EFTA01079793

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA01079793 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged Objection Abbreviation General Objections -- Inadequate Privilege Log Inadequate Log Failure to Prove Factual Underpinnings of Privilege Claim No Factual Underpinnings Waiver of Confidentiality Waiver Government's Fiduciary Duty to Crime Victims Bars Privilege Fiduciary Duty Communications Facilitating Crime-Fraud-Misconduct Not Covered Crime-Fraud-Misconduct Factual Materials Not Covered Factual Materials Documents Not Prepared in Anticipation of CVRA Litigation Not in Anticipation of Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Ordinary Government Communication Attorney-Client Relationship Not Established No Attorney-Client Relationship Deliberative Process Objections - Privilege Not Properly Invoked Improper Invocation Final Decision Exempted from Privilege Final Decision Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need Investigative Privilege - Privilege Not Properly Invoked Improper Invocation Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need Work Product Doctrine No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Claims Against Public Prosecutor Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Attorney Conduct at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) Court Authorized Under 6(e)(3)(E) The Court Has Inherent Power to Release Grand Jury Materials Court Inherent Power to Release Victims Have Properly Petitioned for the Release of Grand Jury Proper Victim's Petition The CVRA Gives the Court Authority to Release Grand Jury Materials CVRA-authorized release Page 1 of 69 EFTA01079794 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 3 of 70 Grand Jury Materials Can Be Severed from Other Materials Material Severable The Privacy Rights of Other Victims Government Redaction Can Resolve Privacy Concerns Redaction No Assertion of Privacy Rights by Other Victims No Assertion by Victims Privacy Act The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Court-Compelled Disclosure Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings; P-000001 SUBPOENAS" containing correspondence Work Product Fiduciary Duty; Not in Anticipation of thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor; P-000039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Overriding Need Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings; P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper P-000549 related to enforcement of same, documents subject to investigative Invocation; Overriding Need; Claims Against produced in response to some subpoenas; privilege Public Prosecutor; Attorney Conduct at Issue; and attorney (Villafafia) handwritten notes Also contains documents Factual Materials; Court Authorized Under subject to privacy rights of 6(e)(3)(E); Court Inherent Power to Release; victims who are not Proper Victim's Petition; CVRA-authorized parties to this litigation release; Material Severable; Redaction; No Assertion by Victims; Overriding Need Page 2 of 69 EFTA01079795 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 4 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "Ritz Compact Flash 6(e) Inadequate Log; No Factual Underpinnings; P-000550 SW" containing copies of a sealed search Contains information Fiduciary Duty; Factual Materials; Not in thru warrant application, warrant, and subject to investigative Anticipation of Litigation; Improper P-000621 supporting documents privilege Invocation; Overriding Need; Factual Also contains information Materials; Court Authorized Under 6(e)(3)(E); subject to privacy rights of Court Inherent Power to Release; Proper victims who are not Victim's Petition; CVRA-authorized release; parties to this litigation Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "PNY Technologies 6(e) Inadequate Log; No Factual Underpinnings; P-000622 Compact Flash SW" containing copies of a Contains information Fiduciary Duty; Factual Materials; Not in thru sealed search warrant application, warrant, subject to investigative Anticipation of Litigation; Improper P-000693 and supporting documents privilege Invocation; Overriding Need; Factual Also contains information Materials; Court Authorized Under 6(e)(3)(E); subject to privacy rights of Court Inherent Power to Release; Proper victims who are not Victim's Petition; CVRA-authorized release; parties to this litigation Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "JE Corporations" Work Product Inadequate Log; No Factual Underpinnings; P-000694 containing attorney research on Epstein- Contains information Fiduciary Duty; Not in Anticipation of thru owned corporations and prior litigation subject to investigative Litigation; Improper Invocation; Overriding P-000781 privilege Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Overriding Need Box #1 File folder entitled "Capital One" 6(e) Inadequate Log; No Factual Underpinnings; P-000782 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court thru Authorized Under 6(e)(3)(E); Court Inherent P-000803 Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 3 of 69 EFTA01079796 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "DTG 6(e) Inadequate Log; No Factual Underpinnings; P-000804 Operations/Dollar Rent-a-Car" containing Contains documents and Fiduciary Duty; Factual Materials; Not in thru subpoena and responsive documents information subject to Anticipation of Litigation; Improper P-000854 investigative privilege Invocation; Overriding Need; Factual Also contains documents Materials; Court Authorized Under 6(e)(3)(E); and information subject to Court Inherent Power to Release; Proper privacy rights of victims Victim's Petition; CVRA-authorized release; who are not parties to this Material Severable; Redaction; No Assertion litigation by Victims Box #1 File folder entitled "JP Morgan Chase" 6(e) Inadequate Log; No Factual Underpinnings; P-000855 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of thru responsive documents information subject to Litigation; Improper Invocation; Overriding P-000937 investigative privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled 'Washington Mutual" 6(e) Inadequate Log; No Factual Underpinnings; P-000938 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of thru responsive documents information subject to Litigation; Improper Invocation; Overriding P-000947 investigative privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled "Computer Search &" Work Product Inadequate Log; No Factual Underpinnings; P-000948 containing legal research on computer Attorney-Client Fiduciary Duty; Factual Materials; Not in thru search and handwritten notes on indictment Contains information Anticipation of Litigation; Ordinary P-000982 preparation subject to investigative Government Communication; No Attorney- privilege. Also contains Client Relationship; Improper Invocation; information subject to Overriding Need; Claims Against Public privacy rights of victims Prosecutor; Attorney Conduct at Issue; who are not parties to this Redaction; No Assertion by Victims litigation Page 4 of 69 EFTA01079797 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 6 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "Attorney Notes from Work product Inadequate Log; No Factual Underpinnings; P-000983 Document Review" containing typed and 6(e) Fiduciary Duty; Factual Materials; Not in thru handwritten attorney (Villafafia) notes, Contains information Anticipation of Litigation; Improper P-001007 target letters, correspondence re grand jury subject to investigative Invocation; Overriding Need; Claims Against subpoena privilege. Also contains Public Prosecutor; Attorney Conduct at Issue; information subject to Factual Materials; Court Authorized Under privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release; who are not parties to this Proper Victim's Petition; CVRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "Notes from Fed Ex Work Product Inadequate Log; No Factual Underpinnings; P-001008 Records" containing handwritten and typed 6(e) Fiduciary Duty; Factual Materials; Not in thru attorney (Villafafia) notes and screen shots Contains information Anticipation of Litigation; Improper P-001056 of FedEx subpoena response electronic file subject to investigative Invocation; Overriding Need; Claims Against privilege. Also contains Public Prosecutor; Attorney Conduct at Issue; information subject to Factual Materials; Court Authorized Under privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release; who are not parties to this Proper Victim's Petition; CVRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "Colonial Bank 6(e) Inadequate Log; No Factual Underpinnings; P-001057 Records" containing records received in Contains information Fiduciary Duty; Not in Anticipation of thru response to grand jury subpoena subject to investigative Litigation; Improper Invocation; Overriding P-001959 privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 5 of 69 EFTA01079798 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 7 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "OLY Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings; P-001960 Vol 2: OLY-51 THROUGH" containing Contains information Fiduciary Duty; Factual Materials; Not in Thru subpoenas numbered OLY-51 through subject to investigative Anticipation of Litigation; Improper P-002089 OLY-81 with related correspondence privilege. Also contains Invocation; Overriding Need; Factual information subject to Materials; Court Authorized Under 6(e)(3)(E); privacy rights of victims Court Inherent Power to Release; Proper who are not parties to this Victim's Petition; CVRA-authorized release; litigation Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled - Epstein Corporate 6(e) Inadequate Log; No Factual Underpinnings; P-002090 Records: OLY-51, OLY-52, OLY-53, Contains information and Fiduciary Duty; Not in Anticipation of Thru OLY-54" containing subpoenas, records documents subject to Litigation; Improper Invocation; Overriding P-002169 received in response to subpoenas, and investigative privilege Need; Factual Materials; Court Authorized related correspondence Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled "Colonial Bank" 6(e) Inadequate Log; No Factual Underpinnings; P-002170 containing subpoenas, correspondence Contains information and Fiduciary Duty; Not in Anticipation of Thru related to subpoenas, records received in documents subject to Litigation; Improper Invocation; Overriding P-002246 response to subpoenas investigative privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled "JEGE & Hyperion 6(e) Inadequate Log; No Factual Underpinnings; P-002247 from Goldberger OLY-46 & OLY-47" Contains information and Fiduciary Duty; Not in Anticipation of Thru containing documents received in response documents subject to Litigation; Improper Invocation; Overriding P-002265 to subpoenas investigative privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 6 of 69 EFTA01079799 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings; P-002266 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue; investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under typed notes, of individuals listed as and documents subject to 6(e)(3)(E); Court Inherent Power to Release; "Additional victims" privacy rights of victims Proper Victim's Petition; CVRA-authorized who are not parties to this release; Material Severable litigation Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings; P-002387 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002769 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue; investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under typed notes, relevant pieces of grand jury and documents subject to 6(e)(3)(E); Court Inherent Power to Release; materials, telephone records/flight records privacy rights of victims Proper Victim's Petition; CVRA-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and litigation Assertion by Victims related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Em lo ees, Misc. Witnesses Page 7 of 69 EFTA01079800 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 9 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings; P-002770 witness/victim list with identifying 6(e) Fiduciary Duty; Factual Materials; Not in Thru information, sexual activity summary, Contains information and Anticipation of Litigation; Improper P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against (Villafafia) handwritten notes, 302s, investigative privilege. Public Prosecutor; Attorney Conduct at Issue; portions of state investigative file, attorney Also contains information Redaction; No Assertion by Victims (Villafafia) typed notes, relevant pieces of and documents subject to grand jury materials, telephone privacy rights of victims records/flight records analysis charts, who are not parties to this victim/witness photographs, DAVID litigation records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings; P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in Thru telephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper P-003545 a number of victim/witnesses documents subject to Invocation; Overriding Need; Claims Against , an investigative privilege. Public Prosecutor; Attorney Conduct at Issue; Also contains information Factual Materials; Court Authorized Under and documents subject to 6(e)(3)(E); Court Inherent Power to Release; privacy rights of victims Proper Victim's Petition; CVRA-authorized who are not parties to this release; Material Severable; Redaction; No litigation Assertion by Victims Page 8 of 69 EFTA01079801 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 10 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 FBI Reports of March 2008 interviews of Work product Inadequate Log; No Factual Underpinnings; P-003546 additional witness/victim located in New 6(e) Fiduciary Duty; Factual Materials; Not in Thru York Contains information and Anticipation of Litigation; Improper P-003552 documents subject to Invocation; Overriding Need; Claims Against investigative privilege. Public Prosecutor; Attorney Conduct at Issue; Also contains information Factual Materials; Court Authorized Under and documents subject to 6(e)(3)(E); Court Inherent Power to Release; privacy rights of victims Proper Victim's Petition; CVRA-authorized who are not parties to this release; Material Severable; Redaction; No litigation Assertion by Victims Box #1 Printout of filenames from Federal Express Work product Inadequate Log; No Factual Underpinnings; P-003553 subpoena response with Attorney notations 6(e) Fiduciary Duty; Not in Anticipation of Thru Litigation; Claims Against Public Prosecutor; P-003555B Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 Document entitled "Identified Numbers" Work product Inadequate