EFTA01079793.pdf
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70
EXHIBIT A
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
EFTA01079793
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged
Objection Abbreviation
General Objections --
Inadequate Privilege Log Inadequate Log
Failure to Prove Factual Underpinnings of Privilege Claim No Factual Underpinnings
Waiver of Confidentiality Waiver
Government's Fiduciary Duty to Crime Victims Bars Privilege Fiduciary Duty
Communications Facilitating Crime-Fraud-Misconduct Not Covered Crime-Fraud-Misconduct
Factual Materials Not Covered Factual Materials
Documents Not Prepared in Anticipation of CVRA Litigation Not in Anticipation of Litigation
Attorney Client Objections -
Ordinary Governmental Communications Not Covered Ordinary Government Communication
Attorney-Client Relationship Not Established No Attorney-Client Relationship
Deliberative Process Objections -
Privilege Not Properly Invoked Improper Invocation
Final Decision Exempted from Privilege Final Decision
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Investigative Privilege -
Privilege Not Properly Invoked Improper Invocation
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Product Doctrine
No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Claims Against Public Prosecutor
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Attorney Conduct at Issue
Rule 6(e)
Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) Court Authorized Under 6(e)(3)(E)
The Court Has Inherent Power to Release Grand Jury Materials Court Inherent Power to Release
Victims Have Properly Petitioned for the Release of Grand Jury Proper Victim's Petition
The CVRA Gives the Court Authority to Release Grand Jury Materials CVRA-authorized release
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EFTA01079794
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Grand Jury Materials Can Be Severed from Other Materials Material Severable
The Privacy Rights of Other Victims
Government Redaction Can Resolve Privacy Concerns Redaction
No Assertion of Privacy Rights by Other Victims No Assertion by Victims
Privacy Act
The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Court-Compelled Disclosure
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings;
P-000001 SUBPOENAS" containing correspondence Work Product Fiduciary Duty; Not in Anticipation of
thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor;
P-000039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable; Overriding Need
Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in
thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper
P-000549 related to enforcement of same, documents subject to investigative Invocation; Overriding Need; Claims Against
produced in response to some subpoenas; privilege Public Prosecutor; Attorney Conduct at Issue;
and attorney (Villafafia) handwritten notes Also contains documents Factual Materials; Court Authorized Under
subject to privacy rights of 6(e)(3)(E); Court Inherent Power to Release;
victims who are not Proper Victim's Petition; CVRA-authorized
parties to this litigation release; Material Severable; Redaction; No
Assertion by Victims; Overriding Need
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EFTA01079795
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Ritz Compact Flash 6(e) Inadequate Log; No Factual Underpinnings;
P-000550 SW" containing copies of a sealed search Contains information Fiduciary Duty; Factual Materials; Not in
thru warrant application, warrant, and subject to investigative Anticipation of Litigation; Improper
P-000621 supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "PNY Technologies 6(e) Inadequate Log; No Factual Underpinnings;
P-000622 Compact Flash SW" containing copies of a Contains information Fiduciary Duty; Factual Materials; Not in
thru sealed search warrant application, warrant, subject to investigative Anticipation of Litigation; Improper
P-000693 and supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "JE Corporations" Work Product Inadequate Log; No Factual Underpinnings;
P-000694 containing attorney research on Epstein- Contains information Fiduciary Duty; Not in Anticipation of
thru owned corporations and prior litigation subject to investigative Litigation; Improper Invocation; Overriding
P-000781 privilege Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Overriding Need
Box #1 File folder entitled "Capital One" 6(e) Inadequate Log; No Factual Underpinnings;
P-000782 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court
thru Authorized Under 6(e)(3)(E); Court Inherent
P-000803 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
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EFTA01079796
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "DTG 6(e) Inadequate Log; No Factual Underpinnings;
P-000804 Operations/Dollar Rent-a-Car" containing Contains documents and Fiduciary Duty; Factual Materials; Not in
thru subpoena and responsive documents information subject to Anticipation of Litigation; Improper
P-000854 investigative privilege Invocation; Overriding Need; Factual
Also contains documents Materials; Court Authorized Under 6(e)(3)(E);
and information subject to Court Inherent Power to Release; Proper
privacy rights of victims Victim's Petition; CVRA-authorized release;
who are not parties to this Material Severable; Redaction; No Assertion
