EFTA00208682.pdf

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 EFTA00208682 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 General Objections -- Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Government's Fiduciary Duty to Crime Victims Bars Privilege Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections - Privilege Not Properly Invoked Final Decision Exempted from Privilege Qualified Privilege Overridden By the Victims' Need for the Documents Investigative Privilege - Privilege Not Properly Invoked Qualified Privilege Overridden By the Victims' Need for the Documents Work Product Doctrine No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Qualified Privilege Overridden By the Victims' Need for the Documents Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand Jury Materials Abbreviation Inadequate Log No Factual Underpinnings Waiver Fiduciary Duty Crime-Fraud-Misconduct Factual Materials Not in Anticipation of Litigation Ordinary Government Communication No Attorney-Client Relationship Improper Invocation Final Decision Overriding Need Improper Invocation Overriding Need Claims Against Public Prosecutor Overriding Need Attorney Conduct at Issue Court Authorized Under 6(e)(3)(E) Court Inherent Power to Release Proper Victim's Petition CVRA-authorized release Page 1 of 69 EFTA00208683 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 The Privacy Rights of Other Victims Government Redaction Can Resolve Privacy Concerns No Assertion of Privacy Rights by Other Victims Privacy Act The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Material Severable Redaction No Assertion by Victims 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 subject to privacy rights of victims who are not parties to this litigation Factual 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; Overriding Need Page 2 of 69 EFTA00208684 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 P-000550 thru P-000621 File folder entitled "Ritz Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #1 P-000622 thru P-000693 File folder entitled "PNY Technologies Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein- owned corporations and prior litigation Work Product Contains information subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Overriding Need Box #1 P-000782 thru P-000803 File folder entitled "Capital One" containing subpoena and correspondence 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 3 of 69 EFTA00208685 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 P-000804 thru P-000854 File folder entitled "DTG Operations/Dollar Rent-a-Car" containing subpoena and responsive documents 6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #1 P-000855 thru P-000937 File folder entitled "JP Morgan Chase" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #1 P-000938 thru P-000947 File folder entitled 'Washington Mutual" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #1 P-000948 thru P-000982 File folder entitled "Computer Search &" containing legal research on computer search and handwritten notes on indictment preparation Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual 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; Redaction; No Assertion by Victims Page 4 of 69 EFTA00208686 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 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-001057 thru P-001959 File folder entitled "Colonial Bank Records" containing records received in response to grand jury subpoena 6(e) Contains information subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Page 5 of 69 EFTA00208687 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 P-001960 Thru P-002089 File folder entitled "OLY Grand Jury Log Vol 2: OLY-51 THROUGH" containing subpoenas numbered OLY-51 through OLY-81 with related correspondence 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #1 P-002090 Thru P-002169 File folder entitled - Epstein Corporate Records: OLY-51, OLY-52, OLY-53, OLY-54" containing subpoenas, records received in response to subpoenas, and related correspondence 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #1 P-002170 Thru P-002246 File folder entitled "Colonial Bank" containing subpoenas, correspondence related to subpoenas, records received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #1 P-002247 Thru P-002265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Page 6 of 69 EFTA00208688 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 who are not parties to this litigation Proper Victim's Petition; CVRA-authorized release; Material Severable 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 related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Em lo ees, Misc. Witnesses Page 7 of 69 EFTA00208689 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, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 8 investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims 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 and investigative privilege. Public Prosecutor; Attorney Conduct at Issue; Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Factual 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 Page 8 of 69 EFTA00208690 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 P-003546 Thru P-003552 FBI Reports of March 2008 interviews of additional witness/victim located in New York Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-003553 Thru P-003555B Printout of filenames from Federal Express subpoena response with Attorney notations Work product 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; 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 P-003556 Thru P-003562 Document entitled "Identified Numbers" with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records Work product 6(e) Contains information subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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 9 of 69 EFTA00208691 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 P-003563 Thru P-003629 Folder entitled "Flight Manifests" containing manifests received pursuant to grand jury subpoena 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #1 P-003630 Thru P-003633 File folder entitled "Recent Attorney Notes" containing handwritten attorney (Villafafia) notes regarding document review and case strategy Work product 6(e) Investigative privilege Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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 Box #1 P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual 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; Factual 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 Page 10 of 69 EFTA00208692 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 P-003647 Thru P-003651 File folder entitled "Summary of Sexual Activity" containing chart bearing handwritten title "Sexual Activity — Summary" with meta-analysis of information, sorted by name of each victim/witness, including name and identifying information of each victim/witness Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-003652 Thru P-003663 File folder entitled "Victim Civil Suits" Not privileged. Produced to counsel for Petitioners N/A Box #1 P-003664 Thru P-003678 File folder entitled "Research it JE Websites" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafia) handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafia) memo to expert witness and handwritten attorney notes Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 11 of 69 