gov.uscourts.nysd.447706.1326.4.pdf

Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 1 of 35 EXHIBIT K  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 2 of 35 B O ,I E S, S CH I LL ER & F LE X N ER LL P 401 EAST LAS OLAS BOULEVARD• SUITE 1200 • FORT LAUDERDALE. FL 33301- 2211 • PH. 954.356.0011 • FAX 954.356.0022 Sigrid s. Mccawley, Esq. E-mail: [email protected] June 10, 2016 VIA E-MAIL Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 [email protected] Re: Giuffre v. Maxwell Case No.15-cv-07433-RWS Dear Ms. Menninger: On behalf of the Plaintiff, Virginia Giuffre, documents, Bates-stamped GIUFFRE005607 through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production. Certain of the documents within this production have been designated as CONFIDENTIAL in accordance with your proposed Protective Order. Please treat these documents accordingly. This production consists solely of all data that is responsive to Defendant's various requests for production from Ms. Giuffre's iCloud account. Attached to this letter, please also find an updated privilege log. If you have any questions concerning the foregoing, or if there are any issues with the media, please do not hesitate to contact me at (954) 356-0011. Sincerely, SSM:dk Enclosures WWW.BSFLLP.COM  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 3 of 35 From: Richards, Jason R. To: Robert Giuffre Subject: RE: Hi There Date: Wednesday, August 27, 2014 10:44:32 AM Hi Jenna, My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information you are looking for because I am not able to release information (should there be any) from FBI records. You need to include as many details as possible so they can focus and narrow the search. Explain that you are looking for information related to your recovery as a victim of Ron Eppinger. The process may take some time but it is the appropriate method for you to obtain any possible records regarding your recovery. Hope this helps. Best wishes, Jason -----Original Message----- From: Robert Giuffre Jane Doe 2 Sent: Wednesday, August 27, 2014 9:49 AM To: Richards, Jason R. Subject: Hi There G'day Jason, I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an era, just need a couple dates confirmed is all. If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept upside down looking through records and come up w nada. What was your acquaintance's name that took my statement about Ron Eppinger? Is it possible that it wasn't Wilton Manors and maybe it was somewhere else? I'm really racking my brain about this!! It would be a personal favor to me and I am so very much appreciative of anything you might know!! Thanks a lot mate!! Jenna Sent from my iPhone GIUFFRE005607 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 4 of 35 From: Richards, Jason R. To: Jane Doe 2 Subject: Re: Hi There Date: Wednesday, August 27, 2014 10:50:27 AM Feel free to reach out to me any time. Take care. Jason ----- Original Message ----- From: Robert Giuffre Jane Doe 2 To: Richards, Jason R. Sent: Wed Aug 27 10:46:50 2014 Subject: Re: Hi There Thank you Jason. I hope all has been well for you and yours! All the best, I won't bother you again. Jenna Sent from my iPhone > On Aug 27, 2014, at 10:44 AM, "Richards, Jason R." <[email protected]> wrote: > > Hi Jenna, > > My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information you are looking for because I am not able to release information (should there be any) from FBI records. You need to include as many details as possible so they can focus and narrow the search. Explain that you are looking for information related to your recovery as a victim of Ron Eppinger. The process may take some time but it is the appropriate method for you to obtain any possible records regarding your recovery. Hope this helps. > > Best wishes, > > Jason > > -----Original Message----- > From: Robert Giuffre Jane Doe 2 > Sent: Wednesday, August 27, 2014 9:49 AM > To: Richards, Jason R. > Subject: Hi There > > G'day Jason, > > I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an era, just need a couple dates confirmed is all. > > If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept upside down looking through records and come up w nada. What was your acquaintance's name that took my statement about Ron Eppinger? Is it possible that it wasn't Wilton Manors and maybe it was somewhere else? > > I'm really racking my brain about this!! It would be a personal favor to me and I am so very much appreciative of anything you might know!! GIUFFRE005608 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 5 of 35 > > Thanks a lot mate!! > > Jenna > > Sent from my iPhone GIUFFRE005609 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 6 of 35 From: Robert Giuffre To: [email protected] Subject: Virginia Roberts(Jane doe 102) Date: Tuesday, April 15, 2014 9:50:31 AM Hi Jason, Long time, no talk. I hope all has been well for you and yours!! I am now back in the USA, not too many people know about that and I'd like to keep it that way as my case against Jeffrey Epstein has intensified!! I am here to get this BS non- prosecution agreement thrown out and speaking w Judge Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI to assist our case further in proving how much pedophilia occurred by Jeffrey and the many other monsters he obliged w underage girls. If this is a possibility please let me know so I can give you Brad Edwards( my attorney) his contact details. Many thanks for your time and I hope we should meet again. Kindest Regards, Virginia Roberts Phone Jane Doe 2 Sent from my iPhone GIUFFRE005610 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 7 of 35 From: Robert Giuffre To: [email protected] Subject: Virginia Roberts re: Jeffrey Epstein Case Date: Wednesday, April 16, 2014 1:52:05 PM Hi Christina, I was wondering if you remember me from Sydney Consulate, I am a victim in the investigation from the Jeffrey Epstein case and was wondering if you could tell me if I would be able to get ahold of any of the pics and/or videos that the FBI might have confiscated from any of Epstein's residences? Also can I ask if you might have any of the flight logs that include my name in them to be sent to me as well. It's all for evidential purposes and would prove a many of things to help my case. Kindest Regards, Virginia Roberts Jane Doe 2 cell Sent from my iPhone GIUFFRE005611 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 8 of 35 From: Jane Doe 2 on behalf of Sharon Rikard To: Virginia Giuffre Subject: Re: Victims Refuse Silence Date: Saturday, March 28, 2015 9:49:55 AM Hi Virginia, So sorry for the late response. Our organization currently works with survivors of sex trafficking provided continuing education, life skills and counseling. We will help with transportation and their basic necessities. Our ultimate goal is a home for domestic minor sex trafficking survivors. Our contact information is: doorstofreedom.com [email protected] 843-817-0740 I am going to forward your information to our Attorney Generals office as Marie Sazehn has compiled a list of organizations in our state of people/organizations and their involvement in helping survivors. Thanks for all you are doing to help others! Blessings, Sharon Rikard GIUFFRE005612 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 9 of 35 From: Virginia Giuffre To: Subject: Victims Refuse Silence Date: Wednesday, March 18, 2015 12:19:06 PM Hi Sharon, This is Virginia, we spoke earlier and I just wanted to say thank you for your time and what your doing to help the victims in your area. The mentality has to be changed!! Good luck!! Kindest Regards, Virginia Roberts Sent from my iPhone GIUFFRE005613 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 10 of 35 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type AC Privilege and Work Product/joint Email chain with Giuffre, Edwards and Cassell re attorney defense/commo 1 2/12/2015 6:14 Virginia Giuffre [email protected] impressions and legal advice relating to deposition testimony n interest Withheld 3 msg - AC Privilege and Work [email protected],br Product/joint Jane Doe 2 [email protected], defense/commo 2 2/16/2015 1:05 [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 msg Attorney Client/joint defense/commo Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work 3 2/16/2015 15:37 Virginia Giuffre [email protected] information provided by client to assist in legal advice product Withheld 2 msg Attorney Client/joint defense/commo Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work 4 2/16/2015 16:15 Sigrid McCawley Jane Doe 2 information provided by client to assist in legal advice product Withheld 2 msg Attorney Client/joint defense/commo Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work 5 2/16/2015 16:24 Virginia Giuffre [email protected] information provided by client to assist in legal advice product Withheld 2 msg Attorney Client/joint defense/commo Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work 6 2/16/2015 16:24 Sigrid McCawley Jane Doe 2 information provided by client to assist in legal advice product Withheld 2 msg AC Privilege and [email protected],bra Work [email protected],cassell Product/joint [email protected],robiejenna defense/commo 7 2/21/2015 16:45 Sigrid McCawley [email protected] [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 11 of 35 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type AC Privilege and Work Product/joint defense/commo 8 2/21/2015 16:58 Virginia Giuffre [email protected] Discussion of evidence among client and attorney n interest Withheld 2 msg AC Privilege and Work - [email protected],cassellp@l Product/joint aw.utah.edu,Jane Doe 2 defense/commo 9 2/21/2015 17:05 Brad Edwards [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 msg AC Privilege and Work Product/joint defense/commo 10 2/21/2015 17:10 Sigrid McCawley Jane Doe 2 Discussion of evidence among client and attorney n interest Withheld 3 msg AC Privilege and Work Product/joint defense/commo 11 2/21/2015 17:16 Virginia Giuffre [email protected] Discussion of evidence among client and attorneys n interest Withheld 3 msg AC Privilege and Work [email protected],brad@pat Product/joint htojustice.com,[email protected]. defense/commo 12 2/23/2015 14:21 Sigrid McCawley Jane Doe 2 edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg AC Privilege and Work Product/joint Jane 2/23/2015 14:29 [email protected] [email