EFTA00296195.pdf

Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION Team privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03089-03099 05/03/2009 Attorneys and RE: Setting Depos Work Product;attorney client Staff privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 13445-13453 08/19/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 12281-12291 07/30/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 09337-09340 08/10/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 09350 10/21/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 09335 08/06/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11983 08/06/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11984-11988 08/06/2009 Litigation Strategy . Work Product;attorney client privilege;irrelevant & reasonably calculated to 29 EFTA00296195  Privile e Lo — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00146 06/29/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00147 06/29/2009 M Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00148 04/22/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00149 04/26/2009 all Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00151-00152 06/26/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 01036-01039 04/26/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 13313-13314 07/30/2009 Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to 43 EFTA00296196  Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights 13315 08/03/3009 Illa Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 01080-01081 06/22/2009 Jane Doe brother Attorney/Client privilege and/or work product 01077 05/28/2009 1 13 Doe family member Attorney/Client privilege and/or work product 02445-02446 05/05/2009 Jones v. Atlantic asphalt Attorney/Client privilege and/or work product 03049 09/21/2009 New addition to the case Attorney/Client privilege and/or work product 02425-02426 06/17/2009 1 Jane Doe v. Dukenik Attorney/Client privilege and/or work product 02669 09/24/2009 Subpoena fo Attorney/Client privilege and/or work product 02647 08/06/2009 1 Samantha Lee Rivera info Attorney/Client privilege and/or work product 03688-03691 04/03/2009 I . Case number assignments Attorney/Client privilege and/or work product 03692-03693 05/06/2009 11. Case list Attorney/Client privilege and/or work product 15678.15680 09/29/2009 1 Subpoena fo Attorney/Client privilege and/or work product 15689 10/01/2009 Client information Attorney/Client privilege and/or work product I I I 02546-02547 09/22/2009 I Client communication Attorney/Client privilege and/or work product 02809-02810 09/28/2009 I Client communication Attorney/Client privilege and/or work product 02262 07/23/2009 Discussion re: client/victim Attorney/Client privilege and/or work product personal information 02807-02808 10/01/2009 Client communication Attorney/Client privilege and/or work product 03760-03828 04/01/2009 Client names/types of action/ Attorney/Client privilege and/or work product, client information privacy right privilege, not relevant 03759 04/01/2009 Conflict Check for Attorney/Client privilege and/or work product files 08358-08359 09/14/2009 Client info Attorney/Client privilege and/or work product 44 EFTA00296197  Privilege Log — Dated 2-23-2011 il lralailni BATES DATE TO FROM DESCRIPTION OBJECTION 08364-08368 10/01/2009 l■ Client info Attorney/Client privilege and/or work product 08370 09/14/2009 Client info Attorney/Client privilege and/or work product ' 08374.08375 10/01/2009 I Client info Attorney/Client privilege and/or work product 03878 06/12/2009 I' Curtis Rivera Attorney/Client privilege and/or work product 02955 04/20/2009 1 • . Juskowich Attorney/Client privilege and/or work product 02932 07/17/2009 II Jane Doe v. Roe Attorney/Client privilege and/or work product 11544-11545 09/28/2009 1I Client info Attorney/Client privilege and/or work product 07432-07435 09/25/2009 New addition to the case Attorney/Client privilege and/or work product 06906-06909 07/17/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product 06913-06914 06/22/2009 . Jane Doe v. Roe Attorney/Client privilege and/or work product 06030-06031 05/04/2009 I • Espina — Walmart case Attorney/Client privilege and/or work product 05646 07/08/2009 I' Client meeting Attorney/Client privilege and/or work product 05573 09/18/2009 1 Client meeting Attorney/Client privilege and/or work product 05540 07/31/2009 Client info Attorney/Client privilege and/or work product 05273-05276 07/28/2009 7 1I Client info Attorney/Client privilege and/or work product 05264 07/27/2009 tt I Client info Attorney/Client privilege and/or work product 05267.05270 07/27/2009 I Client info Attorney/Client privilege and/or work product 02933 06/17/2009 --; I Jane Doe v. Roe Attorney/Client privilege and/or work product I 1-- 01292 09/18/2009 Epstein article Attorney/Client privilege and/or work product 01068.01070 04/02/2009 All Staff Current case list of Attorney/Client privilege and/or work product 01054-01055 04/02/2009 All Staff Updated case list for Attorney/Client privilege and/or work product 01033 05/06/2009 case list Attorney/Client privilege and/or work product 01030-01031 04/03/2009 Case number assignments Attorney/Client privilege and/or work product 45 EFTA00296198  Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 01118-01120 09/22/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product I 01986-01989 04/02/2009 Conflict check Attorney/Client privilege and/or work product I I 01984-01985 04/02/2009 Conflict check Attorney/Client privilege and/or work product 25925 09/30/2009 All Staff Conflict check Attorney/Client privilege and/or work product 25874 09/30/2009 All Staff Additional name added to Attorney/Client privilege and/or work product conflict check 08356-08357 09/16/2009 Client Meeting Attorney/Client privilege and/or work product 16760.16761 09/23/2009 New Client Attorney/Client privilege and/or work product 08005 06/05/2009 New Client Attorney/Client privilege and/or work product 06915.06920 06/17/2009 MG Jane Doe v. Roe Attorney/Client privilege and/or work product 08360-08363 09/16/2009 Client Meeting Attorney/Client privilege and/or work product 04101-04107 09/28/2009 ■ Jane Doe v. Roe Attorney/Client privilege and/or work product 04708.04710 09/18/2009 Epstein Article Attorney/Client privilege and/or work product 06910-06912 06/17/2009 Jane Doe v. Roe Attorney/Client privilege and/or work product 07909 08/10/2009 Jane Doe Same silver car tag Attorney/Client privilege and/or work product 07637-07642 09/10/2009 06795-06799 08/19/2009 III Interview Attorney/ Client Privilege Anthony P Client Meeting Attorney/Client privilege and/or work product 06542-06548 09/15/2009 Client Meeting Attorney/Client privilege and/or work product 06404-06408 09/10/2009 III • Interview Attorney/Client privilege and/or work product 08338-08339 09/16/2009 New Client Attorney/Client privilege and/or work product 08505 09/14/2009 New Client Meeting Attorney/Client privilege and/or work product 02241-02242 05/28/2009 Confidential Other Rape Victims W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 02243-02244 07/07/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02238-02240 05/28/20009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02204 07/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to 46 EFTA00296199  Privilege Log - Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 02298-02299 07/08/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02291 