EFTA00208693 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 P-003688 Thru P-003693 File folder entitled "IR G[] Interview" containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges Work product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims Box #1 P-003694 Thru P-003711 File folder entitled "Research re Travel for Prostitution" containing attorney (Villafaria) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury information Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-003712 Empty file folder bearing name of victim/witness Investigative privilege Also contains information subject to privacy rights of victim who is not a party to this litigation N/A Box #1 P-003713 Thru P-003746 File folder entitled "T[] M[]" containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same 6(e) Documents under seal pursuant to court order Inadequate Log; No Factual Underpinnings; Fiduciary Duty; 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 P-003747 Thru P-003751 File folder entitled ' 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable containing subpoena and correspondence regarding same Page 12 of 69 EFTA00208694 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 P-003752 Thru P-004295 File folder entitled "PBPD Investigative File" obtained via subpoena 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #1 P-004296 Thru P-004350 File folder bearing name of victim/witness containing meta-analysis chart showing telephone calls, travel, and grand jury materials relevant to possible charges Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-004351 Thru P-004381 File folder entitled "Daniel Gonzalez Documents 53909-004" containing attorney research related to bias issue Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-004382 Thru P-004478 File Folder entitled "FEDEX" containing documents obtained via subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; 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 Page 13 of 69 EFTA00208695 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 P-004479 Thru P-004551 File Folder entitled "State of Delaware Records" containing documents obtained in preparation for indictment 6(e) Investigative privilege Work product Inadequate Log No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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 Box #1 P-004552 Thru P-004555 File folder entitled "Jet Blue Records" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-004556 Thru P-004560 File folder entitled "FL EMPLOYMENT RECORDS" containing FDLE records on targets and witnesses obtained at attorney request Investigative privilege Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafia) handwritten notes of interview Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 14 of 69 EFTA00208696 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 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-004717 Thru P-004722 File folder entitled "IGOR ZINOVIEV" containing attorney research regarding witness Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-004723 Thru P-004725 File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-004726 Thru P-004819 File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business litigative practices Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-004820 Thru P-004959 Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorne Conduct at Issue Page 15 of 69 EFTA00208697 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 P-004960 Thru P-005059 File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-005060 Thru P-005081 File folder bearing name of victim/witness containing correspondence with counsel for victim/witness, attorney witness outline with attorney handwritten notes, attorney handwritten notes regarding witness reports and case preparation Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue P-005084 thru P-005107 are non responsive documents and have been removed N/A Page 16 of 69 EFTA00208698 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 P-005108 Thru P-005193 File folder entitled "ANNA SALTER" containing attorney research on select expert, use of experts at trials in child exploitation cases, and additional research materials on offenders and victims Work product Investigative privilege Inadequate Log; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-005194 Thru P-005300 File folder entitled "Extra Copies" containing meta-analysis chart and 302's of victim/witnesses used in preparing indictment package Work product 6(e) i Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-005301 Thru P-005331 File folder entitled "JUAN ALESSI STATEMENT" containing transcript obtained via subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #1 P-005332 Thru P-005341 File folder entitled "KEN LANNING" containing attorney research on select expert, including attorney handwritten notes Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 17 of 69 EFTA00208699 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 P-005342 Thru P-005387 File folder entitled "Info re Planes" containing correspondence regarding subpoenas and documents received in response to subpoenas 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; 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 Box #1 P-005388 Thru P-005442 File folder entitled "Police Reports & PC Affidavit" containing portions of police reports with attorney notes, related phone records, a list entitled "Victims" with identifying information and attorney handwritten notes, photographs and DAVID information, and additional attorney research regarding Epstein sexual activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #1 P-005443 Thru P-005496 File folder entitled "[Victim name] Transcript of Interview & GJ Transcript" 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; 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 Page 18 of 69 EFTA00208700 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 P-005557 Thru P-005576 U.S. Attorney's Office Criminal Case File Jacket containing file opening documents, expert witness payment documents Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-005578 Thru P-005583 U.S. Attorney's Office Asset Forfeiture Case File Jacket containing file opening and file closing documents Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-005584 Thru P-005606 File folder entitled "6001 Immunity Request" containing internal memoranda seeking witness immunity and correspondence with counsel for witness regarding same 6(e) Work product and deliberative process (as to internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-005607 Thru P-005914 File folder entitled "MASTER PHONE RECORDS" containing meta-analysis of all phone, travel, and grand jury data for all victim/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 19 of 69 EFTA00208701 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 P-005915 Thru P-005977 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-005978 Thru P-006050 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-006051 Thru P-006065 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 20 of 69 EFTA00208702 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 P-006066 Thru P-006220 File folder entitled "JANE DOE #4" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-006221 Thru P-006222 File folder entitled 'JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-006223 Thru P-006522 File folder entitled "CORRECTED PHONE RECORDS 5/31/07" containing