EFTA00296195.pdf

Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION Team privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03089-03099 05/03/2009 Attorneys and Staff RE: Setting Depos Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 13445-13453 08/19/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 12281-12291 07/30/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 09337-09340 08/10/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 09350 10/21/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 09335 08/06/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11983 08/06/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11984-11988 08/06/2009 Litigation Strategy . Work Product;attorney client privilege;irrelevant & reasonably calculated to 29 EFTA00296195 Privile e Lo — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00146 06/29/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00147 06/29/2009 M Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00148 04/22/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00149 04/26/2009 all Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00151-00152 06/26/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 01036-01039 04/26/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 13313-13314 07/30/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to 43 EFTA00296196 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights 13315 08/03/3009 Illa Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 01080-01081 06/22/2009 Jane Doe brother Attorney/Client privilege and/or work product 01077 05/28/2009 1 1 3 Doe family member Attorney/Client privilege and/or work product 02445-02446 05/05/2009 Jones v. Atlantic asphalt Attorney/Client privilege and/or work product 03049 09/21/2009 New addition to the case Attorney/Client privilege and/or work product 02425-02426 06/17/2009 1 Jane Doe v. Dukenik Attorney/Client privilege and/or work product 02669 09/24/2009 Subpoena fo Attorney/Client privilege and/or work product 02647 08/06/2009 1 Samantha Lee Rivera info Attorney/Client privilege and/or work product 03688-03691 04/03/2009 I . Case number assignments Attorney/Client privilege and/or work product 03692-03693 05/06/2009 11. Case list Attorney/Client privilege and/or work product 15678.15680 09/29/2009 1 Subpoena fo Attorney/Client privilege and/or work product 15689 10/01/2009 I I I Client information Attorney/Client privilege and/or work product 02546-02547 09/22/2009 I I Client communication Attorney/Client privilege and/or work product 02809-02810 09/28/2009 Client communication Attorney/Client privilege and/or work product 02262 07/23/2009 Discussion re: client/victim Attorney/Client privilege and/or work product personal information 02807-02808 10/01/2009 Client communication Attorney/Client privilege and/or work product 03760-03828 04/01/2009 Client names/types of action/ Attorney/Client privilege and/or work product, client information privacy right privilege, not relevant 03759 04/01/2009 Conflict Check for Attorney/Client privilege and/or work product files 08358-08359 09/14/2009 Client info Attorney/Client privilege and/or work product 44 EFTA00296197 Privilege Log — Dated 2-23-2011 BATES il lralailni DATE TO FROM DESCRIPTION OBJECTION 08364-08368 10/01/2009 Client info Attorney/Client privilege and/or work product 08370 09/14/2009 l■ ' Client info Attorney/Client privilege and/or work product 08374.08375 10/01/2009 I Client info Attorney/Client privilege and/or work product 03878 06/12/2009 I' Curtis Rivera Attorney/Client privilege and/or work product 02955 04/20/2009 1 • . Juskowich Attorney/Client privilege and/or work product 02932 07/17/2009 II Jane Doe v. Roe Attorney/Client privilege and/or work product 11544-11545 09/28/2009 1 I Client info Attorney/Client privilege and/or work product 07432-07435 09/25/2009 New addition to the case Attorney/Client privilege and/or work product 06906-06909 07/17/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product 06913-06914 06/22/2009 . Jane Doe v. Roe Attorney/Client privilege and/or work product 06030-06031 05/04/2009 I • Espina — Walmart case Attorney/Client privilege and/or work product 05646 07/08/2009 I' Client meeting Attorney/Client privilege and/or work product 05573 09/18/2009 1 Client meeting Attorney/Client privilege and/or work product 05540 07/31/2009 Client info Attorney/Client privilege and/or work product 05273-05276 07/28/2009 7 1 I Client info Attorney/Client privilege and/or work product 05264 07/27/2009 tt I Client info Attorney/Client privilege and/or work product 05267.05270 07/27/2009 I Client info Attorney/Client privilege and/or work product 02933 06/17/2009 --; I I Jane Doe v. Roe Attorney/Client privilege and/or work product 01292 09/18/2009 1-- Epstein article Attorney/Client privilege and/or work product 01068.01070 04/02/2009 All Staff Current case list of Attorney/Client privilege and/or work product 01054-01055 04/02/2009 All Staff Updated case list for Attorney/Client privilege and/or work product 01033 05/06/2009 case list Attorney/Client privilege and/or work product 01030-01031 04/03/2009 Case number assignments Attorney/Client privilege and/or work product 45 EFTA00296198 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 01118-01120 09/22/2009 I Jane Doe v. Roe Attorney/Client privilege and/or work product 01986-01989 04/02/2009 I I Conflict check Attorney/Client privilege and/or work product 01984-01985 04/02/2009 Conflict check Attorney/Client privilege and/or work product 25925 09/30/2009 All Staff Conflict check Attorney/Client privilege and/or work product 25874 09/30/2009 All Staff Additional name conflict check added to Attorney/Client privilege and/or work product 08356-08357 09/16/2009 Client Meeting Attorney/Client privilege and/or work product 16760.16761 09/23/2009 New Client Attorney/Client privilege and/or work product 08005 06/05/2009 New Client Attorney/Client privilege and/or work product 06915.06920 06/17/2009 MG Jane Doe v. Roe Attorney/Client privilege and/or work product 08360-08363 09/16/2009 Client Meeting Attorney/Client privilege and/or work product 04101-04107 09/28/2009 ■ Jane Doe v. Roe Attorney/Client privilege and/or work product 04708.04710 09/18/2009 Epstein Article Attorney/Client privilege and/or work product 06910-06912 06/17/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product 07909 08/10/2009 Jane Doe Same silver car tag Attorney/Client privilege and/or work product 07637-07642 09/10/2009 III Interview Attorney/ Client Privilege 06795-06799 08/19/2009 Anthony P Client Meeting Attorney/Client privilege and/or work product 06542-06548 09/15/2009 Client Meeting Attorney/Client privilege and/or work product 06404-06408 09/10/2009 III • Interview Attorney/Client privilege and/or work product 08338-08339 09/16/2009 New Client Attorney/Client privilege and/or work product 08505 09/14/2009 New Client Meeting Attorney/Client privilege and/or work product 02241-02242 05/28/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02243-02244 07/07/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02238-02240 05/28/20009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02204 07/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to 46 EFTA00296199 Privilege Log - Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 02298-02299 07/08/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02291 06/04/2009 IIIIIIMI Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02442-02443 08/17/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02440-02441 10/02/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04318-04321 09/24/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05111 06/02/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05152 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05164 06/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05166 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05169-05170 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05173-05174 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05212-05213 06/23/2009 Confidential Source Secret Plea Deal for Epstein Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05215.05217 06/23/2009 Confidential Source Secret Plea Deal of Epstein providing new witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05175-05189 07/02/2009 I li Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05194-05196 06/23/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05204-05206 06/23/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 47 EFTA00296200 Privilege Log — Dated 2-23-2011 & BATES DATE TO FROM DESCRIPTION OBJECTION 05227-05228 07/08/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05230-05231 07/08/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05303 08/06/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05344-05346 06/23/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05408 07/06/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05425.05429 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05433-05436 05/29/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05433-05436 05/29/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05446 07/07/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05452-05464 05/29/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05535-05536 07/30/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05538.05539 07/30/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05550-05551 08/11/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05577-05578 08/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05619.05620 09/18/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05650 08/06/200 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05688-05689 0/28/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to 48 EFTA00296201 Privilege Log — Dated 2-23-2011 & OBJECTION BATES DATE TO FROM DESCRIPTION discovery of admissible evidence 05693-05695 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05698 08/21/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05706-05709 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05720-05721 05/29/2O09 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05738.05739 05/29/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05743-05745 05/29/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05754 08/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05759.05762 06/01/2O09 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05765-05768 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05771-05773 06/03/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05777.05779 06/03/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05784.05786 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05791-05794 06/03/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05803 07/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05836-05837 07/08/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05842-05843 07/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 49 EFTA00296202 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 05848 07/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05852-05853 07/29/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05857-05858 07/31/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05952-05953 08/25/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06192-06197 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06198-06201 06/24/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06203 07/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06401 09/23/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06643-06651 09/17/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06788.06789 09/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06942-06943 09/26/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06953 08/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06955-06957 10/02/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06959-06961 08/11/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06963-06980 08/11/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06986.06989 10/03/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07010-07014 10/04/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to 50 EFTA00296203 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 07017.07018 09/04/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07143-07144 10/01/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07147-07150 09/18/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 075089- 07513 10/13/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07605-07615 09/07/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07646-07647 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07674.07697 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08376 10/04/2009 Confidential Source = Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08380 09/18/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08427-08430 09/24/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08450 05/17/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08507 10/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 10092.10098 08/31/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01610 06/03/3009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01612 06/04/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01451-01458 05/27/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 51 EFTA00296204 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 01608 07/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01606 07/02/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01510 08/25/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01506 08/24/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01493 08/10/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01488 08/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01486 07/28/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01483 07/28/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01479 07/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01449 05/22/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01433 10/20/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 15207-15208 08/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 19716-19719 09/25/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 19730-19731 10/02/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01683 08/06/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01693 08/21/2009 Confidential Source Litigation Strategy I W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03011 09/17/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to 52 EFTA00296205 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION Epstein Molestations discovery of admissible evidence 01755-01756 10/02/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01756 06/22/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01770 10/08/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03126 09/18/2009 Confidential Source Additional Information RE: Epstein Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02006 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02060 09/23/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03487-03494 09/19/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02269 08/26/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02322-02323 10/16/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02595-02596 09/07/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02866.02867 09/25/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02895 08/31/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02901 09/16/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03032 09/18/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03057 10/13/2009 , 11. Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03070 07/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 53 EFTA00296206 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 03081-03082 09/21/2009 Confidential Source Providing Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03144 10/08/2009 Confidential Source Providing Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03189.03190 10/14/2009 Confidential Source Additional Information RE: Epstein Strategies W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04015 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02913 09/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02956-02957 08/31/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02975 10/21/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04031.04055 08/12/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04057 08/11/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04060 08/12/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02979-02980 10/02/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02998 07/21/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05626 10/12/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05630-05631 10/12/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05664-05665 10/12/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07976 08/14/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06655 