No.101 & Jane Doe Joint W/P Priv.
NO.102 vs. Epstein-Cross-Notice
of Taking Video Deposition
06806-06807 09/09/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv.
06712 10/19/2009 Bradley Edwards Kikka Claudio RE: Igor Zinoview depo Joint W/P Priv.
06713-06714 09/15/2009 Bradley Edwards Robert Josefberg RE:Epstein Joint W/P Priv.
11
EFTA00602845
Privilege Loa - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
06720-06727 10/14/2009 Bradley Edwards Jack Hill RE: Igor Zinoview depo Joint W/P Priv.
06728 09/09/2009 Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv.
06711 09/09/2009 Kikka Claudio Bradley Edwards RE:Epstein Joint W/P Priv.
06472 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06460.06464 05/08/2009 Bradley Edwards Spencer Kuvin RE:FYI Epstein Depo Joint W/P Priv.
06455-06459 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06448-06452 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06420-06427 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06416-06419 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
05925-05926 07/28/2009 Katherine Ezell Bradley Edwards FW:Epstein Joint W/P Priv.
05883-05584 07/24/2009 Katherine Ezell Bradley Edwards RE:Epstein Joint W/P Priv.
05022.05025 09/10/2010 Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
04724-04725 05/27/2009 Bradley Edwards Katherine Ezell RE:Epstein Cases-depostions in Joint W/P Priv.
federal cases
BATES DATE TO FROM DESCRIPTION OBJECTION
06990-07002 06/11/2009 Brad Edwards Katherine W. Ezell June 10th hearing-WPB- Joint-privilege
Confidential
07003-07006 06/26/2009 Amy Ederi Brad Edwards June 25th hearing-WPB- Joint-privilege
12
EFTA00602846
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissint Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Confidential
07030 09/22/2009 Bradley J. Spencer Kuvin IM v. Epstein — defendant, Joint-privilege
Edwards Jeffrey Epstein's response to
plantiff
07090-07091 9/29/2009 Bradley J. Katherine W. Ezell Leslie Wexner Joint-privilege
Edwards
07092 10/29/2009 Stuart Bradley J. Edwards Leslie Wexner Joint-privilege
Mermelstein
07093 09/17/2009 Bradley J. Katherine W. Ezell Leslie Wexner Joint-privilege
Edwards
01484 05/21/2009 Robert C. BradleyJ. Edwards Epstein Joint-privilege
Josefsberg
01503 08/24/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01517 09/18/2009 Adam Horowitz; Bradley J. Edwards Epstein Joint-privilege
Spencer Kuvin
01514 08/26/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01515 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01477 07/21/2009 Adam Horowitz; Bradley J. Edwards Epstein Joint-privilege
Stuart
Mermelstein
01489 08/03/2009 Adam Horowitz Bradley J. Edwards Epstein Joint-privilege
07110-07112 09/25/2009 Bradley J. Spencer Kuvin LM v EPSTEIN hearing 9/22/09
Edwards
07113.07114 09/25/2009 Spencer Kuvin Bradley J. Edwards LM v EPSTEIN hearing 9/22/09 Joint-privilege
07115-07116 09/25/2009 Bradley J. Spencer Kuvin LM v EPSTEIN hearing 9/22/09 Joint-privilege
Edwards
07145-07146 09/22/2009 Adam Horowitz Bradley J. Edwards Mark Epstein Joint-privilege
07211-07213 10/01/2009 Bradley J. Spencer Kuvin Meeting with Stanley Arkin Joint-privilege
Edwards
07210 10/06/2009 Stuart Katherine W. Ezell Meeting with Leslie Wexner Joint-privilege
Mermelstein;
Robert c.
Josefsberg;
13
EFTA00602847
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Bradley J.
Edwards
07214-07215 10/01/2009 Robert C. Katherine W. Ezell Meeting with Stanley Arkin Joint-privilege
Josefsberg
07216-07217 10/02/2009 Bradley J. Katherine W. Ezell Meeting with Stanley Arkin Joint-privilege
Edwards
07220-07223 10/01/2009 Spencer Kuvin Bradley J. Edwards Meeting with Stanley Arkin Joint-privilege
07224-07225 10/02/2009 Katherine W. Bradley J. Edwards Meeting with Stanley Arkin Joint-privilege
Ezell
07226-07227 10/01/2009 Robert C. Spencer Kuvin Meeting with Stanley Arkin Joint-privilege
Josefsberg
07228-07229 10/01/2009 Bradley J. Robert C. Meeting with Stanley Arkin Joint-privilege
Edwards Josefsberg
07280-07283 08/06/2009 Adam Horowitz Bradley J. Edwards Motion for protective order Joint-privilege
07633-07634 08/06/2009 Bradley J. Kikka M. Claudio Proposal Request Joint-privilege
Edwards
07710-07733 06/23/2009 Katherine W. Bradley J. Edwards Regularly Monthly Cong. Call Joint-privilege
Ezell
07740-07746 09/18/2009 Bradley J. Adam Horowitz Report this as a parole violation Joint-privilege
Edwards
07748.07757 09/18/2009 Adam Horowitz Bradley J. Edwards Report this as a parole violation Joint-privilege
07913-07915 08/27/2009 Bradley J. Spencer Kuvin Joint-privilege
Edwards
07917.07918 08/27/2009 Spencer Kuvin Jacquie Johnson Joint-privilege
07965-07966 08/12/2009 Katherine W. Bradley J. Edwards Subpoena directed to the Joint-privilege
Ezell investigators
07977-07978 10/09/2009 Bradley J. Spencer Kuvin Subpoena Info Joint-privilege
Edwards
01716 09/15/2009 Adam Horowitz Elizabeth Villar Epstein: Forensics/Investigations Joint-privilege
INVOICE
01768 07/13/2009 Richard Willits Bradley J. Edwards Epstein Investigator Joint-privilege
01771.01772 08/06/2009 Adam Horowitz Bradley J. Edwards Epstein Investigator Joint-privilege
01931 08/11/2009 Bradley J. Lisa Rivera Alfredo Rodriguez Joint-privilege
14
EFTA00602848
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Edwards
01998-01999 09/21/2009 Adam Horowitz Margaret Berk Correct Number — Epstein Joint-privilege
Deposition
02021 05/14/2009 Bradley J. Mercedes C. Doe v. Epstein Joint-privilege
Edwards Estrada
02044 09/04/2009 Katherine W. Bradley J. Edwards E.W., Doe v. Epstein — Joint-privilege
Ezell Letter from Bob Critton
02048 09/04/2009 Robert C. Bradley J. Edwards E.W., Doe v. Epstein — Joint-privilege
Josefsberg Letter from Bob Critton
02054 05/12/2009 Spencer Kuvin Bradley J. Edwards Emailing Epstein deposition Joint-privilege
revised
02062 10/05/2009 Bradley J. Amy Ederi Epstein — Confirming AT&T Dial Joint-privilege
Edwards in Tel. Conf. for Monday,
10/5/09 at 4:00 p.m.
02087 09/17/2009 Spencer Kuvin Bradley J. Edwards Epstein- Hearing Joint-privilege
02140 08/04/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo — New York Joint-privilege
02147-02149 09/21/2009 Bradley J. Amy Eden Epstein Depo Joint-privilege
Edwards
02174 07/20/2009 Adam Horowitz Bradley J. Edwards Epstein Matter — Cross Notice of Joint-privilege
Alfredo Rodriguez Deposition
02209-02210 07/01/2009 Bert Patton William J. Berger Epstein v. State of Florida — Joint-privilege
Emergency petition for Writ of
Certiorari; Emergency motion to
review denial of stay
02215-02217 07/24/2009 Bradley J. Mercedes C. Epstein Joint-privilege
Edwards Estrada
02290 09/18/2009 Bradley J. Spencer Kuvin Epstein Joint-privilege
Edwards
02355.02356 06/10/2009 Mercedes C. Susan K. Stirling Hearing taken on 06/10/09 Joint-privilege
Estrada onmotion to unseal before Judge
Colbath
02362.02363 06/09/2009 Spencer Kuvin Katherine W. Ezell Hearing to Un-seal Joint-privilege
02374-02375 09/15/2009 Jack Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege
15
EFTA00602849
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
02420-02421 OS/08/2009 Bradley J. Mercedes C. Jane Doe II v. Epstein Joint-privilege
Edwards Estrada
02435 09/15/2009 Bradley J. Lisa Rivera Jane Does v. Epstein Joint-privilege
Edwards
02438 09/18/2009 Bradley J. Adam Horowitz Jeffrey Epstein oat W35755 Joint-privilege
Edwards
02462 09/22/09 Spencer Kuvin Bradley J. Edwards I■ v. Epstein — Defendant, Joint-privilege
Jeffrey Epstein"s Response to
Plantiff •'s Motion for
Protective Order
02476-02477 09/25/2009 Spencer Kuvin BradleyJ. Edwards LM v EPSTEIN hearing Joint-privilege
02516 10/06/2009 Bradley J. Katherine W. Ezell Meeting with Leslie Wexner Joint-privilege
Edwards
02554.02559 08/03/2009 Adam Horowitz Bradley J. Edwards NEW ASSIGNMENT — NEW Joint-privilege
ALBANY — RUSH? — Fwd: Federal
Subpoena
02584 08/11/2009 Bradley J. Kikka M. Claudio Out of state subpoenas Joint-privilege
Edwards
02618 08/04/2009 Bradley J. Kikka M. Claudio Proposal Request Joint-privilege
Edwards
02627-02628 09/18/2009 Bradley J. Adam Horowitz Report this as a parole violation Joint-privilege
Edwards
02672-02673 10/09/2009 Spencer Kuvin Bradley J. Edwards Subpoena Info Joint-privilege
02727 08/03/2009 Spencer Kuvin Bradley J. Edwards Transcript of Alfredo Rodriguez Joint-privilege
deposition
02896 06/08/2009 Bradley J. Spencer Kuvin Hearing to Un-seal Joint-privilege
Edwards
03009-03010 08/07/2009 Adam Horowitz Jacquie Johnson Motion to stay Joint-privilege
03028.03029 09/21/2009 Bradley J. Adam Horowitz Mark Epstein Joint-privilege
Edwards
03038 10/06/2009 Bradley J. Stuart Mermelstein Meeting with Leslie Wexner Joint-privilege
Edwards
03131-03132 08/06/2009 Adam Horowitz Bradley J. Edwards Epsteins assets Joint-privilege
16
EFTA00602850
Privilege Log — Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
03243.03244 09/09/2009 Bradley J. Adam Horowitz EPSTEIN Joint-privilege
Edwards
03397-03400 09/29/2009 Adam Horowitz Bradley J. Edwards Activity in case 9:08-cv-80119- Joint-privilege
KAM Doe v. Epstein Response in
Opposition to Motion
03407-03414 09/29/2009 Bradley J. Adam Horowitz Activity in case 9:08-cv-80119- Joint-privilege
Edwards KAM Doe v. Epstein Response in
Opposition to Motion
03451.03452 05/14/2009 Bradley J. Spencer Kuvin Activity in Case 9:08-cv-80893- Joint-privilege
Edwards KAM Doe v. Epstein Order on
Motion to Stay
03477-03479 05/15/2009 Bradley J. Spencer Kuvin Activity in Case 9:08-cv-80893- Joint -privilege
Edwards KAM Doe v. Epstein Order to
Motion to Stay
03619-03627 09/15/2009 Bradley J. Spencer Kuvin BB v. Epstein/EW v. Epstein Joint-privilege
Edwards
03631-03633 09/15/2009 Jacquie Johnson William J. Berger BB v. Epstein/EW v. Epstein Joint-privilege
03646-03656 10/19/2009 Bradley J. Katherine W. Ezell Bill Riley's Subpoena & Depo Joint-privilege
Edwards Notice
03677.03687 07/08/2009 Bradley J. Adam Horowitz Can you send me those Joint -privilege
Edwards addresses?
03719-03736 09/04/2009 Bradley J. Spencer Kuvin CMA — depo notices attached. Joint-privilege
Edwards
03840-03847 08/02/2009 Stuart Bradley J. Edwards Continuing Deposition of Alfredo Joint-privilege
Mermelstein Rodriguez
03938.03939 09/29/2011 Katherine W. Bradley J. Edwards Deposition of Bill Riley Joint-privilege
Ezell
03943-03945 09/18/2009 Adam Horowitz Jacquie Johnson Deposition of lean Luc Bruhnel Joint-privilege
02911-02912 09/15/2009 Bradley J. Jack P. Hill Igor Zinoview depo Joint-privilege
Edwards
02939 07/14/2009 Bradley J. Adam Horowitz Jane Does 2-7 v. Epstein Joint-privilege
Edwards
02977 10/16/2009 Katherine W. Bradley J. Edwards Leslie Wexner Joint-privilege
17
EFTA00602851
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Ezell
02978 10/29/2009 Bradley J. Stuart Mermelstein Leslie Wexner Joint-privilege
Edwards
02994 06/10/2009 Bradley J. Mercedes C. Preservation of evidence Joint-privilege
Edwards Estrada
07060 10/16/2009 Sid Garcia Bradley J. Edwards v. Epstein Joint-privilege
06202 07/13/2009 Richard Willits Bradley J. Edwards Scheduling various depositions Joint-privilege
regarding Epstein
06409.06415 04/15/2009 Bradley J. Katherine W. Ezell FYI Joint-privilege
Edwards
06428.06447 05/06/2009 Spencer Kuvin Bradley J. Edwards FYI Joint-privilege
06453-06454 04/15/2009 Spencer Kuvin Bradley J. Edwards FYI Joint-privilege
06465-06471 04/15/2009 Katherine W. Bradley J. Edwards FYI Joint-privilege
Ezell
06476-06490 05/08/2009 Bradley J. Spencer Kuvin FYI Joint -privilege
Edwards
06630-06632 09/09/2009 Spencer Kuvin Bradley J. Edwards Hearing to Un-seal Joint-privilege
06636-06639 09/09/2009 Bradley J. Robert C. Hearing to Un-seal Joint-privilege
Edwards Josefsberg
06702-06705 09/16/2009 Bradley J. Kikka M. Claudio Igor Zinoview & Tommy Matola Joint-privilege
Edwards depos
06706-06708 10/14/2009 Bradley J. Kikka M. Claudio Igor Zinoview depo Joint-privilege
Edwards
06715-06719 10/09/2009 Jack P. Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege
06729-06735 10/13/2009 Bradley J. Jack P. Hill Igor Zinoview depo Joint-privilege
Edwards
06763 08/19/2009 Bradley J. Stuart Mermelstein IME's Joint-privilege
Edwards
06764.06766 09/10/2009 Bradley J. Stuart Mermelstein IME's Joint-privilege
Edwards
06770-06781 09/10/2009 Stuart Bradley J. Edwards IME's Joint-privilege
Mermelstein
06811.06812 08/20/2009 Katherine W. Bradley J. Edwards Is Mark Epstein JE's brother? Joint-privilege
18
EFTA00602852
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Ezell
06817.06819 09/23/2009 Adam Horowitz Bradley J. Edwards Is your client being deposed Joint-privilege
tomorrow?