meta-analysis of all phone, travel, and grand jury data related to all victims/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 21 of 69 EFTA00208703 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 P-006523 Thru P-006802 File folder entitled "[Victim Name] Phone Records" containing telephone records received in response to subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-006803 Thru P-006860 File folder entitled "Lists of Identified Phone Numbers" containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-006861 Thru P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents received via subpoena with attorney handwritten notes and highlighting Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 22 of 69 EFTA00208704 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 P-007786 Thru P-008120 Folder entitled "OLY GRAND JURY LOG: OLY-01 THROUGH OLY-50" containing subpoenas, correspondence regarding same, 6(e) letters, attorney handwritten notes regarding records received in response to subpoenas Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-008121 Thru P-008139 Handwritten flight logs received in response to subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; 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 Box #2 P-008140 Thru P-008298 Grand jury presentation folder containing attorney handwritten notes, typed outline with additional handwritten notes, complete indictment package dated 2/19/2008, victim list with identifying information, photographs, and summary of activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 23 of 69 EFTA00208705 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 Thru AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P- N/A 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 11ih Circuit]) Box #2 File folder entitled "Lacerda Immunity 6(e) Inadequate Log; No Factual Underpinnings; P-008364 Thru Request" containing internal memoranda, Justice Department documentation, and Work Product Deliberative Process Fiduciary Duty; Not in Anticipation of 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 EFTA00208706 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 P-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by I Ith Circuit] N/A Box #2 P-008536 Thru P-008542 Handwritten attorney notes to prepare for interview of Jane Doe #2 Work product Investigative Privilege Contains information subject to privacy rights of victims who are not arties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion b Victims Box #2 P-008543 Thru P-008549 Handwritten attorney notes regarding May 8, 2007 grand jury presentation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 25 of 69 EFTA00208707 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 P-008550 Thru P-008615 File folder entitled "Most Recent Indictment & Good Cases" containing draft indictment and legal research Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-008616 Thru P-008686 File folder entitled "FBI Summary Charts" containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual 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; Factual 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 P-008687 Thru P-008776 File folder entitled "[Victim name]llane Doe #4" containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information and documents subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 26 of 69 EFTA00208708 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 P-008777 Thru P-008808 File folder entitled "[Victim name]llane Doe #5" containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-008809 Thru P-008847 File folder entitled "[Victim namej/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-008848 Thru P-008862 File folder entitled "[Victim name]llane Doe #7" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 27 of 69 EFTA00208709 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 P-008863 Thru P-008890 File folder entitled "[Victim name]/Jane Doe #8" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-008891 Thru P-009103 File folder entitled "Certified Copy of State Case" containing certified copy of Epstein state criminal cases and change of plea transcript [not being withheld as privileged — copy provided to opposing counsel] N/A Box #2 P-009104 Thru P-009111 File folder entitled "Meeting Timeline" containing Villafafla typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to A. Marie Villafatia and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit] N/A Page 28 of 69 EFTA00208710 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 P-009114 Thru P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] N/A Box #2 P-009116 Thru P-009125 12/6/2007 Letter from Jeffrey Sloman to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 1 1 di Circuit]) N/A Box #2 P-009126 Thru P-009134 File folder entitled "[Victim name]/Jane Doe #9" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-009135 Thru P-009141 File folder entitled "[Victim name]/Jane Doe #13" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 29 of 69 EFTA00208711 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 P-009141A Thru P-009141C File folder entitled "[Victim name]llane Doe #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-009142 Thru P-009152 File folder entitled "EM' ' Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims M'' containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation Box #2 P-009153 Thru P-009156 File folder entitled ' Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation Page 30 of 69 EFTA00208712 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 P-009157 Thru P-009208 File folder entitled "[Victim name]llane Doe #1" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-009209 Thru P-009213 File folder entitled "[Victim name]/Jane Doe #2" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #2 P-009214 Thru P-009271 File folder entitled "[Victim name]llane Doe #3" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 31 of 69 EFTA00208713 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 P-009272 Thru P-009354 File folder entitled "Purpose of Travel Cases" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009355 Thru P-009403 File folder entitled "Interstate Commerce Cases" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009404 Thru P-009536 File folder entitled "Attorney Conflict Research" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009537 Thru P-009574 File folder entitled "Mann Act/Travel to Have Sex w/Minor" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009575 Thru P-009603 File folder entitled "Travel Act" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009604 Thru P-009711 File folder entitled "Florida Prostitution/Lewdness Statutes" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009712 Thru P-009819 Booklet entitled "Attorney General Guidelines for Victim and Witness Assistance" [not being withheld as privileged — produced to opposing counsel] N/A Box #2 1)-009820 Thru P-009965 File folder entitled "Corporate Liability Rsrch" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 32 of 69 EFTA00208714 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 P-009966 Thru P-010096 File folder entitled "Research re Knowledge of Age Unnecessary" containing attorney research and handwritten notes and copy of grand jury subpoena Work Product 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; 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 P-010097 Thru P-010276 File folder