06/09/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to 54 EFTA00296207 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION Source discovery of admissible evidence 19986-19987 09/28/2009 Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04905-04906 07/15/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04946.04951 10/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05148 05/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05151 05/26/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05161 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05203 06/23/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05207-05208 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05220-05221 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05224.05225 06/24/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05239 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05277-05278 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05324.05325 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05368-05369 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05387-05388 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02811-02812 10/03/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 55 EFTA00296208 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 01280-01288 09/18/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 01131-01134 10/08/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 00988 04/25/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10163-10167 08/12/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10181-10188 08/12/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10245-10251 09/08/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10364-10367 09/17/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10586-10591 09/24/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10625-10632 10/02/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10698-10699 10/13/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10718.10719 10/13/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10927-10937 05/28/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10945-10954 05/29/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10964-10978 06/02/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10991 06/22/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11006.11010 06/23/2009 Confidential Source Additional Information RE: W/P Privilege; Not reasonably calculated to lead 56 EFTA00296209 n alloalik na l 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION Epstein Molestations to discovery of admissible evidence. 11075.11076 07/29/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11080-11082 07/31/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11085-11097 09/04/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11123-11136 09/17/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11140-11142 10/04/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11150.11151 10/12/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 10390-10393 09/19/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11157-11165 10/25/2009 Confidential Source Providing New Witnesses W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11170.11174 06/23/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11184.11185 05/27/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11188-11195 05/28/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11198-11200 05/28/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11208-11214 05/29/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11223-11236 06/01/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11260-11266 06/24/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11320-11325 07/30/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 57 EFTA00296210 Privilege Log — Dated 2-23-2011 FROM & BATES DATE TO DESCRIPTION OBJECTION 11372-11373 08/11/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11380-11383 08/12/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11438-11442 09/17/2009 Confidential Source Additional Information RE: Epstein Molestations W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11549-11550 10/01/2009 Confidential source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. 11574-11579 10/13/2009 Confidential Source Litigation Strategy W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. BOX 2 BATES DATE TO FROM DESCRIPTION OBJECTION 08029.08032 09/14/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08026-08028 05/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07738-07739 05/13/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07747 09/17/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07758-07759 05/05/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 58 EFTA00296211 Privilege Log — Dated 2-23-2011 BATES DATE Ts FROM DESCRIPTION OBJECTION discovery of admissible evidence; protected by privacy rights 07760-07765 09/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07766 10/11/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07767.07784 05/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07785-07790 06/26/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07791 04/04/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07792-07793 04/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07794.07841 04/04/2009 Full draft of motion to stay W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07842.07848 06/16/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by 59 EFTA00296212 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence; protected by privacy rights 05320-05323 07/30/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05312.05313 07/22/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05306-05307 07/22/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05302 07/22/2009 Attorney at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05281 08/03/2009 Review of litigation materials W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05282-05283 04/09/2009 Jane Doe v. Us W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05288-05291 07/22/2009 Dr. Swan W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05292 07/22/2009 Attorneys at. RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by 63 EFTA00296213 Privilege Log — Dated 2-23-2011 BATES DATE IQ FROM DESCRIPTION • BJE I • N privacy rights 05295-05297 07/23/2009 Attorneys at RE: Epstein Conference Room Reserved W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05298 08/03/2009 Discussion of Epstein strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05261 07/23/2009 Victim Psychological Assessment W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18358-18359 07/24/2009 Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04431-04432 08/14/2009 RE: Epstein-Maxwell Subpoena W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04419-04420 04/09/2009 RICO Statement W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04403.04416 10/17/2009 Punitive Damages W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04387-04402 08/19/2009 Victim Complaints, Forensic accountants, & Epstein's Fraudulent Transfers W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 64 EFTA00296214 Privilege Log — Dated 2-23-2011 BATES RATE iv FROM DESCRIPTION OBJECTION 04202-04206 09/08/2009 Epstein's attorneys & Bob Josephsberg have filed several motions on limits of the no contact order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights O4207-04215 09/04/2009 Attorneys at. Letter to Critton RE: Protective Order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04191-04193 09/04/2009 Finding out who is protected by the order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04194-04195 09/04/2009 Attorneys at Seek Court Intervention W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04196.04199 09/08/2009 Finding out who is protected by the order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25937 10/25/2009 Epstein's house staff W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25923 09/09/2009 Attorneys at. Maribel Matiska legal opinion RE: Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25832-25838 06/01/2009 contact Information re: who is pertinent to the case W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25825-25826 10/05/2009 Trial Prep Epstein W/P; Attorney Client Privilege; Irrelevant and 67 EFTA00296215 Privilege Lo — Dated 2-23-2011 ll !I ll fi l l ! ' flip I I I BATES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 19856 10/17/2009 I Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 20888 