06820-06822 07/02/2009 Bradley J. Margaret Berk Jane Doe 2 ( v. Epstein Joint-privilege
Edwards
06841-06860 05/12/2009 Bradley J. Spencer Kuvin Jane Doe II v. Epstein Joint-privilege
Edwards
06864.06875 05/12/2009 Spencer Kuvin Bradley J. Edwards Jane Doe II v. Epstein Joint-privilege
06880-06890 05/12/2009 Bradley J. Katherine W. Ezell Jane Doe II v. Epstein Joint-privilege
Edwards
06898-06900 05/12/2009 Bradley J. Stuart Mermelstein Jane Doe II v. Epstein Joint-privilege
Edwards
06933-06934 07/14/2009 Adam Horowitz Bradley J. Edwards Jane Does 2-7 v. Epstein Joint-privilege
06937-06938 10/05/2009 Spencer Kuvin Jacquie Johnson Jane Does 2-8 v. Epstein — Cross Joint-privilege
NOD's of Oct. 6-8 depos
06944.06952 09/22/2009 Bradley J. Adam Horowitz Jeffrey Epstein DC# W35755 Joint-privilege
Edwards
16107 08/11/2009 Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege
16123-16124 08/11/2009 Kikka M. Claudio Jacquie Johnson Maxwells deposition Joint-privilege
16799-16801 10/02/2009 Robert C. Jacquie Johnson Meeting with Stanley Arkin Joint-privilege
Josefbergs
02947-02948 08/03/2009 Spencer Kuvin Jacquie Johnson Epstein Depo — New York Joint-privilege
02891-20906 10/01/2009 Bradley J. Katherine W. Ezell Meeting with Stanley Arkin Joint-privilege
Edwards
20880-20882 10/02/2009 Bradley J. Katherine W. Ezell Meeting with Stanley Arkin Joint-privilege
Edwards
06042-06090 07/02/2009 William J. Berger Spencer Kuvin Ew 09.22784 cert.4th dca Joint-privilege
06402.06403 06/10/2009 Bradley J. Katherine W. Ezell Hearing to Un-seal Joint-privilege
Edwards
01365-01366 09/15/2009 Adam Horowitz Jacquie Johnson Epstein Hearing Joint-privilege
01340-01341 07/30/2009 Adam Horowitz Jacquie Johnson Epstein Depositions Joint-privilege
01331 06/30/2009 Stuart Bradley J. Edwards Epstein depositions Joint-privilege
19
EFTA00602853
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Mermelstein
01319 08/11/2009 Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege
01316 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo Joint-privilege
01314 10/30/2009 Stuart Jacquie Johnson Epstein Depo of Wexner Joint-privilege
Mermelstein
01298 05/26/2009 Bradley J. Adam Horowitz Epstein cases — depositions in Joint-privilege
Edwards federal cases
01294 08/10/2009 Jack P. Hill Bradley J. Edwards Epstein Assets Joint-privilege
01273 07/13/2009 Katherine W. Bradley J. Edwards Epstein 2255 claims Joint -privilege
Ezell
01250 05/13/2009 Bradley J. Mercedes C. Epstein Joint-privilege
Edwards Estrada
01246 04/08/2009 Bradley J. Mercedes C. Epstein — Telephone Conference Joint-privilege
Edwards Estrada
01233.01234 07/31/2009 Bradley J. Mercedes C. Epstein — Monday, 8/3/09 — Joint-privilege
Edwards Estrada Monthly call in telephone
conference — AT&T Call in No:
(877) 468.2136 — participant
code: 775593. Kathy is the host.
01224 06/16/2009 Bradley J. Mercedes C. Epstein — Monday, 8/3/09 — Joint-privilege
Edwards Estrada Monthly call in telephone
conference — AT&T Call in No:
(877) 468-2136 — participant
code: 775593. Kathy is the host.
01185 10/30/2009 Bradley J. Mercedes C. Epstein — Confirming AT&T dial Joint-privilege
Edwards Estrada in tel. conf. for Monday, 11/2/09
at 4:00 p.m.
01186 10/02/2009 Bradley J. Mercedes C. Epstein — Confirming AT&T Dial Joint-privilege
Edwards Estrada in Tel. Conf. for Monday,
10/5/09 at 4:00 p.m.
01187 05/19/2009 Bradley J. Mercedes C. Epstein — Confirming AT&T Dial Joint-privilege
Edwards Estrada in Telephone Conference for
Monday, 6/8/09 at 2:00 p.m.
20
EFTA00602854
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01188 05/12/2009 Bradley J. Mercedes C. Epstein — Confirming AT&T Dial Joint-privilege
Edwards Estrada in Telephone Conference for
Tomorrow 5/13/09
01189 09/08/2009 Bradley J. Iliana Yarzabal Epstein — Confirming AT&T Dial Joint-privilege
Edwards in Telephone Conference for
Wednesday, 9/9/09 at 3:00
01095.01096 04/15/2009 Spencer Kuvin Bradley J. Edwards Deposition of Epstein was set for Joint-privilege
tomorrow
01045 07/23/2009 Bradley J. Richard Willits CMA vs. Epstein Joint-privilege
Edwards
01649 07/08/2009 Bradley J. Mercedes C. Epstein Joint-privilege
Edwards Estrada
01641 06/11/2009 Bradley J. Mercedes C. Epstein Joint-privilege
Edwards Estrada
01639 05/29/2009 Bradley J. Mercedes C. Epstein Joint-privilege
Edwards Estrada
01619 10/28/2009 Bradley J. Spencer Kuvin Epstein Joint-privilege
Edwards
01660 07/22/2009 Bradley J. Adam Horowitz Epstein Joint-privilege
Edwards
01666 04/20/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01671 07/23/2009 Katherine W. Bradley J. Edwards Epstein Joint-privilege
Ezell
01680 08/24/2O09 Jack P. Hill Bradley J. Edwards Epstein Joint-privilege
04355.04358 09/04/2009 Jack Scarola Bradley J. Edwards Epstein — Depos of Joint-privilege
and
04446 09/03/2009 Bradley J. Iliana Yarzabal Epstein — Monday 8/3/09 — Joint-privilege
Edwards Monthly Call in Telephone
Conference
04200-04201 09/04/2009 Bradley Edwards Katherine W. Ezell Letter from Bob Critton Joint W/P Privilege
04220- 09/04/2009 Bradley Edwards Spencer Kuvin Letter from Bob Critton Joint W/P Privilege
04221
04222.04223 09/04/2009 Bradley Edwards Barry Stone Letter from Bob Critton Joint W/P Privilege
21
EFTA00602855
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
04264 05/12/2009 Bradley Edwards Spencer Kuvin Epstein Depo Joint W/P Privilege
04298.04299 09/16/2009 Jacquie Johnson Adam Horowitz Depo of Epstein Joint W/P Privilege
04304 09/08/2009 Jacquie Johnson Adam Horowitz Epstein Joint W/P Priv.
04335 10/30/2009 Bradley Edwards Robert Josefsberg Epstein- Confirming AT&T Tel. Joint W/P Priv.
Conf.
04359.04360 09/04/2009 Jacquie Johnson Katherine Ezell Is of i 8MI Joint W/P Priv.
04365 09/15/2009 Jacquie Johnson Adam Horowitz Epstein- Depo in New York Joint W/P Priv.
04417 09/17/2009 Bradley Edwards Spencer Kuvin Epstein- Hearing Joint W/P Priv.
04423.04424 09/09/2009 Jacquie Johnson Adam Horowitz Letter regarding Leslie Wexner Joint W/P Priv.
04433-04436 06/16/2009 Spencer Kuvin Bradley Edwards Monthly Call in Tele. Conf. Joint W/P Priv.
04447-04450 07/31/2009 Jacquie Johnson Mercedes Estrada Monthly Call in Tel. Conf. Joint W/P Priv.
04491-04518 04/08/2009 Bradley Edwards Jack Scarola Epstein- Tel. Conf. Joint W/P Priv.
04518 04/08/2009 Bradley Edwards Robert Josefsberg Epstein- Tel Cont. Joint W/P Priv.
04524-04525 05/13/2009 Katherine Ezell Bradley Edwards Epstein Depo Joint W/P Priv.
04580 10/14/2009 Jacquie Johnson Adam Horowitz Depo of Larry Visoski Joint W/P Priv.
04640-04641 10/14/2009 Bradley Edwards Adam Horowitz Depo of Larry Visoski Joint W/P Priv.
04723 05/26/2009 Bradley Edwards Katherine Ezell Epstein cases- Depos Joint W/P Priv.
04726-04729 05/26/2009 Adam Horowitz Bradley Edwards Epstein cases- Witness depos Joint W/P Priv.
04750-04754 08/04/2009 Spencer Kuvin Bradley Edwards Epstein depo- New York Joint W/P Priv.
04763-04785 08/27/2009 Spencer Kuvin Bradley Edwards Epstein Depo Notice Joint W/P Priv.
04797-04799 09/18/2009 Jacquie Johnson Adam Horowitz Epstein Depo Joint W/P Priv.
04806.04813 07/28/2009 Jacquie Johnson Adam Horowitz Epstein Depos in New York Joint W/P Priv.
04819 07/30/2009 Jack Scarola Jacquie Johnson Epstein Depos Joint W/P Priv.
04831-04832 07/30/2009 Spencer Kuvin Jacquine Johnson Epstein Depos Joint W/P Priv.
04835-04836 07/25/2009 Katherine Ezell Bradley Edwards Epstein Depos Joint W/P Priv.
22
EFTA00602856
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
04711 08/10/2009 Bradley Edwards Jack Hill Epstein assests Joint W/P Priv.
04855.04858 08/18/2009 Bradley Edwards Kikka Claudio Epstein Depos Joint W/P Priv.
04861 07/24/2009 Lisa Rivera Jacquie Johnson Epstein Depos Joint W/P Priv.
04876.04877 07/27/2009 Bradley Edwards Spencer Kuvin Epstein Depos Joint W/P Priv.
04922-04923 09/16/2009 Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv.
04925.04926 09/15/2009 Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv.
04929-04934 09/25/2009 Bradley Edwards Adam Horowitz Epstein Hearing Joint W/P Priv.
04937-04938 09/15/2009 Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv.
04969-04972 07/20/2009 Adam Horowitz Bradley Edwards Alfredo Rodriguez Depo Joint W/P Priv.
05026.05027 09/10/2009 Adam Horowitz Jacquie Johnson Notice of Production from Non- Joint W/P Priv.
Parties
05031 09/25/2009 Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv.
05037-05038 09/25/2009 Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv.
05042-05043 09/25/2009 Spencer Kuvin Bradley Edwards Epstein Order Joint W/P Priv.
05046 09/25/2009 Bradley Edwards Spener Kuvin Epstein Order Joint W/P Priv.
05074-05076 08/18/2009 Stuart Jacquie Johnson Epstein Sub. To Bears Stern Joint W/P Priv.
Mermelstein
23
EFTA00602857
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05100-05102 08/05/2009 Mercedes Bradley Edwards Improper Serving of Maxwell Joint W/P Priv.
Estrada
05105-05107 04/20/2009 Bradley Edwards Spencer Kuvin Hearing on Yellow Cab Objection Joint W/P Priv.
05110 08/06/2009 Adam Horowitz Kikka Claudio Address for Joint W/P Priv.
05118-05119 09/09/2009 Adam Horowitz Bradley Edwards Motion for Protective Order Joint W/P Priv.
05157-05158 09/10/2009 Adam Horowitz Bradley Edwards Motion for Protective Order Joint W/P Priv.
05167-05168 05/29/2009 Bradley Edwards Margaret Berk Spencer Cross-Examination Joint W/P Priv.
05171-05172 05/29/2009 Bradley Edwards Mercedes Estrada Transcripts Joint W/P Priv.
05201-05202 09/10/2009 Adam Horowitz Bradley Edwards Rules on Doe no. 4 Joint W/P Priv.
05222-05223 07/10/2009 Bradley Edwards Katherine Ezell File case Joint W/P Priv.
05226 07/10/2009 Bradley Edwards Spencer Kuvin Epstein 5th Amendment rights Joint W/P Priv.
05229 07/10/2009 Bradley Edwards Adam Horowitz Motions to Compel Joint W/P Priv.
05232-05233 07/10/2009 Bradley Edwards Adam Horowitz Motions fully briefed Joint W/P Priv.
05247 07/23/2009 Katherine Ezell Bradley Edwards Answers to the e set of ROGS Joint W/P Priv.
05251-05252 07/24/2009 Katherine Ezell Bradley Edwards Depo dates Joint W/P Priv.
05258 07/25/2009 Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv.
Epstein Egg Shaped 2 inch PENIS!
05265-05266 07/22/2009 Adam Horowitz Spencer Kuvin Alfredo Rodriguez depo Joint W/P Priv.
24
EFTA00602858
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05286-05287 07/28/2009 Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv.
training of little girls as sex traps
05293-05294 07/28/2009 Katherine Ezell Bradley Edwards Calling Switzerland witness Joint W/P Priv.
05326-05327 08/24/2009 Bradley Edwards Spencer Kuvin Emails searchable Joint W/P Priv.
05331 08/06/2009 Kikka Claudio Bradley Edwards Epstein address Joint W/P Priv.
05334-05335 05/29/2009 Bradley Edwards Mercedes Estrada TV Interview that is too explicit Joint W/P Priv.
05347 08/24/2009 Bradley Edwards Spencer Kuvin Seeking Computers Joint W/P Priv.
05350 08/10/2009 Kikka Claudio Bradley Edwards Current address for Joint W/P Priv.
05353.05354 09/09/2009 Katherine Ezell Bradley Edwards Distribution of Costs Joint W/P Priv.
05367 09/10/2009 Jacquie Johnson Bradley Edwards Voicemail Joint W/P Priv.