entitled "Money Laundering" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010277 Thru P-010394 File folder entitled "1960 & Aiding/Abetting" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010395 Thru P-010488 File folder entitled "18 USC § 2255 Cases" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010489 Thru P-010509 File folder entitled "Research re Overt Acts & Witness Testimony" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010510 Thru P-010525 File folder entitled "Extradition" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 33 of 69 EFTA00208715 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 P-010526 Thru P-010641 File folder entitled "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter 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) Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #2 P-010642 Thru P-01650 File folder entitled "Immunity" containing attorney research on granting immunity to witnesses Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010651 Thru P-010659 File folder entitled "Research re G.J. Transcript" containing attorney research and draft pleadings re compelling production of grand jury transcript with subpoena Work Product 6(e) Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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 34 of 69 EFTA00208716 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 P-010660 Thru P-010757 File folder entitled "Research it GJ Transcript" containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to subpoena Work Product 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; 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 P-010758 Thru P-010793 File folder entitled "Original Proposed Ind." containing draft indictment Work Product 6(e) Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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 Box #2 P-010794 Thru P-010829 File folder entitled "Epstein" containing sample indictments and attorney research it potential charges with attorney notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010830 Thru P-010853 File folder entitled "1591 & Money Laundering" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010854 Thm P-010876 File folder entitled "18 USC 2425" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 35 of 69 EFTA00208717 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 P-010877 Thru P-010920 File folder entitled "Knowledge of Age" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010921 Thru P-011049 File folder entitled "2423(b) Constitutionality and Purpose of Travel" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011050 Thru P-011212 File folder entitled "Mistake not a Defense" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011213 Thru P-011237 File folder entitled "Research re `Pandering"' containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011238 Thru P-011319 File folder entitled "Research re Grand Jury Instructions" containing attorney research and handwritten notes Work Product 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; 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 P-011320 Thru P-011361 File folder entitled "Telephone = Facility of Commerce" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011362 Thru P-011374 File folder entitled "Def of Prostitution" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 36 of 69 EFTA00208718 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 P-011375 Thru P-011456 File folder entitled "Relevant Florida Statutes" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011457 Thru P-011626 File folder entitled "Unit of Prosecution Research" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #3 P-011627 Thru P-011662 File folder entitled "Attorney Notes" containing attorney handwritten and typed notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #3 P-011663 Thru P-0I 1698 and P-012189 thru P-012361 (gap was scanning error) File folder entitled "Drafts" containing draft indictments with attorney handwritten notes, draft internal memoranda, relevant witness interview reports and grand jury material and attorney handwritten notes 6(e) Work Product Deliberative Process Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #3 P-011699 Thru P-011777 File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections 6(e) Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; 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 37 of 69 EFTA00208719 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 P-011778 Thru P-011788 File folder entitled "6/12/09 Victim Notif. Log" containing chart with victim contact information and attorney notes regarding dates and type of contacts Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #3 P-011789 Thru P-011879 File folder entitled "Breach Memo" containing memorandum analyzing breach of Non-Prosecution Agreement with attachments Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials Box #3 P-011880 Thru P-011922 File folder entitled "Overt Act Lists" containing handwritten notes cross- checking all overt acts alleged in draft indictment by victim and typed overt act summary charts for indictment preparation Work product Attorney-client privilege Deliberative process 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual 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; 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 EFTA00208720 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 handwritten attorney (Lourie) notes; Attorney-Client Privilege Ordinary Government Communication; No Attorney-Client Relationship; Improper 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 attorney (Villafafia) notes; Proper Victim's Petition; CVRA-authorized 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 subject to privacy rights of victims who are not parties to this litigation 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; Redaction; No Assertion by Victims Page 39 of 69 EFTA00208721 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 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; 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 P-012056 Thru P-012088 Affidavit of Roy Black, Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) i Inadequate Log; No Factual Underpinnings; Fiduciary Duty; 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 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; 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 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty Box #3 P-012151 Thru P-012167 Ex Pane Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Page 40 of 69 EFTA00208722 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 P-012168 Thru P-012170 Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Inadequate Log; No Factual Underpinnings; 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 Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #3 P-012174 Thru P-012176 Draft of September 2009 letter from Marie Villafafia to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney (Villafafia) notes Work Product Attorney-Client Privilege Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #3 P-012177 Thru P-012178 Undated handwritten attorney (Villafafia) notes regarding negotiations and allegations Work Product Attorney-Client Privilege Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 41 of 69 EFTA00208723 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 P-012179 Thru P-012188 File Folder entitled "FBI