09/12/2009 a = Potential New witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 20946 05/11/2009 Attorneys at Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05807-05810 07/23/2009 Attorneys at Conference room reserved W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05262-05263 07/22/2009 Investigator information W/P; Attorney Client Privilege; Irrelevant and not reasonably cakulated to lead to the discovery of admissible evidence; protected by privacy rights 25829 05/11/2009 Motion to unseal criminal records W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25830-25831 05/11/2009 Attorneys at Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25811-25813 05/11/2009 Attorneys at Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 72 EFTA00296216 e alMit ina l 2-23-2011 BATES DATE TO FROM PESCRIPTION OBJECTIQN discovery of admissible evidence; protected by privacy rights 25815-25822 06/01/2009 Depo information W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18358-18359 07/24/2009 Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05382 09/12/2009 Potential new witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08033-08070 10/23/2009 Attorneys at a Legal Research RE: Causes of action against Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25997 10/23/2009 Legal Research RE: causes of action against Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 26741-26763 10/23/2009 Attorneys at Legal Research RE: causes of action against Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 25774-25777 05/12/2009 Filed Motions W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18177-18179 08/24/2009 Epstein Probation W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by 73 EFTA00296217 Privilege Loa — Dated 2-23-2011 FROM DESCRIPTION & BATES DATE TO OBJECTION privacy rights 18174-18176 08/24/2009 El Epstein Probation W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18172-18173 08/24/2009 IIII Epstein Probation W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18170 08/24/2009 Epstein Probation W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy ri hts 03106 06/03/3009 Epstein Case Info W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02593-02594 05/13/2009 Discussion with secretary regarding client information W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08014 Undated Unknown Staff Miscellaneous case info W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 27494 10/23/2009 Attorneys at ■ IIII Legal Research RE: Causes of action against Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18166.18167 08/04/2009 Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 74 EFTA00296218 Privilege Log — Dated 2-23-2011 FROM & DESCRIPTION OBJECTION BATES DATE TO not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16795-16796 10/01/2009 ism Trump Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16455-16759 09.10/2009 Depo Dates W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16436-16437 09/09/2009 Dershowitz Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16400-16404 09/02/2009 Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16394-16395 08/31/2009 Depo Dates W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01046 08/25/2009 Computer information W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01048-01050 07/28/2010 Hard drive of Plaintiffs computer W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01052 09/09/2009 Attorneys at ■ Maribel Matiska legal Opinion RE: Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 76 EFTA00296219 Privile e Lo — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence; protected by privacy rights 01100 10/19/2009 Dershowitz Involvement W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01105 08/11/2009 Potential New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01111 05/13/2009 Legal research W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01112.01117 05/12/2009 Dr. Swan W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01139-01142 04/29/2009 Staff Epstein Depo revised W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01151 09/11/2009 Motion for protective order final draft W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01167 09/11/2009 Epstein MPO W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01216 05/21/2009 Immunity for testimony about prostitution W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by EFTA00296220 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION privacy rights 01247 09/30/2009 Therapy Notes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01268-01269 10/22/2009 Epstein meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01293 08/19/2009 Epstein Assets W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01299 04/21/2009 Order denying the motion to reassign or transfer W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01305 08/24/2009 Epstein Computers W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01313 09/02/2009 Attorneys at Epstein Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01333 08/03/3009 Epstein Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01335 08/03/2009 Investigation into Epstein planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 78 EFTA00296221 Privilege Log- Dated 2-23-2011 FROM & BATES DATE TO DESCRIPTION OBJECTION 01337 08/10/2009 Epstein Depo list W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01363 09/08/2009 Motion to freeze assets W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01414-01416 98/18/2009 & Epstein Potential Witness List W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01417 08/24/2009 Potential Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01429 09/09/2009 Attorneys at. Epstein telephone conference today W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01431 07/31/2009 Epstein case info W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01432 09/15/2009 New Victims W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01434 10/19/2009 Epstein Evidence W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01461 04/27/2009 Epstein Info W/P; Attorney Client Privilege; Irrelevant and 79 EFTA00296222 Privilege Log - Datec r i s i 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01466 07/31/20009 Epstein Presentation W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01471 07/18/2009 Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01480 07/22/2009 Attorneys at al Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01482 07/24/2009 Investigation into Epstein planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01491 08/10/2009 Investigative fees W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01492 08/10/2009 ME The Mar-a-Lago Club Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01495 08/11/2009 Potential Witness W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01498 08/17/2009 Legal opinion re:Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 80 EFTA00296223 Privile e Lo — Dated 2-23-2011 BATES DATE • FROM DESCRIPTION OBJECTION 01628 06/15/2009 Investigations W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01635 05/21/2009 le Personal Conversation W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01636 06/23/2009 Motion to unseal W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01638 06/29/2009 Litigation Strategy RE: Motion to unseal W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01644 07/06/2009 Confidential Source Request for admission W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01646 07/06/2009 Confidential Source Secret Plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01648 07/11/2009 Investigating Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01650 07/13/2009 Epstein's Assets W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01658-01659 07/18/2009 DOJ W/P; Attorney Client Privilege; Irrelevant and 83 EFTA00296224 Privilege Log — Dated 2-23-2011 FROM DESCRIPTION at BATES DATE TO OBJECTION discovery of admissible evidence; protected by privacy rights 01692 09/12/2009 Proposal for settlement W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01698 05/05/2009 IMI Epstein Victim Depos W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01702 09/17/2009 Epstein Depos W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01705 05/14/2009 Statutory Rape W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01711 04//01/2009 Third party subs W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01737 07/14/2009 Facebook/Myspace W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01564 05/11/2009 Attorneys at ■ Investigation Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01603 10/15/2009 Adam Horowitz Testimony RE: Vehicles W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by 85 EFTA00296225 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 04237-04242 06/15/2009 Epstein secret plea deal with Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04246 06/15/2009 Epstein secret plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04250 06/15/2009 Epstein Victims W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04255-04256 06/15/2009 Epstein secret plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04260 06/15/2009 Epstein secret plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 04523 05/14/2009 Investigating Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05088-05090 10/27/2009 Attorneys at Epstein's assets W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05108 04/01/2009 Victims employment W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 87 EFTA00296226 Privile e Lo. — Dated 2-23-2011 11 & BATES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02728.02729 08/04/2009 Spencer Kuvin Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02746 07/22/2009 Adam Steinberg Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02813.02814 08/26/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02817-02826 08/04/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02827-02832 05/12/2009 Attorneys at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02833-02835 08/23/2009 Other Rape Victims W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02874.02876 05/23/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02887-02888 08/26/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 89 EFTA00296227 Privile e Lo — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03050-03052 10/16/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03053 10/17/2009 a Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03054 10/13/2009 Attorneys at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03056 09/04/2009 Other Rape Victims W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03072 06/22/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03073 09/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03074-03075 10/28/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03100 10/15/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 93 EFTA00296228 Privilege Lori— Dated 2-23-2011 BATES DATE 11Q ROM DESCRIPTION OBJECTION 03197-03199 08/14/2009 Attorneys at., Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03205-03211 09/13/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03212 08/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03213 10/28/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03214-03218 10/27/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03223.03232 04/15/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03233-03242 09/28/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03245 06/01/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03251-03252 09/24/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and 96 EFTA00296229 Privilege Log — Dated 2-23-2011 i~iii& FROM DESCRIPTION BATES DATE IQ OBJECTION privacy rights 03524 09/04/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03525-03530 09/05/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03532 08/24/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03536 07/19/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03539-03540 08/26/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03541-03544 10/12/2009 Attorneys at ■ Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03545.03547 06/26/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03548.03549 04/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 99 EFTA00296230 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 03550-03574 09/09/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03575-03588 10/19/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03589-03604 04/11/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03605-03606 10/16/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03607-03610 10/16/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03611-03612 10/16/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03613.03615 10/29/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03616-03618 10/01/2009 Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03628-03637 09/15/2009 I Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and 100 EFTA00296231 Privilege Log — Dated 2-23-2011 BATES DATE 11Q FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03638-03641 09/08/2009 Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08454 10/23/2010 Attorneys at Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08118-08123 10/23/2009 Attorneys at. Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08124-08156 10/23/2009 Attorneys at Steven Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at I Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01913-01914 06/15/2009 I I Activity in case 9:08-cv-80893- KAM Doe v. Epstein Motion to Dismiss Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01918- 01919 04/15/2009 Attorneys at I Activity In case 9:08-cv-80893- KAM Doe v. Epstein Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01920-01924 05/20/2009 I. Activity in case 9:08-cv-80994- KAM Jane Doe No. 6 v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 101 EFTA00296232 Privilege Log — Dated 2-23-2011 BATES DATE 12 FROM DESCRIPTION OBJECTION Motion to Strike to the discovery of the admissible evidence; protected by privacy rights 01925 08/26/2009 I Surveillance/Interview Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01928-01929 08/03/2009 I Alfredo Rodriguez address Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01930 09/05/2009 I I Client info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01940 09/10/2009 I. Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01944-01952 04/10/2009 I Epstein assets Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01969 05/04/2009 I I Call from sources of information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01971.01972 05/13/2009 Attorneys at I Draft Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01973-01974 07/23/2009 I vs. Epstein — new investigator info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 102 EFTA00296233 Privilege Log — Dated 2-23-2011 St BATES PATE IQ FROM DESCRTTJal OBJECTION 02023 05/14/2009 Attorneys at. I deposition of Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02045-02046 09/04/2009 Attorneys at Doe v. Epstein — Letter Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights from Bob Critton 02049-02053 09/04/2009 Doe v. Epstein — Letter Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights from Bob Critton 02063-02064 05/19/2009 1 I. Epstein — Confirming Dialin Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights Telephone Conference for Monday , 6/8/09 at 2:00 p.m. 02089.02090 09/17/2009 I Epstein hearing Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02091.02092 06/16/2009 Attorneys at I. Epstein — Monthly Call in Telephone Conference Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02106-02108 04/29/2009 I I Epstein — Telephone Conference Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02109 05/13/2009 I. Epstein info — List of Plaintiff lawyers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02110-02111 09/15/2009 1 Epstein - Cancelling depositions Work product; attorney/client privilege; 104 EFTA00296234 Privilege Log — Dated 2-23-2011 & BATES DATE TO FROM DESCRIPTION OBJECTION in New York for the following week irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02112-02116 09/10/2009 Epstein — Yearbook picture of Epstein rape victims Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02117-02118 10/23/2009 I Epstein (AUSA) Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02119-02121 09/08/2009 S. I Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02130-02137 05/26/2009 I I Epstein cases- depositions in federal cases Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02138-02139 08/04/2009 I Epstein depo — New York Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02143-02146 09/28/2009 I Epstein Depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02229 05/05/2009 I Epstein Depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02236-02337 05/20/2009 Attorneys at I Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 105 EFTA00296235 Privilege Log- Dated 2-23-2011 FROM & Rau Rag ILR ----- DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 02256-02257 07/22/2009 Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02260-02261 07/22/2009 I Epstein — coordinating meetings Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02263-02265 07/23/2009 Attorneys at. Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02266 07/30/2009 I Epstein — Video Deposition oM in NY Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02273.02276 09/18/2009 I Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02278-02279 07/23/2009 Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02284-02855 05/11/2009 I I Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01769 10/30/2009 I Barbara Berg info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 106 EFTA00296236 Privilege Log— Dated 2-23-2011 BATES pATt TO FROM DESCRIPTION OBJECTION protected by privacy rights 01780 09/14/2009 I Discussion of belief that Epstein is transferring assets to avoid judgments Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01787-01788 09/04/2009 I 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01799-01801 10/14/2009 I Activity in case 9:08-cv-80119- KAM Doe v. Epstein Notification of ninety days expiring Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01804-01805 09/04/2009 S. I Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Order on motion for Medical Exam Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01806.01807 09/09/2009 I Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Motion for protective order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01808-01809 09/10/2009 I Activity in case 9:08-cv-80119- KAM Doe v. Epstein - Order on Motion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01810-01816 09/09/2009 Attorneys at 1 1 Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Response to Motion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01817-01818 06/11/2009 I Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Response to motion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 107 EFTA00296237 Privilege Log — Dated 2-23-2011 DESCRIPTION OBJECTION BATES DATE :EQ FROM 01840-01841 07/16/2009 IIIIIIIIII la I Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Order on Motion to Stay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01867-01868 09/28/2009 la I. Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Notice (Other) Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03662-03663 08/10/2009 Attorneys at. la I. Meeting with clients Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03664.03668 09/18/2009 I. Litigation strategy and preparation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08166-08168 10/28/2009 ■- I. Weds filing Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08169-08170 08/06/2009 1 Wexner deposition for 14th Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08190-08196 04/07/2009 I: Motion to unseal/Motion to stay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08265-08300 09/04/2009 Attorneys at ■ I Witness Information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08377-08378 10/02/2009 I Zorro Trust research info. Work product; attorney/client privilege; 108 EFTA00296238 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08441-08446 10/05/2009 Attorneys at Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03706-03718 08/05/2009 Cf. Response to Motion to File Epstein Affidavit Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03737 08/25/2009 Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03746-03753 08/02/2009 Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02335-02338 05/08/2009 Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02360-02361 06/09/2009 Hearing to Un-seal- Criminal Plea Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02368-02373 10/14/2009 Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 110 EFTA00296239 Privilege Log — Dated 2-23-2011 BATES DATE IQ FROM DESCRIPTION OBJECTION protected by privacy rights 02376-02392 10/14/2009 Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02401-02410 05/08/2009 Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02414-02419 05/12/2009 Attorneys at. Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03669-03670 10/08/2009 Epstein house arrest monitor Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02288-02289 05/26/2009 Motion date Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02292-02293 05/19/2009 Pimp and His Game Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 023O4-O2308 09/17/2009 Forensics/Investigations Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02313-02316 07/01/2009 Confidential Agreement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 111 EFTA00296240 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02173 09/04/2009 Attorneys at. Epstein Juan Alessi Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02187 07/26/2009 Epstein matter Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02195-02197 09/17/2009 Epstein Order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02199-02203 09/18/2009 Epstein Order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02211-02214 07/01/2009 Epstein v. State of Florida- Emergency Petition for Writ of Certiorari Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02224 07/28/2009 Witness of Epstein rapes from Switzerland Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10787-10799 10/19/2009 Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10901-10902 05/11/2009 RICO Enterprise Work product; attorney/client privilege; 112 EFTA00296241 Privilege Log — Dated 2-23-2011 BATES DATE 12 FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10904-10905 05/11/2009 Attorneys at RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10908-10909 05/11/2009 Attorneys at RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10912.10913 05/11/2009 Attorneys at. RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10955-10963 06/01/2009 Plaintiff's Witness list Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10979.10981 06/03/2009 Serve Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11022-11025 06/26/2009 Info on 2 MC2 Workers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11036.11037 07/21/2009 Serve Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11039-11071 07/21/2009 Retainer from the Firm Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 113 EFTA00296242 Privilege Log — Dated 2-23-2011 BATES DATE 12 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 11083-11084 09/04/2009 Attorneys at. Witness info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11105-11110 09/09/2009 Disseminate letter from Wexner attorney Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11137-11139 10/03/2009 Zorro Trust research info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11143-11146 10/04/2009 11/28 Discovery Cutoff Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11155-11156 10/18/2009 Attorneys at. New Property Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11175-11183 04/27/2009 Epstein Case info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11196-11197 05/28/2009 Jail Visitors Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11205.11207 05/28/2009 Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; i 114 EFTA00296243 Privilege Log — Dated 2-23-2011 BATES DATE 12 RIPKA DESCRIPTION OBJECTION 11359.11362 08/10/2009 Epstein depos Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11366-11371 08/11/2009 Trump depo info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11377-11379 08/12/2009 Issuing Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11390-11395 08/17/2009 Witness depos Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11400-11415 08/18/2009 Subpoenas for pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11420-11426 08/24/2009 Attorneys at Serving Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11428-11429 08/26/2009 Attorneys at Witness info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11568 10/07/2009 Meeting with Leslie Wexner Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11587 10/23/2009 Visoski Depo Work product; attorney/client privilege; 116 EFTA00296244 Privilege Log — Dated 2-23-2011 BATES DATE 12 FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11861.11865 10/23/2009 Attorneys at Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11870-11871 08/24/2009 Attorneys at Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11874 08/24/2009 Confidential info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11876 08/24/2009 Attorneys at Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11967-11972 10/29/2009 Subpoenas for Epstein's Attorneys Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08072-08075 07/22/2009 Total counts for Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08090.08091 10/05/2009 Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08114-08117 08/18/2009 Updated Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 117 EFTA00296245 Privilege Log — Dated 2-23-2011 BATES PATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08157-08159 06/03/2009 Vanity Fair Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08499.08501 08/24/2009 Attorneys at. Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10063.10068 08/03/2009 Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10090-10091 08/31/2009 Attorneys at Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10103-10104 08/27/2009 Attorneys at Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10106-10137 08/24/2009 Attorneys at Meetings/ Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 12569 07/30/2009 Epstein Sex Abuse Litigation Forum Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15827.15837 07/22/2009 Retainer for Investigator Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 118 EFTA00296246 Privilege Log— Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 15820-15822 10/29/2009 Subpoenas for Epstein's Attorneys Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15401-15412 09/09/2009 Disseminate the letter from wexner atty Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15356-15359 08/26/2009 Attorneys at Witness info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 14934-14950 07/22/2009 Investigator Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 13413-13414 08/06/2009 Epstein information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 13908-13911 08/24/2009 Attorneys at Meeting info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10595-10597 09/29/2009 Subpoena for Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10621.10624 10/02/2009 Meeting with Wexner atty Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 119 EFTA00296247 Privilege Log — Dated 2-23-2011 & BATES DATE TO FROM DESCRIPTION OBJECTION 10633.10638 10/05/2009 Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10681-10692 10/07/2009 Depositions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10777-10786 10/16/2009 New Evidence of Epstein Fraudulent Transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04094-04100 04/07/2009 Draft Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02915 10/03/2009 Attorneys at Finances Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02971 10/14/2009 Larry Visoski depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02976 09/09/2009 Disseminate the letter from wexner Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02995 06/24/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10172-10178 08/12/2009 Trump Depo Work product; attorney/client privilege; 120 EFTA00296248 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10193 08/11/2009 Trump Depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10255 09/09/2009 Depo of Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10259-10263 09/09/2009 Attorneys of. Cooperfield Service Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03876-03877 10/26/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03879-03884 07/13/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03886-03891 07/13/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03905-03920 09/08/2009 . Doe v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03937 08/17/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 121 EFTA00296249 Privilege Log — Dated 2-23-2011 BAT€S DATE M FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 04005-04011 05/13/2009 Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04070-04093 04/07/2009 Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03754 07/08/2009 Conference Call Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03848-03858 09/09/2009 Cooperfield Service Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03642-03643 09/04/2009 1. Accounts/ 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03657-03661 09/04/2009 Attorneys at Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02475 06/15/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02494.02515 09/20/2009 Mark Epstein Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 122 EFTA00296250 Privilege Log— Dated 2-23-2011 BATES DATE Lo FROM DESCRIPTION OBJECTION protected by privacy rights 02520-02543 06/06/2009 Memo of Assest Transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02560-02565 07/31/2009 Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02568-02570 10/13/2009 New Times Article Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02578.02583 05/28/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02619-02622 09/09/2009 New client Retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02633-02646 05/01/2009 Response to Motion to Consolidate + strategy Memo for Jay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07959.07964 09/24/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 123 EFTA00296251 Privilege Log— Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07616 07/22/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07530-07549 06/11/2009 Overtime Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07470-07507 07/09/2009 Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07447-07469 10/13/2009 Attorneys at New Times Article on epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07444-07446 05/01/2009 Response to Motion to Consolidate + Strategy Memo for Jay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07440 10/18/2009 Attorneys at New Trump Property Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07436 04/11/2009 New cases Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 125 EFTA00296252 Privilege Log — Dated 2-23-2011 BATES DATE m FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06800-06803 09/06/2009 RE: 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06761-06762 08/19/2009 Attorneys at. IME Rules Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06767-06769 09/10/2009 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06782.06787 04/10/2009 Confidential Detailed Strategy Memo on Asset Protection Issues Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06744.06747 05/01/2009 Depo of Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06736-06739 05/01/2009 Asset Protection Issue Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06709.06710 10/14/2009 Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 130 EFTA00296253 Privilege Log — Dated 2-23-2011 & BATES QATE 12 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05845 07/24/2009 Plane Tail Numbers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05811 06/09/2009 Witness Numbers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05813 08/15/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05748-05749 08/11/2009 Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05711 05/11/2009 Attorneys at. Subpoena Clinton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05701-05704 04/20/2009 Epstein strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05687 08/21/2009 Alfredo Rodriguez Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05690-05691 05/11/2009 Motion to Unseal Work product; attorney/client privilege; 136 EFTA00296254 Privilege Log— Dated 2-23-2011 BATES DATE IQ FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05680-05682 05/11/2009 Subpoena Clinton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05676 08/24/2009 Attorneys at. Topics for Meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05648 07/23/2009 Attorneys at Gary Assemble Epstein Litigation meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05629 08/03/2009 Law Enforcement cannot release juvenile reports Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05621.05622 09/18/2009 Preparing Motion to take an IME of Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05610-05612 04/27/2009 Request for Copies Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05588-05590 08/24/2009 Attorneys at. Travel restrictions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 137 EFTA00296255 Privilege Log— Dated 2-23-2011 & BATES DATE IQ FROM DESCRIPTION OBJECTION 05575-05576 08/21/2009 Alfredo Rodriguez Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05582 09/11/2009 Epstein strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05569-05570 08/17/2009 Legal