Log; No Factual Underpinnings; P-003556 with accompanying handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of Thru list compiled from grand jury materials and Contains information Litigation; Improper Invocation; Overriding P-003562 attorney analysis of records subject to investigative Need; Claims Against Public Prosecutor; privilege Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 9 of 69 EFTA01079802 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 11 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 Folder entitled "Flight Manifests" 6(e) Inadequate Log; No Factual Underpinnings; P-003563 containing manifests received pursuant to Contains information and Fiduciary Duty; Not in Anticipation of Thru grand jury subpoena documents subject to Litigation; Improper Invocation; Overriding P-003629 investigative privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled "Recent Attorney Work product Inadequate Log; No Factual Underpinnings; P-003630 Notes" containing handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of Thru (Villafafia) notes regarding document Investigative privilege Litigation; Improper Invocation; Overriding P-003633 review and case strategy Deliberative process Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 File folder bearing victim name containing Work product Inadequate Log; No Factual Underpinnings; P-003634 FBI interview report from May 2008, Attorney-client privilege Fiduciary Duty; Factual Materials; Not in Thru telephone activity report with attorney 6(e) Anticipation of Litigation; Ordinary P-003646 (Villafanafia) handwritten notes, related Investigative privilege Government Communication; No Attorney- grand jury material Also contains information Client Relationship; Improper Invocation; and documents subject to Overriding Need; Claims Against Public privacy rights of victims Prosecutor; Attorney Conduct at Issue; Factual who are not parties to this Materials; Court Authorized Under 6(e)(3)(E); litigation Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 10 of 69 EFTA01079803 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #I File folder entitled "Summary of Sexual Work product Inadequate Log; No Factual Underpinnings; P-003647 Activity" containing chart bearing 6(e) Fiduciary Duty; Factual Materials; Not in Thru handwritten title "Sexual Activity — Investigative privilege Anticipation of Litigation; Improper P-003651 Summary" with meta-analysis of Deliberative process Invocation; Overriding Need; Claims Against information, sorted by name of each Also contains information Public Prosecutor; Attorney Conduct at Issue; victim/witness, including name and and documents subject to Factual Materials; Court Authorized Under identifying information of each privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release; victim/witness who are not parties to this Proper Victim's Petition; CVRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "Victim Civil Suits" Not privileged. N/A P-003652 Produced to counsel for Thru Petitioners P-003663 Box #1 File folder entitled "Research it JE Work product Inadequate Log; No Factual Underpinnings; P-003664 Websites" containing attorney research Fiduciary Duty; Not in Anticipation of Thru Litigation; Claims Against Public Prosecutor; P-003678 Overriding Need; Attorney Conduct at Issue Box #1 File folder entitled "Serene Cano (N.Y. Work product Inadequate Log; No Factual Underpinnings; P-003679 AUSA)" containing attorney (Villafafia) Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-003680 Overriding Need; Attorney Conduct at Issue Box #1 File folder entitled "Dr. Anna Salter" Work product Inadequate Log; No Factual Underpinnings; P-003681 containing attorney (Villafafia) memo to Investigative privilege Fiduciary Duty; Not in Anticipation of Thru expert witness and handwritten attorney Litigation; Improper Invocation; Overriding P-003687 notes Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 11 of 69 EFTA01079804 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 13 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "IR G[] Interview" Work product Inadequate Log; No Factual Underpinnings; P-003688 containing attorney handwritten notes of Investigative privilege Fiduciary Duty; Factual Materials; Not in Thru interview, and attorney handwritten notes Also contains information Anticipation of Litigation; Improper P-003693 regarding potential charges subject to privacy rights of Invocation; Overriding Need; Claims Against victims who are not Public Prosecutor; Attorney Conduct at Issue; parties to this litigation Redaction; No Assertion by Victims Box #1 File folder entitled "Research re Travel for Work product Inadequate Log; No Factual Underpinnings; P-003694 Prostitution" containing attorney 6(e) Fiduciary Duty; Factual Materials; Not in Thru (VillafaiIa) handwritten notes regarding Investigative privilege Anticipation of Litigation; Improper P-003711 grand jury presentation, chart entitled Also contains information Invocation; Overriding Need; Claims Against "Brought to Epstein's House" with and documents subject to Public Prosecutor; Attorney Conduct at Issue; handwritten notes, Message Pad meta- privacy rights of victims Factual Materials; Court Authorized Under analysis chart, summary of evidence who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; related to one victim/witness, and relevant litigation Proper Victim's Petition; CVRA-authorized grand jury information release; Material Severable; Redaction; No Assertion by Victims Box #1 Empty file folder bearing name of Investigative privilege N/A P-003712 victim/witness Also contains information subject to privacy rights of victim who is not a party to this litigation Box #1 File folder entitled "T[] M[]" containing 6(e) Inadequate Log; No Factual Underpinnings; P-003713 grand jury subpoenas, motion and order to Documents under seal Fiduciary Duty; Factual Materials; Court Thru compel testimony, and correspondence pursuant to court order Authorized Under 6(e)(3)(E); Court Inherent P-003746 regarding same Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 File folder entitled 6(e) Inadequate Log; No Factual Underpinnings; P-003747 containing subpoena an correspondence Fiduciary Duty; Factual Materials; Court Thru regarding same Authorized Under 6(e)(3)(E); Court Inherent P-003751 Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 12 of 69 EFTA01079805 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "PBPD Investigative 6(e) Inadequate Log; No Factual Underpinnings; P-003752 File" obtained via subpoena Investigative privilege Fiduciary Duty; Factual Materials; Not in Thru Also contains information Anticipation of Litigation; Improper P-004295 and documents subject to Invocation; Overriding Need; Factual privacy rights of victims Materials; Court Authorized Under 6(e)(3)(E); who are not parties to this Court Inherent Power to Release; Proper litigation Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings; P-004296 containing meta-analysis chart showing 6(e) Fiduciary Duty; Factual Materials; Not in Thru telephone calls, travel, and grand jury Investigative privilege Anticipation of Litigation; Improper P-004350 materials relevant to possible charges Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled Work product Inadequate Log; No Factual Underpinnings; P-004351 Documents 53909- Fiduciary Duty; Not in Anticipation of Thru attorney research related to bias issue Litigation; Claims Against Public Prosecutor; P-004381 Overriding Need; Attorney Conduct at Issue Box #1 File Folder entitled "FEDEX" containing 6(e) Inadequate Log; No Factual Underpinnings; P-004382 documents obtained via subpoena Investigative privilege Fiduciary Duty; Not in Anticipation of Thru Litigation; Improper Invocation; Overriding P-004478 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 13 of 69 EFTA01079806 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 15 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File Folder entitled "State of Delaware 6(e) Inadequate Log No Factual Underpinnings; P-004479 Records" containing documents obtained Investigative privilege Fiduciary Duty; Not in Anticipation of Thru in preparation for indictment Work product Litigation; Improper Invocation; Overriding P-004551 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 File folder entitled "Jet Blue Records" 6(e) Inadequate Log; No Factual Underpinnings; P-004552 containing documents obtained via Work product Fiduciary Duty; Factual Materials; Not in Thru subpoena Investigative privilege Anticipation of Litigation; Improper P-004555 Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege Inadequate Log; No Factual Underpinnings; P-004556 RECORDS" containing FDLE records on Work product Fiduciary Duty; Not in Anticipation of Thru targets and witnesses obtained at attorney Litigation; Improper Invocation; Overriding P-004560 request Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 Filed folder entitled "JANUSZ Work product Inadequate Log; No Factual Underpinnings; P-004561 BANASIAK" containing attorney Investigative privilege Fiduciary Duty; Not in Anticipation of Thru (Villafafia) handwritten notes of interview Litigation; Improper Invocation; Overriding P-004565 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 14 of 69 EFTA01079807 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 16 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "JANUSZ BANASIAK 6(e) Inadequate Log; No Factual Underpinnings; P-004566 RECORDS 23-0001 THROUGH 23-" Work product Fiduciary Duty; Factual Materials; Not in Thru containing documents obtained via Investigative privilege Anticipation of Litigation; Improper P-004716 subpoena Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "IGOR ZINOVIEV" Work product Inadequate Log; No Factual Underpinnings; P-004717 containing attorney research regarding Investigative privilege Fiduciary Duty; Not in Anticipation of Thru witness Litigation; Improper Invocation; Overriding P-004722 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 File folder entitled "BEAR STEARNS Work Product Inadequate Log; No Factual Underpinnings; P-004723 RESEARCH" containing attorney research Investigative privilege Fiduciary Duty; Not in Anticipation of Thru regarding potential witness and subpoena Litigation; Improper Invocation; Overriding P-004725 recipient Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 File folder entitled "LAWSUITS Work Product Inadequate Log; No Factual Underpinnings; P-004726 INVOLVING EPSTEIN CORP'S" Investigative privilege Fiduciary Duty; Not in Anticipation of Thru containing attorney research regarding Litigation; Improper Invocation; Overriding P-004819 Epstein's past personal and business Need; Claims Against Public Prosecutor; litigative practices Attorney Conduct at Issue Box #1 Filed folder entitled "SEC RECORDS" Work Product Inadequate Log; No Factual Underpinnings; P-004820 containing attorney research regarding Investigative privilege Fiduciary Duty; Not in Anticipation of Thru Epstein financial relationships Litigation; Improper Invocation; Overriding P-004959 Need; Claims Against Public Prosecutor; Attorne Conduct at Issue Page 15 of 69 EFTA01079808 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 17 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "Message Pads" Work Product Inadequate Log; No Factual Underpinnings; P-004960 containing selected items from evidence 6(e) Fiduciary Duty; Factual Materials; Not in Thru obtained via subpoena Investigative privilege Anticipation of Litigation; Improper P-005059 Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder bearing name of victim/witness Work Product Inadequate Log; No Factual Underpinnings; P-005060 containing correspondence with counsel 6(e) Fiduciary Duty; Factual Materials; Not in Thru for victim/witness, attorney witness outline Investigative privilege Anticipation of Litigation; Improper P-005081 with attorney handwritten notes, attorney Also contains information Invocation; Overriding Need; Claims Against handwritten notes regarding witness and documents subject to Public Prosecutor; Attorney Conduct at Issue; reports and case preparation privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "New York Trip" Work product Inadequate Log; No Factual Underpinnings; P-005082 containing attorney notes re witness Investigative privilege Fiduciary Duty; Not in Anticipation of Thru interview Litigation; Improper Invocation; Overriding P-005083 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue P-005084 thru P-005107 are non N/A responsive documents and have been removed Page 16 of 69 EFTA01079809 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 18 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "ANNA SALTER" Work product Inadequate Log; Fiduciary Duty; Factual P-005108 containing attorney research on select Investigative privilege Materials; Not in Anticipation of Litigation; Thru expert, use of experts at trials in child Improper Invocation; Overriding Need; Claims P-005193 exploitation cases, and additional research Against Public Prosecutor; Attorney Conduct materials on offenders and victims at Issue Box #1 File folder entitled "Extra Copies" Work product Inadequate Log; No Factual Underpinnings; P-005194 containing meta-analysis chart and 302's of 6(e) i Fiduciary Duty; Factual Materials; Not in Thru victim/witnesses used in preparing Investigative privilege Anticipation of Litigation; Improper P-005300 indictment package Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "JUAN ALESSI 6(e) Inadequate Log; No Factual Underpinnings; P-005301 STATEMENT" containing transcript Investigative privilege Fiduciary Duty; Not in Anticipation of Thru obtained via subpoena Litigation; Improper Invocation; Overriding P-005331 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled "KEN LANNING" Work product Inadequate Log; No Factual Underpinnings; P-005332 containing attorney research on select Investigative privilege Fiduciary Duty; Not in Anticipation of Thru expert, including attorney handwritten Litigation; Improper Invocation; Overriding P-005341 notes Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 17 of 69 EFTA01079810 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 19 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "Info re Planes" 6(e) Inadequate Log; No Factual Underpinnings; P-005342 containing correspondence regarding Investigative privilege Fiduciary Duty; Improper Invocation; Thru subpoenas and documents received in Overriding Need; Factual Materials; Court P-005387 response to subpoenas Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 File folder entitled "Police Reports & PC Work product Inadequate Log; No Factual Underpinnings; P-005388 Affidavit" containing portions of police 6(e) Fiduciary Duty; Factual Materials; Not in Thru reports with attorney notes, related