05373-05374 08/10/2009 Kikka Claudio Bradley Edwards Supoenas for depos Joint W/P Priv.
05391-05393 04/20/2009 Spencer Kuvin Bradley Edwards Yellow Cab stuff Joint W/P Priv.
05400-05401 10/19/2009 Adam Horowitz Bradley Edwards Religious Dildo Washer Joint W/P Priv.
05414-05415 08/10/2009 Kikka Claudio Bradley Edwards current address Joint W/P Priv.
05437-05439 04/20/2009 Bradley Edwards Spencer Kuvin Yellow Cab stuff Joint W/P Priv.
05444.05445 08/10/2009 Bradley Edwards Kikka Claudio Setting Depos Joint W/P Priv.
05451 05/29/2009 Mercedes Bradley Edwards Motion for Status Conf. Joint w/P Priv.
Estrada
25
EFTA00602859
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05469 07/08/2009 Mercedes Bradley Edwards Judge Marra's July 6th Order Joint W/P Priv.
Estrada
05476-05494 07/08/2009 Spencer Kuvin Bradley Edwards NPA from Marie Villafana Joint W/P Priv.
05546 08/03/2009 Adam Horowitz Bradley Edwards Haley's affidavit Joint W/P Priv.
05579-05581 08/24/2009 Spencer Kuvin Bradley Edwards Seeking all of Plaintiff's Joint W/P Priv.
computer
05613.05618 09/18/2009 Spencer Kuvin Bradley Edwards Non-Pros Agreement Joint W/P Priv.
05633 10/16/2009 Adam Horowitz Bradley Edwards Motion to freeze assets Joint W/P Priv.
05638-05639 10/28/2009 Spencer Kuvin Bradley Edwards Daliah Weiss Joint W/P Priv.
05647 07/09/2009 Adam Horowitz Katherine Ezell NPA under seal for in camera Joint W/P Priv.
review
05656 08/10/2009 Bradley Edwards Kikka Claudio Supoenas for depo Joint W/P Priv.
05659 08/27/2009 Bradley Edwards Spencer Kuvin Order Joint W/P Priv.
05668 10/16/2009 Bradley Edwards Adam Horowitz Florida Science Foundation Joint W/P Priv.
05705 09/09/2009 Mercedes Kikka Claudio Video tape of Epstein Joint W/P Priv.
Estrada
05724 05/29/2009 Bradley Edwards Jack Scarola Motion for Status Conf. Joint W/P Priv.
05727 05/29/2009 Bradley Edwards Sid Garcia Motion for Status Conf. Joint W/P Priv.
05730.05731 08/14/2009 Adam Horowitz Jacquie Johnson Motion for Status Conf. Joint W/P Priv.
05734 05/29/2009 Adam Horowitz Jacquie Johnson Motion for status conf. Joint W/P Priv.
26
EFTA00602860
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05737 08/12/2009 Adam Horowitz Jacquie Johnson NPNP and sub to Palm Beach Joint W/P Priv.
Natl Bank
05750 05/29/2009 Mercedes Spencer Kuvin Motion for status conf. Joint W/P Priv.
Estrada
05770 07/08/2009 Bradley Edwards Spencer Kuvin NPA in camera review Joint W/P Priv.
05774-05776 09/04/2009 Katherine Ezell Jacquie Johnson being rescheduled Joint W/P Priv.
05782-05783 07/09/2009 Bradley Edwards Spencer Kuvin Motion to appoint commissioner Joint W/P Priv.
05788-05790 07/09/2009 Bradley Edwards Spencer Kuvin Notice and serve everyone Joint W/P Priv.
05802 09/04/2009 Adam Horowitz Jacquie Johnson Bill being split up evenly Joint W/P Priv.
05806 09/04/2009 Jacquie Johnson Spencer Kuvin Bill will be split evenly for each Joint W/P Priv.
case
05812 09/04/2009 Adam Horowitz Jacquie Johnson Bill will be split evenly Joint W/P Priv.
05814 08/03/2009 Bradley Edwards Adam Horowitz Haley's affidavit Joint W/P Priv.
05818-05819 09/09/2009 Bradley Edwards Robert Josefsberg CMA Order Joint W/P Priv.
01781 05/01/2009 Bradley Edwards William Berger Epstein Depo Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
07619 07/13/2009 Paul Cassell Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
27
EFTA00602861
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
03181 09/14/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
03181 09/14/2009 William Berger Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
03182-03185 07/14/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
03186-03188 05/01/2009 William Berger Bradley Edwards Epstein Depo Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
13860-13874 05/28/2009 Elizabeth Kim Christinia Fitch Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
14173 10/21/2009 Gary Farmer Bradley Edwards Stanely Arkin Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
13419 08/11/2009 Denis Kleinfeld Bradley Edwards Trump's Depo Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
03087 06/29/2010 Investigators Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
03088 04/11/2009 Epstein Litigation Russell Adler Litigation Strategy Work Product;attorney client
28
EFTA00602862
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 Russell Adler 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 Denis Kleinfeld Bradley Edwards 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 Carl Linder Bradley Edwards 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 Barry Stone Bradley Edwards 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 Barry Stone Bradley Edwards 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 Barry Stone Bradley Edwards 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 Carl Linder Jacquie Johnson Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
f 1 lead to the discovery of admissible
evidence;protected by privacy rights
11984-11988 08/06/2009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
29
EFTA00602863
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
lead to the discovery of admissible
evidence;protected by privacy rights
11995 08/19/2009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
12012 10/21/20009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
11879 10/21/2009 Cara Holmes Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
11868 08/19/2009 Cara Holmes Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
10938 05/28/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
13592 10/21/2009 Denis Kleinfeld Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
04421 05/21/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25814 05/28/2009 William Berger Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
30
EFTA00602864
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
evidence;protected by privacy rights
25778.25782 07/30/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25792-25797 05/28/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25798 08/06/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25799-25802 08/10/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25773 10/21/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25738 08/03/2009 William Berger Beth Williamson Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
25739-25740 08/11/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
17940 07/30/2009 Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client
Birkman privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
31
EFTA00602865
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
17917-17927 08/03/2009 Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client
Birkman privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
17932-17934 05/28/2009 Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client
Birkman privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
17935 05/28/2009 Jonathan Paul Cassell Litigation Strategy Work Product;attorney client
Birkman privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
17936-17938 07/30/2009 Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client
Birkman privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00014 05/01/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00015 05/04/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00016 05/04/2009 Bradley Edwards Paul Cassell Litigation Stratgey Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00017 05/06/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00018 05/06/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
32
EFTA00602866
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES I DATE TO FROM DESCRIPTION OBJECTION
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00019-00021 05/07/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00022 06/23/3009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00023 07/13/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00024 07/13/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00025-00029 05/01/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00030 05/02/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00031 05/03/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00032 05/03/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
33
EFTA00602867
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
lead to the discovery of admissible
evidence;protected by privacy rights
00033-00034 05/03/3009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00035 05/05/2009 Bradley Edwards Susan Sterling Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00036 05/06/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00037-00040 05/25/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00041 07/06/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00042 07/06/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
0043 05/05 Bradley Edwards Susan Sterling Litigation Strategy Work Product;attorney client
/2009 privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00044 08/17/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
34
EFTA00602868
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
evidence;protected by privacy rights
00045 05/01/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00046 05/01/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00047-00049 05/01/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00050 05/05/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00051 05/05/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00052 05/05/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00053 05/05/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00054 05/05/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of
admissibleevidence;protected by privacy rights
35
EFTA00602869
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
00055 04/29/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00056 05/05/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00057 05/05/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00058 05/05/2009 Bradley Edwards Russell Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00059 05/05/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00060 05/05/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00061-0064 05/06/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00065 05/12/2009 Bradley Edwards Paul Cassell litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00066 04/29/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
36
EFTA00602870
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00067 05/12/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00068 05/12/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00069-00070 05/13/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00071 05/13/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00072 05/15/2009 Bradley Edwards Susan Sterling Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00073 05/15/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00074 05/18/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00075 05/18/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
37
EFTA00602871
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
lead to the discovery of admissible
evidence;protected by privacy rights
00076 05/18/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00077 04/04/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00078 05/18/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00079 05/19/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00080 05/19/2009 Bradley Edwards Beth Williamson Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00081-00082 05/20/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00083-00085 05/21/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00086-00087 05/25/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
38
EFTA00602872
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
evidence;protected by privacy rights
00088 04/30/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00089 05/28/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00090 05/28/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00091 05/28/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00092 05/28/2099 Bradley Edwards Rob Buschell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00093 06/01/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00094-00095 06/23/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00096 07/06/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
39
EFTA00602873
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
00097 07/06/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00098-00100 07/07/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00101 07/09/2009 Bradley Edwards Mike Fisten Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00102-00106 07/09/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00107 07/10/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00108 07/10/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00109 07/10/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00110 07/10/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00111 07/11/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
40
EFTA00602874
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00112.00120 05/012009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00121 05/12/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00122 05/12/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00123 05/12/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00124-00125 05/12/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00126 05/22/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00127 05/26/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
41
EFTA00602875
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
00128-00131 5/26/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00132 5/21/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00133 06/23/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00134 06/03/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00135-00137 06/03/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00138.00140 06/08/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00141 06/12/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00142 06/13/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
00143.00145 06/15/2009 Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client
42
EFTA00602876
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 Bradley Edwards William Berger 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 Bradley Edwards Mike Fisten 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 Bradley Edwards Rob Buschel 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 Bradley Edwards Russell Adler 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 Rob Buschel 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 Bradley Edwards Rob Buschel 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 Susan Sterling Russell Adler Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
lead to the discovery of admissible
evidence;protected by privacy rights
13313.13314 07/30/2O09 Denis Kleinfeld Bradley Edwards Litigation Strategy Work Product;attorney client
privilege;irrelevant & reasonably calculated to
43
EFTA00602877
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
lead to the discovery of admissible
evidence;protected by privacy rights
13315 08/03/3009 Denis Kleinfeld Beth Williamson 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 Robert C. Buschel Bradley J. Edwards Jane Doe brother Attorney/Client privilege and/or work product
01077 05/28/2009 Robert C. Buschel Bradley J. Edwards Doe family member Attorney/Client privilege and/or work product
02445-02446 05/05/2009 Bradley J. Susan K. Stirling Jones v. Atlantic asphalt Attorney/Client privilege and/or work product
Edwards
03049 09/21/2009 Bradley J. D.F. New addition to the case Attorney/Client privilege and/or work product
Edwards
02425-02426 06/17/2009 Susan K. Stirling Bradley J. Edwards Jane Doe v. Dukenik Attorney/Client privilege and/or work product
02669 09/24/2009 Bradley J. Jacquie Johnson Subpoena fo Attorney/Client privilege and/or work product
Edwards
02647 08/06/2009 Mike Fisten Bradley J. Edwards Samantha Lee Rivera info Attorney/Client privilege and/or work product
03688-03691 04/03/2009 Robin T. Bradley J. Edwards Case number assignments Attorney/Client privilege and/or work product
Kempner
03692-03693 05/06/2009 Bradley J. Susan K. Stirling Case list Attorney/Client privilege and/or work product
Edwards
15678.15680 09/29/2009 Jacquie Johnson Bradley J. Edwards Subpoena for Attorney/Client privilege and/or work product
15689 10/01/2009 Jacquie Johnson Bradley J. Edwards Client information Attorney/Client privilege and/or work product
02546-02547 09/22/2009 D.F. Bradley 1. Edwards Client communication Attorney/Client privilege and/or work product
02809-02810 09/28/2009 N.R. Bradley J. Edwards Client communication Attorney/Client privilege and/or work product
02262 07/23/2009 Jacquie Johnson Bradley J. Edwards Discussion re: client/victim Attorney/Client privilege and/or work product
personal information
02807-02808 10/01/2009 N.R. Bradley J. Edwards Client communication Attorney/Client privilege and/or work product
03760-03828 04/01/2009 RRA Personnel RRA personnel Client names/types of action/ Attorney/Client privilege and/or work product,
client information privacy right privilege, not relevant
03759 04/01/2009 Russell Adler Bradley J. Edwards Conflict Check for Brad Edwards Attorney/Client privilege and/or work product
files
08358.08359 09/14/2009 Pat Bradley J. Edwards Client info Attorney/Client privilege and/or work product
44
EFTA00602878
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
08364-08368 10/01/2009 Jacquie Johnson Bradley J. Edwards Client info Attorney/Client privilege and/or work product
08370 09/14/2009 Bradley J. Pat.= Client info Attorney/Client privilege and/or work product
Edwards
08374.08375 10/01/2009 Bradley J. Jacquie Johnson Client info Attorney/Client privilege and/or work product
Edwards
03878 06/12/2009 Bradley J. Robert C. Buschel Curtis Rivera Attorney/Client privilege and/or work product
Edwards
02955 04/20/2009 Susan K. Stirling Bradley J. Edwards Juskowich Attorney/Client privilege and/or work product
02932 07/17/2009 Christina Fitch Bradley J. Edwards Jane Doe v. Roe Attorney/Client privilege and/or work product
11544-11545 09/28/2009 Jacquie Johnson Bradley J. Edwards Client info Attorney/Client privilege and/or work product
07432-07435 09/25/2009 D.F. Bradley J. Edwards New addition to the case Attorney/Client privilege and/or work product
06906-06909 07/17/2009 Christina Fitch Bradley J. Edwards Jane Doe v. Roe Attorney/Client privilege and/or work product
06913-06914 06/22/2009 Bradley J. Susan K. Stirling Jane Doe v. Roe Attorney/Client privilege and/or work product
Edwards
06030.06031 05/04/2009 Susan K. Stirling Bradley J. Edwards Espina — Walmart case Attorney/Client privilege and/or work product
05646 07/08/2009 Bradley J. William J. Berger Client meeting Attorney/Client privilege and/or work product
Edwards
05573 09/18/2009 Mike Fisten Bradley J. Edwards Client meeting Attorney/Client privilege and/or work product
05540 07/31/2009 Amy Swan Bradley J. Edwards Client info Attorney/Client privilege and/or work product
05273-05276 07/28/2009 Amy Swan Bradley J. Edwards Client info Attorney/Client privilege and/or work product
05264 07/27/2009 Amy Swan Bradley J. Edwards Client info Attorney/Client privilege and/or work product
05267.05270 07/27/2009 Amy Swan Bradley J. Edwards Client info Attorney/Client privilege and/or work product
02933 06/17/2009 Bradley J. M. G. Jane Doe v. Roe Attorney/Client privilege and/or work product
Edwards
01292 09/18/2009 Bradley J. M.G. Epstein article Attorney/Client privilege and/or work product
Edwards
01068.01070 04/02/2009 All Staff Robin T. Kempner Current case list of Brad Edwards Attorney/Client privilege and/or work product
01054-01055 04/02/2009 All Staff Robin T. Kempner Updated case list for Brad Attorney/Client privilege and/or work product
Edwards
01033 05/06/2009 Susan K. Stirling Bradley J. Edwards case list Attorney/Client privilege and/or work product
01030-01031 04/03/2009 Bradley J. Robin T. Kempner Case number assignments Attorney/Client privilege and/or work product
Edwards
45
EFTA00602879
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01118-01120 09/22/2009 Bradley J. MG Jane Doe v. Roe Attorney/Client privilege and/or work product
Edwards
01986-01989 04/02/2009 Bradley J. Robin T. Kempner Conflict check Attorney/Client privilege and/or work product
Edwards
01984-01985 04/02/2009 Bradley J. Robin T. Kempner Conflict check Attorney/Client privilege and/or work product
Edwards
25925 09/30/2009 All Staff Robin T. Kempner Conflict check Attorney/Client privilege and/or work product
25874 09/30/2009 All Staff Robin T. Kempner Additional name added to Attorney/Client privilege and/or work product
conflict check
08356-08357 09/16/2009 Bradley Edwards NR Client Meeting Attorney/Client privilege and/or work product
16760.16761 09/23/2009 Bradley Edwards Jacquie Johnson New Client Attorney/Client privilege and/or work product
08005 06/05/2009 Bradley Edwards MG New Client Attorney/Client privilege and/or work product
06915.06920 06/17/2009 MG Bradley Edwards Jane Doe v. Roe Attorney/Client privilege and/or work product
08360-08363 09/16/2009 NR Bradley Edwards Client Meeting Attorney/Client privilege and/or work product
04101-04107 09/28/2009 Bradley Edwards MG Jane Doe v. Roe Attorney/Client privilege and/or work product
04708-04710 09/18/2009 Bradley Edwards MG Epstein Article Attorney/Client privilege and/or work product
06910-06912 06/17/2009 MG Bradley Edwards Jane Doe v. Roe Attorney/Client privilege and/or work product
