gov.uscourts.nysd.447706.165.1.pdf

Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 1 of 6 EXHIBIT A  Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 2 of 6 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page 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 Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Jane Doe #1 and Jane Doe #2 Edwards, Paul Cassell, v. United States ("CVRA case"), Case no. 08-80736-CIV-Marra, Brittany Henderson (and Virginia Giuffre, Brad pending in the Southern District of Florida. Documents withheld other , Sigrid McCawley, Edwards, Paul Cassell, pursuant to the privileges asserted included communications Meredith Schultz, David Brittany Henderson, Sigrid from Ms. Giuffre to the attorneys listed seeking legal advice Boies, Jack Scarola, Stan McCawley, Meredith related to the CVRA case, communications from the attorneys to Pottinger, Ellen Schultz, David Boies, Jack Ms. Giuffre giving legal advice or giving attorney mental Brockman, Legal Scarola, Stan Pottinger, Ellen impressions related to the CVRA case, communications sending Assistants, Professionals Brockman, Legal Assistants, or attaching attorney work product related to the CVRA case, AC Privilege and Approx. 1.3K retained by attorneys to Professionals retained by and/or communications sending or attaching client revisions to Work docs Emails, letters, and aid in the rendition of attorneys to aid in the attorney work product related to the CVRA case, and Product/joint overlapping other communications legal advice and rendition of legal advice and communications re evidence. defense/commo with other 125 from 2011 - Present representation representation n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016  Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 3 of 6 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page 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 Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Giuffre v. Maxwell (“Maxwell Edwards, Paul Cassell, case”), 15-cv-07433-RWS, pending in the Southern District of Brittany Henderson, Virginia Giuffre, Brad New York, since the date of filing, September 21, 2015. Sigrid McCawley, Edwards, Paul Cassell, Documents withheld pursuant to the privileges asserted Meredith Schultz, David Brittany Henderson, Sigrid included communications from Ms. Giuffre to the attorneys Boies, Stephen Zach, McCawley, Meredith listed seeking legal advice related to the Maxwell case, Stan Pottinger, Ellen Schultz, David Boies, communications from the attorneys to Ms. Giuffre giving legal Brockman, Legal Stephen Zach, Stan advice or giving attorney mental impressions related to the Assistants, Professionals Pottinger, Ellen Brockman, Maxwell case, communications sending or attaching attorney AC Privilege and Approx. 1.3K retained by attorneys to Legal Assistants, work product related to the Maxwell case, and/or Work docs Emails, letters, and aid in the rendition of Professionals retained by communications sending or attaching client revisions to Product/joint overlapping other communications legal advice and attorneys to aid in the attorney work product related to the Maxwell case, and defense/commo with other 126 from 9/21/15 - Present representation rendition of legal advice and communications re evidence. n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016  Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 4 of 6 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page 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 Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Bradley Edwards and Paul Edwards, Paul Cassell, Cassell v. Alan Dershowitz (“Dershowitz case”), Case no. 15- Brittany Henderson, Virginia Giuffre, Brad 000072, pending in the Seventeenth Judicial Circuit, Broward Sigrid McCawley, Edwards, Paul Cassell, County, Florida. Documents withheld pursuant to the privileges Meredith Schultz, David Brittany Henderson, Sigrid asserted included communications from Ms. Giuffre to the Boies, Stephen Zach, McCawley, Meredith attorneys listed seeking legal advice related to the Dershowitz Stan Pottinger, Ellen Schultz, David Boies, case, communications from the attorneys to Ms. Giuffre giving Brockman, Legal Stephen Zach, Stan legal advice or giving attorney mental impressions related to the Assistants, Professionals Pottinger, Ellen Brockman, Dershowitz case, communications sending or attaching attorney AC Privilege and Approx. 