litigation by Victims
Box #1 File folder entitled "JP Morgan Chase" 6(e) Inadequate Log; No Factual Underpinnings;
P-000855 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000937 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled 'Washington Mutual" 6(e) Inadequate Log; No Factual Underpinnings;
P-000938 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000947 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Computer Search &" Work Product Inadequate Log; No Factual Underpinnings;
P-000948 containing legal research on computer Attorney-Client Fiduciary Duty; Factual Materials; Not in
thru search and handwritten notes on indictment Contains information Anticipation of Litigation; Ordinary
P-000982 preparation subject to investigative Government Communication; No Attorney-
privilege. Also contains Client Relationship; Improper Invocation;
information subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue;
who are not parties to this Redaction; No Assertion by Victims
litigation
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EFTA01079797
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Attorney Notes from Work product Inadequate Log; No Factual Underpinnings;
P-000983 Document Review" containing typed and 6(e) Fiduciary Duty; Factual Materials; Not in
thru handwritten attorney (Villafafia) notes, Contains information Anticipation of Litigation; Improper
P-001007 target letters, correspondence re grand jury subject to investigative Invocation; Overriding Need; Claims Against
subpoena privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Notes from Fed Ex Work Product Inadequate Log; No Factual Underpinnings;
P-001008 Records" containing handwritten and typed 6(e) Fiduciary Duty; Factual Materials; Not in
thru attorney (Villafafia) notes and screen shots Contains information Anticipation of Litigation; Improper
P-001056 of FedEx subpoena response electronic file subject to investigative Invocation; Overriding Need; Claims Against
privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Colonial Bank 6(e) Inadequate Log; No Factual Underpinnings;
P-001057 Records" containing records received in Contains information Fiduciary Duty; Not in Anticipation of
thru response to grand jury subpoena subject to investigative Litigation; Improper Invocation; Overriding
P-001959 privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
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EFTA01079798
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "OLY Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-001960 Vol 2: OLY-51 THROUGH" containing Contains information Fiduciary Duty; Factual Materials; Not in
Thru subpoenas numbered OLY-51 through subject to investigative Anticipation of Litigation; Improper
P-002089 OLY-81 with related correspondence privilege. Also contains Invocation; Overriding Need; Factual
information subject to Materials; Court Authorized Under 6(e)(3)(E);
privacy rights of victims Court Inherent Power to Release; Proper
who are not parties to this Victim's Petition; CVRA-authorized release;
litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled - Epstein Corporate 6(e) Inadequate Log; No Factual Underpinnings;
P-002090 Records: OLY-51, OLY-52, OLY-53, Contains information and Fiduciary Duty; Not in Anticipation of
Thru OLY-54" containing subpoenas, records documents subject to Litigation; Improper Invocation; Overriding
P-002169 received in response to subpoenas, and investigative privilege Need; Factual Materials; Court Authorized
related correspondence Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Colonial Bank" 6(e) Inadequate Log; No Factual Underpinnings;
P-002170 containing subpoenas, correspondence Contains information and Fiduciary Duty; Not in Anticipation of
Thru related to subpoenas, records received in documents subject to Litigation; Improper Invocation; Overriding
P-002246 response to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "JEGE & Hyperion 6(e) Inadequate Log; No Factual Underpinnings;
P-002247 from Goldberger OLY-46 & OLY-47" Contains information and Fiduciary Duty; Not in Anticipation of
Thru containing documents received in response documents subject to Litigation; Improper Invocation; Overriding
P-002265 to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
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EFTA01079799
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002266 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, of individuals listed as and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
"Additional victims" privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable
litigation
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002387 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002769 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, relevant pieces of grand jury and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
materials, telephone records/flight records privacy rights of victims Proper Victim's Petition; CVRA-authorized
analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No
photographs, DAVID records, NCICs, and litigation Assertion by Victims
related materials for persons identified as
Jane Does #15, 16, 17, 18, 19, Past
Em lo ees, Misc. Witnesses
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EFTA01079800