07909 08/10/2009 Jane Doe Bradley Edwards Same silver car tag Attorney/Client privilege and/or work product
07637-07642 09/10/2009 Bradley Edwards NR NR Interview Attorney/ Client Privilege
06795-06799 08/19/2009 Anthony P Bradley Edwards Client Meeting Attorney/Client privilege and/or work product
06542-06548 09/15/2009 Bradley Edwards Pat Diaz Client Meeting Attorney/Client privilege and/or work product
06404-06408 09/10/2009 Bradley Edwards Pat Diaz NR Interview Attorney/Client privilege and/or work product
08338-08339 09/16/2009 Bradley Edwards NR New Client Attorney/Client privilege and/or work product
08505 09/14/2009 NR Bradley Edwards New Client Meeting Attorney/Client privilege and/or work product
02241-02242 05/28/2009 Confidential Bradley Edwards Other Rape Victims W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02243-02244 07/07/2009 Bradley Edwards Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02238.02240 05/28/20009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02204 07/14/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
46
EFTA00602880
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
02298-02299 07/08/2009 Bradley Edwards Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02291 06/04/2009 Bradley Edwards 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 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02440-02441 10/02/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04318-04321 09/24/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05111 06/02/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05152 06/03/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05164 06/03/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05166 06/03/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05169-05170 06/03/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05173-05174 06/03/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05212-05213 06/23/2009 Confidential Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05194-05196 06/23/2009 Bradley Edwards Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05204-05206 06/23/2009 Bradley Edwards Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
47
EFTA00602881
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05227-05228 07/08/2009 Confidential Bradley Edwards 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 Bradley Edwards Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
05303 08/06/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05344-05346 06/23/2009 Bradley Edwards Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05408 07/06/2009 Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05433-05436 05/29/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05433-05436 05/29/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05446 07/07/2009 Bradley Edwards Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05452-05464 05/29/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05535-05536 07/30/2009 Confidential Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05550-05551 08/11/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05577-05578 08/22/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05619.05620 09/18/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05650 08/06/200 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05688-05689 0/28/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
48
EFTA00602882
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
05693-05695 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05698 08/21/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05706-05709 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05720-05721 05/29/2O09 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05738.05739 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05743-05745 05/29/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05754 08/03/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05759.05762 06/01/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05765-05768 06/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05771-05773 06/03/2009 Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05791-05794 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05803 07/22/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05836-05837 07/08/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05842-05843 07/08/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
49
EFTA00602883
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05848 07/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05852-05853 07/29/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05857-05858 07/31/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05952-05953 08/25/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06192-06197 06/23/2009 Bradley Edwards 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 Bradley Edwards Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
06203 07/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06401 09/23/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06643-06651 09/17/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06788.06789 09/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06942-06943 09/26/2009 Confidential Bradley Edwards Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
06953 08/14/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06955-06957 10/02/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06959-06961 08/11/2009 Bradley Edwards 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 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06986.06989 10/03/2009 Bradley Edwards 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 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
50
EFTA00602884
Privilege Log — Dated 2-23-2011
Farmer. Jaffe, Weissing. Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
07017.07018 09/04/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
07143-07144 10/01/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
07147-07150 09/18/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
075089- 10/13/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
07513 Source discovery of admissible evidence
07605-07615 09/07/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07646-07647 09/08/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07674.07697 09/08/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08376 10/04/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
08380 09/18/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08427-08430 09/24/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08450 05/17/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08507 10/03/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
10092.10098 08/31/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01610 06/03/3009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01612 06/04/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01451-01458 05/27/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
51
EFTA00602885
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01608 07/03/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01606 07/02/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01510 08/25/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01506 08/24/2009 Confidential Bradley Edwards Other Rape Victims W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01493 08/10/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01488 08/03/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01486 07/28/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01483 07/28/2009 Confidential Bradley Edwards Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
01479 07/22/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01449 05/22/2009 Bradley Edwards Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01433 10/20/2009 Bradley Edwards 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 Jacquie Johnson Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
19716-19719 09/25/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
19730-19731 10/02/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01683 08/06/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
01693 08/21/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03011 09/17/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
52
EFTA00602886
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Epstein Molestations discovery of admissible evidence
01755-01756 10/02/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
01756 06/22/2009 Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01770 10/08/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03126 09/18/2009 Confidential Bradley Edwards Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Strategy discovery of admissible evidence
02006 06/23/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02060 09/23/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03487-03494 09/19/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02269 08/26/2009 Confidential Bradley Edwards Other Rape Victims W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02322-02323 10/16/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02595-02596 09/07/2009 Bradley Edwards 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 Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02895 08/31/2009 Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03032 09/18/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03057 10/13/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03070 07/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
53
EFTA00602887
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
03081-03082 09/21/2009 Bradley Edwards Confidential Source Providing Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03144 10/08/2009 Confidential Bradley Edwards Providing Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
03189.03190 10/14/2009 Bradley Edwards 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 Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
02913 09/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02956-02957 08/31/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02975 10/21/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
04031.04055 08/12/2009 Bradley Edwards 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 Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
04060 08/12/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02979-02980 10/02/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
02998 07/21/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05626 10/12/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05630-05631 10/12/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05664-05665 10/12/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07976 08/14/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
06655 06/09/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
54
EFTA00602888
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Source discovery of admissible evidence
19986-19987 09/28/2009 Confidential Mike Fisten Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Source Epstein Molestations discovery of admissible evidence
04905-04906 07/15/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04946.04951 10/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05148 05/22/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05151 05/26/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05161 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05203 06/23/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05207-05208 06/23/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05220-05221 06/23/2009 Confidential Bradley Edwards 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 Bradley Edwards Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to
Source discovery of admissible evidence
05239 06/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05277-05278 06/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05324.05325 06/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05368-05369 06/23/2009 Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
55
EFTA00602889
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01280-01288 09/18/2009 Confidential Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
01131-01134 10/08/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
00988 04/25/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10163-10167 08/12/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10181-10188 08/12/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10245-10251 09/08/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10364-10367 09/17/2009 Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10927-10937 05/28/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10945-10954 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10964.10978 06/02/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations to discovery of admissible evidence.
10991 06/22/2009 Bradley Edwards 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 Bradley Edwards Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead
56
EFTA00602890
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Epstein Molestations to discovery of admissible evidence.
11075.11076 07/29/2009 Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards Providing New Witnesses W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11123-11136 09/17/2009 Confidential Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
10390-10393 09/19/2009 Bradley Edwards 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 Bradley Edwards Providing New Witnesses w/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11170.11174 06/23/2009 Confidential Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11188-11195 05/28/2009 Confidential Bradley Edwards Additional Information RE: W/P Privilege; Not reasonably calculated to lead
Source Epstein Molestations to discovery of admissible evidence.
11198-11200 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11208-11214 05/29/2009 Confidential Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11260-11266 06/24/2009 Confidential Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11320-11325 07/30/2009 Confidential Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
57
EFTA00602891
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
11372-11373 08/11/2009 Confidential Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11380-11383 08/12/2009 Confidential Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
Source to discovery of admissible evidence.
11438-11442 09/17/2009 Confidential Bradley Edwards 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 Bradley Edwards Litigation Strategy W/P Privilege; Not reasonably calculated to lead
source to discovery of admissible evidence.
11574-11579 10/13/2009 Confidential Bradley Edwards 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 Bradley Edwards Tami Wolfe 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Jonathan William Berger Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
Birkman not reasonably calculated to lead to the
58
EFTA00602892
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 1g FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
07760-07765 09/11/2009 Bradley Edwards Paul Cassell 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 Jacquie Johnson Attorneys at RRA 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
59
EFTA00602893
Privilege Log — Dated 2-23-2011
Farmer. Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
privacy rights
07849.07852 04/10/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07853-07856 06/10/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07857-07862 09/11/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07863-07864 06/10/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07685-07874 05/14/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07875-07876 04/14/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07877-07884 08/03/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07886.07888 08/02/2009 Cara Holmes Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
60
EFTA00602894
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE Ha FROM DESCRIPTION OBJECTION
07889-07892 05/01/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07893.07904 07/27/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07905.07908 07/22/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07910-07912 08/10/2009 Bradley Edwards Mike Fisten Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07916 10/16/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07919 08/27/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07920-07930 10/18/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05399 10/17/2009 William Berger Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05355-05357 09/09/2009 Russell Adler Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
61
EFTA00602895
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05375-05378 09/10/2009 Jacquie Johnson Bradley Edward Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05372 04/20/2009 Marc Nurik Bradley Edwards litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05380-05381 09/11/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05384.05385 09/15/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05348 09/15/2009 Bradley Edwards William Berger Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05341 09/04/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05329-05330 04/09/2009 Beth Williamson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05332.05333 05/20/2009 William Berger Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
62
EFTA00602896
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE Lo FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
05320-05323 07/30/2009 Bradley Edwards Amy Swan 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 Nora Batian Bradley Edwards 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 Nora Batian Bradley Edwards 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 RRA Bradley Edwards 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 Bradley Edwards Mike Fisten 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 Beth Williamson Bradley Edwards 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 Bradley Edwards William Berger 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 RRA Ken Jenne RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
63
EFTA00602897
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE m FROM DESCRIPTION OBJECTION
privacy rights
05295-05297 07/23/2009 Attorneys at RRA Priscilla RE: Epstein Conference Room W/P; Attorney Client Privilege; Irrelevant and
Nascimento Reserved not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05298 08/03/2009 Mike Fisten Bradley Edwards 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 Amy Swan Bradley Edwards 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 Bradley Edwards Ken Jenne 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 Jacquie Johnson Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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
EFTA00602898
Privilege Loft— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE LQ
'I FROM DESCRIPTION OBJECTION
01082 09/02/2009 Jacquie Johnson Mike Fisten Subpoenas for Epstein's W/P; Attorney Client Privilege; Irrelevant and
Housekeepers not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04363 09/14/2009 Jacquie Johnson Bradley Edwards LM W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04343-04344 09/04/2009 Bradley Edwards Jacquie Johnson 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
04340-04342 09/04/2009 Jacquie Johnson Bradley Edwards 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
04339 09/03/2009 Mike Fisten Bradley Edwards 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
00989 09/04/2009 Bradley Edwards William Berger Alessi Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04325-04328 07/30/2009 Paul Cassell Bradley Edwards RE: Epstein- beneficiaries & W/P; Attorney Client Privilege; Irrelevant and
response to asset freeze motion not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
00155 06/25/2009 Bradley Edwards Paul Cassell 20 Cases & Bond W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04312-04313 05/26/2009 Bradley Edwards Paul Cassell RE: Epstein Accounting; Freezing W/P; Attorney Client Privilege; Irrelevant and
65
EFTA00602899
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
Assets not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04314.04317 09/11/2009 Paul Cassell Bradley Edwards RE: Epstein- Add to our motion W/P; Attorney Client Privilege; Irrelevant and
for a protective order ' not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04307-04308 04/08/2009 Bradley Edwards Paul Cassell Motion to stay-response & W/P; Attorney Client Privilege; Irrelevant and
motion to unseal Fed Civil Case not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04309-04311 05/26/2009 Paul Cassell Bradley Edwards Epstein Assets & Forensic
Accounting
04295 09/11/2009 Jacquie Johnson Bradley Edwards thoughts on Epstein's Victims W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04305-04306 04/08/2009 Paul Cassell Bradley Edwards Motion to Strike references to W/P; Attorney Client Privilege; Irrelevant and
the NPA & Revised response to not reasonably calculated to lead to the
the motion to stay discovery of admissible evidence; protected by
privacy rights
04274.04276 05/06/2009 William Berger Bradley Edwards Sandy Berger Telephone call W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18334-18336 07/24/2009 Ken Jenne Bradley Edwards 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
04216-04219 09/08/2009 William Berger Bradley Edwards State Judge ordered no contact W/P; Attorney Client Privilege; Irrelevant and
with any underage girl not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
