gov.uscourts.nysd.447706.156.7.pdf

Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 1 of 6 EXHIBIT G  Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 2 of 6 Unidentified "Professionals" Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type Plaintiff has objected that Defendant’s requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Jane Doe #1 and Jane Doe #2 v. United States ("CVRA case"), Case no. 08‐ 80736‐CIV‐Marra, pending in the Southern District Virginia Giuffre, Brad of Florida. Documents withheld pursuant to the Edwards, Paul Cassell, Virginia Giuffre, Brad privileges asserted included communications from Brittany Henderson (and Edwards, Paul Cassell, Ms. Giuffre to the attorneys listed seeking legal other , Sigrid McCawley, Brittany Henderson, Sigrid advice related to the CVRA case, communications Meredith Schultz, David McCawley, Meredith from the attorneys to Ms. Giuffre giving legal Appro Emails, Boies, Jack Scarola, Stan Schultz, David Boies, Jack advice or giving attorney mental impressions x. 1.3K letters, and Pottinger, Ellen Brockman, Scarola, Stan Pottinger, related to the CVRA case, communications sending docs other Legal Assistants, Ellen Brockman, Legal or attaching attorney work product related to the overla communicat Professionals retained by Assistants, Professionals CVRA case, and/or communications sending or AC Privilege and pping ions from attorneys to aid in the retained by attorneys to aid attaching client revisions to attorney work product Work Product/joint with 2011 ‐ rendition of legal advice in the rendition of legal related to the CVRA case, and communications re defense/common other 125 Present and representation advice and representation evidence. interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 3 of 6 Unidentified "Professionals" Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type Plaintiff has objected that Defendant’s requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Giuffre v. Maxwell (“Maxwell case”), 15‐cv‐07433‐RWS, pending in the Southern District of New York, since the date Virginia Giuffre, Brad of filing, September 21, 2015. Documents Edwards, Paul Cassell, Virginia Giuffre, Brad withheld pursuant to the privileges asserted Brittany Henderson, Sigrid Edwards, Paul Cassell, included communications from Ms. Giuffre to the McCawley, Meredith Brittany Henderson, Sigrid attorneys listed seeking legal advice related to the Schultz, David Boies, McCawley, Meredith Maxwell case, communications from the attorneys Appro Emails, Stephen Zach, Stan Schultz, David Boies, to Ms. Giuffre giving legal advice or giving attorney x. 1.3K letters, and Pottinger, Ellen Brockman, Stephen Zach, Stan mental impressions related to the Maxwell case, docs other Legal Assistants, Pottinger, Ellen Brockman, communications sending or attaching attorney overla communicat Professionals retained by Legal Assistants, work product related to the Maxwell case, and/or AC Privilege and pping ions from attorneys to aid in the Professionals retained by communications sending or attaching client Work Product/joint with 9/21/15 ‐ rendition of legal advice attorneys to aid in the revisions to attorney work product related to the defense/common other 126 Present and representation rendition of legal advice and Maxwell case, and communications re evidence. interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 4 of 6 Unidentified "Professionals" Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type Plaintiff has objected that Defendant s requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Bradley Edwards and Paul Cassell v. Alan Dershowitz(“Dershowitz case”), Case no. 15000072, pending in the Seventeenth Judicial Circuit, Broward County, Virginia Giuffre, Brad Florida. Documents withheld pursuant to the Edwards, Paul Cassell, Virginia Giuffre, Brad privileges asserted included communications from Brittany Henderson, Sigrid Edwards, Paul Cassell, Ms. Giuffre to the attorneys listed seeking legal McCawley, Meredith Brittany Henderson, Sigrid advice related to the Dershowitz case, Emails, Schultz, David Boies, McCawley, Meredith communications from the attorneys to Ms. Giuffre Appro letters, and Stephen Zach, Stan Schultz, David Boies, giving legal advice or giving attorney mental x. 1.3K other Pottinger, Ellen Brockman, Stephen Zach, Stan impressions related to the Dershowitz case, docs communicat Legal Assistants, Pottinger, Ellen Brockman, communications sending or attaching attorney overla ions from Professionals retained by Legal Assistants, work product related to the Dershowitz case, AC Privilege and pping January attorneys to aid in the Professionals retained by and/or communications sending or attaching Work Product/joint with 2015 ‐ rendition of legal advice attorneys to aid in the client revisions to attorney work product related defense/common other 127 Present and representation rendition of legal advice and to the Dershowitz case, and communications re interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 5 of 6 Unidentified "Professionals" Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type Plaintiff has objected that Defendant’s requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). Correspondence re: Jane Doe No. 102 v. Jeffrey Epstein(“Epstein case”), Case No. 09‐80656‐ CIV‐Marra/Johnson (Southern District of Florida). Documents withheld pursuant to the privileges asserted included communications from Ms. Giuffre to the attorneys listed seeking legal advice related to the Epstein case, communications from Virginia Giuffre, Bob the attorneys to Ms. Giuffre giving legal advice or Appro Emails, Josefsberg, Katherine W. giving attorney mental impressions related to the x. 1.3K letters, and Ezell, Amy Ederi, other Epstein case, communications sending or docs other Podhurst attorneys, Legal attaching attorney work product related to the overla communicat Assistants, and Epstein case, and/or communications sending or AC Privilege and pping ions from Professionals retained by attaching client revisions to attorney work product Work Product/joint with 2009 ‐ attorneys to aid in the related to the Epstein case, and communications defense/common other 128 Present rendition of legal advice re evidence. interest Withheld cases  Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 6 of 6 Unidentified "Professionals" Log Email Sent Privilege Page Doc ID Date Email From Email To CC Address Subject Matter Type of Privilege Action Count Type Plaintiff has objected that Defendant’s requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule26.2(c). This categorical entry is regarding correspondencere potential legal action against entities and individuals. Documents withheld pursuant to the privileges asserted included Virginia Giuffre, Brad Virginia Giuffre, Brad communications from Ms. Giuffre to the attorneys Edwards, Paul Cassell, Edwards, Paul Cassell, listed seeking legal advice related to potential law Brittany Henderson, Sigrid Brittany Henderson, Sigrid suits, communications from the attorneys to Ms. Emails, McCawley, Meredith McCawley, Meredith Giuffre giving legal advice or giving attorney letters, and Schultz, David Boies, Schultz, David Boies, mental impressions related to the law suits, Appro other Stephen Zach, Stan Stephen Zach, Stan communications sending or attaching attorney x. 1.3K communicat Pottinger, Ellen Brockman, Pottinger, Ellen Brockman, work product related to potential lawsuits, and/or overla ions from Legal Assistants, Legal Assistants, communications sending orattaching client AC Privilege and pping January Professionals retained by Professionals retained by revisions to attorney work product relatedto Work Product/joint with 2015 ‐ attorneys to aid in the attorneys to aid in the potential lawsuits, and communications re defense/common other 152 Present rendition of legal advice rendition of legal advice evidence. interest Withheld cases