phone Investigative privilege Anticipation of Litigation; Improper P-005442 records, a list entitled "Victims" with Also contains information Invocation; Overriding Need; Claims Against identifying information and attorney and documents subject to Public Prosecutor; Attorney Conduct at Issue; handwritten notes, photographs and privacy rights of victims Factual Materials; Court Authorized Under DAVID information, and additional who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; attorney research regarding Epstein sexual litigation Proper Victim's Petition; CVRA-authorized activity release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "[Victim name] 6(e) Inadequate Log; No Factual Underpinnings; P-005443 Transcript of Interview & GJ Transcript" Investigative privilege Fiduciary Duty; Factual Materials; Not in Thru Also contains information Anticipation of Litigation; Improper P-005496 and documents subject to Invocation; Overriding Need; Factual privacy rights of victims Materials; Court Authorized Under 6(e)(3)(E); who are not parties to this Court Inherent Power to Release; Proper litigation Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled "Bear Stearns Subpoena 6(e) Inadequate Log; No Factual Underpinnings; P-005497 Resp." containing material received in Investigative privilege Fiduciary Duty; Not in Anticipation of Thru response to subpoena Litigation; Improper Invocation; Overriding P-005556 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 18 of 69 EFTA01079811 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 20 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 U.S. Attorney's Office Criminal Case File Work product Inadequate Log; No Factual Underpinnings; P-005557 Jacket containing file opening documents, Deliberative process Fiduciary Duty; Not in Anticipation of Thru expert witness payment documents Litigation; Improper Invocation; Overriding P-005576 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 U.S. Attorney's Office Asset Forfeiture Work product Inadequate Log; No Factual Underpinnings; P-005578 Case File Jacket containing file opening Deliberative process Fiduciary Duty; Not in Anticipation of Thru and file closing documents Litigation; Improper Invocation; Overriding P-005583 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 File folder entitled "6001 Immunity 6(e) Inadequate Log; No Factual Underpinnings; P-005584 Request" containing internal memoranda Work product and Fiduciary Duty; Not in Anticipation of Thru seeking witness immunity and deliberative process (as to Litigation; Improper Invocation; Overriding P-005606 correspondence with counsel for witness internal memoranda) Need; Claims Against Public Prosecutor; regarding same Investigative privilege Attorney Conduct at Issue; Factual Materials; Also contains information Court Authorized Under 6(e)(3)(E); Court and documents subject to Inherent Power to Release; Proper Victim's privacy rights of victims Petition; CVRA-authorized release; Material who are not parties to this Severable; Redaction; No Assertion by litigation Victims Box #2 File folder entitled "MASTER PHONE Work product Inadequate Log; No Factual Underpinnings; P-005607 RECORDS" containing meta-analysis of 6(e) Fiduciary Duty; Factual Materials; Not in Thru all phone, travel, and grand jury data for all Investigative privilege Anticipation of Litigation; Improper P-005914 victim/witnesses for indictment preparation Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 19 of 69 EFTA01079812 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 21 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings; P-005915 containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that Investigative privilege Anticipation of Litigation; Improper P-005977 victim/witness for indictment preparation Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings; P-005978 containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that Investigative privilege Anticipation of Litigation; Improper P-006050 victim/witness for indictment preparation Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings; P-006051 containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that Investigative privilege Anticipation of Litigation; Improper P-006065 victim/witness for indictment preparation Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 20 of 69 EFTA01079813 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 22 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "JANE DOE #4" Work product Inadequate Log; No Factual Underpinnings; P-006066 containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that Investigative privilege Anticipation of Litigation; Improper P-006220 victim/witness for indictment preparation Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled 'JANE DOE #12" Work product Inadequate Log; No Factual Underpinnings; P-006221 containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that Investigative privilege Anticipation of Litigation; Improper P-006222 victim/witness for indictment preparation Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "CORRECTED Work product Inadequate Log; No Factual Underpinnings; P-006223 PHONE RECORDS 5/31/07" containing 6(e) Fiduciary Duty; Factual Materials; Not in Thru meta-analysis of all phone, travel, and Investigative privilege Anticipation of Litigation; Improper P-006522 grand jury data related to all Also contains information Invocation; Overriding Need; Claims Against victims/witnesses for indictment and documents subject to Public Prosecutor; Attorney Conduct at Issue; preparation privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 21 of 69 EFTA01079814 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 23 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "[Victim Name] Phone Work product Inadequate Log; No Factual Underpinnings; P-006523 Records" containing telephone records 6(e) Fiduciary Duty; Factual Materials; Not in Thru received in response to subpoena Investigative privilege Anticipation of Litigation; Improper P-006802 Also contains information Invocation; Overriding Need; Claims Against and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "Lists of Identified Work product Inadequate Log; No Factual Underpinnings; P-006803 Phone Numbers" containing charts of 6(e) Fiduciary Duty; Factual Materials; Not in Thru information culled from grand jury Investigative privilege Anticipation of Litigation; Improper P-006860 materials, interviews, and other Also contains information Invocation; Overriding Need; Claims Against investigation, with attorney handwritten and documents subject to Public Prosecutor; Attorney Conduct at Issue; notes, and information to issue follow-up privacy rights of victims Factual Materials; Court Authorized Under grand jury subpoena who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "EPSTE Work product Inadequate Log; No Factual Underpinnings; P-006861 CELL PHONE RECORDS" 6(e) Fiduciary Duty; Factual Materials; Not in Thru documents received via subpoena with Investigative privilege Anticipation of Litigation; Improper P-007785 attorney handwritten notes and Also contains information Invocation; Overriding Need; Claims Against highlighting and documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 22 of 69 EFTA01079815 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 24 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 Folder entitled "OLY GRAND JURY Work product Inadequate Log; No Factual Underpinnings; P-007786 LOG: OLY-01 THROUGH OLY-50" 6(e) Fiduciary Duty; Factual Materials; Not in Thru containing subpoenas, correspondence Investigative privilege Anticipation of Litigation; Improper P-008120 regarding same, 6(e) letters, attorney Also contains information Invocation; Overriding Need; Claims Against handwritten notes regarding records and documents subject to Public Prosecutor; Attorney Conduct at Issue; received in response to subpoenas privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 Handwritten flight logs received in 6(e) Inadequate Log; No Factual Underpinnings; P-008121 response to subpoena Investigative privilege Fiduciary Duty; Not in Anticipation of Thru Litigation; Improper Invocation; Overriding P-008139 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #2 Grand jury presentation folder containing Work product Inadequate Log; No Factual Underpinnings; P-008140 attorney handwritten notes, typed outline 6(e) Fiduciary Duty; Factual Materials; Not in Thru with additional handwritten notes, Investigative privilege Anticipation of Litigation; Improper P-008298 complete indictment package dated Also contains information Invocation; Overriding Need; Claims Against 2/19/2008, victim list with identifying and documents subject to Public Prosecutor; Attorney Conduct at Issue; information, photographs, and summary of privacy rights of victims Factual Materials; Court Authorized Under activity who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 23 of 69 EFTA01079816 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 25 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "FINAL P-008299 AGREEMENTS" containing subfolder N/A Thru entitled "Agrmts Filed in State Court" (P- P-008363 008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non- Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez- Acosta letter (P-008328-P-008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanchez Ltr" containing unredacted copies of that letter (P-008344-P-008363 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 1 I th Ci • Box #2 File folder entitled Immunity 6(e) Inadequate Log; No Factual Underpinnings; P-008364 Request" containing i emoranda, Work Product Fiduciary Duty; Not in Anticipation of Thru Justice Department documentation, and Deliberative Process Litigation; Improper Invocation; Overriding P-008382 subpoena regarding immunity request Investigative privilege Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 24 of 69 EFTA01079817 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 26 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder containing March 18, 2008 Work product Inadequate Log; No Factual Underpinnings; P-008383 grand jury presentation materials, including 6(e) Fiduciary Duty; Factual Materials; Not in Thru "Operation Leap Year Revised Indictment Investigative privilege Anticipation of Litigation; Improper P-008516 Summary Chart (by victim)," grand jury Deliberative process Invocation; Overriding Need; Claims Against materials, draft indictments, victim Also contains information Public Prosecutor; Attorney Conduct at Issue; reference list, grand jury subpoena log and documents subject to Factual Materials; Court Authorized Under privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release; who are not parties to this Proper Victim's Petition; CVRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #2 6/25/2007 Letter from Gerald Lefcourt to P-008517 Jeffrey Sloman and Andrew Lourie Thru [pursuant to Court's Order, not being N/A P-008535 withheld as privileged — will be produced to opposing counsel upon lift of stay by I I th Circuit] Box #2 Handwritten attorney notes to prepare for Work product Inadequate Log; No Factual Underpinnings; P-008536 interview of Jane Doe #2 Investigative Privilege Fiduciary Duty; Factual Materials; Not in Thru Contains information Anticipation of Litigation; Improper P-008542 subject to privacy rights of Invocation; Overriding Need; Claims Against victims who are not Public Prosecutor; Attorney Conduct at Issue; arties to this suit Redaction; No Assertion b Victims Box #2 Handwritten attorney notes regarding May Work product Inadequate Log; No Factual Underpinnings; P-008543 8, 2007 grand jury presentation 6(e) Fiduciary Duty; Factual Materials; Not in Thru Investigative privilege Anticipation of Litigation; Improper P-008549 Contains information Invocation; Overriding Need; Claims Against subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 25 of 69 EFTA01079818 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 27 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Most Recent Work product Inadequate Log; No Factual Underpinnings; P-008550 Indictment & Good Cases" containing draft 6(e) Fiduciary Duty; Factual Materials; Not in Thru indictment and legal research Investigative privilege Anticipation of Litigation; Improper P-008615 Deliberative process Invocation; Overriding Need; Claims Against Contains information Public Prosecutor; Attorney Conduct at Issue; subject to privacy rights of Factual Materials; Court Authorized Under victims who are not 6(e)(3)(E); Court Inherent Power to Release; parties to this suit Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "FBI Summary Charts" Work product Inadequate Log; No Factual Underpinnings; P-008616 containing chart prepared at direction of Attorney-Client Privilege Fiduciary Duty; Factual Materials; Not in Thru AUSA, containing victim names, 6(e) Anticipation of Litigation; Ordinary P-008686 identifying information, summary of Investigative privilege Government Communication; No Attorney- activity, and other information relevant to Contains information Client Relationship; Improper Invocation; indictment subject to privacy rights of Overriding Need; Claims Against Public victims who are not Prosecutor; Attorney Conduct at Issue; Factual parties to this suit Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable ; Redaction; No Assertion by Victims Box #2 File folder entitled "[Victim name]llane Work product Inadequate Log; No Factual Underpinnings; P-008687 Doe #4" containing phone records and 6(e) Fiduciary Duty; Factual Materials; Not in Thru meta-analysis of all phone, travel, and Investigative privilege Anticipation of Litigation; Improper P-008776 grand jury data related to that Contains information and Invocation; Overriding Need; Claims Against victim/witness for indictment preparation documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims Factual Materials; Court Authorized Under who are not parties to this 6(e)(3)(E); Court Inherent Power to Release; suit Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 26 of 69 EFTA01079819 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 28 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "[Victim name]llane Work product Inadequate Log; No Factual Underpinnings; P-008777 Doe #5" containing handwritten notes and 6(e) Fiduciary Duty; Factual Materials; Not in Thru meta-analysis of all phone, travel, and Investigative privilege Anticipation of Litigation; Improper P-008808 grand jury data related to that Contains information Invocation; Overriding Need; Claims Against victim/witness for indictment preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "[Victim namej/Jane Work product Inadequate Log; No Factual Underpinnings; P-008809 Doe #6" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-008847 