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002770 witness/victim list with identifying 6(e) Fiduciary Duty; Factual Materials; Not in
Thru information, sexual activity summary, Contains information and Anticipation of Litigation; Improper
P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against
(Villafafia) handwritten notes, 302s, investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
portions of state investigative file, attorney Also contains information Redaction; No Assertion by Victims
(Villafafia) typed notes, relevant pieces of and documents subject to
grand jury materials, telephone privacy rights of victims
records/flight records analysis charts, who are not parties to this
victim/witness photographs, DAVID litigation
records, NCICs, and related materials for
persons identified as Jane Does #1, 2, 3, 4,
5, 6, 7, 8
Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings;
P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper
P-003545 a number of victim/witnesses documents subject to Invocation; Overriding Need; Claims Against
, an investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
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EFTA01079801
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 FBI Reports of March 2008 interviews of Work product Inadequate Log; No Factual Underpinnings;
P-003546 additional witness/victim located in New 6(e) Fiduciary Duty; Factual Materials; Not in
Thru York Contains information and Anticipation of Litigation; Improper
P-003552 documents subject to Invocation; Overriding Need; Claims Against
investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Box #1 Printout of filenames from Federal Express Work product Inadequate Log; No Factual Underpinnings;
P-003553 subpoena response with Attorney notations 6(e) Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003555B Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable
Box #1 Document entitled "Identified Numbers" Work product Inadequate Log; No Factual Underpinnings;
P-003556 with accompanying handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru list compiled from grand jury materials and Contains information Litigation; Improper Invocation; Overriding
P-003562 attorney analysis of records subject to investigative Need; Claims Against Public Prosecutor;
privilege Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
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EFTA01079802
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Folder entitled "Flight Manifests" 6(e) Inadequate Log; No Factual Underpinnings;
P-003563 containing manifests received pursuant to Contains information and Fiduciary Duty; Not in Anticipation of
Thru grand jury subpoena documents subject to Litigation; Improper Invocation; Overriding
P-003629 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Recent Attorney Work product Inadequate Log; No Factual Underpinnings;
P-003630 Notes" containing handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru (Villafafia) notes regarding document Investigative privilege Litigation; Improper Invocation; Overriding
P-003633 review and case strategy Deliberative process Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Box #1 File folder bearing victim name containing Work product Inadequate Log; No Factual Underpinnings;
P-003634 FBI interview report from May 2008, Attorney-client privilege Fiduciary Duty; Factual Materials; Not in
Thru telephone activity report with attorney 6(e) Anticipation of Litigation; Ordinary
P-003646 (Villafanafia) handwritten notes, related Investigative privilege Government Communication; No Attorney-
grand jury material Also contains information Client Relationship; Improper Invocation;
and documents subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue; Factual
who are not parties to this Materials; Court Authorized Under 6(e)(3)(E);
litigation Court Inherent Power to Release; Proper
Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
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EFTA01079803
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #I File folder entitled "Summary of Sexual Work product Inadequate Log; No Factual Underpinnings;
P-003647 Activity" containing chart bearing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru handwritten title "Sexual Activity — Investigative privilege Anticipation of Litigation; Improper
P-003651 Summary" with meta-analysis of Deliberative process Invocation; Overriding Need; Claims Against
information, sorted by name of each Also contains information Public Prosecutor; Attorney Conduct at Issue;
victim/witness, including name and and documents subject to Factual Materials; Court Authorized Under
identifying information of each privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
victim/witness who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Victim Civil Suits" Not privileged. N/A
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research it JE Work product Inadequate Log; No Factual Underpinnings;
P-003664 Websites" containing attorney research Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003678 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Serene Cano (N.Y. Work product Inadequate Log; No Factual Underpinnings;
P-003679 AUSA)" containing attorney (Villafafia) Fiduciary Duty; Not in Anticipation of
Thru handwritten notes Litigation; Claims Against Public Prosecutor;