66
EFTA00602900
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
04202.04206 09/08/2009 Bradley Edwards William Berger 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 RRA Paul Cassell 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 Paul Cassell William Berger 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 RRA Steven Jaffe 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 Bradley Edwards William Berger 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 Scott Rothstein Ken Jenne 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 RRA 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 Bradley Edwards William Berger 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 Bradley Edwards William Berger Trial Prep Epstein W/P; Attorney Client Privilege; Irrelevant and
67
EFTA00602901
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE m FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19649.19651 07/24/2009 Bradley Edwards Ken Jenne 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
19658-19661 08/03/3009 Bradley Edwards Ken Jenne Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25809-25810 10/04/2009 William Berger Bradley Edwards Trail Prep W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04466.04469 08/18/2009 Bradley Edwards Paul Cassell Epstein Assets Subpoena W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01296 10/02/2009 Mike Fisten Michael Wheeler Subpoena of Detective Recarey W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04439-0442 09/16/2009 Bradley Edwards Paul Cassell RE: Epstein-Notice Of IME W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04445 07/31/2009 Jacquie Johnson Bradley Edwards RE:Epstein Reminder-Mon W/P; Attorney Client Privilege; Irrelevant and
8/3/09-Monthly Call in not reasonably calculated to lead to the
Telephone Conference discovery of admissible evidence; protected by
privacy rights
04425.04428 09/18/2009 Paul Cassell Bradley Edwards Jane Doe Depo Set for the 30th W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
68
EFTA00602902
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
04429 10/07/2009 Bradley Edwards Paul Cassell Motion for Sanctions W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25770-25772 10/05/2009 William Berger Bradley Edwards Victims for Trial W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25768-25769 10/05/2009 Bradley Edwards William Berger Victims for Trail W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26716.26717 09/04/2009 Mike Fisten Ken Jenne NR as a victim W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26714.26715 10/13/2009 Attorneys at RRA Russell Adler Trial date procured W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20907-20908 10/05/2009 Bradley Edwards William Berger Victims for Trial W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19857.19860 10/17/2009 Mike Fisten Pat Epstein's Palm Beach Property W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19861-19862 10/23/2009 Paul Cassell Bradley Edwards Larry Visoski Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
69
EFTA00602903
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
privacy rights
19713-19715 09/09/2009 Bradley Edwards Jacquie Johnson Copperfield Subpoena W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19720.19729 09/30/2009 Mike Fisten Jacquie Johnson Tentative Subpoena dates and W/P; Attorney Client Privilege; Irrelevant and
people list not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19706-19707 09/09/2009 Bradley Edwards Jacquie Johnson Dershowitz Subpoena ready to be W/P; Attorney Client Privilege; Irrelevant and
signed not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19693.19695 09/04/2009 Mike Fisten Bradley Edwards 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
19696-19697 09/04/2009 Jacquie Johnson Bradley Edwards Setting Up Depo Times W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19698.19700 09/04/2009 Mike Fisten Bradley Edwards Investigation in 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
19685-19688 08/27/2009 Bradley Edwards Ken Jenne RE: Witness information that we W/P; Attorney Client Privilege; Irrelevant and
need to use not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19689-19690 09/02/2009 Mike Fisten Jacquie Johnson Awaiting dates for the 2 other W/P; Attorney Client Privilege; Irrelevant and
pilots, Dershowitz & Copperfield not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
70
EFTA00602904
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
19691-19692 09/02/2009 Mike Fisten Pat Diaz Bill Riley Subpoena W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19673-19674 08/10/2009 Jacquie Johnson Bradley Edwards Depo List W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19654-19655 08/03/2009 Mike Fisten Bradley Edwards Setting Up Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19656-19657 08/03/2009 Mike Fisten Bradley Edwards List of people to subpoena W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19662-19663 08/03/2009 Mike Fisten Bradley Edwards Setting Up Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19652-19653 08/26/2009 Jacquie Johnson Bradley Edwards Witness information that we W/P; Attorney Client Privilege; Irrelevant and
need to use not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18348-18349 08/27/2009 Bradley Edwards Ken Jenne RE: Witnesses information that W/P; Attorney Client Privilege; Irrelevant and
we need to use not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04272 06/30/2009 William Berger Bradley Edwards 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
19683-19684 08/19/2009 Mike Fisten Pat Diaz Potential New Witnesses W/P; Attorney Client Privilege; Irrelevant and
71
EFTA00602905
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 Mike Fisten Mike Fisten 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 Russell Adler Bradley Edwards 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 RRA Bradley Edwards 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 RRA Priscila Conference room reserved W/P; Attorney Client Privilege; Irrelevant and
Nascimento not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05262-05263 07/22/2009 Bradley Edwards Jacquie Johnson 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 Bradley Edwards William Berger 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 RRA Bradley Edwards 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 RRA Bradley Edwards Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and
planes not reasonably calculated to lead to the
72
EFTA00602906
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE 1.52 FROM DESCRIPTION OBJECTIQN
discovery of admissible evidence; protected by
privacy rights
25815.25822 06/01/2009 William Berger Bradley Edwards 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 Bradley Edwards Ken Jenne 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 Bradley Edwards Mike Fisten 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 RRA Mike Fistos 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 Scott Rothstein Russell Adler 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 RRA Bradley Edwards 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 Bradley Edwards Susan Stirling 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 Ken Jenne Bradley Edwards Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
73
EFTA00602907
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES RATE TO FROM DESCRIPTION OBJECTION
privacy rights
18174-18176 08/24/2009 Ken Jenne Mike Fisten Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18172-18173 08/24/2009 Mike Fisten Bradley Edwards 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 Bradley Edwards Mike Fisten Epstein Probation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03106 06/03/3009 Bradley Edwards Shawn Gilbert 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 Bradley Edwards Shawn Gilbert 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 Bradley Edwards 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 RRA Mike Fistos 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
18166.18167 08/04/2009 Bradley Edwards Mike Fisten 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
EFTA00602908
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
18164-18165 08/03/2009 Bradley Edwards Mike Fisten Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the,
discovery of admissible evidence; protected by
privacy rights
18771-18773 04/27/2009 Marc Nurik Bradley Edwards 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
18742-18744 09/10/2009 Jacquie Johnson Bradley Edwards Dershowitz Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18737-18741 09/10/2009 Jacquie Johnson Bradley Edwards Depo technicalities W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20263-20282 10/14/2009 Pat Ronald Wise Vehicle Registrations-Visoski W/P; Attorney Client Privilege; Irrelevant and
Mike Fisten not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20219-20262 10/14/2009 Pat Ronald Wise Visoski Research & Questions W/P; Attorney Client Privilege; Irrelevant and
Mike Fisten not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
17225.17230 07/22/2009 Bradley Edwards Jacquie Johnson Wayne Black Retainer W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
17038.17040 10/29/2009 Cara Holmes Jacquie Johnson RE: Subpoenas for Epstein's W/P; Attorney Client Privilege; Irrelevant and
attorneys not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16916-16928 10/19/2009 Bradley Edwards Jacquie Johnson Witness List W/P; Attorney Client Privilege; Irrelevant and
75
EFTA00602909
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
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 Bradley Edwards Jacquie Johnson 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 Bradley Edwards Jacquie Johnson 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 Bradley Edwards Jacquie Johnson 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 Mike Fisten Jacquie Johnson 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 Bradley Edwards Jacquie Johnson 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 Cara Holmes Bradley Edwards 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 William Berger Bradley Edwards 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 RRA Maribel Matiska legal Opinion RE: Epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
76
EFTA00602910
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
01100 10/19/2009 Russell Adler Bradley Edwards 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 Bradley Edwards Alan Garten 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 Bradley Edwards Paul Cassell 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 Bradley Edwards William Berger 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 Bradley Edwards 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 Beth Williamson Bradley Edwards 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 Bradley Edwards Jacquie Johnson 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 Bradley Edwards William Berger 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
77
EFTA00602911
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
privacy rights
01247 09/30/2009 Bradley Edwards Jacquie Johnson 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 Bradley Edwards Marc Nurik 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 Ken Jenne Bradley Edwards 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 Bradley Edwards Carolyn Edwards 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 Paul Cassell Bradley Edwards 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 RRA Jacquie Johnson 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 Jacquie Johnson Bradley Edwards 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 Mike Fisten Bradley Edwards 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
EFTA00602912
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01337 08/10/2009 Jacquie Johnson Bradley Edwards 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 Ken Jenne Bradley Edwards 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 Bradley Edwards Mike Fisten Epstein Potential Witness List W/P; Attorney Client Privilege; Irrelevant and
& Ken Jenne not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01417 08/24/2009 Mike Fisten Bradley Edwards 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 RRA Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Bradley Edwards Pat Diaz 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 Marc Nurik Bradley Edwards 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 Marc Nurik Bradley Edwards Epstein Info W/P; Attorney Client Privilege; Irrelevant and
79
EFTA00602913
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 William Berger Bradley Edwards 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 Wayne Black Bradley Edwards 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 RRA Bradley Edwards 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 Ken Jenne Bradley Edwards 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 Ken Jenne Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Marc Nurik Bradley Edwards 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 Marc Nurik Bradley Edwards Legal opinion re:Epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
80
EFTA00602914
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
01502 08/21/2009 Marc Nurik Bradley Edwards Epstein Evidence W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01513 08/25/2009 Jacquie Johnson Bradley Edwards Discovery for the girls W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01522 08/14/2009 Bradley Edwards Marc Nurik Legal opinion W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01522 10/08/2009 Ken Jenne Bradley Edwards New Victim W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01523-01524 10/26/2009 Marc Nurik Bradley Edwards Meeting on Epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01527 04/27/2009 Marc Nurik Bradley Edwards New Victim W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01540 05/01/2009 William Berger Bradley Edwards Litigation Strategy on punitive W/P; Attorney Client Privilege; Irrelevant and
damages not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01553 09/10/2009 Bradley Edwards Jacquie Johnson Letter from JP Morgan Chase W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
81
EFTA00602915
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
privacy rights
01566 05/11/2009 Wayne Black Bradley Edwards New Victim W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01586 05/26/2009 Paul Cassell Bradley Edwards Opposition to the continuance of W/P; Attorney Client Privilege; Irrelevant and
the trial date not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
15690-15691 10/01/2009 Jacquie Johnson Bradley Edwards Trump Depo W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01607 10/17/2009 Paul Cassell Bradley Edwards Litigation Strategy on motions W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01621 04/19/2009 Marc Nurik Bradley Edwards Potential New Witness W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01622 06/09/2009 Susan Stirling Bradley Edwards Important phone call due today W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01624 06/11/2009 Robert Buschel Bradley Edwards Motion for bond asset transfer W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01627 05/06/2009 Bradley Edwards Marc Nurik Dateline interest into epstein W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
82
EFTA00602916
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01628 06/15/2009 Robert Buschel Bradley Edwards 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 Bradley Edwards Carolyn Edwards Personal Conversation W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01636 06/23/2009 Susan Stirling Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Bradley Edwards 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 Bradley Edwards 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 Wayne Black Bradley Edwards 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 Carl Linder Bradley Edwards 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 Paul Cassell Bradley Edwards DOJ W/P; Attorney Client Privilege; Irrelevant and
83
EFTA00602917
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01663 07/18/2009 Mike Fisten Bradley Edwards Epstein's cars W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01668 07/29/2009 Bradley Edwards Wayne Black MIIINnumber W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01764 07/31/2009 Bradley Edwards Carolyn Edwards Case Numbers W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01676 10/17/2009 Paul Cassell Bradley Edwards Motions W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01681 08/03/20009 Mike Fisten Bradley Edwards Positing regarding litigation W/P; Attorney Client Privilege; Irrelevant and
preparation not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01682 09/04/2009 Paul Cassell Bradley Edwards Litigation Strategy-Order 242 W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01684 09/11/2009 Jacquie Johnson Bradley Edwards Plaintiff firms the notices of W/P; Attorney Client Privilege; Irrelevant and
depos not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01686 09/11/2009 Mike Fisten Bradley Edwards Potential new witnesses W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
84
EFTA00602918
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
01692 09/12/2009 William Berger Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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 William Berger Bradley Edwards 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 Carolyn Edwards Bradley Edwards 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 Richard Wolfe Bradley Edwards 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 RRA Bradley Edwards 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 Bradley Edwards 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
EFTA00602919
Privilege Log — Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
privacy rights
01742 10/12/2009 Beth Williamson Bradley Edwards Filing fee check W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01743 10/29/2009 Beth Williamson Bradley Edwards New folder for Jane Doe Created W/P; Attorney Client Privilege; Irrelevant and
& Jacquie not reasonably calculated to lead to the
Johnson discovery of admissible evidence; protected by
privacy rights
01745 10/15/2009 Bradley Edwards Paul Cassell Epstein's Cars W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05726 08/14/2009 Bradley Edwards William Berger Legal opinion W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
27395 08/13/2009 Marc Nurik Scot Rothstein 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
26356 08/13/2009 Scott Rothstein Russell Adler 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
04225 06/15/2009 Bradley Edwards Wayne Black Epstein Victims W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04229-04233 06/16/2009 Wayne Black Bradley Edwards 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
86
EFTA00602920
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
04237-04242 06/15/2009 Bradley Edwards Wayne Black 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 Wayne Black Bradley Edwards 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 Wayne Black Bradley Edwards 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 Wayne Black Bradley Edwards 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 Bradley Edwards Wayne Black 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 Bradley Edwards Wayne Black 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 RRA Ken Jenne 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 Bradley Edwards Carolyn Edwards 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
EFTA00602921
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES I DATE IQ FROM DESCRIPTION OBJECTION
05145 05/21/2009 Bradley Edwards Carolyn Edwards Epstein Hearing W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05237 07/20/2009 Wayne Black Bradley Edwards 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
02648-02650 08/10/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02651 07/29/2009 Bradley Edwards Wayne Black Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02661-02662 05/12/2009 Russell Adler Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02674-02677 08/18/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02678-02679 04/10/2009 Russell Adler Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02682-02683 08/10/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02718-02720 06/25/2009 Bradley Edwards Seth Lehman Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
88
EFTA00602922
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02728.02729 08/04/2009 Bradley Edwards Spencer Kuvin Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02746 07/22/2009 Bradley Edwards 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 Bradley Edwards Pat Diaz 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 Bradley Edwards William Berger 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 RRA William Berger 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 Bradley Edwards Pat Diaz 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 Bradley Edwards William Berger 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 Bradley Edwards Pat Diaz Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
89
EFTA00602923
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
