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Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 32 of 35 Log Privilege Doc 1D Email Sent Date__|Email From Email To CC Address Subject Matter [Type of Privilege |Action Page Count _| Type Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Jane Doe No. 102 v. Jeffrey [Epstein (“Epstein case”), Case No. 09-80656-CIV-Marra/Johnson (Southern District of Florida). Documents withheld pursuant to the privileges asserted included communications from Ms. Virginia Giuffre, Bob —_| Virginia Giuffre, Bob |Giuffre to the attorneys listed seeking legal advice related to the Josefsberg, Katherine W. |Josefsberg, Katherine W. Epstein case, communications from the attorneys to Ms. Giuffre Ezell, Amy Ederi, other _|Ezell, Amy Ederi, other giving legal advice or giving attorney mental impressions related Podhurst attorneys, Podhurst attorneys, Legal to the Epstein case, communications sending or attaching |AC Privilege and Approx. 1.3K Legal Assistants, and —_| Assistants, and Professionals attorney work product related to the Epstein case, and/or Work docs Emails, letters, and _ Professionals retained by |retained by attorneys to aid communications sending or attaching client revisions to Product/joint overlapping other communications Jattorneys to aid inthe _|in the rendition of legal attorney work product related to the Epstein case, and Jdefense/commo with other 128 | from 2009- Present _|rendition of legal advice_Jadvice communications re evidence. ninterest Withheld cases Email chain with Giuffre and McCawley seeking information to 129 6/10/2015 Virginia Giuffre robiejennag@y7mail.com assist with attorney advice. [Attorney Client _|withheld 2 msg Letter from Virginia Giuffre to David Boies conveying requested |AC Privilege and 130 information to assist in providing legal advice. Work Product __|withheld 26 pdf Ismccawley@BSFLLP.com,brad@pa {thtojustice.com,robiejennag@y7m. |AC Privilege and 131 4/30/2015 Brittany Henderson leperez@BSFLLP.com jail.com |Communication re VRS registrations |Work Product. Withheld 1 msg Smccawley@BSFLLP.com,brad@pa thtojustice.com,garvin@lclark.edu, |Email chain with McCawley, Edwards, Garvin, Henderson, |AC Privilege and 132 4/29/2015 Andres Ortiz bh699@nova.edu robiejennag@y7mail.com |Giuffre and BSF staff re legal advice re VRS communications. __|Work Product _|Withheld 1 msg Ismccawley@BSFLLP.com,brad@pa thtojustice.com,garvin@lclark.edu, |AC Privilege and 133 4/29/2015 brittany henderson laortiz@BSFLLP.com robiejennag@y7mail.com [Communication re legal advice re VRS communications. Work Product —_|Withheld 1 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016