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "[Victim name]llane Work product Inadequate Log; No Factual Underpinnings; P-008848 Doe #7" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-008862 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 27 of 69 EFTA01079820 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 29 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings; P-008863 Doe #8" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-008890 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "Certified Copy of State P-008891 Case" containing certified copy of Epstein Thru state criminal cases and change of plea N/A P-009103 transcript [not being withheld as privileged — copy provided to opposing counsel] Box #2 File folder entitled "Meeting Timeline" Work product Inadequate Log; No Factual Underpinnings; P-009104 containing Villafafla typed notes Deliberative process Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru summarizing meetings with opposing in Anticipation of Litigation; Improper P-009111 counsel prepared at request of R. Invocation; Overriding Need; Claims Against Alexander Acosta, with handwritten Public Prosecutor; Attorney Conduct at Issue correction and typed guideline estimate Box #2 11/26/2008 Email from Roy Black to A. P-009112 Marie Villafatia and Karen Atkinson re N/A Thru Jeffrey Epstein (work release) P-009113 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit] Page 28 of 69 EFTA01079821 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 7/3/2008 Email from A. Marie Villafafia to P-009114 Col. M. Gauger at PBSO re Epstein work N/A Thru release with attachment [not being P-009115 withheld as privileged — produced to opposing counsel] Box #2 12/6/2007 Letter from Jeffrey Sloman to P-009116 Jay P. Lefkowitz re Jeffrey Epstein (victim N/A Thru notification) [pursuant to Court's Order, P-009125 not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11di Circuit]) Box #2 File folder entitled "[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings; P-009126 Doe #9" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009134 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings; P-009135 Doe #13" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009141 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 29 of 69 EFTA01079822 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 31 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "[Victim name]llane Work product Inadequate Log; No Factual Underpinnings; P-009141A Doe #12" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009141C that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 ' der entitled Work product Inadequate Log; No Factual Underpinnings; P-009142 containing meta-anaysis o a 6(e) Fiduciary Duty; Factual Materials; Not in Thru p one, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009152 that individual for indictment preparation Contains information Invocation; Overriding Need; Claims Against subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled Work product Inadequate Log; No Factual Underpinnings; P-009153 containing meta-an ysis o a p one, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that Investigative privilege Anticipation of Litigation; Improper P-009156 individual for indictment preparation Contains information Invocation; Overriding Need; Claims Against subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 30 of 69 EFTA01079823 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 32 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "[Victim name]llane Work product Inadequate Log; No Factual Underpinnings; P-009157 Doe #1" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009208 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings; P-009209 Doe #2" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009213 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled "[Victim name]llane Work product Inadequate Log; No Factual Underpinnings; P-009214 Doe #3" containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to Investigative privilege Anticipation of Litigation; Improper P-009271 that victim/witness for indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 31 of 69 EFTA01079824 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 33 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Purpose of Travel Work product Inadequate Log; No Factual Underpinnings; P-009272 Cases" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009354 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Interstate Commerce Work product Inadequate Log; No Factual Underpinnings; P-009355 Cases" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009403 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Attorney Conflict Work product Inadequate Log; No Factual Underpinnings; P-009404 Research" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009536 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Mann Act/Travel to Work product Inadequate Log; No Factual Underpinnings; P-009537 Have Sex w/Minor" containing attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-009574 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Travel Act" containing Work Product Inadequate Log; No Factual Underpinnings; P-009575 attorney research and handwritten notes Fiduciary Duty; Not in Anticipation of Thru Litigation; Claims Against Public Prosecutor; P-009603 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Florida Work Product Inadequate Log; No Factual Underpinnings; P-009604 Prostitution/Lewdness Statutes" containing Fiduciary Duty; Not in Anticipation of Thru attorney research and handwritten notes Litigation; Claims Against Public Prosecutor; P-009711 Overriding Need; Attorney Conduct at Issue Box #2 Booklet entitled "Attorney General P-009712 Guidelines for Victim and Witness N/A Thru Assistance" [not being withheld as P-009819 privileged — produced to opposing counsel] Box #2 File folder entitled "Corporate Liability Work Product Inadequate Log; No Factual Underpinnings; 1)-009820 Rsrch" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009965 Overriding Need; Attorney Conduct at Issue Page 32 of 69 EFTA01079825 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 34 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Research re Work Product Inadequate Log; No Factual Underpinnings; P-009966 Knowledge of Age Unnecessary" 6(e) Fiduciary Duty; Not in Anticipation of Thru containing attorney research and Litigation; Claims Against Public Prosecutor; P-010096 handwritten notes and copy of grand jury Overriding Need; Attorney Conduct at Issue; subpoena Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 File folder entitled "Money Laundering" Work Product Inadequate Log; No Factual Underpinnings; P-010097 containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010276 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "1960 & Work Product Inadequate Log; No Factual Underpinnings; P-010277 Aiding/Abetting" containing attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-010394 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "18 USC § 2255 Cases" Work Product Inadequate Log; No Factual Underpinnings; P-010395 containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010488 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Research re Overt Acts Work Product Inadequate Log; No Factual Underpinnings; P-010489 & Witness Testimony" containing attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-010509 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Extradition" Work Product Inadequate Log; No Factual Underpinnings; P-010510 containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010525 Overriding Need; Attorney Conduct at Issue Page 33 of 69 EFTA01079826 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 35 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Rsrch re Crime Work Product Inadequate Log; No Factual Underpinnings; P-010526 Victims Rights" containing attorney Deliberative Process Fiduciary Duty; Crime-Fraud-Misconduct; Thru research, handwritten notes, draft victim Crime-Fraud-Misconduct; Factual Materials; P-010641 notification letter, and draft Not in Anticipation of Litigation; Improper correspondence to Jay Lefkowitz Invocation; Overriding Need; Claims Against (Also contains a November 28, 2007 letter Public Prosecutor; Attorney Conduct at Issue from Kenneth Starr to Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P- 010528 thru P-010530 and P-010556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by Ilth Circuit) Box #2 File folder entitled "Immunity" containing Work Product Inadequate Log; No Factual Underpinnings; P-010642 attorney research on granting immunity to Fiduciary Duty; Not in Anticipation of Thru witnesses Litigation; Claims Against Public Prosecutor; P-01650 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Research re G.J. Work Product Inadequate Log; No Factual Underpinnings; P-010651 Transcript" containing attorney research 6(e) Fiduciary Duty; Not in Anticipation of Thru and draft pleadings re compelling Deliberative process Litigation; Improper Invocation; Overriding P-010659 production of grand jury transcript with Need; Claims Against Public Prosecutor; subpoena Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 34 of 69 EFTA01079827 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 36 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Research it GJ Work Product Inadequate Log; No Factual Underpinnings; P-010660 Transcript" containing grand jury 6(e) Fiduciary Duty; Not in Anticipation of Thru subpoena, 6(e) letters, attorney research Litigation; Claims Against Public Prosecutor; P-010757 and correspondence related to subpoena Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 File folder entitled "Original Proposed Work Product Inadequate Log; No Factual Underpinnings; P-010758 Ind." containing draft indictment 6(e) Fiduciary Duty; Not in Anticipation of Thru Deliberative process Litigation; Improper Invocation; Overriding P-010793 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 File folder entitled "Epstein" containing Work Product Inadequate Log; No Factual Underpinnings; P-010794 sample indictments and attorney research Fiduciary Duty; Not in Anticipation of Thru it potential charges with attorney notes Litigation; Claims Against Public Prosecutor; P-010829 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "1591 & Money Work Product Inadequate Log; No Factual Underpinnings; P-010830 Laundering" containing attorney research Fiduciary Duty; Not in Anticipation of Thru and handwritten notes Litigation; Claims Against Public Prosecutor; P-010853 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "18 USC 2425" Work Product Inadequate Log; No Factual Underpinnings; P-010854 containing attorney research and Fiduciary Duty; Not in Anticipation of Thm handwritten notes Litigation; Claims Against Public Prosecutor; P-010876 Overriding Need; Attorney Conduct at Issue Page 35 of 69 EFTA01079828 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 37 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Knowledge of Age" Work Product Inadequate Log; No Factual Underpinnings; P-010877 containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010920 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "2423(b) Work Product Inadequate Log; No Factual Underpinnings; P-010921 Constitutionality and Purpose of Travel" Fiduciary Duty; Not in Anticipation of Thru containing attorney research and Litigation; Claims Against Public Prosecutor; P-011049 handwritten notes Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Mistake not a Work Product Inadequate Log; No Factual Underpinnings; P-011050 Defense" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011212 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Research re Work Product Inadequate Log; No Factual Underpinnings; P-011213 `Pandering"' containing attorney research Fiduciary Duty; Not in Anticipation of Thru and handwritten notes Litigation; Claims Against Public Prosecutor; P-011237 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Research re Grand Work Product Inadequate Log; No Factual Underpinnings; P-011238 Jury Instructions" containing attorney 6(e) Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-011319 Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 File folder entitled "Telephone = Facility Work Product Inadequate Log; No Factual Underpinnings; P-011320 of Commerce" containing attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-011361 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Def of Prostitution" Work Product Inadequate Log; No Factual Underpinnings; P-011362 containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011374 Overriding Need; Attorney Conduct at Issue Page 36 of 69 EFTA01079829 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 38 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "Relevant Florida Work Product Inadequate Log; No Factual Underpinnings; P-011375 Statutes" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011456 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled "Unit of Prosecution Work Product Inadequate Log; No Factual Underpinnings; P-011457 Research" containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011626 Overriding Need; Attorney Conduct at Issue Box #3 File folder entitled "Attorney Notes" Work Product Inadequate Log; No Factual Underpinnings; P-011627 containing attorney handwritten and typed Fiduciary Duty; Not in Anticipation of Thru notes Litigation; Claims Against Public Prosecutor; P-011662 Overriding Need; Attorney Conduct at Issue Box #3 File folder entitled "Drafts" containing 6(e) Inadequate Log; No Factual Underpinnings; P-011663 draft indictments with attorney handwritten Work Product Fiduciary Duty; Factual Materials; Not in Thru notes, draft internal memoranda, relevant Deliberative Process Anticipation of Litigation; Improper P-0I 1698 and witness interview reports and grand jury Investigative Privilege Invocation; Overriding Need; Claims Against P-012189 thru material and attorney handwritten notes Contains information Public Prosecutor; Attorney Conduct at Issue; P-012361 subject to privacy rights of Factual Materials; Court Authorized Under (gap was victims who are not 6(e)(3)(E); Court Inherent Power to Release; scanning parties to this Proper Victim's Petition; CVRA-authorized error) release; Material Severable; Redaction; No Assertion by Victims Box #3 File folder entitled "6/9/09 Signed 6(e) Inadequate Log; No Factual Underpinnings; P-011699 Indictment" containing signed indictment Work product Fiduciary Duty; Not in Anticipation of Thru package dated 6/9/2009 with corrections Deliberative process Litigation; Improper Invocation; Overriding P-011777 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 37 of 69 EFTA01079830 