P-003680 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Dr. Anna Salter" Work product Inadequate Log; No Factual Underpinnings;
P-003681 containing attorney (Villafafia) memo to Investigative privilege Fiduciary Duty; Not in Anticipation of
Thru expert witness and handwritten attorney Litigation; Improper Invocation; Overriding
P-003687 notes Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue
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EFTA01079804
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "IR G[] Interview" Work product Inadequate Log; No Factual Underpinnings;
P-003688 containing attorney handwritten notes of Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru interview, and attorney handwritten notes Also contains information Anticipation of Litigation; Improper
P-003693 regarding potential charges subject to privacy rights of Invocation; Overriding Need; Claims Against
victims who are not Public Prosecutor; Attorney Conduct at Issue;
parties to this litigation Redaction; No Assertion by Victims
Box #1 File folder entitled "Research re Travel for Work product Inadequate Log; No Factual Underpinnings;
P-003694 Prostitution" containing attorney 6(e) Fiduciary Duty; Factual Materials; Not in
Thru (VillafaiIa) handwritten notes regarding Investigative privilege Anticipation of Litigation; Improper
P-003711 grand jury presentation, chart entitled Also contains information Invocation; Overriding Need; Claims Against
"Brought to Epstein's House" with and documents subject to Public Prosecutor; Attorney Conduct at Issue;
handwritten notes, Message Pad meta- privacy rights of victims Factual Materials; Court Authorized Under
analysis chart, summary of evidence who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
related to one victim/witness, and relevant litigation Proper Victim's Petition; CVRA-authorized
grand jury information release; Material Severable; Redaction; No
Assertion by Victims
Box #1 Empty file folder bearing name of Investigative privilege N/A
P-003712 victim/witness Also contains information
subject to privacy rights of
victim who is not a party
to this litigation
Box #1 File folder entitled "T[] M[]" containing 6(e) Inadequate Log; No Factual Underpinnings;
P-003713 grand jury subpoenas, motion and order to Documents under seal Fiduciary Duty; Factual Materials; Court
Thru compel testimony, and correspondence pursuant to court order Authorized Under 6(e)(3)(E); Court Inherent
P-003746 regarding same Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Box #1 File folder entitled 6(e) Inadequate Log; No Factual Underpinnings;
P-003747 containing subpoena an correspondence Fiduciary Duty; Factual Materials; Court
Thru regarding same Authorized Under 6(e)(3)(E); Court Inherent
P-003751 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
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EFTA01079805
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "PBPD Investigative 6(e) Inadequate Log; No Factual Underpinnings;
P-003752 File" obtained via subpoena Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru Also contains information Anticipation of Litigation; Improper
P-004295 and documents subject to Invocation; Overriding Need; Factual
privacy rights of victims Materials; Court Authorized Under 6(e)(3)(E);
who are not parties to this Court Inherent Power to Release; Proper
litigation Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings;
P-004296 containing meta-analysis chart showing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone calls, travel, and grand jury Investigative privilege Anticipation of Litigation; Improper
P-004350 materials relevant to possible charges Also contains information Invocation; Overriding Need; Claims Against
and documents subject to Public Prosecutor; Attorney Conduct at Issue;
privacy rights of victims Factual Materials; Court Authorized Under
who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
litigation Proper Victim's Petition; CVRA-authorized
release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled Work product Inadequate Log; No Factual Underpinnings;
P-004351 Documents 53909- Fiduciary Duty; Not in Anticipation of
Thru attorney research related to bias issue Litigation; Claims Against Public Prosecutor;
P-004381 Overriding Need; Attorney Conduct at Issue
Box #1 File Folder entitled "FEDEX" containing 6(e) Inadequate Log; No Factual Underpinnings;
P
EXHIBIT A
PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
EFTA01079793
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PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS
Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged
Objection Abbreviation
General Objections --
Inadequate Privilege Log Inadequate Log
Failure to Prove Factual Underpinnings of Privilege Claim No Factual Underpinnings
Waiver of Confidentiality Waiver
Government's Fiduciary Duty to Crime Victims Bars Privilege Fiduciary Duty
Communications Facilitating Crime-Fraud-Misconduct Not Covered Crime-Fraud-Misconduct
Factual Materials Not Covered Factual Materials
Documents Not Prepared in Anticipation of CVRA Litigation Not in Anticipation of Litigation
Attorney Client Objections -
Ordinary Governmental Communications Not Covered Ordinary Government Communication
Attorney-Client Relationship Not Established No Attorney-Client Relationship
Deliberative Process Objections -
Privilege Not Properly Invoked Improper Invocation