02889-02890 10/14/2009 Bradley Edwards Mike Fisten Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02891 10/12/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02892 08/03/2009 Bradley Edwards William Berger Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02894 09/09/2009 Mike Fisten Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02899 09/29/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03001-03002 05/15/2009 Susan Stirling Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03003 04/15/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03004 06/23/2009 Wayne Black Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
90
EFTA00602924
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES DATE 11Q FROM DESCRIPTION OBJECTION
privacy rights
03005-03006 08/03/2009 Mike Fisten Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03007 10/07/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03008 04/23/2009 Susan Stirling Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03013 05/25/2009 Bradley Edwards Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03014 10/08/2009 Bradley Edwards Cara Holmes Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03015 04/24/2009 Steven Jaffe Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03017.03018 08/18/2009 Mike Fisten Bradley Edwards 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
03019 09/19/2009 Bradley Edwards Pat Diaz Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
91
EFTA00602925
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE lig FROM DESCRIPTION OBJECTION
03020 09/16/2009 Bradley Edwards Jacquie Johnson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03021-03027 09/19/2009 Bradley Edwards Pat Diaz Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03031-03034 09/18/2009 Pat Diaz Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03035 09/29/2009 Russell Adler Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03039 06/05/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03040 09/04/2009 Mike Fisten William Berger Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03044 09/09/2009 Bradley Edwards Jacquie Johnson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03045-03047 09/30/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03048 04/21/2009 Paul Cassell Susan Stirling Litiation Strategy W/P; Attorney Client Privilege; Irrelevant and
92
EFTA00602926
Privilege Log— Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
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 Bradley Edwards Paul Cassell 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 Bradley Edwards Mike Fisten 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 RRA Grant Smith 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 Bradley Edwards Mike Fisten 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 Bradley Edwards Wayne Black 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 Bradley Edwards Mike Fisten 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 Jacquie Johnson Michael Wheeler 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 Bradley Edwards Mike Fisten Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
93
EFTA00602927
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATE TO FROM DESCRIPTION OBJECTION
BATES
discovery of admissible evidence; protected by
privacy rights
07/21/2009 Bradley Edwards Paul Cassell Other Rape Victims W/P; Attorney Client Privilege; Irrelevant and
03102-03103
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07/24/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
03107-03113
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03114 08/04/2009 Bradley Edwards Mike Fisten Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03115.03118 05/16/2009 Bradley Edwards Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03124 06/23/2009 Bradley Edwards Wayne Back Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03125 09/08/2009 William Berger Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03127-03128 05/19/2009 Susan Stirling Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03135-03136 08/04/2009 Mike Fisten Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
94
EFTA00602928
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
TO FROM DESCRIPTION OBJECTION
BATES DATE
privacy rights
Wayne Black Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
03137 08/22/2009
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
10/08/2009 Beth Williamson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
03138
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
10/30/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
03145
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03146 08/22/2009 Bradley Edwards Wayne Black Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
10/07/2009 Bradley Edwards Beth Williamson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
03147-03154
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03155-03155 10/08/2009 Bradley Edwards Jacquie Johnson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03158-3159 04/28/2009 Bradley Edwards Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03191-03196 10/14/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
95
EFTA00602929
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
03197-03199 08/14/2009 Attorneys at RRA Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Bradley Edwards Jacquie Johnson 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 Paul Cassell Bradley Edwards 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 Paul Cassell Ronald Wise 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 Bradley Edwards Paul Cassell 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 Bradley Edwards Paul Cassell 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 William Berger Bradley Berger 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 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
96
EFTA00602930
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE Q
11 FROM DESCRIPTION OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03303 07/30/2009 Bradley Edwards Beth Williamson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03306-03307 09/04/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03308-03309 09/04/2009 Beth Williamson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03310-03314 09/04/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03389 07/30/2009 Beth Williamson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03392-03393 09/04/2009 Bradley Beth Williamson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
Williamson not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03461-03463 09/19/2009 Bradley Edwards Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03464-03465 06/14/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
97
EFTA00602931
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence; protected by
privacy rights
03469-03486 06/15/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03495 08/27/2009 Bradley Edwards Jacquie Johnson Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03496-03501 10/28/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03502-03506 10/27/2009 Paul Cassell Ronald Wise Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03507.03510 10/28/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03511-03513 10/28/2009 Bradley Edwards Ronald Wise Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03514-03516 10/26/2009 Paul Cassell Ronald Wise Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03520-03523 07/04/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
98
EFTA00602932
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 1.4 FROM DESCRIPTION OBJECTION
privacy rights
03524 09/04/2009 William Berger Bradley Edwards 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 William Berger Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Pat Diaz Bradley Edwards 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 RRA Ronald Wise 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 Bradley Edwards Paul Cassell 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 Wayne Black Bradley Edwards 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
EFTA00602933
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
03550-03574 09/09/2009 Attorneys at RRA Paul Cassell 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 Kendall Coffey Bradley Edwards 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 Paul Cassell Bradley Edwards 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 RRA Bradley Edwards 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 William Berger Bradley Edwards 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 RRA Bradley Edwards 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 Bradley Edwards Cara Holmes 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 Pat Diaz Bradley Edwards 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 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and
100
EFTA00602934
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 Bradley Edwards Paul Cassell 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 RRA Mark Fistos 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 RRA Russell Adler 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 RRA Steven Jaffe 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 RRA Bradley J. Jane Doe II v. Epstein Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01913-01914 06/15/2009 Susan K. Stirling Bradley J. Activity in case 9:08-cv-80893- Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Activity in case 9:08-cv-80893- Work product; attorney/client privilege;
Edwards 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 Paul Cassell Bradley J. Activity in case 9:08-cv-80994- Work product; attorney/client privilege;
Edwards KAM Jane Doe No. 6 v. Epstein irrelevant and not reasonably calculated to lead
101
EFTA00602935
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
Motion to Strike to the discovery of the admissible evidence;
protected by privacy rights
01925 08/26/2009 Jacquie Johnson Bradley J. Adriana Surveillance/Interview Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01928-01929 08/03/2009 Jacquie Johnson Bradley J. Alfredo Rodriguez address Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01930 09/05/2009 Bradley J. William J. Berger Client info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01940 09/10/2009 Russell Adler Bradley J. Witness Info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01944.01952 04/10/2009 Russell Adler Bradley J. Epstein assets Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01969 05/04/2009 Susan K. Stirling Bradley J. Call from sources of information Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Cassell Draft Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01973-01974 07/23/2009 Mike Fisten Bradley J. CMA vs. Epstein — new Work product; attorney/client privilege;
Edwards investigator info irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
102
EFTA00602936
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
protected by privacy rights
01975 08/10/2009 Jacquie Johnson Bradley J. Computers Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01976-01978 07/06/2009 Bradley J. Paul Cassell Conference Call Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01981.01982 04/01/2009 Bradley J. Russell Adler Conflict check for Brad Edwards Work product; attorney/client privilege;
Edwards files irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01990 05/14/2009 Bradley J. Paul Cassell Consolidation order Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02000 09/03/2009 Jacquie Johnson Bradley J. Dates for Subpoena — Epstein's Work product; attorney/client privilege;
Edwards housekeepers irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02001-02003 10/09/2009 Jacquie Johnson Bradley J. David Copperfield Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02009-2010 09/09/2009 Pasquale Diaz Bradley J. Deposition of Bill Riley Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02017-02018 05/18/2009 William J. Berger Bradley J. Doe v. Epstein Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
103
EFTA00602937
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES AT 12 FROM DESCRIPTION OBJECTION
02023 05/14/2009 Attorneys at RRA Bradley J. Sid's deposition of Epstein Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. E.W., Doe v. Epstein — Letter Work product; attorney/client privilege;
Edwards 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 Paul Cassell Bradley J. E.W., Doe v. Epstein — Letter Work product; attorney/client privilege;
Edwards 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 William J. Berger Bradley J. Epstein — Confirming AT&T Dial in Work product; attorney/client privilege;
Edwards 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 Paul Cassell Bradley J. Epstein hearing Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Epstein — Monthly Call in Work product; attorney/client privilege;
Edwards 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 Susan K. Stirling Bradley J. Epstein — Telephone Conference Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02109 05/13/2009 Wayne Black Bradley J. Epstein info — List of Plaintiff Work product; attorney/client privilege;
Edwards lawyers irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02110-02111 09/15/2009 Bradley J. Jacquie Johnson Epstein - Cancelling depositions Work product; attorney/client privilege;
104
EFTA00602938
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Edwards 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 Bradley J. Jacquie Johnson Epstein — Yearbook picture of Work product; attorney/client privilege;
Edwards 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 Jacquie Johnson Bradley J. Epstein (AUSA) Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02119-02121 09/08/2009 Beth S. Bradley J. Epstein info Work product; attorney/client privilege;
Williamson Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02130-02137 05/26/2009 Susan K. Stirling Bradley J. Epstein cases- depositions in Work product; attorney/client privilege;
Edwards 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 Jacquie Johnson Bradley J. Epstein depo — New York Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02143-02146 09/28/2009 Jacquie Johnson Bradley J. Epstein Depo Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02229 05/05/2009 Paul Cassell Bradley J. Epstein Depo Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Epstein info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
105
EFTA00602939
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE Lo FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
02256-02257 07/22/2009 Jacquie Johnson Bradley J. Epstein info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02260-02261 07/22/2009 Nora Batian Bradley J. Epstein — coordinating meetings Work product; attorney/client privilege;
Edwards 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 RRA Nora Batian 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 Jacquie Johnson Bradley J. Epstein — Video Deposition of S.K. Work product; attorney/client privilege;
Edwards 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 Jacquie Johnson Bradley J. Epstein info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02278-02279 07/23/2009 Priscila A. Nora Batian Epstein info Work product; attorney/client privilege;
Nascimento irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02284-02855 05/11/2009 Susan K. Stirling Bradley J. Epstein info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01769 10/30/2009 Mike Fisten Bradley J. Barbara Berg info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
106
EFTA00602940
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES pATt TO FROM DESCRIPTION OBJECTION
protected by privacy rights
01780 09/14/2009 Bradley J. William J. Berger Discussion of belief that Epstein Work product; attorney/client privilege;
Edwards 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 Ken Jenne Bradley J. 1. Accountants 2. Motion for IME Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01799-01801 10/14/2009 Bradley J. Paul Cassell Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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 Beth S. Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Williamson Edwards 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 Paul Cassell Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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 Paul Cassell Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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 Paul Cassell Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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
EFTA00602941
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
01840-01841 07/16/2009 Paul Cassell Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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 Paul Cassell Bradley J. Activity in case 9:08-cv-80119- Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Meeting with clients Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03664.03668 09/18/2009 Paul Cassell Bradley J. Litigation strategy and Work product; attorney/client privilege;
Edwards preparation irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08166-08168 10/28/2009 Paul Cassell Bradley J. Weds filing Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08169-08170 08/06/2009 Bradley J. Jacquie Johnson Wexner deposition for 14th Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08190-08196 04/07/2009 Bradley J. Paul Cassell Motion to unseal/Motion to stay Work product; attorney/client privilege;
Edwards 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 RRA Bradley J. Witness Information Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08377-08378 10/02/2009 Bradley J. Paul Cassell Zorro Trust research info. Work product; attorney/client privilege;
108
EFTA00602942
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08381-08383 09/06/2009 Bradley J. Paul Cassell Epstein — complaint Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08384-08388 04/13/2009 Bradley J. Paul Cassell Epstein fraudulent transfer Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08389-08397 05/14/2009 Bradley J. Paul Cassell Revisited sexual history memo Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08401 07/22/2009 Bradley J. Paul Cassell Reply memo on asset transfers Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08409-08410 08/01/2009 Bradley J. Cara I Holmes Rodriguez Deposition Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08421 06/02/2009 Bradley J. William J. Berger Strategy Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08423.08425 10/09/2009 Bradley J. Mike Fisten Subpoena info Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08426 08/10/2009 Bradley J. Mike Fisten Synopsis Work product; attorney/client privilege;
Edwards irrelevant and not reasonably calculated to lead
109
EFTA00602943
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08441-08446 10/05/2009 Attorneys at RRA William J. Berger 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 Wayne Black Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Bradley Edwards Cara Holmes 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 Bradley Edwards William Berger 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 William Berger Bradley Edwards 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 Susan Stirling Bradley Edwards 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 Bradley Edwards Jacquie Johnson Igor Zinoview depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
110
EFTA00602944
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
protected by privacy rights
02376-02392 10/14/2009 Mike Fisten Bradley Edwards 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 William Berger Bradley Edwards 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 RRA Bradley Edwards 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 Carolyn Edwards Bradley Edwards 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 Susan Stirling Bradley Edwards 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 Dr. Lee (Expert) Bradley Edwards 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
02304-02308 09/17/2009 Bradley Edwards Jacquie Johnson 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 Bradley Edwards William Berger 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
EFTA00602945
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
02331-02334 05/08/2009 Susan Stirling Bradley Edwards 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 MA Mike Fisten 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 Bradley Edwards Wayne Black 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 Jacquie Johnson Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Bradley Edwards Jacquie Johnson 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 Bradley Edwards William Berger RICO Enterprise Work product; attorney/client privilege;
112
EFTA00602946
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
MILS 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 RRA Bradley Edwards 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 RRA Bradley Edwards 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 RRA Bradley Edwards 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 Bradley Edwards William Berger 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 Bradley Edwards Wayne Black 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 Bradley Edwards Wayne Black 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 Bradley Edwards Wayne Black 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 Bradley Edwards Wayne Black Retainer from the Firm Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
113
EFTA00602947
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