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 39 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 File folder entitled "6/12/09 Victim Notif. Work product Inadequate Log; No Factual Underpinnings; P-011778 Log" containing chart with victim contact Fiduciary Duty; Crime-Fraud-Misconduct; Thru information and attorney notes regarding Factual Materials; Not in Anticipation of P-011788 dates and type of contacts Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #3 File folder entitled "Breach Memo" Work product Inadequate Log; No Factual Underpinnings; P-011789 containing memorandum analyzing breach Deliberative process Fiduciary Duty; Not in Anticipation of Thru of Non-Prosecution Agreement with Litigation; Improper Invocation; Overriding P-011879 attachments Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials Box #3 File folder entitled "Overt Act Lists" Work product Inadequate Log; No Factual Underpinnings; P-011880 containing handwritten notes cross- Attorney-client privilege Fiduciary Duty; Factual Materials; Not in Thru checking all overt acts alleged in draft Deliberative process Anticipation of Litigation; Ordinary P-011922 indictment by victim and typed overt act 6(e) Government Communication; No Attorney- summary charts for indictment preparation Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 38 of 69 EFTA01079831 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 40 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in Anticipation of Litigation; P-011966 Sanchez to Andrew Lourie with Attorney-Client Privilege Ordinary Government Communication; No handwritten attorney (Lourie) Attorney-Client Relationship; Improper notes; Invocation; Overriding Need; Claims Against ■ 6/25/2007 letter from Gerald Public Prosecutor; Attorney Conduct at Issue; Lefcourt to Jeffrey Sloman, Matt Factual Materials; Court Authorized Under Menchal, Andrew Lourie, and 6(e)(3)(E); Court Inherent Power to Release; Marie Villafafia with handwritten Proper Victim's Petition; CVRA-authorized attorney (Villafafia) notes; release; Material Severable ■ 6/25/2007 email from Andrew Lourie to Matt Menchel and Marie Villafafia entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney (Villafafia) notes regarding main themes raised by Epstein counsel Box #3 Composition book entitled "Operation Work product Inadequate Log; No Factual Underpinnings; P-011967 Leap Year" containing attorney Investigative privilege Fiduciary Duty; Factual Materials; Not in Thru handwritten notes regarding investigation 6(e) Anticipation of Litigation; Improper P-012016 and case strategy Contains information Invocation; Overriding Need; Claims Against subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this litigation 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 39 of 69 EFTA01079832 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 41 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Motion of Jeffrey Epstein to Intervene and 6(e) Inadequate Log; No Factual Underpinnings; P-012017 to Quash Grand Jury Subpoenas and Fiduciary Duty; Factual Materials; Court Thru Incorporated Memorandum of Law Authorized Under 6(e)(3)(E); Court Inherent P-012055 Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 Affidavit of Roy Black, Esq. in Support of 6(e) Inadequate Log; No Factual Underpinnings; P-012056 Motion of Jeffrey Epstein to Intervene and i Fiduciary Duty; Factual Materials; Court Thru to Quash Grand Jury Subpoenas Authorized Under 6(e)(3)(E); Court Inherent P-012088 Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 United States' Response to Motion of 6(e) Inadequate Log; No Factual Underpinnings; P-012089 Jeffrey Epstein to Intervene and to Quash Fiduciary Duty; Factual Materials; Court Thru Grand Jury Subpoenas and Cross-Motion Authorized Under 6(e)(3)(E); Court Inherent P-012129 to Compel Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 Declaration of Joseph Recarey 6(e) Inadequate Log; No Factual Underpinnings; P-012130 Fiduciary Duty Thru P-012150 Box #3 Ex Pane Declaration Number One in 6(e) Inadequate Log; No Factual Underpinnings; P-012151 Support of United States' Response to Investigative Privilege Fiduciary Duty; Factual Materials; Not in Thru Motion to Quash Subpoenas Also contains information Anticipation of Litigation; Improper P-012167 subject to privacy rights of Invocation; Overriding Need; Factual victims who are not Materials; Court Authorized Under 6(e)(3)(E); parties to this litigation Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 40 of 69 EFTA01079833 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 42 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Ex Parte Declaration Number Two in 6(e) Inadequate Log; No Factual Underpinnings; P-012168 Support of United States' Response to Investigative Privilege Fiduciary Duty; Not in Anticipation of Thru Motion to Quash Subpoenas Litigation; Improper Invocation; Overriding P-012170 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #3 Supplement to Ex Parte Declaration 6(e) Inadequate Log; No Factual Underpinnings; P-012171 Number One in Support of United States' Investigative Privilege Fiduciary Duty; Factual Materials; Not in Thru Response to Motion to Quash Subpoenas Also contains information Anticipation of Litigation; Improper P-012173 subject to privacy rights of Invocation; Overriding Need; Factual victims who are not Materials; Court Authorized Under 6(e)(3)(E); parties to this litigation Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 Draft of September 2009 letter from Marie Work Product Inadequate Log; No Factual Underpinnings; P-012174 Villafafia to Roy Black regarding breach of Attorney-Client Privilege Fiduciary Duty; Not in Anticipation of Thru Non Prosecution Agreement with Deliberative Process Litigation; Ordinary Government P-012176 handwritten attorney (Villafafia) notes Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #3 Undated handwritten attorney (Villafafia) Work Product Inadequate Log; No Factual Underpinnings; P-012177 notes regarding negotiations and Attorney-Client Privilege Fiduciary Duty; Not in Anticipation of Thru allegations Deliberative Process Litigation; Ordinary Government P-012178 Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 41 of 69 EFTA01079834 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 43 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 File Folder entitled "FBI G.J. Log" 6(e) Inadequate Log; No Factual Underpinnings; P-012179 containing copy of FBI grand jury Work Product Fiduciary Duty; Factual Materials; Not in Thru subpoena log with attorney (Villafafia) Investigative Privilege Anticipation of Litigation; Improper P-012188 handwritten notes Also contains information Invocation; Overriding Need; Claims Against subject to privacy rights of Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this litigation 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 File folder entitled "Key Documents" 6(e) Inadequate Log; No Factual Underpinnings; P-012362 containing correspondence between AUSA Work Product Fiduciary Duty; Factual Materials; Not in Thru and case agent regarding indictment prep Attorney-Client privilege Anticipation of Litigation; Ordinary P-012451 questions, victim identification Investigative Privilege Government Communication; No Attorney- information, corrections to draft Also contains information Client Relationship; Improper Invocation; indictment, indictment preparation subject to privacy rights of Overriding Need; Claims Against Public timeline, key grand jury material victims who are not Prosecutor; Attorney Conduct at Issue; Factual parties to this litigation Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 File folder entitled "Victim List" Work Product Inadequate Log; No Factual Underpinnings; P-012451 containing list of victims with dates of Investigative Privilege Fiduciary Duty; Factual Materials; Not in Thru birth and age information Also contains information Anticipation of Litigation; Improper P-012452 subject to privacy rights of Invocation; Overriding Need; Claims Against victims who are not Public Prosecutor; Attorney Conduct at Issue; parties to this litigation Redaction; No Assertion by Victims Page 42 of 69 EFTA01079835 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 44 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Complete indictment package marked Work-product Inadequate Log; No Factual Underpinnings; P-012453 "Originals 12/12/07" Deliberative process Fiduciary Duty; Factual Materials; Not in Thru 6(e) Anticipation of Litigation; Improper P-012623 Also contains documents Invocation; Overriding Need; Factual subject to investigative Materials; Court Authorized Under 6(e)(3)(E); privilege Court Inherent Power to Release; Proper Also contains documents Victim's Petition; CVRA-authorized release; subject to privacy rights of Material Severable; Redaction; No Assertion victims who are not by Victims parties to this litigation Box #3 Folder entitled "(Victims) Additional Investigative Privilege Inadequate Log; No Factual Underpinnings; P-012624 302's" containing reports of interviews Also contains documents Fiduciary Duty; Factual Materials; Not in Thru conducted in June 2007, October 2007, and subject to privacy rights of Anticipation of Litigation; Improper P-012653 March 2008. victims who are not Invocation; Overriding Need; Redaction; No parties to this litigation Assertion by Victims Box #3 3-ring binder entitled "Child Molesters: A Work-product Inadequate Log; No Factual Underpinnings; P-012654 Behavioral Analysis" with attorney Fiduciary Duty; Overriding Need Thru (Villafafia) handwritten notes P-012864 Box #3 Indictment preparation binder containing: Work Product Inadequate Log; No Factual Underpinnings; P-012865 witness/victim list with identifying Deliberative Process Fiduciary Duty; Factual Materials; Not in Thru information, sexual activity summary, 6(e) Anticipation of Litigation; Improper P-013226 telephone call summary chart, attorney Also contains documents Invocation; Overriding Need; Claims Against (Villafafia) handwritten notes, 302s, subject to investigative Public Prosecutor; Attorney Conduct at Issue; portions of state investigative file, attorney privilege Factual Materials; Court Authorized Under (Villafafia) typed notes, relevant pieces of Also contains documents 6(e)(3)(E); Court Inherent Power to Release; grand jury materials, telephone subject to privacy rights of Proper Victim's Petition; CVRA-authorized records/flight records analysis charts, victims who are not release; Material Severable; Redaction; No victim/witness photographs, DAVID parties to this litigation Assertion by Victims records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Page 43 of 69 EFTA01079836 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 45 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 April 23, 2008 Memo from Jeffrey Sloman Privacy Act Inadequate Log; No Factual Underpinnings; P-013227 to Office of Professional Responsibility re Fiduciary Duty; Crime-Fraud-Misconduct; Self Reporting, Corrected Version of the Factual Materials; Court Compelled previously submitted April 21, 2008 Letter Disclosure; Waiver to OPR Box #3 April 21, 2008 Letter from Jeffrey Sloman Privacy Act Inadequate Log; No Factual Underpinnings; P-013226 to Office of Professional Responsibility re Fiduciary Duty; Court Compelled Disclosure; Thru Self Reporting Factual Materials; Waiver P-013230 Box #3 April 22, 2008 Letter from A. Marie Privacy Act Inadequate Log; No Factual Underpinnings; P-013231 Villafafia to Office of Professional Factual Materials; Fiduciary Duty; Court Thru Responsibility re Self-Report of Allegation Compelled Disclosure; Waiver P-013239 of Conflict of Interest Box #3 April 21, 2008 Letter from Jeffrey Sloman Privacy Act Inadequate Log; No Factual Underpinnings; P-013240 to Office of Professional Responsibility re Fiduciary Duty; Court Compelled Disclosure; Thru Self Reporting with attachments Factual Materials; Waiver P-013247 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013248 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013251 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013252 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013253 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Page 44 of 69 EFTA01079837 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 46 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013254 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013257 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013258 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013259 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Box #3 Email from Richard Sudder, Assistant Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013260 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, to Wifredo Ferrer Attorney-Client Relationship; Waiver P-013262 (U.S. Attorney, SDFL), Robert O'Neill (U.S. Attorney, MDFL), Benjamin Greenberg, (FAUSA, SDFL), and Lee Bentley (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24, 2011. CC's David Margolis (ODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Michelle Tapken (USAEO), James Read (USAEO) Page 45 of 69 EFTA01079838 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 47 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Emails between Richard Sudder, Assistant Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013263 General Counsel, Executive Office for Deliberative Process Not in Anticipation of Litigation; Ordinary Thru United States Attorneys, and Benjamin Work Product Government Communication; No Attorney- P-013271 Greenberg, First Assistant U.S. Attorney, Client Relationship; Improper Invocation; Southern District of Florida, regarding Overriding Need; Claims Against Public recusal of Southern District of Florida, Prosecutor; Attorney Conduct at Issue; Waiver dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey E stein Investi ation Box #3 Emails between Peter Mason, Executive Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013272 Office for United States Attorneys, and Ordinary Government Communication; No Thru Dexter Lee, Southern District of Florida, Attorney-Client Relationship; Factual P-013278 seeking advice regarding office-wide Materials; Waiver recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Suppl. Box #3 8/15/08 Emails between A. Acosta and Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013279 A. Marie Villafafia, R. Senior, D. Lee Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Thru and K. Atkinson re proposed Crime-Fraud-Misconduct; Not in Anticipation P-013280 correspondence to Jay Lefkowitz of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 Handwritten note re Epstein investigation Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; Work Product Fiduciary Duty; Factual Materials; Not in Investigative