Final Decision Exempted from Privilege Final Decision
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Investigative Privilege -
Privilege Not Properly Invoked Improper Invocation
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Product Doctrine
No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Claims Against Public Prosecutor
Qualified Privilege Overridden By the Victims' Need for the Documents Overriding Need
Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Attorney Conduct at Issue
Rule 6(e)
Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) Court Authorized Under 6(e)(3)(E)
The Court Has Inherent Power to Release Grand Jury Materials Court Inherent Power to Release
Victims Have Properly Petitioned for the Release of Grand Jury Proper Victim's Petition
The CVRA Gives the Court Authority to Release Grand Jury Materials CVRA-authorized release
Page 1 of 69
EFTA01079794
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Grand Jury Materials Can Be Severed from Other Materials Material Severable
The Privacy Rights of Other Victims
Government Redaction Can Resolve Privacy Concerns Redaction
No Assertion of Privacy Rights by Other Victims No Assertion by Victims
Privacy Act
The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Court-Compelled Disclosure
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings;
P-000001 SUBPOENAS" containing correspondence Work Product Fiduciary Duty; Not in Anticipation of
thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor;
P-000039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable; Overriding Need
Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in
thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper
P-000549 related to enforcement of same, documents subject to investigative Invocation; Overriding Need; Claims Against
produced in response to some subpoenas; privilege Public Prosecutor; Attorney Conduct at Issue;
and attorney (Villafafia) handwritten notes Also contains documents Factual Materials; Court Authorized Under
subject to privacy rights of 6(e)(3)(E); Court Inherent Power to Release;
victims who are not Proper Victim's Petition; CVRA-authorized
parties to this litigation release; Material Severable; Redaction; No
Assertion by Victims; Overriding Need
Page 2 of 69
EFTA01079795
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Ritz Compact Flash 6(e) Inadequate Log; No Factual Underpinnings;
P-000550 SW" containing copies of a sealed search Contains information Fiduciary Duty; Factual Materials; Not in
thru warrant application, warrant, and subject to investigative Anticipation of Litigation; Improper
P-000621 supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "PNY Technologies 6(e) Inadequate Log; No Factual Underpinnings;
P-000622 Compact Flash SW" containing copies of a Contains information Fiduciary Duty; Factual Materials; Not in
thru sealed search warrant application, warrant, subject to investigative Anticipation of Litigation; Improper
P-000693 and supporting documents privilege Invocation; Overriding Need; Factual
Also contains information Materials; Court Authorized Under 6(e)(3)(E);
subject to privacy rights of Court Inherent Power to Release; Proper
victims who are not Victim's Petition; CVRA-authorized release;
parties to this litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled "JE Corporations" Work Product Inadequate Log; No Factual Underpinnings;
P-000694 containing attorney research on Epstein- Contains information Fiduciary Duty; Not in Anticipation of
thru owned corporations and prior litigation subject to investigative Litigation; Improper Invocation; Overriding
P-000781 privilege Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Overriding Need
Box #1 File folder entitled "Capital One" 6(e) Inadequate Log; No Factual Underpinnings;
P-000782 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court
thru Authorized Under 6(e)(3)(E); Court Inherent
P-000803 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Page 3 of 69
EFTA01079796
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "DTG 6(e) Inadequate Log; No Factual Underpinnings;
P-000804 Operations/Dollar Rent-a-Car" containing Contains documents and Fiduciary Duty; Factual Materials; Not in
thru subpoena and responsive documents information subject to Anticipation of Litigation; Improper
P-000854 investigative privilege Invocation; Overriding Need; Factual
Also contains documents Materials; Court Authorized Under 6(e)(3)(E);
and information subject to Court Inherent Power to Release; Proper
privacy rights of victims Victim's Petition; CVRA-authorized release;
who are not parties to this Material Severable; Redaction; No Assertion
litigation by Victims
Box #1 File folder entitled "JP Morgan Chase" 6(e) Inadequate Log; No Factual Underpinnings;
P-000855 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000937 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled 'Washington Mutual" 6(e) Inadequate Log; No Factual Underpinnings;
P-000938 containing subpoena, correspondence, and Contains documents and Fiduciary Duty; Not in Anticipation of
thru responsive documents information subject to Litigation; Improper Invocation; Overriding
P-000947 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Computer Search &" Work Product Inadequate Log; No Factual Underpinnings;