protected], I [email protected],cassellp@ law.utah.edu Discussion of thoughts and impressions of attorneys defense/commo n interest Withheld 13 1 msg AC Privilege and Work [email protected],brad@pat Product/joint htojustice.com,[email protected]. defense/commo 14 2/23/2015 16:01 Virginia Giuffre [email protected] edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 12 of 35 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type AC Privilege and Work Product/joint Email chain with McCawley, Giuffre, and Paralegals re seeking defense/commo 15 2/24/2015 17:51 Sigrid McCawley Jane Doe 2 information to assist in legal advice, with attachment n interest Withheld 4 msg AC Privilege and Work Product/joint defense/commo 16 Attached case research n interest Withheld 14 rtf AC Privilege and Work Product/joint Email chain with Giuffre, McCawley and legal assistant re legal defense/commo 17 2/26/2015 12:59 Virginia Giuffre [email protected] document, with attachment n interest Withheld 1 msg AC Privilege and Work Product/joint defense/commo 18 Attached draft legal document n interest Withheld 1 jfif AC Privilege and Work Product/joint Email with Giuffre, McCawley, Edwards and Henderson re defense/commo 19 2/28/2015 17:47 Virginia Giuffre [email protected] discussion of draft statement n interest Withheld 3 msg AC Privilege and Work Product/joint [email protected],brad@pa Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 20 3/13/2015 17:29 Stan Pottinger Jane Doe 2 thtojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg AC Privilege and Work Product/joint Email chain with Giuffre, Edwards, McCawley and Pottinger re defense/commo 21 3/13/2015 17:49 Virginia Giuffre [email protected] legal advice on media issues n interest Withheld 2 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 13 of 35 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type AC Privilege and Work Product/joint [email protected],brad@pa Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 22 3/13/2015 17:56 [email protected] Jane Doe 2 thtojustice.com Pottinger re legal advice on media issues n interest Withheld 3 msg AC Privilege and Work Product/joint Jane Doe [email protected],■ Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 23 3/13/2015 18:00 Brad Edwards [email protected] Pottinger re legal advice on media issues n interest Withheld 3 msg AC Privilege and Work Product/joint Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 24 3/13/2015 18:24 Virginia Giuffre [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg AC Privilege and Work Product/joint Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 25 3/13/2015 18:25 Virginia Giuffre [email protected] Pottinger re legal advice on media issues n interest Withheld 3 msg AC Privilege and Work Product/joint [email protected],StanPotti Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 26 3/13/2015 21:53 Virginia Giuffre [email protected] [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg AC Privilege and Work Product/joint Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 27 3/13/2015 23:38 Brad Edwards Jane Doe 2 Pottinger re legal advice on media issues n interest Withheld 4 msg AC Privilege and Work Product/joint Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo 28 3/13/2015 23:40 Virginia Giuffre [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 14 of 35 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type Attorney Client/joint [email protected],br defense/commo [email protected],stan Providing information to assist in legal advice re potential legal n interest/work 29 3/17/2015 15:20 Virginia Giuffre [email protected] action, with attachments product Withheld 1 msg - Attorney Client/joint [email protected],br defense/commo Jane Doe 2 [email protected], Email chain with Giuffre, Edwards, Pottinger and McCawley re n interest/work 30 3/17/2015 18:40 Stan legal advice related to VRS product Withheld 1 msg Attorney Client/joint defense/commo Email chain with Giuffre, Edwards, Pottinger and McCawley re n interest/work 31 3/17/2015 19:42 Virginia Giuffre [email protected] legal advice related to VRS product Withheld 1 msg Attorney Client/joint Jane [email protected], I ,stan [email protected],brittany@path Email chain with Giuffre, Edwards, Henderson, Pottinger, defense/commo n interest/work 32 3/20/2015 15:43 Sigrid McCawley [email protected] tojustice.com McCawley and BSF staff re legal advice related to VRS product Withheld 1 msg Attorney Client/joint defense/commo n interest/work 33 3/20/2015 15:57 Sigrid McCawley Jane Doe 2 Providing legal advice re potential deposition product Withheld 1 msg Attorney Client/joint defense/commo Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work 34 3/24/2015 21:19 Sigrid McCawley Jane Doe 2 [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016  Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 15 of 35 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type Attorney Client/joint defense/commo Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work 35 3/24/2015 21:21 Virginia Giuffre [email protected] [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg Attorney Client/joint defense/commo Jane 36 3/24/2015 21:36 A