privilege Anticipation of Litigation; Ordinary Also contains information Government Communication; No Attorney- subject to privacy rights of Client Relationship; Improper Invocation; victims who are not Overriding Need; Claims Against Public Page 46 of 69 EFTA01079839 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 48 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013281 parties to this litigation Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims Suppl. Box #3 7/9/08 Email from A. Marie Villafarla to Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013282 A. Acosta, J. Sloman, K. Atkinson, and Work product Crime-Fraud-Misconduct; Crime-Fraud- Thru FBI re proposed response to Goldberger Deliberative Process Misconduct; Crime-Fraud-Misconduct; Factual P-013283 letter re victim notification Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Suppl. Box #3 7/10/08 Emails between J. Sloman and Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013284 A. Marie Villafaa, K. Atkinson, and FBI Work Product Crime-Fraud-Misconduct; Factual Materials; re proposed response to Goldberger's Deliberative Process Not in Anticipation of Litigation; Ordinary letter e victim notification Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Suppl. Box #3 File folder entitled "8/5/08 AMCV e- Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013285 mail re correct agrmt" containing 8/5/08 Work Product Crime-Fraud-Misconduct; Crime-Fraud- Thru email from A. Marie Villafarla to A. Deliberative Process Misconduct; Not in Anticipation of Litigation; P-013289 Acosta, J. Sloman, R. Senior, K. Ordinary Government Communication; No Atkinson re "Jeffrey Epstein Agreement" Attorney-Client Relationship; Improper discussing 6/24/08 email from A. Marie Invocation; Overriding Need; Claims Against Villafafia to R. Black and J. Goldberger Public Prosecutor; Attorney Conduct at Issue concerning the binding nature of the Agreement Page 47 of 69 EFTA01079840 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 49 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Suppl. Box #3 File folder entitled "8/14/08 E-mail from Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013290 Lefk to AMCV" containing (undated) Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru emails from A. Marie Villafafia to R. in Anticipation of Litigation; Ordinary P-013292 Senior, J. Sloman, A. Acosta, K. Government Communication; No Attorney- Atkinson, D. Lee re draft response to Client Relationship; Claims Against Public 8/14/08 email from J. Leflcowitz Prosecutor; Overriding Need; Attorney regarding "the December 2007 proposal" Conduct at Issue Suppl. Box #3 File folder entitled "8/15/08 AMCV e- Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013293 mail re Agrmt" containing 8/15/08 e- Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Thru mails from A. Marie Villafafia to A. Deliberative Process Factual Materials; Not in Anticipation of P-013299 Acosta, J. Sloman, R. Senior, K. Litigation; Ordinary Government Atkinson, D. Lee re follow up on Communication; No Attorney-Client Agreement and from A. Acosta to Ann Relationship; Improper Invocation; Overriding Marie Villafana on issue of Special Need; Claims Against Public Prosecutor; Master with attached 8/15/08 emails from Attorney Conduct at Issue; Waiver A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreement; 8/15/08 email from J. Lefkowitz to A. Marie Villafana, K. Atkinson, R. Black, M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafafia to J. Leflcowitz, K. Atkinson, R. Black re interpretation of Agreement; email from J. Leflcowitz to A. Marie Villafafia, K. Atkinson re questions re Agreement; email from A. Marie Villafafia to J. Lefkowitz, K. Atkinson re production of Agreement to victims Suppl. Box #3 File folder entitled "8/18/08 Leflcowitz Ltr Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013300 to AMCV" containing A. Marie Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru Villafatia's handwritten draft notes for in Anticipation of Litigation; Ordinary Page 48 of 69 EFTA01079841 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 50 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-0133303 proposed letter to J. Lefkowitz; 5/22/07 e- Work Product Government Communication; No Attorney- mail from A. Lourie to M. Menchel, J. Client Relationship; Claims Against Public Sloman, A. Marie Villafafia re meeting Prosecutor; Overriding Need; Attorney with G. Lefcourt with attached email from Conduct at Issue; Waiver G. Lefcourt re solicitation for meetings Suppl. Box #3 File folder entitled "6/25/07 Lefcourt to Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013304 Sloman & Lourie containing 6/25/07 letter Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru (with handwritten notes by A. Marie in Anticipation of Litigation; Ordinary P-013325 Villafafia) from G. Lefcourt to J. Sloman, Government Communication; No Attorney- M. Menchel, A. Lourie, A. Marie Client Relationship Villafafia addressing reasons for not prosecuting Epstein; handwritten outline by A. Marie Villafafia of possible response to letter Suppl. Box #3 File folder entitled "9/17/07 Villafafia Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013326 Lefkowitz containing 9/17/07 e-mail from Work Product Fiduciary Duty; Not in Anticipation of Thru A. Marie Villafafia to R. Garcia, A. Lourie Litigation; Ordinary Government P-013329 and from R. Garcia to A. Marie Villafafia Communication; No Attorney-Client concerning status of plea negotiations Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 File folder entitled "11/8/07 Lefkowitz Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013330 Sloman" containing 11/8/07 letter from Work Product Fiduciary Duty; Not in Anticipation of Thru J. Lefkowitz re issues arising during Litigation; Ordinary Government P-013333 pendency of matter with attorney Communication; No Attorney-Client handwritten notes Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 File folder entitled "11/13/07 Sloman to Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013334 Lefkowitz (was this sent?)" containing Fiduciary Duty; Not in Anticipation of Thru draft 11/13/07 letter from J. Sloman Litigation; Ordinary Government Page 49 of 69 EFTA01079842 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 51 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013337 responding to J. Leflcowitz's letter Work Product Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 File folder entitled "12/6/07 Sloman to [Not considered N/A P-013338 Lefkowitz" containing 12/5/07 faxed letter privileged. Will be Thru w/ cover sheet from K. Starr and J. produced to opposing 013341 Lefkowitz to A. Acosta counsel upon lifting of stay] Suppl. Box #3 File folder entitled "12/05/07 Starr to Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013342 Acosta" containing drafts of 11/30/07 Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Thru letters from A. Acosta to K. Starr and Deliberative Process Factual Materials; Not in Anticipation of P-013350 from J. Sloman to J. Leflcowitz re Litigation; Ordinary Government performance and victim notification with Communication; No Attorney-Client handwritten notes and edits by A. Marie Relationship; Improper Invocation; Overriding Villafafia Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box #3 File folder entitled "12/21/07 Lefkowitz Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-13351 Acosta" containing handwritten notes by Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru A. Marie Villafafia, 12/21/07 letter in Anticipation of Litigation; Ordinary P-013361 from J. Leflcowitz to A. Acosta re Government Communication; No Attorney- performance of NPA and appeal to Client Relationship; Claims Against Public Washington with attorney handwritten Prosecutor; Overriding Need; Factual notes Materials; Attorney Conduct at Issue Suppl. Box #3 File folder labeled "12/26/07 Lefkowitz Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013362 to Acosta" containing 2 copies of draft Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru letter from A. Acosta to J. Lefkowitz Deliberative Process in Anticipation of Litigation; Ordinary P-013366 (with 12/28/07 fax header) Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box #3 File folder labeled "Draft kr from Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; Page 50 of 69 EFTA01079843 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 52 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013367 Sloman to Lefkowitz re termination" Work Product Fiduciary Duty; Not in Anticipation of Thru containing draft letter dated "April , Litigation; Ordinary Government P-013372 2008" from J. Sloman to J. Lefkowitz Communication; No Attorney-Client concerning the compliance with the Relationship; Claims Against Public Agreement Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 File folder labeled "6/3/08 Sloman Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013373 Submission to the DAG" containing Deliberative Process Fiduciary Duty; Not in Anticipation of Thru 6/3/08 letter from J. Sloman to Mark Work Product Litigation; Ordinary Government P-013503 Filip, Office of the DAG, cc'd to R. Investigative privilege Communication; No Attorney-Client Senior, A. Marie Villafafia, K. Atkinson, Relationship; Improper Invocation; Overriding re Jeffrey Epstein, detailing events Need; Claims Against Public Prosecutor; concerning the Agreement and thereafter Overriding Need; Attorney Conduct at Issue; and with relevant attachments Waiver Suppl. Box #3 File folder labeled "Mtg w/ Ken Starr, Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013504 RAA, JS, Drew" containing handwritten Work Product Fiduciary Duty; Not in Anticipation of Thru notes by A. Marie Villafafia Litigation; Ordinary Government P-013507 Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 File folder labeled "Internal Con." Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013508 containing 11/28/07 e-mails from J. Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Thru Sloman to A. Marie Villafafia re Factual Materials; Not in Anticipation of P-013514 responding to 11/28/07 e-mail from J. Litigation; Ordinary Government Lefkowitz to J. Sloman regarding victim Communication; No Attorney-Client notification with attachments Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Factual Materials; Waiver Suppl. Box #3 Draft 11/30/07 letter from A. Acosta to Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013515 K. Starr cc'd to J. Sloman and A. Marie Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru Villafafia re compliance with Agreement in Anticipation of Litigation; Ordinary Page 51 of 69 EFTA01079844 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 53 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013525 and internal emails from J. Sloman, A. Deliberative Process Government Communication; No Attorney- Acosta, and A. Lourie re items to Client Relationship; Improper Invocation; address in letter Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver; Factual Materials Suppl. Box #3 5/23/07 e-mail from A. Marie Villafatla Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013526 to K. Atkinson re draft proposed internal Work Product Fiduciary Duty; Not in Anticipation of Thru e-mail about handling of case and Deliberative Process Litigation; Ordinary Government P-013527 attached email correspondence between Communication; No Attorney-Client Andrew Lourie and G. Lefcourt Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials Suppl. Box #3 Handwritten notes by A. Marie Villafana Work Product Inadequate Log; No Factual Underpinnings; P-013528 dated 9/21 re telephone conference with Fiduciary Duty; Factual Materials; Not in Thru possible victim representative, conflict Anticipation of Litigation; Claims Against P-013530 check with names and email listed, list of Public Prosecutor; Overriding Need; Attorney names of potential victim representatives, Conduct at Issue P-013532 payment discussion, and guideline Thru calculation, email containing contact info P-013537 for potential victim representative, draft Non Prosecution Agreement dated 9/10/07 4:17 .m Suppl. Box #3 Typed note addressed to "Dear David" re 6(e) Inadequate Log; No Factual Underpinnings; P-013531 response to grand jury subpoena Investigative privilege Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Suppl. Box #3 File folder labeled "Notes Re Post- Work Product Inadequate Log; No Factual Underpinnings; P-013538 Agreement Communications" containing Fiduciary Duty; Not in Anticipation of Thru Litigation; Improper Invocation; Overriding Page 52 of 69 EFTA01079845 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 54 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013553 handwritten notes by A. Marie Villafaila Deliberative Process Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials Suppl. Box #3 File folder labeled "E-mails Re Plea Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; P-013554 Negotiations" containing: Work Product Crime-Fraud-Misconduct; Not in Anticipation Thru Deliberative Process of Litigation; Ordinary Government ■ 11/28/07 e-mail from A. Lourie to Investigative Privilege Communication; No Attorney-Client A. Marie Villafafia, A. Oosterbaan, Relationship; Improper Invocation; Overriding R. Garcia re non-prosecution Need; Claims Against Public Prosecutor; agreement, with attached Attorney Conduct at Issue; Waiver; Final correspondence; Decision ■ 9/19/07 e-mail from A. Marie Villafafia to A. Laurie, R. Garcia, K. Atkinson re negotiating strategy, with attached correspondence; ■ 9/18/07 e-mail from A. Marie Villafafia to A. Acosta, A. Laurie, R.Gar ■ 9/17/07 e-mail from A. Marie Villafafia to A. Acosta re negotiation; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Acosta, A. Laurie, K. Atkinson, J. McMillan re negotiations; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Laurie re negotiation strategy; ■ 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, R. Garcia, A Laurie, K. Atkinson, S. Ball re proposed plea agreement and Information Page 53 of 69 EFTA01079846 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 55 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections ■ 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, A Lourie, R Garcia, K. Atkinson, J. McMillan, S. Ball re plea negotiations ■ 9/13/07 e-mail from A. Marie Villafafia to J. Atkinson, S. Ball, J. McMillan re indictment package; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Oosterbaan re trust agreement with attached correspondence ■ 9/13/07 e-mail from A. Marie Villafafia to A. Oosterbaan re trust agreement ■ 9/13/07 e-mail from A. Marie Villafafia to R. Garcia, J. Sloman re conference call with J. Lefkowitz; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Lourie re plea negotiations