P-000948 containing legal research on computer Attorney-Client Fiduciary Duty; Factual Materials; Not in
thru search and handwritten notes on indictment Contains information Anticipation of Litigation; Ordinary
P-000982 preparation subject to investigative Government Communication; No Attorney-
privilege. Also contains Client Relationship; Improper Invocation;
information subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue;
who are not parties to this Redaction; No Assertion by Victims
litigation
Page 4 of 69
EFTA01079797
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "Attorney Notes from Work product Inadequate Log; No Factual Underpinnings;
P-000983 Document Review" containing typed and 6(e) Fiduciary Duty; Factual Materials; Not in
thru handwritten attorney (Villafafia) notes, Contains information Anticipation of Litigation; Improper
P-001007 target letters, correspondence re grand jury subject to investigative Invocation; Overriding Need; Claims Against
subpoena privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Notes from Fed Ex Work Product Inadequate Log; No Factual Underpinnings;
P-001008 Records" containing handwritten and typed 6(e) Fiduciary Duty; Factual Materials; Not in
thru attorney (Villafafia) notes and screen shots Contains information Anticipation of Litigation; Improper
P-001056 of FedEx subpoena response electronic file subject to investigative Invocation; Overriding Need; Claims Against
privilege. Also contains Public Prosecutor; Attorney Conduct at Issue;
information subject to Factual Materials; Court Authorized Under
privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Colonial Bank 6(e) Inadequate Log; No Factual Underpinnings;
P-001057 Records" containing records received in Contains information Fiduciary Duty; Not in Anticipation of
thru response to grand jury subpoena subject to investigative Litigation; Improper Invocation; Overriding
P-001959 privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Page 5 of 69
EFTA01079798
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "OLY Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings;
P-001960 Vol 2: OLY-51 THROUGH" containing Contains information Fiduciary Duty; Factual Materials; Not in
Thru subpoenas numbered OLY-51 through subject to investigative Anticipation of Litigation; Improper
P-002089 OLY-81 with related correspondence privilege. Also contains Invocation; Overriding Need; Factual
information subject to Materials; Court Authorized Under 6(e)(3)(E);
privacy rights of victims Court Inherent Power to Release; Proper
who are not parties to this Victim's Petition; CVRA-authorized release;
litigation Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder entitled - Epstein Corporate 6(e) Inadequate Log; No Factual Underpinnings;
P-002090 Records: OLY-51, OLY-52, OLY-53, Contains information and Fiduciary Duty; Not in Anticipation of
Thru OLY-54" containing subpoenas, records documents subject to Litigation; Improper Invocation; Overriding
P-002169 received in response to subpoenas, and investigative privilege Need; Factual Materials; Court Authorized
related correspondence Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Colonial Bank" 6(e) Inadequate Log; No Factual Underpinnings;
P-002170 containing subpoenas, correspondence Contains information and Fiduciary Duty; Not in Anticipation of
Thru related to subpoenas, records received in documents subject to Litigation; Improper Invocation; Overriding
P-002246 response to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "JEGE & Hyperion 6(e) Inadequate Log; No Factual Underpinnings;
P-002247 from Goldberger OLY-46 & OLY-47" Contains information and Fiduciary Duty; Not in Anticipation of
Thru containing documents received in response documents subject to Litigation; Improper Invocation; Overriding
P-002265 to subpoenas investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Page 6 of 69
EFTA01079799
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002266 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, of individuals listed as and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
"Additional victims" privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable
litigation
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002387 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in
Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper
P-002769 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against
handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under
typed notes, relevant pieces of grand jury and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
materials, telephone records/flight records privacy rights of victims Proper Victim's Petition; CVRA-authorized
analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No
photographs, DAVID records, NCICs, and litigation Assertion by Victims
related materials for persons identified as
Jane Does #15, 16, 17, 18, 19, Past
Em lo ees, Misc. Witnesses
Page 7 of 69
EFTA01079800
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Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings;
P-002770 witness/victim list with identifying 6(e) Fiduciary Duty; Factual Materials; Not in
Thru information, sexual activity summary, Contains information and Anticipation of Litigation; Improper
P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against
(Villafafia) handwritten notes, 302s, investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
