EFTA00795271.pdf
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23
Bates Range Description Privilege(s) Asserted
Box #1 Filed folder entitled "JANUSZ BANASIAK" Work product
P-004561 containing attorney (Villafafia) handwritten notes Investigative privilege
Thru of interview
P-004565
Box #1 File folder entitled "JANUSZ BANASIAK 6(e)
P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product
Thru documents obtained via subpoena Investigative privilege
P-004716 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "IGOR ZINOVIEV" Work product
P-004717 containing attorney research regarding witness Investigative privilege
Thru
P-004722
Box #1 File folder entitled "BEAR STEARNS Work Product
P-004723 RESEARCH" containing attorney research Investigative privilege
Thru regarding potential witness and subpoena
P-004725 recipient
Box #1 File folder entitled "LAWSUITS INVOLVING Work Product
P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege
Thru regarding Epstein's past personal and business
P-004819 litigative practices
Box #1 Filed folder entitled "SEC RECORDS" Work Product
P-004820 containing attorney research regarding Epstein Investigative privilege
Thru financial relationships
P-004959
Box #1 File folder entitled "Message Pads" containing Work Product
P-004960 selected items from evidence obtained via 6(e)
Thru subpoena Investigative privilege
P-005059 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work Product
P-005060 containing correspondence with counsel for 6(e)
Thru victim/witness, attorney witness outline with Investigative privilege
P-005081 attorney handwritten notes, attorney handwritten Also contains information and
notes regarding witness reports and case documents subject to privacy
preparation rights of victims who are not
parties to this litigation
Box #1 File folder entitled "New York Trip" containing Work product
P-005082 attorney notes re witness interview Investigative privilege
Thru
P-005083
Page 7 of 23
EFTA00795271
Bates Range Description Privilege(s) Asserted
Box #1 Filed folder entitled "JANUSZ BANASIAK" Work product
P-004561 containing attorney (Villafafia) handwritten notes Investigative privilege
Thru of interview
P-004565
Box #1 File folder entitled "JANUSZ BANASIAK 6(e)
P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product
Thru documents obtained via subpoena Investigative privilege
P-004716 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "IGOR ZINOVIEV" Work product
P-004717 containing attorney research regarding witness Investigative privilege
Thru
P-004722
Box #1 File folder entitled "BEAR STEARNS Work Product
P-004723 RESEARCH" containing attorney research Investigative privilege
Thru regarding potential witness and subpoena
P-004725 recipient
Box #1 File folder entitled "LAWSUITS INVOLVING Work Product
P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege
Thru regarding Epstein's past personal and business
P-004819 litigative practices
Box #1 Filed folder entitled "SEC RECORDS" Work Product
P-004820 containing attorney research regarding Epstein Investigative privilege
Thru financial relationships
P-004959
Box #1 File folder entitled "Message Pads" containing Work Product
P-004960 selected items from evidence obtained via 6(e)
Thru subpoena Investigative privilege
P-005059 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work Product
P-005060 containing correspondence with counsel for 6(e)
Thru victim/witness, attorney witness outline with Investigative privilege
P-005081 attorney handwritten notes, attorney handwritten Also contains information and
notes regarding witness reports and case documents subject to privacy
preparation rights of victims who are not
parties to this litigation
Box #1 File folder entitled "New York Trip" containing Work product
P-005082 attorney notes re witness interview Investigative privilege
Thru
P-005083
Page 7 of 23
EFTA00795271