11083-11084 09/04/2009 Attorneys at RRA Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Paul Cassell Bradley Edwards 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 William Berger Bradley Edwards 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 RRA Bradley Edwards 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 Marc Nurik Bradley Edwards 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 Susan Stirling Bradley Edwards 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 Paul Cassell Bradley Edwards Litigation strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence; i
114
EFTA00602948
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE. TO FROM DESCRIPTION OBJECTION
protected by privacy rights
11215 06/01/2009 William Berger Bradley Edwards Activity in Case Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11238-11239 06/03/2009 Wayne Black Bradley Edwards 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
11246-11247 06/22/2009 Wayne Black Bradley Edwards Epstein Article Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11251-11254 06/23/2009 Wayne Black Bradley Edwards 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
11267-11268 06/30/2009 William Berger Bradley Edwards Witness List revised Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11282-11315 07/18/2009 Wayne Black Bradley Edwards 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
11326-11331 08/03/2009 Jacquie Johnson Bradley Edwards Donald 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
11337-11339 08/04/2009 Mike Fisten Bradley Edwards Confidential Info Work product; attorney/client privilege;
irrelevant and not reasonably cakulated to lead
to the discovery of the admissible evidence;
protected by privacy rights
115
EFTA00602949
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
11359.11362 08/10/2009 Jacquie Johnson Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 RRA Bradley Edwards 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 RRA Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards Visoski Depo Work product; attorney/client privilege;
116
EFTA00602950
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 RRA Bradley Edwards 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 RRA Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 RRA Ken Jenne 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 Cara Holmes Jacquie Johnson 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 Paul Cassell Bradley Edwards Total counts for E.W. 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 William Berger Bradley Edwards 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 Pat Din Bradley Edwards Updated Witness List Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
117
EFTA00602951
Privilege Loft— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES PATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08157-08159 06/03/2009 Carla Martinez Bradley Edwards 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 RRA Bradley Edwards 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 Bradley Edwards Mike Fisten 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 RRA Jacquie Johnson 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 RRA Ken Jenne 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 RRA Ken Jenne 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 Carl Linder Bradley Edwards 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 Jacquie Johnson Bradley Edwards Retainer for Investigator Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
118
EFTA00602952
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
protected by privacy rights
15820-15822 10/29/2009 Jacquie Johnson Cara Holmes 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 Jacquie Johnson Bradley Edwards 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 RRA Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Denis Kleinfeld Bradley Edwards 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 RRA Mike Fisten 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 Bradley Edwards Jacquie Johnson 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 Bradley Edwards Jacquie Johnson 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
EFTA00602953
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
10633-10638 10/05/2009 Bradley Edwards William Berger 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 Jacquie Johnson Mike Fisten 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 Bradley Edwards Paul Cassell 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 Bradley Edwards Paul Cassell 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 RRA Mike Fisten 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 Jacquie Johnson Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Bradley Edwards Bradley Edwards 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 Bradley Edwards Jacquie Johnson Trump Depo Work product; attorney/client privilege;
120
EFTA00602954
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE 12 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 Bradley Edwards Jacquie Johnson 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 Bradley Edwards William Berger 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 RRA Jacquie Johnson 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 Bradley Edwards Paul Cassell 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Paul Cassell 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 William Berger Bradley Edwards E.W., 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 Carolyn Edwards Bradley Edwards Litigation Strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
121
EFTA00602955
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
;I TES DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
04005-04011 05/13/2009 Bradley Edwards William Berger 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 Bradley Edwards Paul Cassell 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Jacquie Johnson 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 Paul Cassell Bradley Edwards 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 RRA Paul Cassell 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 Susan Stirling Bradley Edwards 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 Bradley Edwards Pat Diaz Mark Epstein Info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
122
EFTA00602956
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
protected by privacy rights
02520-02543 06/06/2009 Bradley Edwards Paul Cassell 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 Beth Williamson Bradley Edwards 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 Bradley Edwards Jacquie Johnson 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 Jacquie Johnson Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 Paul Cassell Bradley Edwards Response to Motion to Work product; attorney/client privilege;
Consolidate + Cassell 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 Bradley Edwards Paul Cassell 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
EFTA00602957
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
07967-07975 09/22/2009 Jacquie Johnson Mike Fisten Subpoena on 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
07979-08000 08/18/2009 Bradley Edwards Jacquie Johnson 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
07735-07736 07/24/2009 Bradley Edwards Jacquie Johnson Releases for therapist Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07643-07645 09/09/2009 Bradley Edwards Jacquie Johnson 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
07698-07706 09/06/2009 Paul Cassell Bradley Edwards Answer to the Complaint Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07620-07632 08/14/2009 Jacquie Johnson Bradley Edwards Review of "Notice of Taking Depo Work product; attorney/client privilege;
— RC — Bear Sterns" irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07635-07636 10/15/2009 Mike Fisten Bradley Edwards Questions from forensic Work product; attorney/client privilege;
accountant detecting Epstein irrelevant and not reasonably calculated to lead
fraudulent transfers to the discovery of the admissible evidence;
protected by privacy rights
07617-07618 07/13/2009 Paul Cassell Bradley Edwards 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
07550-07589 10/30/2009 Bradley Edwards Paul Cassell Motion to Supplement with the Work product; attorney/client privilege;
124
EFTA00602958
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissine. Edwards, Fistos & Lehrman
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 Bradley Edwards Paul Cassell 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Susan Stirling 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 Paul Cassell Bradley Edwards 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 RRA Russell Adler 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 Bradley Edwards Paul Cassell Response to Motion to Work product; attorney/client privilege;
Consolidate + Cassell 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 RRA Bradley Edwards 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 Russell Adler Bradley Edwards New cases Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
125
EFTA00602959
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards. Fistos & Lehrman
BATES DATE TO FROM • ESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
07424.07431 09/26/2009 Bradley Edwards Paul Cassell Need Depo Transcript Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07412.07423 04/08/2009 Bradley Edwards Paul Cassell 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
07403-07411 04/08/2009 Paul Cassell Bradley Edwards 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
07394.07402 07/10/2009 Bradley Edwards Paul Cassell Multiple 2255 Counts Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07386-07392 05/28/2009 William Berger Bradley Edwards Motion to Unseal Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07378-07385 04/07/2009 Bradley Edwards Paul Cassell Motion to Unseal Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07370-07377 04/07/2009 Paul Cassell Bradley Edwards Motion to Unseal Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07354-07369 10/28/2009 Beth Williamson Bradley Edwards Motion to Protect 2nd depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
126
EFTA00602960
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
protected by privacy rights
07346 10/28/2009 Beth Williamson Bradley Edwards Motion to protect 2"d depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07337 10/28/2009 Bradley Edwards Jacquie Johnson Motion to protect r d depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07328 10/28/2009 Bradley Edwards Beth Williamson Motion to protect e d depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07319 10/28/2009 Bradley Edwards Jacquie Johnson Motion to protect 2"d depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07313.07318 04/10/2009 Paul Cassell Bradley Edwards Motion to Compel — Photograph Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07287.07301 07/08/2009 Bradley Edwards Paul Cassell Motion to Compel — File this Work product; attorney/client privilege;
week? irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07252.07278 09/08/2009 Bradley Edwards Paul Cassell Motion for IME + Accountant Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07247-07251 09/08/2009 Paul Cassell Bradley Edwards Motion for IME + Accountant Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
127
EFTA00602961
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
07230-07233 06/08/2009 Paul Cassell Bradley Edwards Memo on Asset Transfers Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07157-07158 09/29/2009 Russell Adler Bradley Edwards RE: Mark Schwartz Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07128-07141 07/08/2009 Paul Cassell Bradley Edwards Motion for bond asset transfer Work product; attorney/client privilege;
and memo final irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07094-07098 09/14/2009 Paul Cassell Bradley Edwards Letter to Critton RE: Motions to Work product; attorney/client privilege;
Compel irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07025-07027 10/29/2009 Bradley Edwards Paul Cassell ■. and E.W. 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
07099-07106 09/14/2009 Bradley Edwards Paul Cassell Letter to Critton RE: Motions to Work product; attorney/client privilege;
Compel irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07071-07078 07/23/2009 Paul Cassell Bradley Edwards ■'s Son's B-day Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07066-07070 07/23/2009 Bradley Edwards Paul Cassell M.'s Son's B-day Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07015-07016 10/13/2009 Bradley Edwards Paul Cassell Evidence of Asset transfers Work product; attorney/client privilege;
128
EFTA00602962
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 1.2 FROM DESCRIPTION OBJECTION
and/or liquidations irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07019-07024 10/29/2009 Bradley Edwards Paul Cassell and E.W. v. Epstein — I'm on Work product; attorney/client privilege;
it irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06837-06839 04/08/2009 Beth Williamson Bradley Edwards Jane Doe change of address Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06826-06836 04/08/2009 Bradley Edwards Beth Williamson Jane Doe change of address Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06823-06825 04/08/2009 Bradley Edwards Beth Williamson Jane Doe change of address Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06813-06816 07/02/2009 Paul Cassell Bradley Edwards Doe v. Epstein Motion for Work product; attorney/client privilege;
Extension of Time to File irrelevant and not reasonably calculated to lead
Response/Reply/Answer to the discovery of the admissible evidence;
protected by privacy rights
06808-06810 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Work product; attorney/client privilege;
Madoff — Running a giant Ponzi irrelevant and not reasonably calculated to lead
scheme?" to the discovery of the admissible evidence;
protected by privacy rights
06804.06805 09/13/2009 Paul Cassell Bradley Edwards "Is Jeffrey Epstein the new Work product; attorney/client privilege;
Madoff — Running a giant Ponzi irrelevant and not reasonably calculated to lead
schemer' to the discovery of the admissible evidence;
protected by privacy rights
06794 10/23/2009 Mike Fisten Bradley Edwards Interesting Web Site Work product; attorney/client privilege;
129
EFTA00602963
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES DATE TO 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 Paul Cassell Bradley Edwards 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 RftA Paul Cassell 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 Bradley Edwards Jacquie Johnson IME's 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 Paul Cassell Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Bradley Edwards Mike Fisten 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
EFTA00602964
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
06691.06696 07/09/2009 Bradley Edwards Paul Cassell How many 2255 claims? Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06683-06686 07/08/2009 Paul Cassell Bradley Edwards Hiding Assets Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06654 07/24/2009 Paul Cassell Bradley Edwards Secretary Contact info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06599.06600 07/08/2009 Bradley Edwards Paul Cassell Hiding Assets Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06574.06590 04/07/2009 Paul Cassell Bradley Edwards Motion to Unseal Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06567.06570 07/09/2009 Bradley Edwards Paul Cassell 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
06558-06561 07/09/2009 Paul Cassell Bradley Edwards 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
131
EFTA00602965
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
06554-06557 05/14/2009 Bradley Edwards Paul Cassell 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
06549-06553 05/14/2009 Paul Cassell Bradley Edwards 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
06540-06541 09/21/2009 Bradley Edwards Mike Fisten Info on Maxwell Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06537 10/23/2009 Bradley Edwards Paul Cassell Doe v. 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
06529-06530 10/23/2009 Paul Cassell Bradley Edwards 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
06496-06505 10/20/2009 Bradley Edwards Paul Cassell 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
06177-06181 09/25/2009 William Berger Bradley Edwards Financial discovery Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06149-06153 07/10/2009 Paul Cassell Bradley Edwards Federal First Amendment Work product; attorney/client privilege;
Complaint irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
132
EFTA00602966
Privilege LoR — Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
protected by privacy rights
06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Marys case Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06113-06117 07/14/2009 Bradley Edwards Richard Wolfe Facebook/Myspace Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06106-06112 05/19/2009 Amy Swan William Berger Expert Witness Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06091 08/04/2009 William Berger Paul Cassell EW and LM 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
06001-06011 07/18/2009 Paul Cassell Bradley Edwards Epstein's Address and Position of Work product; attorney/client privilege;
Critton on Motion irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05996 04/08/2009 Bradley Edwards Beth Williamson 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
05998-06000 09/17/2009 Jacquie Johnson Bradley Edwards Epstein: Forensics/Investigations Work product; attorney/client privilege;
INVOICE irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05992 04/19/2009 Bradley Edwards Marc Nurik Litigation Strategy Work product; attorney/client privilege;
133
EFTA00602967
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05968 10/17/2009 Bradley Edwards William Berger 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
05944-05947 05/01/2009 William Berger Bradley Edwards 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
05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05931-05932 07/27/2009 Amy Swan Bradley Edwards Client's Cell Phone Number Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05919-05920 07/28/2009 Bradley Edwards Amy Swan Client's Cell Phone Number Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05915 04/22/2009 Bradley Edwards Marc Nurik 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
05911 05/28/2009 Bradley Edwards William Berger 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
134
EFTA00602968
Privilege Log— Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
B_ATES DATE IQ FROM DESCRIPTION OBJECTION
05890 07/27/2009 Bradley Edwards Amy Swan 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
05893-05894 07/27/2009 Bradley Edwards Amy Swan 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
05898-05899 07/28/2009 Bradley Edwards Amy Swan 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
05885 09/15/2009 Bradley Edwards Jacquie Johnson 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
05874.05879 07/23/2009 Bradley Edwards Jacquie Johnson 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
05868 08/03/2009 Bradley Edwards Ken Jenne 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
05865 09/10/2009 Bradley Edwards Jacquie Johnson 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
05860-05861 09/10/2009 Bradley Edwards Maribel Matiska Litigation strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
135
EFTA00602969
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES QATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05845 07/24/2009 Bradley Edwards Ken Jenne 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 Bradley Edwards Susan Stirling 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 Bradley Edwards Ken Jenne 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 Bradley Edwards Jacquie Johnson 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 RRA Bradley Edwards 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 Bradley Edwards Russell Adler 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 Bradley Edwards Marc Nurik 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 Bradley Edwards Susan Stirling Motion to Unseal Work product; attorney/client privilege;
136
EFTA00602970
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE Ig 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 Bradley Edwards William Berger 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 RRA Mike Fisten 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 RRA Gary Farmer 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 Bradley Edwards Mike Fisten 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 Amy Swan Bradley Edwards 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 Susan Stirling Bradley Edwards 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 RRA Bradley Edwards 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
EFTA00602971
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTIOft
05575-05576 08/21/2009 Marc Nurik Bradley Edwards 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 Bradley Edwards Mike Fisten 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 Marc Nurik Bradley Edwards 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 RRA Bradley Edwards 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 Jacquie Johnson Bradley Edwards No objections from defense Work product; attorney/client privilege;