with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Lourie re charging strategy with attached correspondence; ■ 9/13/07 e-mail from A. Marie Villafafia to K. Atkinson, S. Ball, J. McMillan re indictment package; ■ 9/13/07 e-mail from A. Marie Villafafia to A. Acosta, J. Sloman, R. Garcia, K. Atkinson, A. Lourie re plea negotiations; Page 54 of 69 EFTA01079847 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 56 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections ■ 9/11/07 e-mail from A. Marie Villafafia to A. Lourie re meeting w/ G. Lefcourt with attached correspondence; ■ 9/11/07 e-mail from A. Marie Villafafia to A. Lourie re revised Agreement with attached correspondence; ■ 9/11/07 e-mail from A. Marie Villafafia to J. Sloman re non- prosecution agreement edits with attached correspondence; ■ 9/11/07 e-mail from A. Marie Villafafia to A. Oosterbaan re status of negotiations with attached correspondence; ■ 9/10/07 e-mail from A. Marie Villafafia to J. Sloman re negotiations; 9/10/07 e-mail from A. Marie Villafafia to J. Sloman, J. McMillan re state grand jury proceedings; ■ 9/17/07 e-mail from A. Acosta to A. Marie Villafafia, R. Garcia, A. Lourie, K. Atkinson, J. McMillan re draft Agreement with attached correspondence; ■ 9/14/07 e-mail from J. Sloman to A. Marie Villafafia, A. Acosta, R. Garcia, A. Lourie, K. Atkinson, S. Ball, re finalizing documents; ■ 9/14/07 e-mail from A. Lourie to A. Marie Villafafia re charging strategy Page 55 of 69 EFTA01079848 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 57 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections with attached correspondence; ■ 9/13/07 e-mail from A. Oosterbaan to A. Marie Villafafia re setting up trust fund; ■ 9/13/07 e-mail from A. Lourie to A. Marie Villafafia re final negotiations with attached correspondence; ■ 9/11/07 e-mail from A. Lourie to A. Marie Villafafia re scheduling a meeting regarding finalizing the agreement with attached correspondence; ■ 9/11/07 e-mail from J. Sloman to A. MarieVillafafia re non-prosecution agree ■ 9/11/07 e-mail from J. Sloman to A. MarieVillafafia re non-prosecution agree ■ 9/11/07 e-mail from A. Oosterbaan to A. Marie Villafafia re negotiations with attached correspondence; ■ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia A. Lourie re negotiation strategy Suppl. Box #3 File folder entitled "0 Target Letter" 6(e) Inadequate Log; No Factual Underpinnings; P-013609 containing copy of signed letter and Investigative Privilege Fiduciary Duty; Not in Anticipation of Thru contact info for counsel for target Litigation; Improper Invocation; Overriding P-013615 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Suppl. Box #3 File folder entitled "Atty Notes re Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013616 Revised Indictment" containing Deliberative Process Fiduciary Duty; Factual Materials; Not in Page 56 of 69 EFTA01079849 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 58 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Thru handwritten notes by A. Marie Villafafia Work Product Anticipation of Litigation; Ordinary P-013621 Investigative Privilege Government Communication; No Attorney- Also contains information Client Relationship; Improper Invocation; subject to privacy rights of Overriding Need; Claims Against Public victims who are not Prosecutor; Attorney Conduct at Issue parties to this litigation Suppl. Box #3 File folder entitled "Research Re Possible Work product Inadequate Log; No Factual Underpinnings; P-013622 Misdemeanors" containing attorney Fiduciary Duty; Not in Anticipation of Thru research Litigation; Claims Against Public Prosecutor; P-013643 Overriding Need; Attorney Conduct at Issue Suppl. Box #3 File folder entitled "Notes Re Plea Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013644 Negotiations" containing 9/17/07 e-mail Work Product Fiduciary Duty; Factual Materials; Not in Thru from A. Marie Villafafia to J. Richards, N. Deliberative Process Anticipation of Litigation; Ordinary P-013653 Kuyrkendall re status update; undated and Investigative privilege Government Communication; No Attorney- typed handwritten notes by A. Marie Also contains information Client Relationship; Improper Invocation; Villafafia re items to be completed on subject to privacy rights of Overriding Need; Claims Against Public case, strength of case, victim interviews, victims who are not Prosecutor; Attorney Conduct at Issue; Waiver summary of evidence, guidelines parties to this litigation calculations Suppl. Box #3 File folder entitled "Plea Agreement Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013654 Drafts" containing several draft plea Work Product Fiduciary Duty; Not in Anticipation of Thru agreements some with handwritten notes Deliberative Process Litigation; Ordinary Government P-013745 by A. Marie Villafafia; copies of draft Communication; No Attorney-Client non-prosecution agreement some with Relationship; Improper Invocation; Overriding handwritten notes by A. Marie Villafafia; Need; Claims Against Public Prosecutor; copy of a draft Information Attorney Conduct at Issue Suppl. Box #3 File folder entitled "Draft Non- Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-0013747 Prosecution Agreements" containing Work Product Fiduciary Duty; Not in Anticipation of Page 57 of 69 EFTA01079850 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 59 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Thru several draft non- prosecution agreements Deliberative Process Litigation; Ordinary Government P-013810 some with handwritten notes by A. Marie Communication; No Attorney-Client Villafaria; plea sheet State Circuit Court; Relationship; Improper Invocation; Overriding copies of draft Information; draft plea Need; Claims Against Public Prosecutor; proffer; draft motion and order to seal; Attorney Conduct at Issue; Factual Materials draft penalty sheet; draft plea agreement Suppl. Box 3 File folder entitled "Information Packet Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013811 Drafts" containing several drafts of Work Product Fiduciary Duty; Not in Anticipation of Thru Informations, and complete draft Deliberative Process Litigation; Ordinary Government P-013833 Information packet Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue 3uppl. Box 3 P- Two pages of filed document, D.E. 62, Atty work-product Inadequate Log; No Factual Underpinnings; 013834 page 2 of 54 and page 6 of 54, Fiduciary Duty; Claims Against Public Through P- containing handwritten attorney notes Prosecutor; Overriding Need; Attorney 013835 Conduct at Issue Suppl. Box 3 Palm Beach Daily News Article, Atty work-product Inadequate Log; No Factual Underpinnings; P-013836 "Attorneys want Jeffrey Epstein Fiduciary Duty; Claims Against Public Thru Agreement Thrown Out," with Prosecutor; Overriding Need; Attorney P-013837 attorney's notes written on margin Conduct at Issue Suppl. Box 3 Letter from Paul Cassell to Wifredo A. Atty work-product Inadequate Log; No Factual Underpinnings; P-013838 Ferrer, December 10, 2010, Subject: Fiduciary Duty; Claims Against Public Thru Request for Investigation of Jeffrey Epstein Prosecutor; Overriding Need; Attorney P-013841 Prosecution, with underlines, written notes, Conduct at Issue and comments by DOJ attorney Suppl. Box 3 Email from Dexterr Lee to Ruth Atty work-product Inadequate Log; No Factual Underpinnings; P-013842 Plagenhoef (OPR), February 25, 2011, Atty-client privilege Fiduciary Duty; Crime-Fraud-Misconduct; 4:31 p.m., Re: request for OPR Factual Materials; Ordinary Government Investigation — Jeffrey Epstein Non- Communication; No Attorney-Client Prosecution Agreement Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Page 58 of 69 EFTA01079851 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 60 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Andrew Lourie, Atty work-product Inadequate Log; No Factual Underpinnings; P-013843 Rolando Garcia, and Karen Atkinson, atty-client privilege Fiduciary Duty; Ordinary Government Thru September 19, 2007, 4:33 p.m., RE: Plea Communication; No Attorney-Client P-013844 Agreement Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Andrew Lourie to Marie Villafana, Atty work-product Inadequate Log; No Factual Underpinnings; P-013845 September 19, 2007, 4:21 p.m., RE: Fiduciary Duty; Claims Against Public Thru Epstein, with internal U.S. Attorney's Prosecutor; Overriding Need; Attorney P-013846 Office e-mails attached Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Andrew Lourie, Atty work-product Inadequate Log; No Factual Underpinnings; P-013847 Rolando Garcia, and Karen Atkinson, Fiduciary Duty; Claims Against Public Thru September 18, 2007, 11:43 a.m., RE: Draft Prosecutor; Overriding Need; Attorney P-013849 Agreements?, with e-mail from Jay Conduct at Issue Waiver Lefkowitz (September 18, 2007, 11:09 a.m.) attached Suppl. Box 3 E-mail, Marie Villafana to Alex Acosta, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013850 Andrew Lourie, Rolando Garcia, Karen Crime-Fraud-Misconduct; Crime-Fraud- Atkinson, and John McMillan, Misconduct; Waiver; Claims Against Public September 18, 2007, 9:31 a.m., RE: Prosecutor; Overriding Need; Attorney Epstein Negotiations Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Rolando Atty work-product Inadequate Log; No Factual Underpinnings; P-013851 Garcia and Andrew Lourie, September Fiduciary Duty; Claims Against Public Thru 17, 2007, 10:35 a.m., RE: Epstein Prosecutor; Overriding Need; Attorney P-013853 [providing update re plea negotiations] Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Andrew Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013854 Oosterbaan, September 13, 2007, 8:10 Claims Against Public Prosecutor; Overriding p.m., RE: Epstein, with e-mail from Need; Attorney Conduct at Issue Andrew Oosterbaan (September 13, 2007, 7:54 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman Atty work-product Inadequate Log; No Factual Underpinnings; Page 59 of 69 EFTA01079852 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 61 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013855 and Andrew Lourie, September 10, Atty-client privilege Fiduciary Duty; Ordinary Government ; 2007, 5:24 p.m., RE: FBI Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Communication; No Attorney-Client Relationship Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013856 September 6, 2007, 5:47 p.m., RE: Epstein, Atty-client privilege Ordinary Government Communication; No Thru with e-mail from Jeff Sloman (September Attorney-Client Relationship; Claims Against P-013857 6, 2007, 5:35 p.m.), attached Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 Email, Marie Villafana to Jeff Sloman, ally work-product No Factual Underpinnings; Fiduciary Duty; P-013858 September 6, 2007, 9:29 a.m., Re: Meeting Claims Against Public Prosecutor; Overriding on Friday Need; Attorney Conduct at Issue Suppl. Box Email, Gerald Lefcourt to Marie [Not considered 3 Villafana, Lilly Ann Sanchez, Roy privileged. Will be N/A P-013859 Black, re: Jeffrey Epstein produced to opposing Through counsel upon lifting of P-013860 stay] Suppl. Box 3 E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013861 Menchel, July 13, 2007, 3:14 p.m., RE: atty-client privilege Fiduciary Duty; Crime-Fraud-Misconduct; Thru Epstein, with e- mail from Menchel (July Ordinary Government Communication; No P-013865 5, 2007, 3:30 p.m.), Villafana to Attorney-Client Relationship; Waiver; Claims Menchel (July 4, 2007, 5:16 p.m.), and Against Public Prosecutor; Overriding Need; Sloman to Villafana (July 3, 2007, 1:47 Attorney Conduct at Issue p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013866 Matthew Menchel, Andrew Lourie, Crime-Fraud-Misconduct; Waiver; Claims Karen Atkinson, and Shawn Ball, July 3, Against Public Prosecutor; Overriding Need; 2007, 6:26 a.m., RE: Epstein Attorney Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013867 Menchel, June 21, 2007, 3:24 p.m., RE: Fiduciary Duty; Crime-Fraud-Misconduct; Thru Meeting Next Week, with e-mails from Waiver; Claims Against Public Prosecutor; Page 60 of 69 EFTA01079853 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 62 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013868 Menchel to Villafana (June 21, 2007, 2:58 Overriding Need; Attorney Conduct at Issue p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013869 Menchel, Jeff Sloman, Andrew Lourie, and Fiduciary Duty; Crime-Fraud-Misconduct; Karen Atkinson, June 18, 2007, 5:04 p.m., Waiver; Claims Against Public Prosecutor; RE: Epstein Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Andrew Lourie to Marie Atty work-product Inadequate Log; No Factual Underpinnings; P-013870 Villafana, May 24, 2007, 9:25 a.m., FW: Fiduciary Duty; Claims Against Public Thru Jeffrey Epstein, with e-mail from Gerald Prosecutor; Overriding Need; Attorney P-013871 Lefcourt to Andrew Lourie (May 23, Conduct at Issue 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail, Andrew Lourie to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013872 Menchel, Jeff Sloman, and Marie Fiduciary Duty; Crime-Fraud-Misconduct; Villafana, May 22, 2007, 3:11 p.m., FW: Waiver; Claims Against Public Prosecutor; Jeffrey Epstein, with e-mail from Overriding Need; Attorney Conduct at Issue Lefcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail Menchel to Villafana and Lourie, Atty work-product Inadequate Log; No Factual Underpinnings; P-013873 May 14, 2007, 10:52 a.m., RE: Fiduciary Duty; Crime-Fraud-Misconduct; Operation Leap Year, with e-mail from Waiver; Claims Against Public Prosecutor; Villafana to Lourie and Menchel (May Overriding Need; Attorney Conduct at Issue 14, 2007, 10:38 a.m.), attached Suppl. Box Inadvertently marked as privileged, will N/A 3 P- be produced 013874 Page 61 of 69 EFTA01079854 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 63 of 70 Bates Ran e Descri lion Privil e(s) Asserted Victims' Objections Through P-013875 Suppl. Box 3 E-mail, Villafana to Lourie,Garcia, and Any work-product Inadequate Log; No Factual Underpinnings; P-013876 Atkinson, September 19, 2007, 4:33 p.m., Fiduciary Duty; Waiver; Claims Against Thru RE: Draft Plea Agreement, with e-mail Public Prosecutor; Overriding Need; Attorney P-013877 from Lefkowitz to Villafana (September Conduct at Issue 19, 2007, 3:44 p.m.), and Lefkowitz to Villafana (September 19, 2007, 3:35 p.m.) attached Suppl. Box 3 E-mail, Lourie to Villafana, September 19, Atty work-product Inadequate Log; No Factual Underpinnings; P-013878 2007, 4:21 p.m., RE: Epstein, with e-mails Fiduciary Duty; Claims Against Public Thru from Villafana to Lourie and Garcia Prosecutor; Overriding Need; Attorney P-013879 (September 19, 2007, 4:13 p.m.), Conduct at Issue Villafana to Lourie and Garcia (September 19, 2007, 4:05 p.m.), and Lourie to Villafana and Garcia (September 19, 2007, 