G.J. Log" containing copy of FBI grand jury subpoena log with attorney (Villafafia) handwritten notes 6(e) Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Box #3 P-012362 Thru P-012451 File folder entitled "Key Documents" containing correspondence between AUSA and case agent regarding indictment prep questions, victim identification information, corrections to draft indictment, indictment preparation timeline, key grand jury material 6(e) Work Product Attorney-Client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual 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; Factual 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 P-012451 Thru P-012452 File folder entitled "Victim List" containing list of victims with dates of birth and age information Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims Page 42 of 69 EFTA00208724 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 P-012453 Thru P-012623 Complete indictment package marked "Originals 12/12/07" Work-product Deliberative process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; 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; Redaction; No Assertion by Victims Box #3 P-012624 Thru P-012653 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008. Investigative Privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Redaction; No Assertion by Victims Box #3 P-012654 Thru P-012864 3-ring binder entitled "Child Molesters: A Behavioral Analysis" with attorney (Villafafia) handwritten notes Work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Overriding Need Box #3 P-012865 Thru P-013226 Indictment preparation binder containing: witness/victim list with identifying information, sexual activity summary, telephone call summary chart, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Work Product Deliberative Process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; 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; Redaction; No Assertion by Victims Page 43 of 69 EFTA00208725 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 P-013227 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Privacy Act Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Court Compelled Disclosure; Waiver Box #3 P-013226 Thru P-013230 April 21, 2008 Letter from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting Privacy Act Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013231 Thru P-013239 April 22, 2008 Letter from A. Marie Villafafia to Office of Professional Responsibility re Self-Report of Allegation of Conflict of Interest Privacy Act Inadequate Log; No Factual Underpinnings; Factual Materials; Fiduciary Duty; Court Compelled Disclosure; Waiver Box #3 P-013240 Thru P-013247 April 21, 2008 Letter from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting with attachments Privacy Act Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Court Compelled Disclosure; Factual Materials; Waiver Box #3 P-013248 Thru P-013251 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin 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 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver Box #3 P-013252 Thru P-013253 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver Page 44 of 69 EFTA00208726 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 P-013254 Thru P-013257 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin 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 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver Box #3 P-013258 Thru P-013259 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin 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 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver Box #3 P-013260 Thru P-013262 Email from Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, to Wifredo Ferrer (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) Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver Page 45 of 69 EFTA00208727 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 P-013263 Thru P-013271 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey E stein Investi ation Attorney-Client Privilege Deliberative Process Work Product No Factual Underpinnings; Fiduciary Duty; 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 Box #3 P-013272 Thru P-013278 Emails between Peter Mason, Executive Office for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Attorney-Client Privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Factual Materials; Waiver Suppl. Box #3 P-013279 Thru P-013280 8/15/08 Emails between A. Acosta and A. Marie Villafafia, R. Senior, D. Lee and K. Atkinson re proposed correspondence to Jay Lefkowitz Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud-Misconduct; Not in Anticipation 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 Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Page 46 of 69 EFTA00208728 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 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafarla to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger letter re victim notification Attorney-Client Privilege Work product Deliberative Process No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud- Misconduct; Crime-Fraud-Misconduct; Factual 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 P-013284 7/10/08 Emails between J. Sloman and A. Marie Villafaa, K. Atkinson, and FBI re proposed response to Goldberger's letter e victim notification Attorney-Client Privilege Work Product Deliberative Process No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual 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 P-013285 Thru P-013289 File folder entitled "8/5/08 AMCV e- mail re correct agrmt" containing 8/5/08 email from A. Marie Villafarla to A. Acosta, J. Sloman, R. Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email from A. Marie Villafafia to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege Work Product Deliberative Process No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud- Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 47 of 69 EFTA00208729 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 P-013290 Thru P-013292 File folder entitled "8/14/08 E-mail from Lefk to AMCV" containing (undated) emails from A. Marie Villafafia to R. Senior, J. Sloman, A. Acosta, K. Atkinson, D. Lee re draft response to 8/14/08 email from J. Leflcowitz regarding "the December 2007 proposal" Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013293 Thru P-013299 File folder entitled "8/15/08 AMCV e- mail re Agrmt" containing 8/15/08 e- mails from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re follow up on Agreement and from A. Acosta to Ann Marie Villafana on issue of Special Master with attached 8/15/08 emails from 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 Attorney-Client Privilege Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual 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 P-013300 Thru File folder entitled "8/18/08 Leflcowitz Ltr to AMCV" containing A. Marie Villafatia's handwritten draft notes for Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Page 48 of 69 EFTA00208730 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- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafia re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Work Product Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013304 Thru P-013325 File folder entitled "6/25/07 Lefcourt to Sloman & Lourie containing 6/25/07 letter (with handwritten notes by A. Marie Villafafia) from