06/04/2009 IIIIIIMI Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 02442-02443 08/17/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02440-02441 10/02/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 04318-04321 09/24/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05111 06/02/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05152 06/03/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05164 06/03/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05166 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05169-05170 06/03/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05173-05174 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05212-05213 06/23/2009 Confidential Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to Source Providing New Witnesses discovery of admissible evidence 05215.05217 06/23/2009 Confidential Secret Plea Deal of Epstein W/P Priv.; not reasonably calculated to lead to Source providing new witnesses discovery of admissible evidence 05175-05189 07/02/2009 I li Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05194-05196 06/23/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05204-05206 06/23/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 47 EFTA00296200  Privilege Log — Dated 2-23-2011 & BATES DATE TO FROM DESCRIPTION OBJECTION 05227-05228 07/08/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence 05230-05231 07/08/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence 05303 08/06/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05344-05346 06/23/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05408 07/06/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05425.05429 05/28/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05433-05436 05/29/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05433-05436 05/29/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05446 07/07/2009 Confidential Source Other Rape Victims W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05452-05464 05/29/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05535-05536 07/30/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence 05538.05539 07/30/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05550-05551 08/11/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05577-05578 08/22/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05619.05620 09/18/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 05650 08/06/200 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05688-05689 0/28/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to 48 EFTA00296201  Privilege Log — Dated 2-23-2011 & BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 05693-05695 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05698 08/21/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05706-05709 05/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05720-05721 05/29/2O09 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05738.05739 05/29/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05743-05745 05/29/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05754 08/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05759.05762 06/01/2O09 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05765-05768 06/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05771-05773 06/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 05777.05779 06/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 05784.05786 06/03/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05791-05794 06/03/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 05803 07/22/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05836-05837 07/08/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05842-05843 07/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 49 EFTA00296202  Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 05848 07/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05852-05853 07/29/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05857-05858 07/31/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05952-05953 08/25/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06192-06197 06/23/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06198-06201 06/24/2009 Confidential Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 06203 07/23/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06401 09/23/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06643-06651 09/17/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06788.06789 09/28/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06942-06943 09/26/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence 06953 08/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06955-06957 10/02/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06959-06961 08/11/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06963-06980 08/11/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 06986.06989 10/03/2009 Confidential Source Secret Plea Deal For Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07010-07014 10/04/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to 50 EFTA00296203  Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 07017.07018 09/04/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 07143-07144 10/01/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 07147-07150 09/18/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 075089- 10/13/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to 07513 Source discovery of admissible evidence 07605-07615 09/07/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07646-07647 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 07674.07697 09/08/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08376 10/04/2009 Confidential = Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 08380 09/18/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08427-08430 09/24/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08450 05/17/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 08507 10/03/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 10092.10098 08/31/2009 Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01610 06/03/3009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01612 06/04/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01451-01458 05/27/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 51 EFTA00296204  Privilege Log — Dated 2-23-2011 BATES DATE TO FROM DESCRIPTION OBJECTION 01608 07/03/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01606 07/02/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01510 08/25/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01506 08/24/2009 Confidential Other Rape Victims W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01493 08/10/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01488 08/03/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01486 07/28/2009 Confidential Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01483 07/28/2009 Confidential Additional Information RE: W/P Priv.; not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence 01479 07/22/2009 Confidential Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 01449 05/22/2009 Confidential Source Secret Plea Deal for Epstein W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 01433 10/20/2009 Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 15207-15208 08/14/2009 Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 19716-19719 09/25/2009 Confidential