counsel regarding depo for irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05534 07/24/2009 Ken Jenne Bradley Edwards 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 RRA Bradley Edwards 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 Priscila Nora Batian Assemble Epstein Litigation Work product; attorney/client privilege;
Nascimento meeting irrelevant and not reasonably calculated to lead
138
EFTA00602972
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DAlg TO FROM pESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05502-05507 07/22/2009 Jacquie Johnson Bradley Edwards Wayne Black's email Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05475 04/21/2009 Marc Nurik Bradley Edwards Call with Chris Hanson from Work product; attorney/client privilege;
dateline irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05471-05472 08/14/2009 Marc Nurik William Berger Legal expert regarding legal issue Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05447 08/14/2009 Marc Nurik William Berger 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
05420-05423 05/20/2009 William Berger Bradley Edwards Research on cases saying a judge Work product; attorney/client privilege;
can postpone one party's depo irrelevant and not reasonably calculated to lead
until the other is completed to the discovery of the admissible evidence;
protected by privacy rights
05409.05412 08/17/2009 Bradley Edwards Marc Nurik Legal opinion regarding Work product; attorney/client privilege;
discovery irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
139
EFTA00602973
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE 12 FROM DESCRIPTION OBJECTION
05399 10/17/2009 William Berger Bradley Edwards 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 William Berger Bradley Edwards 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 Bradley Edwards Jacquie Johnson Depo Dates to take SR, LM, and Work product; attorney/client privilege;
CW irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05259-05260 07/22/2009 Bradley Edwards Jacquie Johnson 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 Bradley Edwards William Berger 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 RRA Ken Jenne Judge's 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 RRA Ken Jenne Michael Reiter 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
EFTA00602974
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05155.05156 04/20/2009 Russell Adler Bradley Edwards 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 William Berger Bradley Edwards 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 Susan Stirling Bradley Edwards 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 Bradley Edwards Mike Fisten 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 Paul Cassell Bradley Edwards 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 RRA Russell Adler 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 05/11/2O09 William Berger Bradley Edwards 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 Bradley Edwards Phaedra Xanthos Final affidavit from forensic Work product; attorney/client privilege;
accountant irrelevant and not reasonably calculated to lead
141
EFTA00602975
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATt TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05125-05132 05/05/2009 William Berger Bradley Edwards Response to motion to compel all Work product; attorney/client privilege;
the sex information of his clients irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05115-05117 04/27/2009 Bradley Edwards Susan Stirling 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
01699 09/15/2009 Jacquie Johnson Bradley Edwards V2 depo Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05120-05121 05/04/2009 William Berger Bradley Edwards Reporter asking how the depo of Work product; attorney/client privilege;
Epstein went irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05095.05098 07/01/2009 Bradley Edwards Paul Cassell Epstein v. State of Florida — Work product; attorney/client privilege;
Emergency Petition for Writ of irrelevant and not reasonably calculated to lead
Certiorari; Emergency Motion to to the discovery of the admissible evidence;
Review Denial of Stay protected by privacy rights
01694 10/17/2009 Jacquie Johnson Bradley Edwards PFS Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05066-05067 05/06/2009 Marc Nurik William Berger Epstein sealed records and TV Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
142
EFTA00602976
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
pATES DATE IQ FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05054-05065 08/18/2009 Attorneys at RRA Mike Fisten 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 Mike Fisten Bradley Edwards 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 Bradley Edwards Scott Goldstein 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 RRA Paul Cassell 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 RRA Bradley Edwards 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 Elizabeth Villar Bradley Edwards 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 Bradley Edwards Jacquie Johnson 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
EFTA00602977
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE M FROM DESCRIPTION OBJECTION
04893-04896 09/10/2009 Jacquie Johnson Bradley Edwards 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
04890 09/10/2009 Jacquie Johnson Bradley Edwards 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
04884-04885 09/10/2009 Bradley Edwards Jacquie Johnson 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
01469 07/17/2009 Ken Jenne Bradley Edwards Discussions about the Epstein Work product; attorney/client privilege;
case irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04745.04747 08/04/2009 Bradley Edwards Jacquie Johnson Epstein depo in 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
04738.04744 08/25/2009 Bradley Edwards Paul Cassell Hearing regarding the Epstein Work product; attorney/client privilege;
computers irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04660 10/22/2009 Bradley Edwards Marc Nurik Epstein AUSA — Attorneys Fees Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04642-04646 09/11/2009 Bradley Edwards Beth Williamson Discussions about Brad's Work product; attorney/client privilege;
recovery irrelevant and not reasonably calculated to lead
144
EFTA00602978
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
04607.04617 09/11/2009 Jacquie Johnson Bradley Edwards Holding Fed Subs until we get Work product; attorney/client privilege;
response on form irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04526-04535 10/17/2009 Bradley Edwards Paul Cassell Two ideas regarding strategy Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04488-04490 07/18/2009 Bradley Edwards Paul Cassell Taking the 5th Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01362 09/11/2009 Elizabeth Villar Bradley Edwards Getting the forensic aspect off Work product; attorney/client privilege;
the ground —epstein's asset irrelevant and not reasonably calculated to lead
transfers to the discovery of the admissible evidence;
protected by privacy rights
04481-04487 08/18/2009 Paul Cassell Bradley Edwards Epstein Subpoena Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05465-05467 06/26/2009 Wayne Black Bradley Edwards Subpoenas for trial Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05470 07/11/2009 Bradley Edwards Wayne Black Flight Logs Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05496.05497 08/10/2009 Bradley Edwards Alfredo Phone Numbers Work product; attorney/client privilege;
145
EFTA00602979
Privilege Log— Dated 2-23-2011
Farmer. Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Rodriguez irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05501 07/21/2009 Wayne Black Bradley Edwards 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
05524.05533 07/23/2009 Wayne Black Bradley Edwards Addresses for people involved in Work product; attorney/client privilege;
the case irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05541 07/31/2009 Carolyn Edwards Bradley Edwards All depos in Jane doe's case Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05635 10/22/2009 Pat Diaz Bradley Edwards New developments that require Work product; attorney/client privilege;
your expertise irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights0
146
EFTA00602980
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05640 10/29/2009 Pat Diaz Bradley Edwards New Epstein victim Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05652-05653 04/01/2009 Bradley Edwards Carolyn Edwards personal discussion Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05671 10/22/2009 Bradley Edwards Pat Diaz 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
05696 05/11/2009 Bradley Edwards Wayne Black Phone number for one of the Work product; attorney/client privilege;
other girls on the list of irrelevant and not reasonably calculated to lead
prospective clients to the discovery of the admissible evidence;
protected by privacy rights
05815-05816 04/01/2009 Carolyn Edwards Bradley Edwards Taking the depos of everyone Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05820-05821 07/23/2009 Bradley Edwards Wayne Black Dates for depos of all witnesses Work product; attorney/client privilege;
in the case irrelevant and not reasonably calculated to lead
147
EFTA00602981
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATE DATE IQ FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05824.05825 07/23/2009 Bradley Edwards Wayne Black Paula Heil Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05828-05829 07/23/2009 Bradley Edwards Wayne Black Dates for depos of all witnesses Work product; attorney/client privilege;
in the case irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05833-05835 07/23/2009 Bradley Edwards Wayne Black FBI has original flight logs and Work product; attorney/client privilege;
they interviewed pilots irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05839-05841 07/23/2009 Bradley Edwards Wayne Black Copies of the flight logs Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05869-05870 04/01/2009 Carolyn Edwards Bradley Edwards Personal convo between Brad Work product; attorney/client privilege;
and Mom irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05913-05914 04/01/2009 Carolyn Edwards Bradley Edwards Personal convo between Brad Work product; attorney/client privilege;
and Mom irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
148
EFTA00602982
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05995 04/01/2009 Bradley Edwards Carolyn Edwards Third party subpoenas for Work product; attorney/client privilege;
Tatum/Courtney irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06513-06523 06/15/2009 Bradley Edwards Wayne Black Ghisella Maxwell info Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06699-06701 06/17/2009 Wayne Black Bradley Edwards Epstein litigation Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07079-07089 09/03/2009 Bradley Edwards Pat Diaz Discussion about girls involved in Work product; attorney/client privilege;
the case irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07437-07439 10/19/2009 Paul Cassell Ronald Wise New evidence of Epstein Work product; attorney/client privilege;
Fraudulent transfers + Affidavit irrelevant and not reasonably calculated to lead
from you to the discovery of the admissible evidence;
protected by privacy rights
07936-07958 04/28/2009 Earleen Cote Bradley Edwards Cases against mansion nightclub Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08006-08011 06/03/2009 Bradley Edwards Wayne Black Getting addresses for people for Work product; attorney/client privilege;
us to serve subpoenas irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11186-11187 08/19/2009 Bradley Edwards Bradley Edwards Plaintiffs Witness List Work product; attorney/client privilege;
149
EFTA00602983
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
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 RRA Ken Jenne 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 RRA Steven Jaffe 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 Ken Jenne 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 Scott Rothstein Marc Nurik 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 RRA Jacquie Johnson 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 Shawn Gilbert Bradley Edwards 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 Shawn Gilbert Bradley Edwards 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
EFTA00602984
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
06679-06682 08/26/2009 Bradley Edwards Shawn Gilbert 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 Shawn Gilbert Bradley Edwards 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 Bradley Edwards Pat Diaz 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 Carla Martinez Bradley Edwards 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 RRA Bradley Edwards 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 Wayne Black Bradley Edwards Info on a guy going to victim's 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 Bradley Edwards Wayne Black 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 Bradley Edwards Paul Cassell Epstein affidavit to the reply Work product; attorney/client privilege;
memo irrelevant and not reasonably calculated to lead
151
EFTA00602985
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08406 10/30/2O09 Attorneys at RRA Russell Adler 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 Bradley Edwards Mike Fisten 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 Bradley Edwards Pat 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 RRA Mike Fisten 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 RRA Bradley Edwards 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 RRA Mike Fisten 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 RRA Ken Jenne 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
EFTA00602986
Privilege Loa — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
20085.20091 10/15/2009 Bradley Edwards Mike Fisten 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 10/14/2009 Attorneys at RRA Mike Fisten 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 Bradley Edwards Mike Fisten 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 RRA Ken Jenne 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 Mike Fisten Bradley Edwards 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 Jacquie Johnson Bradley Edwards 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 RRA Bradley Edwards 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
EFTA00602987
Privilege Log — Dated 2-23-2011
Farmer. Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
20193-20200 08/24/2009 Attorneys at RRA Bradley Edwards 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 Jacquie Johnson Mike Fisten 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 Jacquie Johnson Mike Fisten 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 RRA Mike Fisten 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 Bradley Edwards Mike Fisten 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 Bradley Edwards Mike Fisten 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 Pat Bradley Edwards Personal emails regarding Brad's 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 08/24/2O09 Attorneys at RRA Ken Jenne Epstein travel Work product; attorney/client privilege;
irrelevant and not reasonably calculated to lead
154
EFTA00602988
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
RATES DATE 12 FROM DESCRIPTION OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
19959-19961 07/24/2009 Attorneys at RRA Bradley Edwards 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 Bradley Edwards Paul Cassell 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 RRA Bradley Edwards 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 Bradley Edwards Paul Cassell 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 Bradley Edwards Cara Holmes 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 Marc Nurik Bradley Edwards 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 Josh Bradley Edwards 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
EFTA00602989
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
03129.03130 06/09/2009 Josh Bradley Edwards 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
03119.03121 06/09/2009 Bradley Edwards Josh 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
05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal CW Personal information Work product; attorney/client privilege;
Asst. to Jay irrelevant and not reasonably calculated to lead
Howell, Co- to the discovery of the admissible evidence;
Counsel) protected by privacy rights
02593-02594 05/13/2009 T. Edwards (wife) Bradley Edwards Regarding personal information. Privileged document- irrelevant and not
calculated to lead to discovery of admissible
evidence, privacy rights of parties involved,
spouse privilege
18877-18879 09/10/209 Marc Nurik Bradley Edwards Concerning the names of Work product; attorney/client privilege;
potential witnesses and the irrelevant and not reasonably calculated to lead
issuance of subpoena's for them. to the discovery of the admissible evidence;
protected by privacy rights
18344-18347 08/24/2009 Bradley Edwards Mike Fisten Investigative information and Work product; attorney/client privilege;
techniques on the Epstein case irrelevant and not reasonably calculated to lead
are discussed. to the discovery of the admissible evidence;
protected by privacy rights
156
EFTA00602990
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
18339-18340 08/24/2009 Ken Jenne Bradley Edwards Investigative information and Work product; attorney/client privilege;
techniques on the Epstein case irrelevant and not reasonably calculated to lead
are discussed. to the discovery of the admissible evidence;
protected by privacy rights
18341-18343 08/24/2009 Mike Fisten Bradley Edwards Investigative information and Work product; attorney/client privilege;
techniques on the Epstein case irrelevant and not reasonably calculated to lead
are discussed. to the discovery of the admissible evidence;
protected by privacy rights
18853.18854 09/10/2009 Bradley Edwards Jacquie Johnson Concerning the names of Work product; attorney/client privilege;
potential witnesses and the irrelevant and not reasonably calculated to lead
issuance of subpoena's for them. to the discovery of the admissible evidence;
protected by privacy rights
18337-18338 08/03/2009 Bradley Edwards Mike Fisten Investigative information and Work product; attorney/client privilege;
techniques on the Epstein case irrelevant and not reasonably calculated to lead
are discussed. to the discovery of the admissible evidence;
protected by privacy rights
18306 10/16/2009 Pat Ken Jenne List of future depo's in Epstein Work product; attorney/client privilege;
case and names of potential irrelevant and not reasonably calculated to lead
witnesses. to the discovery of the admissible evidence;
protected by privacy rights
18307 10/17/2009 Mike Fisten Bradley Edwards Investigative Discussion re: Work product; attorney/client privilege;
finding of Epstein Assets. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
157
EFTA00602991
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE IQ FROM DESCRIPTION OBJECTION
18308.18309 10/18/2006 Mike Fisten Bradley Edwards Investigative Discussion re: Work product; attorney/client privilege;
finding of Epstein Assets. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18188-18189 09/04/2009 Mike Fisten Bradley Edwards Investigative Discussion re: Work product; attorney/client privilege;
finding of Epstein witnesses and irrelevant and not reasonably calculated to lead
names of potential witnesses. to the discovery of the admissible evidence;
protected by privacy rights
18184.18185 08/26/2009 Mike Fisten Bradley Edwards Investigative Discussion re: Work product; attorney/client privilege;
finding of Epstein witnesses and irrelevant and not reasonably calculated to lead
names of potential witnesses. to the discovery of the admissible evidence;
protected by privacy rights
18186.18187 08/31/2009 Bradley Edwards Jacquie Johnson Discussion of potential witnesses Work product; attorney/client privilege;
and the process of subpoena for irrelevant and not reasonably calculated to lead
depo's. to the discovery of the admissible evidence;
protected by privacy rights
18180.18183 08/24/2009 Bradley Edwards Mike Fisten Investigative Discussion re: Work product; attorney/client privilege;
finding of Epstein witnesses and irrelevant and not reasonably calculated to lead
names of potential witnesses. to the discovery of the admissible evidence;
protected by privacy rights
05256.05257 07/21/2009 Bradley Edwards Wayne Black Investigative Discussion re: Work product; attorney/client privilege;
strategy of case. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
158
EFTA00602992
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05253 08/24/2009 Bradley Edwards Wayne Black Investigative Discussion re: Work product; attorney/client privilege;
strategy of case. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05279.05280 08/24/2009 Bradley Edwards Pat= Investigative Discussion re: Work product; attorney/client privilege;
strategy of case. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05315-05318 07/26/2009 Bradley Edwards Wayne Black Investigative Discussion re: Work product; attorney/client privilege;
strategy of case. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05209-05211 06/26/2009 Bradley Edwards Wayne Black Investigative Discussion re: Work product; attorney/client privilege;
strategy of case. irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
159
EFTA00602993