portions of state investigative file, attorney Also contains information Redaction; No Assertion by Victims
(Villafafia) typed notes, relevant pieces of and documents subject to
grand jury materials, telephone privacy rights of victims
records/flight records analysis charts, who are not parties to this
victim/witness photographs, DAVID litigation
records, NCICs, and related materials for
persons identified as Jane Does #1, 2, 3, 4,
5, 6, 7, 8
Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings;
P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper
P-003545 a number of victim/witnesses documents subject to Invocation; Overriding Need; Claims Against
, an investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Page 8 of 69
EFTA01079801
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 10 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 FBI Reports of March 2008 interviews of Work product Inadequate Log; No Factual Underpinnings;
P-003546 additional witness/victim located in New 6(e) Fiduciary Duty; Factual Materials; Not in
Thru York Contains information and Anticipation of Litigation; Improper
P-003552 documents subject to Invocation; Overriding Need; Claims Against
investigative privilege. Public Prosecutor; Attorney Conduct at Issue;
Also contains information Factual Materials; Court Authorized Under
and documents subject to 6(e)(3)(E); Court Inherent Power to Release;
privacy rights of victims Proper Victim's Petition; CVRA-authorized
who are not parties to this release; Material Severable; Redaction; No
litigation Assertion by Victims
Box #1 Printout of filenames from Federal Express Work product Inadequate Log; No Factual Underpinnings;
P-003553 subpoena response with Attorney notations 6(e) Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003555B Overriding Need; Attorney Conduct at Issue;
Factual Materials; Court Authorized Under
6(e)(3)(E); Court Inherent Power to Release;
Proper Victim's Petition; CVRA-authorized
release; Material Severable
Box #1 Document entitled "Identified Numbers" Work product Inadequate Log; No Factual Underpinnings;
P-003556 with accompanying handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru list compiled from grand jury materials and Contains information Litigation; Improper Invocation; Overriding
P-003562 attorney analysis of records subject to investigative Need; Claims Against Public Prosecutor;
privilege Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Page 9 of 69
EFTA01079802
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 11 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 Folder entitled "Flight Manifests" 6(e) Inadequate Log; No Factual Underpinnings;
P-003563 containing manifests received pursuant to Contains information and Fiduciary Duty; Not in Anticipation of
Thru grand jury subpoena documents subject to Litigation; Improper Invocation; Overriding
P-003629 investigative privilege Need; Factual Materials; Court Authorized
Under 6(e)(3)(E); Court Inherent Power to
Release; Proper Victim's Petition; CVRA-
authorized release; Material Severable
Box #1 File folder entitled "Recent Attorney Work product Inadequate Log; No Factual Underpinnings;
P-003630 Notes" containing handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of
Thru (Villafafia) notes regarding document Investigative privilege Litigation; Improper Invocation; Overriding
P-003633 review and case strategy Deliberative process Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue; Factual Materials;
Court Authorized Under 6(e)(3)(E); Court
Inherent Power to Release; Proper Victim's
Petition; CVRA-authorized release; Material
Severable
Box #1 File folder bearing victim name containing Work product Inadequate Log; No Factual Underpinnings;
P-003634 FBI interview report from May 2008, Attorney-client privilege Fiduciary Duty; Factual Materials; Not in
Thru telephone activity report with attorney 6(e) Anticipation of Litigation; Ordinary
P-003646 (Villafanafia) handwritten notes, related Investigative privilege Government Communication; No Attorney-
grand jury material Also contains information Client Relationship; Improper Invocation;
and documents subject to Overriding Need; Claims Against Public
privacy rights of victims Prosecutor; Attorney Conduct at Issue; Factual
who are not parties to this Materials; Court Authorized Under 6(e)(3)(E);
litigation Court Inherent Power to Release; Proper
Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Page 10 of 69
EFTA01079803
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #I File folder entitled "Summary of Sexual Work product Inadequate Log; No Factual Underpinnings;
P-003647 Activity" containing chart bearing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru handwritten title "Sexual Activity — Investigative privilege Anticipation of Litigation; Improper
P-003651 Summary" with meta-analysis of Deliberative process Invocation; Overriding Need; Claims Against
information, sorted by name of each Also contains information Public Prosecutor; Attorney Conduct at Issue;
victim/witness, including name and and documents subject to Factual Materials; Court Authorized Under
identifying information of each privacy rights of victims 6(e)(3)(E); Court Inherent Power to Release;
victim/witness who are not parties to this Proper Victim's Petition; CVRA-authorized