1.3K Emails, letters, and retained by attorneys to Legal Assistants, work product related to the Dershowitz case, and/or Work docs other communications aid in the rendition of Professionals retained by communications sending or attaching client revisions to Product/joint overlapping from January 2015 - legal advice and attorneys to aid in the attorney work product related to the Dershowitz case, and defense/commo with other 127 Present representation rendition of legal advice and communications re evidence. n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016  Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 5 of 6 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page 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. Virginia Giuffre, Bob Virginia Giuffre, Bob Giuffre to the attorneys listed seeking legal advice related to the Josefsberg, Katherine W. Josefsberg, Katherine W. Epstein case, communications from the attorneys to Ms. Giuffre Ezell, Amy Ederi, other Ezell, Amy Ederi, other giving legal advice or giving attorney mental impressions related Podhurst attorneys, Podhurst attorneys, Legal to the Epstein case, communications sending or attaching AC Privilege and Approx. 1.3K Legal Assistants, and Assistants, and Professionals attorney work product related to the Epstein case, and/or Work docs Emails, letters, and Professionals retained by retained by attorneys to aid communications sending or attaching client revisions to Product/joint overlapping other communications attorneys to aid in the in the rendition of legal attorney work product related to the Epstein case, and defense/commo with other 128 from 2009 - Present rendition of legal advice advice communications re evidence. n interest Withheld cases Email chain with Giuffre and McCawley seeking information to 129 6/10/2015 Virginia Giuffre [email protected] assist with attorney advice. Attorney Client Withheld 2 msg Letter from Virginia Giuffre to David Boies conveying requested AC Privilege and 130 information to assist in providing legal advice. Work Product Withheld 26 pdf [email protected],brad@pat htojustice.com,robiejennag@y7mai AC Privilege and 131 4/30/2015 Brittany Henderson [email protected] l.com Communication re VRS registrations Work Product Withheld 1 msg [email protected],brad@pat htojustice.com,[email protected],r Email chain with McCawley, Edwards, Garvin, Henderson, AC Privilege and 132 4/29/2015 Andres Ortiz [email protected] [email protected] Giuffre and BSF staff re legal advice re VRS communications. Work Product Withheld 1 msg [email protected],brad@pat htojustice.com,[email protected],r AC Privilege and 133 4/29/2015 brittany henderson [email protected] [email protected] Communication re legal advice re VRS communications. Work Product Withheld 1 msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016  Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 6 of 6 Log Privilege Doc ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type Email chain with Giuffre, McCawley, Pottinger and BSF staff re 150 2/11/2015 Virginia Giuffre [email protected] media communications. Attorney Client Redacted 3 msg AC Privilege and 151 1/13/2015 Virginia Giuffre [email protected] Email chain with Pottinger and Giuffre re anticipated litigation. Work Product Withheld 1 msg 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). This categorical entry is regarding correspondence re potential legal action against entities and individuals. Documents withheld pursuant to the privileges asserted Virginia Giuffre, Brad included communications from Ms. Giuffre to the Edwards, Paul Cassell, Virginia Giuffre, Brad attorneys listed seeking legal advice related to potential Brittany Henderson, Edwards, Paul Cassell, law suits, communications from the attorneys to Ms. Sigrid McCawley, Brittany Henderson, Sigrid Giuffre giving legal advice or giving attorney mental Meredith Schultz, David McCawley, Meredith impressions related to the law suits, communications Boies, Stephen Zach, Schultz, David Boies, sending or attaching attorney work product related to Stan Pottinger, Ellen Stephen Zach, Stan potential lawsuits, and/or communications sending or Brockman, Legal Pottinger, Ellen Brockman, AC Privilege and attaching client revisions to attorney work product related Emails, letters, and Assistants, Professionals Legal Assistants, Work Approx. 1.3K other communications retained by attorneys to Professionals retained by to potential lawsuits, and communications re evidence. Product/joint overlapping from January 2015 - aid in the rendition of attorneys to aid in the defense/commo with other 152 Present legal advice rendition of legal advice n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016