3:50 p.m.), Villafana to Lourie (September 19 2007, 2:36 p.m.), Lourie to Villafana (September 19, 2007, 2:33 p.m.), and Villafana to Lourie and Garcia (September 19, 2007, 2:31 p.m.), attached Suppl. Box 3 E-mail, Villafana to Lourie,Garcia, and Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013880 Atkinson, September 18, 2007, 11:43 Waiver; Claims Against Public Prosecutor; Thru a.m., RE: Draft Agreements?, with e-mails Overriding Need; Attorney Conduct at Issue P-013882 from Villafana to Lourie, Garcia and Atkinson (September 18, 2007, 11:18a.m.), Page 62 of 69 EFTA01079855 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 64 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Suppl. Box 3 E-mail, Villafana to Acosta, Lourie, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013883 Garcia, Atkinson, and McMillan, Crime-Fraud-Misconduct; Waiver; Claims September 18, 2007, 9:31 a.m., RE: Against Public Prosecutor; Overriding Need; Epstein Negotiations Attorney Conduct at Issue Suppl. Box 3 E-mail, Villafana to Garcia and Lourie, Atty work-product Inadequate Log; No Factual Underpinnings; P-013884 September 17, 2007 10:35 a.m., RE: Fiduciary Duty; Waiver; Claims Against Thru Epstein, with e-mail from Garcia Public Prosecutor; Overriding Need; Attorney P-013886 (September 17, 2007, 10:26 a.m.), Conduct at Issue attached Suppl. Box 3 E-mail, Marie Villafana to Andrew Atty work-product Inadequate Log; No Factual Underpinnings; P-013887 Oosterbaan, September 13, 2007, 8:10 Fiduciary Duty; Waiver; Claims Against p.m., RE: Epstein, with e-mail from Public Prosecutor; Overriding Need; Attorney Andrew Oosterbaan (September 13, 2007, Conduct at Issue 7:54 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman Atty work-product Inadequate Log; No Factual Underpinnings; P-013888 and Andrew Lourie, September 10, Atty-client privilege Fiduciary Duty; Ordinary Government 2007, 5:24 p.m., RE: FBI Communication; No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Atty work-product Inadequate Log; No Factual Underpinnings; P-013889 September 6, 2007, 5:47 p.m., RE: Epstein, Atty-client privilege Fiduciary Duty; Ordinary Government Thru with e-mail from Jeff Sloman (September Communication; No Attorney-Client P-013890 6, 2007, 5:35 p.m.), attached Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 Email, Marie Villafana to Jeff Sloman, atty work-product Inadequate Log; No Factual Underpinnings; P-013891 September 6, 2007, 9:29 a.m., Re: Meeting Fiduciary Duty; Claims Against Public on Friday Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box Email, Gerald Lefcourt to Marie [Not considered N/A 3 Villafana, Lilly Ann Sanchez, Roy privileged. Will be Page 63 of 69 EFTA01079856 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 65 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013892 Black, re: Jeffrey Epstein produced to opposing Through counsel upon lifting of P-013893 stay] Suppl. Box 3 E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013894 Menchel, July 13, 2007, 3:14 p.m., RE: atty-client privilege Fiduciary Duty; Crime-Fraud-Misconduct; Thru Epstein, with e- mail from Menchel (July Ordinary Government Communication; No P-013898 5, 2007, 3:30 p.m.), Villafana to Attorney-Client Relationship; Claims Against Menchel (July 4, 2007, 5:16 p.m.), and Public Prosecutor; Overriding Need; Attorney Sloman to Villafana (July 3, 2007, 1:47 Conduct at Issue p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Jeff Sloman, Atty work-product Inadequate Log; No Factual Underpinnings; P-013899 Matthew Menchel, Andrew Lourie, Fiduciary Duty; Crime-Fraud-Misconduct; Karen Atkinson, and Shawn Ball, July 3, Waiver; Claims Against Public Prosecutor; 2007, 6:26 a.m., RE: Epstein Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013900 Menchel, June 21, 2007, 3:24 p.m., RE: Fiduciary Duty; Crime-Fraud-Misconduct; Thru Meeting Next Week, with e-mails from Claims Against Public Prosecutor; Overriding P-013901 Menchel to Villafana (June 21, 2007, 2:58 Need; Attorney Conduct at Issue p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Suppl. Box 3 E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013902 Menchel, Jeff Sloman, Andrew Lourie, and Fiduciary Duty; Crime-Fraud-Misconduct; Karen Atkinson, June 18, 2007, 5:04 p.m., Waiver; Claims Against Public Prosecutor; RE: Epstein Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Andrew Lourie to Marie Atty work-product Inadequate Log; No Factual Underpinnings; P-013903 Villafana, May 24, 2007, 9:25 a.m., FW: Fiduciary Duty; Waiver; Claims Against Thru Jeffrey Epstein, with e-mail from Gerald Public Prosecutor; Overriding Need; Attorney P-013904 Lefcourt to Andrew Lourie (May 23, Conduct at Issue 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Page 64 of 69 EFTA01079857 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 66 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail, Andrew Lourie to Matthew Atty work-product Inadequate Log; No Factual Underpinnings; P-013905 Menchel, Jeff Sloman, and Marie Fiduciary Duty; Crime-Fraud-Misconduct; Villafana, May 22, 2007, 3:11 p.m., FW: Claims Against Public Prosecutor; Overriding Jeffrey Epstein, with e-mail from Need; Attorney Conduct at Issue Lefcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail Menchel to Villafana and Lourie, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013906 May 14, 2007, 10:52 a.m., RE: Crime-Fraud-Misconduct; Claims Against Operation Leap Year, with e-mail from Public Prosecutor; Overriding Need; Attorney Villafana to Lourie and Menchel (May Conduct at Issue 14, 2007, 10:38 a.m.), attached Suppl. Box Inadvertently marked as privileged, will 3 P- be produced N/A 013907 Through P-013908 Suppl. Box 3 Memorandum, Lisa Howard, Assistant Deliberative Process Inadequate Log; No Factual Underpinnings; P-013909 Counsel, U.S. Department of Justice, Privilege; atty work- Fiduciary Duty; Crime-Fraud-Misconduct; Thru Office of Professional Responsibility product Factual Materials; Improper Invocation; Final P-013911 (OPR), to Ruth Plagenhoef, Acting Decision; Waiver; Claims Against Public Associate Counsel, OPR, undated, Prosecutor; Overriding Need; Attorney Subject: Recommendation Conduct at Issue Suppl. Box 3 Memorandum, Lisa Howard, Assistant Deliberative Process Inadequate Log; No Factual Underpinnings; P-013912 Counsel, OPR, to Ruth Plagenhoef, Privilege, atty work- Fiduciary Duty; Crime-Fraud-Misconduct; Thru Acting Associate Counsel, OPR, Subject: product Factual Materials; Improper Invocation; P-013914 Recommendation, with handwritten note Waiver; Final Decision; Claims Against Public dated 5/4/11 Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 Memorandum, Lisa Howard, Assistant Deliberative Process Inadequate Log; No Factual Underpinnings; Page 65 of 69 EFTA01079858 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 67 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013915 Counsel, OPR, to Ruth Plagenhoef, Privilege; atty work- Fiduciary Duty; Crime-Fraud-Misconduct; Thru Acting Associate Counsel, OPR, Subject: product Factual Materials; Improper Invocation; P-013918 Recommendation, with two post-it notes Waiver; Final Decision; Claims Against Public attached with handwritten attorney Prosecutor; Overriding Need; Attorney notations, and handwritten notations, Conduct at Issue underlines, and circled text throughout the body of the two page memorandum Suppl. Box 3 Draft letter, marked "Confidential", from Deliberative Process Inadequate Log; No Factual Underpinnings; P-013919 Robin C. Ashton, Counsel, Office of Privilege Fiduciary Duty; Not in Anticipation of Thru Professional Responsibility to Wifredo A. Attorney Work Product Litigation; Improper Invocation; Overriding P-013921 Ferrer, United States Attorney, with Need; Claims Against Public Prosecutor; handwritten corrections, strikethroughs, Attorney Conduct at Issue; Waiver; Final and added text Decision Suppl. Box 3 Draft Letter, marked "Confidential", from Deliberative Process Inadequate Log; No Factual Underpinnings; P-013922 Robin C. Ashton, to Wifredo A. Ferrer, Privilege Fiduciary Duty; Not in Anticipation of Thru with handwritten corrections Attorney Work Product Litigation; Improper Invocation; Overriding P-013924 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 Draft Letter, from Robin C. Ashton to Deliberative Process Inadequate Log; No Factual Underpinnings; P-013925 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten correction Attorney Work Product Litigation; Improper Invocation; Overriding P-013927 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 Draft Letter, from Robin C. Ashton to Deliberative Process Inadequate Log; No Factual Underpinnings; P-013928 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten corrections Attorney Work Product Litigation; Improper Invocation; Overriding P-013930 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 Draft Letter, from Robin C. Ashton to Deliberative Process Inadequate Log; No Factual Underpinnings; P-013931 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten corrections, circled text, Attorney Work Product Litigation; Improper Invocation; Overriding P-013933 Need; Claims Against Public Prosecutor; Page 66 of 69 EFTA01079859 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 68 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections strikethroughs, and additional text Attorney Conduct at Issue Suppl. Box 3 Draft Letter, marked "Confidential," Deliberative Process Inadequate Log; No Factual Underpinnings; P-013934 from Robin C. Ashton to Wifredo A. Privilege Fiduciary Duty; Not in Anticipation of Thru Ferrer, with handwritten corrections Attorney Work Product Litigation; Improper Invocation; Overriding P-013936 Need; Claims Against Public Prosecutor; Attome Conduct at Issue Suppl. Box 3 Draft Letter, Robin C. Ashton to Deliberative Process Inadequate Log; No Factual Underpinnings; P-013937 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten corrections Attorney Work Product Litigation; Improper Invocation; Overriding P-013939 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Suppl. Box 3 Draft Letter, marked "Confidential: To Be Deliberative Process Inadequate Log; No Factual Underpinnings; P-013940 Opened by Addressee Only," Robin C. Privilege Fiduciary Duty; Not in Anticipation of Thru Ashton to Wifredo A. Ferrer, with Attorney Work Product Litigation; Improper Invocation; Crime-Fraud- P-013942 handwritten corrections Misconduct; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver; Final Decision; Factual Materials Suppl. Box 3 E-mail, Ruth Plagenhoef to Lisa Deliberative Process No Factual Underpinnings; Fiduciary Duty; P-013943 Howard, May 5, 2011, 11:19 a.m., RE: Privilege Not in Anticipation of Litigation; Improper Re-write of Epstein letters for your Attorney Work Product Invocation; Overriding Need; Claims Against review, with e-mail from Lisa Howard to Public Prosecutor; Attorney Conduct at Issue; Ruth Plagenhoef (May 5, 2011, 11:08 Final Decision; Waiver a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Suppl. Box 3 E-mail, Plagenhoef to Howard, May 5, Deliberative Process No Factual Underpinnings; Fiduciary Duty; P-013944 2011, Privilege Improper Invocation; Overriding Need; Final 11:17 a.m., RE: Re-write of Epstein lett Decision; Waiver your review, with e-mail from Howard to Plagenhoef (May 5, 2011, 11:08 Page 67 of 69 EFTA01079860 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 69 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Plagenhoef to Howard (May 5, 2011, 11:01 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41), attached Suppl. Box 3 E-mail, Plagenhoef to Howard, May 4, Deliberative Process No Factual Underpinnings; Fiduciary Duty; P-013945 2011, 5:01 p.m., RE: draft letters in Epstein Privilege Improper Invocation; Overriding Need matter, with e-mail from Howard to Plagenhoef (May 4, 2011, 4:57 p.m.), attached Suppl. Box 3 E-mail, Plagenhoef to Robin C. Ashton, Law Enforcement No Factual Underpinnings; Fiduciary Duty; P-013946 May 4, 2011, 4:08 p.m., RE: FYI on the investigatory record, atty Not in Anticipation of Litigation; Improper Florida matter work product; deliberative Invocation; Overriding Need; Claims Against process privilege Public Prosecutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 E-mail, Paul Cassell to Plagenhoef, May 3, atty work product; law No Factual Underpinnings; Fiduciary Duty; P-013947 2011,12:23 p.m., RE: OPR Inquiry — enforcement Crime-Fraud-Misconduct; Factual Materials; request for information, with post-it note investigatiory Not in Anticipation of Litigation; Improper attached with handwritten attorney notes record Invocation; Overriding Need; Claims Against on telephone call between Plagenhoef and Public Prosecutor; Attorney Conduct at Issue; Howard with Dexter Lee and Marie Factual Materials; Final Decision Villafana Suppl. Box 3 E-mail, Plagenhoef to Howard and Robin atty work-product No Factual Underpinnings; Fiduciary Duty; P-013948 C. Ashton, May 3, 2011, 12:30 p.m., FW: Crime-Fraud-Misconduct; Factual Materials; Thru OPR Inquiry — request for information, Claims Against Public Prosecutor; Overriding P-013951 with attached e-mails. Handwritten Need; Attorney Conduct at Issue attorney notes on margin Suppl. Box 3 E-mail, Dexter Lee to Ruth Plagenhoef, atty work-product; atty- No Factual Underpinnings; Fiduciary Duty; P-013952 March 16, 2011, 10:52 a.m., RE: Referral client privilege Ordinary Government Communication; No Thru of Cassell Request for Investigation, with Attorney-Client Relationship; Claims Against P-013953 e-mail from Paul Cassell to Dexter Lee and Public Prosecutor; Overriding Need; Attorney Marie Villafana (March 15, 2011, 7:21 Conduct at Issue p.m.), attached Suppl. Box 3 E-mail, Plagenhoef to Neil Hurley, OPR, atty work-product, atty- Inadequate Log; No Factual Underpinnings; Page 68 of 69 EFTA01079861 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 70 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections P-013954 December 16, 2010, 10:59 a.m., FW: OPR client privilege Fiduciary Duty; Crime-Fraud-Misconduct; Thru Referral — Allegation of Misconduct — Factual Materials; Ordinary Government P-013955 U.S. Attorney's Office, S.D.Fla., with e- Communication; No Attorney-Client mail from Dexter Lee to Plagenhoef Relationship; Waiver; Claims Against Public (December 16, 2010, 10:22 a.m.), Prosecutor; Overriding Need; Attorney attached. Handwritten attorney notations. Conduct at Issue Suppl. Box 3 Fourteen (14) pages of handwritten any work-product Inadequate Log; No Factual Underpinnings; P-013956 attorney notes on case, telephone Fiduciary Duty; Material Severable; Crime- Thru interviews with DOJ attorneys Fraud-Misconduct; Factual Materials; Claims P-013846 Against Public Prosecutor; Overriding Need; Attorney Conduct At Issue. Page 69 of 69 EFTA01079862