litigation release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled "Victim Civil Suits" Not privileged. N/A
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research it JE Work product Inadequate Log; No Factual Underpinnings;
P-003664 Websites" containing attorney research Fiduciary Duty; Not in Anticipation of
Thru Litigation; Claims Against Public Prosecutor;
P-003678 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Serene Cano (N.Y. Work product Inadequate Log; No Factual Underpinnings;
P-003679 AUSA)" containing attorney (Villafafia) Fiduciary Duty; Not in Anticipation of
Thru handwritten notes Litigation; Claims Against Public Prosecutor;
P-003680 Overriding Need; Attorney Conduct at Issue
Box #1 File folder entitled "Dr. Anna Salter" Work product Inadequate Log; No Factual Underpinnings;
P-003681 containing attorney (Villafafia) memo to Investigative privilege Fiduciary Duty; Not in Anticipation of
Thru expert witness and handwritten attorney Litigation; Improper Invocation; Overriding
P-003687 notes Need; Claims Against Public Prosecutor;
Attorney Conduct at Issue
Page 11 of 69
EFTA01079804
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 13 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "IR G[] Interview" Work product Inadequate Log; No Factual Underpinnings;
P-003688 containing attorney handwritten notes of Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru interview, and attorney handwritten notes Also contains information Anticipation of Litigation; Improper
P-003693 regarding potential charges subject to privacy rights of Invocation; Overriding Need; Claims Against
victims who are not Public Prosecutor; Attorney Conduct at Issue;
parties to this litigation Redaction; No Assertion by Victims
Box #1 File folder entitled "Research re Travel for Work product Inadequate Log; No Factual Underpinnings;
P-003694 Prostitution" containing attorney 6(e) Fiduciary Duty; Factual Materials; Not in
Thru (VillafaiIa) handwritten notes regarding Investigative privilege Anticipation of Litigation; Improper
P-003711 grand jury presentation, chart entitled Also contains information Invocation; Overriding Need; Claims Against
"Brought to Epstein's House" with and documents subject to Public Prosecutor; Attorney Conduct at Issue;
handwritten notes, Message Pad meta- privacy rights of victims Factual Materials; Court Authorized Under
analysis chart, summary of evidence who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
related to one victim/witness, and relevant litigation Proper Victim's Petition; CVRA-authorized
grand jury information release; Material Severable; Redaction; No
Assertion by Victims
Box #1 Empty file folder bearing name of Investigative privilege N/A
P-003712 victim/witness Also contains information
subject to privacy rights of
victim who is not a party
to this litigation
Box #1 File folder entitled "T[] M[]" containing 6(e) Inadequate Log; No Factual Underpinnings;
P-003713 grand jury subpoenas, motion and order to Documents under seal Fiduciary Duty; Factual Materials; Court
Thru compel testimony, and correspondence pursuant to court order Authorized Under 6(e)(3)(E); Court Inherent
P-003746 regarding same Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Box #1 File folder entitled 6(e) Inadequate Log; No Factual Underpinnings;
P-003747 containing subpoena an correspondence Fiduciary Duty; Factual Materials; Court
Thru regarding same Authorized Under 6(e)(3)(E); Court Inherent
P-003751 Power to Release; Proper Victim's Petition;
CVRA-authorized release; Material Severable
Page 12 of 69
EFTA01079805
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of
70
Bates Range Description Privilege(s) Asserted Victims' Objections
Box #1 File folder entitled "PBPD Investigative 6(e) Inadequate Log; No Factual Underpinnings;
P-003752 File" obtained via subpoena Investigative privilege Fiduciary Duty; Factual Materials; Not in
Thru Also contains information Anticipation of Litigation; Improper
P-004295 and documents subject to Invocation; Overriding Need; Factual
privacy rights of victims Materials; Court Authorized Under 6(e)(3)(E);
who are not parties to this Court Inherent Power to Release; Proper
litigation Victim's Petition; CVRA-authorized release;
Material Severable; Redaction; No Assertion
by Victims
Box #1 File folder bearing name of victim/witness Work product Inadequate Log; No Factual Underpinnings;
P-004296 containing meta-analysis chart showing 6(e) Fiduciary Duty; Factual Materials; Not in
Thru telephone calls, travel, and grand jury Investigative privilege Anticipation of Litigation; Improper
P-004350 materials relevant to possible charges Also contains information Invocation; Overriding Need; Claims Against
and documents subject to Public Prosecutor; Attorney Conduct at Issue;
privacy rights of victims Factual Materials; Court Authorized Under
who are not parties to this 6(e)(3)(E); Court Inherent Power to Release;
litigation Proper Victim's Petition; CVRA-authorized
release; Material Severable; Redaction; No
Assertion by Victims
Box #1 File folder entitled Work product Inadequate Log; No Factual Underpinnings;
P-004351 Documents 53909- Fiduciary Duty; Not in Anticipation of
Thru attorney research related to bias issue Litigation; Claims Against Public Prosecutor;
P-004381 Overriding Need; Attorney Conduct at Issue
Box #1 File Folder entitled "FEDEX" containing 6(e) Inadequate Log; No Factual Underpinnings;
P