Opinion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05556-05558 08/14/2009 Attorneys at Communication with legal expert Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05537 _ 07/30/2009 No objections from defense counsel regarding depo fora Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05534 07/24/2009 Flight logs for Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05518 07/22/2009 Attorneys at Assemble Epstein Litigation meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05512-05513 07/23/2009 Assemble Epstein Litigation meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 138 EFTA00296256 Privilege Log — Dated 2-23-2011 & BATES TO I FROM DESCRIPTION S 05399 10/17/2009 Proposal for settlement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05399 10/17/2009 Proposal for settlement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05271-05272 07/22/2009 Depo Dates to take_, and Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05259-05260 07/22/2009 Investigator retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05238 07/14/2009 File a request to produce Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05240-05241 08/24/2009 Attorneys at order on the Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights probation 05197-05199 08/24/2009 Attorneys at. Michael info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 140 EFTA00296257 Privilege Log - Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 05155.05156 04/20/2009 Set Epstein's depo duces tecum Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05159.05160 05/28/2009 Right to move to reconsider all rulings Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05149-05150 05/27/2009 Epstein filed a motion to continue the trial Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05153 08/24/2009 Epstein traveling Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05146-05147 05/26/2009 The response to the motion to continue is due 6/8 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05137-05144 05/20/2009 Attorneys at Epstein litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05133-05136 05/11/2009 Subpoena Clinton and others on Sid Garcia's witness list work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01749-01751 10/28/2009 Phaedra Xanthos Final affidavit from forensic accountant Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 141 EFTA00296258 Privilege Log — Dated 2-23-2011 BATE, DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05054-05065 08/18/2009 Attorneys at Epstein Potential witnesses Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05049-05053 08/18/2009 Subpoenas for potential witnesses Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04957-04964 09/04/2009 Juan Alessi statement and burglary report Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04952-04953 10/28/2009 Attorneys at. Epstein injunction filing — accountant affidavit will be sent Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04955-04956 09/03/2009 Attorneys at Epstein Invoice Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04916-04920 09/11/2009 Updates on # of victims, billing amounts, etc. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04899 09/10/2009 Epstein Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 143 EFTA00296259 Privile e Lo — Dated 2-23-2011 BATES DATE 1g FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 26479-26481 08/19/2009 Attorneys at. Assistance on the Epstein Case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 27155-27159 10/23/2009 Attorneys at. Steven PACER entries Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 26604-26605 10/27/2009 Phaedra Xanthos Political Contributions/advertisement for the rental on Little St. James Island Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 26570 08/13/2009 Discussions about Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04954 10/28/2009 Attorneys at. Creation of another Doe file Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06665.06670 08/12/2009 Epstein Costs Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06675-06676 08/26/2009 Personal convo in regards to moving offices Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 150 EFTA00296260 Privilege Loa — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 06679-06682 08/26/2009 Personal convo in regards to moving offices Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07590-07594 05/13/2009 Office information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08451-08453 08/17/2009 Updated Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08455.08456 06/03/2009 Vanity Fair Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08466-08479 08/26/2009 Attorneys at Witness info that we need to use Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01767 07/06/2009 Info on a guy going to Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights boyfriends house 08379 06/06/2009 Info on Former FHP trooper subcontracted by Riley Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08399 07/23/2009 Epstein affidavit to the reply memo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 151 EFTA00296261 Privilege Log — Dated 2-23-2011 BATcS DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08406 10/30/2009 Attorneys at Flying epstein rape survivor to St. Louis to see expert Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05697 08/19/2009 Meeting with client Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20330.20334 08/24/2009 Serving Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20327-20329 10/17/2009 Attorneys at. Property purchased by Epstein in Palm Beach Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20100.20102 08/24/2009 Attorneys at. Epstein's arrival at his building Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20283-20326 10/14/2009 Attorneys at Research regarding Mr. Visoski and questions to consider during the depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20092.20099 08/24/2009 Attorneys at Epstein travel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 152 EFTA00296262 Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 20085.20091 10/15/2009 Questions from accountant Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19996-20084 10/14/2O09 Attorneys at. Visoski Research and Questions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20217.20218 08/04/2009 Info on Copperfield Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20213-20216 08/03/2009 Attorneys at. Info on Copperfield Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20211-20212 08/03/2009 Pilots depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20207-20210 08/10/2009 List of witness Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20201-20204 08/24/2009 Attorneys at Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 153 EFTA00296263 Privilege Log - Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 20193-20200 08/24/2009 Attorneys at. Proof of him being out of FL — Violation of the agreement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19982-19985 09/03/2009 Dave Rogers depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19988 10/07/2009 Depositions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19971-19981 08/24/2009 Attorneys at. Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19969-19970 08/18/2009 Subpoenas for Pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19962.19968 08/03/2009 Working with the FBI to get some info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20190.20192 08/24/2009 Personal emails regarding Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights surgery 20187-20189 08/24/2009 Attorneys at Epstein travel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 154 EFTA00296264 Privilege Log — Dated 2-23-2011 RATES DATE 12 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 19959-19961 07/24/2009 Attorneys at Flight logs for Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 00156-00157 07/09/2009 2255 Problem Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15366-15367 09/04/2009 Attorneys at. Witness info that we need to use Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01003.01005 10/12/2009 Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01013.01014 10/29/2009 Subpoenaing Epstein's attorneys for their fees and accompanying documents Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01042 07/22/2009 New Info that our investigators obtained from current FBI agents Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03133-03134 06/09/2009 Personal conversation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 155 EFTA00296265