G. Lefcourt to J. Sloman, M. Menchel, A. Lourie, A. Marie Villafafia addressing reasons for not prosecuting Epstein; handwritten outline by A. Marie Villafafia of possible response to letter Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship Suppl. Box #3 P-013326 Thru P-013329 File folder entitled "9/17/07 Villafafia Lefkowitz containing 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Lourie and from R. Garcia to A. Marie Villafafia concerning status of plea negotiations Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013330 Thru P-013333 File folder entitled "11/8/07 Lefkowitz Sloman" containing 11/8/07 letter from J. Lefkowitz re issues arising during pendency of matter with attorney handwritten notes Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013334 Thru File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Page 49 of 69 EFTA00208731 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 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] N/A Suppl. Box #3 P-013342 Thru P-013350 File folder entitled "12/05/07 Starr to Acosta" containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Leflcowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia Attorney-Client Privilege Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual 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 Suppl. Box #3 P-13351 Thru P-013361 File folder entitled "12/21/07 Lefkowitz Acosta" containing handwritten notes by A. Marie Villafafia, 12/21/07 letter from J. Leflcowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding Need; Factual Materials; Attorney Conduct at Issue Suppl. Box #3 P-013362 Thru P-013366 File folder labeled "12/26/07 Lefkowitz to Acosta" containing 2 copies of draft letter from A. Acosta to J. Lefkowitz (with 12/28/07 fax header) Attorney-Client Privilege Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary 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 EFTA00208732 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 Thru P-013372 Sloman to Lefkowitz re termination" containing draft letter dated "April , 2008" from J. Sloman to J. Lefkowitz concerning the compliance with the Agreement Work Product Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013373 Thru P-013503 File folder labeled "6/3/08 Sloman Submission to the DAG" containing 6/3/08 letter from J. Sloman to Mark Filip, Office of the DAG, cc'd to R. Senior, A. Marie Villafafia, K. Atkinson, re Jeffrey Epstein, detailing events concerning the Agreement and thereafter and with relevant attachments Attorney-Client Privilege Deliberative Process Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013504 Thru P-013507 File folder labeled "Mtg w/ Ken Starr, RAA, JS, Drew" containing handwritten notes by A. Marie Villafafia Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013508 Thru P-013514 File folder labeled "Internal Con." containing 11/28/07 e-mails from J. Sloman to A. Marie Villafafia re responding to 11/28/07 e-mail from J. Lefkowitz to J. Sloman regarding victim notification with attachments Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Factual Materials; Waiver Suppl. Box #3 P-013515 Thru Draft 11/30/07 letter from A. Acosta to K. Starr cc'd to J. Sloman and A. Marie Villafafia re compliance with Agreement Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Page 51 of 69 EFTA00208733 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. Acosta, and A. Lourie re items to address in letter Deliberative Process Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver; Factual Materials Suppl. Box #3 P-013526 Thru P-013527 5/23/07 e-mail from A. Marie Villafatla to K. Atkinson re draft proposed internal e-mail about handling of case and attached email correspondence between Andrew Lourie and G. Lefcourt Attorney-Client Privilege Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials Suppl. Box #3 P-013528 Thru P-013530 P-013532 Thru P-013537 Handwritten notes by A. Marie Villafana dated 9/21 re telephone conference with possible victim representative, conflict check with names and email listed, list of names of potential victim representatives, payment discussion, and guideline calculation, email containing contact info for potential victim representative, draft Non Prosecution Agreement dated 9/10/07 4:17 .m Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013531 Typed note addressed to "Dear David" re response to grand jury subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; 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 P-013538 Thru File folder labeled "Notes Re Post- Agreement Communications" containing Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Page 52 of 69 EFTA00208734 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, R. Garcia re non-prosecution agreement, with attached correspondence; Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver; Final 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 EFTA00208735 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 EFTA00208736 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 EFTA00208737 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 P-013609 Thru P-013615 File folder entitled "0 Target Letter" containing copy of signed letter and contact info for counsel for target 6(e) Investigative Privilege Inadequate Log; No Factual Underpinnings; 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 P-013616 File folder entitled "Atty Notes re Revised Indictment" containing Attorney-Client Privilege Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Page 56 of 69 EFTA00208738 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 P-013621 handwritten notes by A. Marie Villafafia Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box #3 P-013622 Thru P-013643 File folder entitled "Research Re Possible Misdemeanors" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013644 Thru P-013653 File folder entitled "Notes Re Plea Negotiations" containing 9/17/07 e-mail from A. Marie Villafafia to J. Richards, N. Kuyrkendall re status update; undated and typed handwritten notes by A. Marie Villafafia re items to be completed on case, strength of case, victim interviews, summary of evidence, guidelines calculations Attorney-Client Privilege Work Product Deliberative Process Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual 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 P-013654 Thru P-013745 File folder entitled "Plea Agreement Drafts" containing several draft plea agreements some with handwritten notes by A. Marie Villafafia; copies of draft non-prosecution agreement some with handwritten notes by A. Marie Villafafia; copy of a draft Information Attorney-Client Privilege Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box #3 P-0013747 File folder entitled "Draft Non- Prosecution Agreements" containing Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Page 57 of 69 EFTA00208739 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 P-013810 several draft non- prosecution agreements some with handwritten notes by A. Marie Villafaria; plea sheet State Circuit Court; copies of draft Information; draft plea proffer; draft motion and order to seal; draft penalty sheet; draft plea agreement Deliberative Process Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials Suppl. Box 3 P-013811 Thru P-013833 File folder entitled "Information Packet Drafts" containing several drafts of Informations, and complete draft Information packet Attorney-Client Privilege Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue 3uppl. Box 3 P- 013834 Through P- 013835 Two pages of filed document, D.E. 62, page 2 of 54 and page 6 of 54, containing handwritten attorney notes Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013836 Thru P-013837 Palm Beach Daily News Article, "Attorneys want Jeffrey Epstein Agreement Thrown Out," with attorney's notes written on margin Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013838 Thru P-013841 Letter from Paul Cassell to Wifredo A. Ferrer, December 10, 2010, Subject: Request for Investigation of Jeffrey Epstein Prosecution, with underlines, written notes, and comments by DOJ attorney Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013842 Email from Dexterr Lee to Ruth Plagenhoef (OPR), February 25, 2011, 4:31 p.m., Re: request for OPR Investigation — Jeffrey Epstein Non- Prosecution Agreement Atty work-product Atty-client privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Page 58 of 69 EFTA00208740 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 P-013843 Thru P-013844 E-mail, Marie Villafana to Andrew Lourie, Rolando Garcia, and Karen Atkinson, September 19, 2007, 4:33 p.m., RE: Plea Agreement Atty work-product atty-client privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013845 Thru P-013846 E-mail, Andrew Lourie to Marie Villafana, September 19, 2007, 4:21 p.m., RE: Epstein, with internal U.S. Attorney's Office e-mails attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013847 Thru P-013849 E-mail, Marie Villafana to Andrew Lourie, Rolando Garcia, and Karen Atkinson, September 18, 2007, 11:43 a.m., RE: Draft Agreements?, with e-mail from Jay Lefkowitz (September 18, 2007, 11:09 a.m.) attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Waiver Suppl. Box 3 P-013850 E-mail, Marie Villafana to Alex Acosta, Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud- Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013851 Thru P-013853 E-mail, Marie Villafana to Rolando Garcia and Andrew Lourie, September 17, 2007, 10:35 a.m., RE: Epstein [providing update re plea negotiations] Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013854 E-mail, Marie Villafana to Andrew Oosterbaan, September 13, 2007, 8:10 p.m., RE: Epstein, with e-mail from Andrew Oosterbaan (September 13, 2007, 7:54 p.m.), attached Atty work-product No Factual Underpinnings; Fiduciary Duty; 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; Page 59 of 69 EFTA00208741 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, 2007, 5:24 p.m., RE: FBI Atty-client privilege Fiduciary Duty; Ordinary Government ; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Communication; No Attorney-Client Relationship Suppl. Box 3 P-013856 Thru P-013857 E-mail, Marie Villafana to Jeff Sloman, September 6, 2007, 5:47 p.m., RE: Epstein, with e-mail from Jeff Sloman (September 6, 2007, 5:35 p.m.), attached Atty work-product Atty-client privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013858 Email, Marie Villafana to Jeff Sloman, September 6, 2007, 9:29 a.m., Re: Meeting on Friday ally work-product No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P-013860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] N/A Suppl. Box 3 P-013861 Thru P-013865 E-mail, Marie Villafana to Matthew Menchel, July 13, 2007, 3:14 p.m., RE: Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Atty work-product atty-client privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Ordinary Government Communication; No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013866 E-mail, Marie Villafana to Jeff Sloman, Matthew Menchel, Andrew Lourie, Karen Atkinson, and Shawn Ball, July 3, 2007, 6:26 a.m., RE: Epstein Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013867 Thru E-mail, Marie Villafana to Matthew Menchel, June 21, 2007, 3:24 p.m., RE: Meeting Next Week, with e-mails from Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Page 60 of 69 EFTA00208742 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 p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013869 E-mail, Marie Villafana to Matthew Menchel, Jeff Sloman, Andrew Lourie, and Karen Atkinson, June 18, 2007, 5:04 p.m., RE: Epstein Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013870 Thru P-013871 E-mail, Andrew Lourie to Marie Villafana, May 24, 2007, 9:25 a.m., FW: Jeffrey Epstein, with e-mail from Gerald Lefcourt to Andrew Lourie (May 23, 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 Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013872 E-mail, Andrew Lourie to Matthew Menchel, Jeff Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with e-mail from Lefcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013873 E-mail Menchel to Villafana and Lourie, May 14, 2007, 10:52 a.m., RE: Operation Leap Year, with e-mail from Villafana to Lourie and Menchel (May 14, 2007, 10:38 a.m.), attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P- 013874 Inadvertently marked as privileged, will be produced N/A Page 61 of 69 EFTA00208743 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 P-013876 Thru P-013877 E-mail, Villafana to Lourie,Garcia, and Atkinson, September 19, 2007, 4:33 p.m., RE: Draft Plea Agreement, with e-mail from Lefkowitz to Villafana (September 19, 2007, 3:44 p.m.), and Lefkowitz to Villafana (September 19, 2007, 3:35 p.m.) attached Any work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013878 Thru P-013879 E-mail, Lourie to Villafana, September 19, 2007, 4:21 p.m., RE: Epstein, with e-mails from Villafana to Lourie and Garcia (September 19, 2007, 4:13 p.m.), 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 Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013880 Thru P-013882 E-mail, Villafana to Lourie,Garcia, and Atkinson, September 18, 2007, 11:43 a.m., RE: Draft Agreements?, with e-mails from Villafana to Lourie, Garcia and Atkinson (September 18, 2007, 11:18a.m.), Atty work-product No Factual Underpinnings; Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 62 of 69 EFTA00208744 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 P-013883 E-mail, Villafana to Acosta, Lourie, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013884 Thru P-013886 E-mail, Villafana to Garcia and Lourie, September 17, 2007 10:35 a.m., RE: Epstein, with e-mail from Garcia (September 17, 2007, 10:26 a.m.), attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013887 E-mail, Marie Villafana to Andrew Oosterbaan, September 13, 2007, 8:10 p.m., RE: Epstein, with e-mail from Andrew Oosterbaan (September 13, 2007, 7:54 p.m.), attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013888 E-mail, Marie Villafana to Jeff Sloman and Andrew Lourie, September 10, 2007, 5:24 p.m., RE: FBI Atty work-product Atty-client privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013889 Thru P-013890 E-mail, Marie Villafana to Jeff Sloman, September 6, 2007, 5:47 p.m., RE: Epstein, with e-mail from Jeff Sloman (September 6, 2007, 5:35 p.m.), attached Atty work-product Atty-client privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013891 Email, Marie Villafana to Jeff Sloman, September 6, 2007, 9:29 a.m., Re: Meeting on Friday atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy [Not considered privileged. Will be N/A Page 63 of 69 EFTA00208745 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 Through P-013893 Black, re: Jeffrey Epstein produced to opposing counsel upon lifting of stay] Suppl. Box 3 P-013894 Thru P-013898 E-mail, Marie Villafana to Matthew Menchel, July 13, 2007, 3:14 p.m., RE: Epstein, with e- mail from Menchel (July 5, 2007, 3:30 p.m.), Villafana to Menchel (July 4, 2007, 5:16 p.m.), and Sloman to Villafana (July 3, 2007, 1:47 p.m.), attached Atty work-product atty-client privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013899 E-mail, Marie Villafana to Jeff Sloman, Matthew Menchel, Andrew Lourie, Karen Atkinson, and Shawn Ball, July 3, 2007, 6:26 a.m., RE: Epstein Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013900 Thru P-013901 E-mail, Marie Villafana to Matthew Menchel, June 21, 2007, 3:24 p.m., RE: Meeting Next Week, with e-mails from Menchel to Villafana (June 21, 2007, 2:58 p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013902 E-mail, Marie Villafana to Matthew Menchel, Jeff Sloman, Andrew Lourie, and Karen Atkinson, June 18, 2007, 5:04 p.m., RE: Epstein Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013903 Thru P-013904 E-mail, Andrew Lourie to Marie Villafana, May 24, 2007, 9:25 a.m., FW: Jeffrey Epstein, with e-mail from Gerald Lefcourt to Andrew Lourie (May 23, 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 Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 64 of 69 EFTA00208746 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 P-013905 E-mail, Andrew Lourie to Matthew Menchel, Jeff Sloman, and Marie Villafana, May 22, 2007, 3:11 p.m., FW: Jeffrey Epstein, with e-mail from Lefcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013906 E-mail Menchel to Villafana and Lourie, May 14, 2007, 10:52 a.m., RE: Operation Leap Year, with e-mail from Villafana to Lourie and Menchel (May 14, 2007, 10:38 a.m.), attached Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P- 013907 Through P-013908 Inadvertently marked as privileged, will be produced N/A Suppl. Box 3 P-013909 Thru P-013911 Memorandum, Lisa Howard, Assistant Counsel, U.S. Department of Justice, Office of Professional Responsibility (OPR), to Ruth Plagenhoef, Acting Associate Counsel, OPR, undated, Subject: Recommendation Deliberative Process Privilege; atty work- product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Improper Invocation; Final Decision; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013912 Thru P-013914 Memorandum, Lisa Howard, Assistant Counsel, OPR, to Ruth Plagenhoef, Acting Associate Counsel, OPR, Subject: Recommendation, with handwritten note dated 5/4/11 Deliberative Process Privilege, atty work- product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Improper Invocation; Waiver; Final Decision; Claims Against Public 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 EFTA00208747 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 Thru P-013918 Counsel, OPR, to Ruth Plagenhoef, Acting Associate Counsel, OPR, Subject: Recommendation, with two post-it notes attached with handwritten attorney notations, and handwritten notations, underlines, and circled text throughout the body of the two page memorandum Privilege; atty work- product Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Improper Invocation; Waiver; Final Decision; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013919 Thru P-013921 Draft letter, marked "Confidential", from Robin C. Ashton, Counsel, Office of Professional Responsibility to Wifredo A. Ferrer, United States Attorney, with handwritten corrections, strikethroughs, and added text Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver; Final Decision Suppl. Box 3 P-013922 Thru P-013924 Draft Letter, marked "Confidential", from Robin C. Ashton, to Wifredo A. Ferrer, with handwritten corrections Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 P-013925 Thru P-013927 Draft Letter, from Robin C. Ashton to Professor Paul G. Cassell, with handwritten correction Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 P-013928 Thru P-013930 Draft Letter, from Robin C. Ashton to Professor Paul G. Cassell, with handwritten corrections Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box 3 P-013931 Thru P-013933 Draft Letter, from Robin C. Ashton to Professor Paul G. Cassell, with handwritten corrections, circled text, Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Page 66 of 69 EFTA00208748 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 P-013934 Thru P-013936 Draft Letter, marked "Confidential," from Robin C. Ashton to Wifredo A. Ferrer, with handwritten corrections Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attome Conduct at Issue Suppl. Box 3 P-013937 Thru P-013939 Draft Letter, Robin C. Ashton to Professor Paul G. Cassell, with handwritten corrections Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Suppl. Box 3 P-013940 Thru P-013942 Draft Letter, marked "Confidential: To Be Opened by Addressee Only," Robin C. Ashton to Wifredo A. Ferrer, with handwritten corrections Deliberative Process Privilege Attorney Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Crime-Fraud- Misconduct; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver; Final Decision; Factual Materials Suppl. Box 3 P-013943 E-mail, Ruth Plagenhoef to Lisa Howard, May 5, 2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 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 Deliberative Process Privilege Attorney Work Product No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013944 E-mail, Plagenhoef to Howard, May 5, 2011, 11:17 a.m., RE: Re-write of Epstein lett your review, with e-mail from Howard to Plagenhoef (May 5, 2011, 11:08 Deliberative Process Privilege No Factual Underpinnings; Fiduciary Duty; Improper Invocation; Overriding Need; Final Decision; Waiver Page 67 of 69 EFTA00208749 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 P-013945 E-mail, Plagenhoef to Howard, May 4, 2011, 5:01 p.m., RE: draft letters in Epstein matter, with e-mail from Howard to Plagenhoef (May 4, 2011, 4:57 p.m.), attached Deliberative Process Privilege No Factual Underpinnings; Fiduciary Duty; Improper Invocation; Overriding Need Suppl. Box 3 P-013946 E-mail, Plagenhoef to Robin C. Ashton, May 4, 2011, 4:08 p.m., RE: FYI on the Florida matter Law Enforcement investigatory record, atty work product; deliberative process privilege No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Final Decision; Waiver Suppl. Box 3 P-013947 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter Lee and Marie Villafana atty work product; law enforcement investigatiory record No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Final Decision Suppl. Box 3 P-013948 Thru P-013951 E-mail, Plagenhoef to Howard and Robin C. Ashton, May 3, 2011, 12:30 p.m., FW: OPR Inquiry — request for information, with attached e-mails. Handwritten attorney notes on margin atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013952 Thru P-013953 E-mail, Dexter Lee to Ruth Plagenhoef, March 16, 2011, 10:52 a.m., RE: Referral of Cassell Request for Investigation, with e-mail from Paul Cassell to Dexter Lee and Marie Villafana (March 15, 2011, 7:21 p.m.), attached atty work-product; atty- client privilege No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Plagenhoef to Neil Hurley, OPR, atty work-product, atty- Inadequate Log; No Factual Underpinnings; Page 68 of 69 EFTA00208750 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- mail from Dexter Lee to Plagenhoef Communication; No Attorney-Client Relationship; Waiver; Claims Against Public (December 16, 2010, 10:22 a.m.), attached. Handwritten attorney notations. Prosecutor; Overriding Need; Attorney 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 EFTA00208751