EFTA01118445.pdf

Privilege Log — Dated 2-23-2011 Farmer. Jaffe. Weissing. Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights 11995 08/19/2009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 12012 10/21/20009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11879 10/21/2009 ±ar nes , Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11868 08/19/2009 ( Cara Holmes .\; Bradley Edwards Litigation Strategy Work Product;attorney client C. --- privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 10938 05/28/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 13592 10/21/2009 Denis Kleinfeld Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 04421 05/21/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 25814 05/28/2009 William Berger Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible 30 EFTA01118445  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE LQ iggig wo nn t_______ privacy rights 07849.07852 04/10/2009 Bradley Edwards Paul Cassell Litigation Strategy WM Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07853-07856 06/10/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07857.07862 09/11/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07863-07864 06/10/2009 Bradley Edwards Paul Cassell litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07685-07874 05/14/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07875-07876 04/14/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 07877-07884 08/03/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by ------b-=-1 privacy rights 07886.07888 08/02/2009 Cara Holmes . Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and ---> not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 60 EFTA01118446  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissinga Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 18164-18165 08/03/2009 Bradley Edwards Mike Fisten Copperfield Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the . discovery of admissible evidence; protected by privacy rights 18771-18773 04/27/2009 Marc Nurik Bradley Edwards Legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18742.18744 09/10/2009 Jacquie Johnson Bradley Edwards Dershowitz Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 18737.18741 09/10/2009 Jacquie Johnson Bradley Edwards Depo technicalities W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 20263-20282 10/14/2009 Pat Roberts, Ronald Wise Vehicle Registrations-Visoski W/P; Attorney Client Privilege; Irrelevant and Mike Fisten not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 20219.20262 10/14/2009 Pat Roberts, Ronald Wise Visoski Research & Questions W/P; Attorney Client Privilege; Irrelevant and Mike Fisten not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 17225-17230 07/22/2009 Bradley Edwards Jacquie Johnson Wayne Black Retainer W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 17038-17040 10/29/2009 Cara Holmes Jacquie Johnson RE: Subpoenas for Epstein's W/P; Attorney Client Privilege; Irrelevant and l ----.. ---) attorneys not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16916-16928 10/19/2009 Bradley Edwards Jacquie Johnson Witness List W/P; Attorney Client Privilege; Irrelevant and 75 EFTA01118447  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATES it T FROM DESCRIPTION OBJE N not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16795.16796 10/01/2009 Bradley Edwards Jacquie Johnson Trump Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16455.16759 09.10/2009 Bradley Edwards Jacquie Johnson Depo Dates W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16436-16437 09/09/2009 Bradley Edwards Jacquie Johnson Dershowitz Depo W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16400.16404 09/02/2009 Mike Fisten Jacquie Johnson Investigation into Epstein's W/P; Attorney Client Privilege; Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 16394.16395 08/31/2009 Bradley Edwards Jacquie Johnson Depo Dates W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01046 08/25/2009 LC71-lolmes Bradley Edwards Computer information W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01048-01050 07/28/2010 William Berger Bradley Edwards Hard drive of Plaintiffs computer W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01052 09/09/2009 Attorneys at RRA Maribel Matiska legal Opinion RE: Epstein W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the 76 EFTA01118448  Privilege Log — Dated 2-23-2011 Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman BATES DATE i OBJECTION privacy rights 03005-03006 08/03/2009 Mike Fisten Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03007 10/07/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03008 04/23/2009 Susan Stirling Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03013 05/25/2009 Bradley Edwards Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by _ privacy rights 03014 10/08/2009 Bradley Edwards CC!ra Wilmer) Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03015 04/24/2009 Steven Jaffe Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03017.03018 08/18/2009 Mike Fisten Bradley Edwards Providing New witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03019 09/19/2009 Bradley Edwards Pat Diaz Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 91 EFTA01118449  Privilege Log— Dated 2-23-2011 Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECT • 03550.03574 09/09/2009 Attorneys at RRA Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03575.03588 10/19/2009 Kendall Coffey Bradley Edwards Providing New Witnesses W/P; Attorney Client Privilege; irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03589-03604 04/11/2009 Paul Cassell Bradley Edwards litigation Strategy w/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03605-03606 10/16/2009 Attorneys at RRA Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03607-03610 10/16/2009 William Berger Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03611-03612 10/16/2009 Attorneys at RRA Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by .. _ privacy rights 03613-03615 10/29/2009 Bradley Edwards/ Cara Holmes ) Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03616.03618 10/01/2009 Pat Diaz Bradley Edwards Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03628-03637 09/15/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privile e; Irrelevant and 100 EFTA01118450  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATkss aea 12 FROM DESCRIPTION OBJECTION Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08381-08383 09/06/2009 Bradley J. Paul Cassell Epstein — complaint Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08384.08388 04/13/2009 Bradley J. Paul Cassell Epstein fraudulent transfer Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; _ protected by privacy rights 08389.08397 05/14/2009 Bradley J. Paul Cassell Revisited sexual history memo Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08401 07/22/2009 Bradley J. Paul Cassell Reply memo on asset transfers Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; .7.-------____, protected by privacy rights 08409.08410 08/01/2009 Bradley J. 'Cara L. Holmel-‘, Rodriguez Deposition Work product; attorney/client privilege; Edwards .... _--1 irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08421 06/02/2009 Bradley J. William J. Berger Strategy Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08423-08425 10/09/2009 Bradley J. Mike Fisten Subpoena info Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08426 08/10/2009 Bradley J. Mike Fisten Synopsis Work product; attorney/client privilege; Edwards irrelevant and not reasonably calculated to lead 109 EFTA01118451  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing. Edwards. Fistos & Lehrman DATES DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08441.08446 10/05/2009 Attorneys at RBA William J. Berger Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel Information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03706.03718 08/05/2009 Bradley Edwards Paul Cassell Cf. Response to Motion to File Work product; attorney/client privilege; Epstein Affidavit irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; --- -------. protected by privacy rights 03737 08/25/2009 Bradley Edwards (Sara Holmes ) Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03746-03753 08/02/2009 Bradley Edwards William Berger Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02335-02338 05/08/2009 William Berger Bradley Edwards Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02360-02361 06/09/2009 Susan Stirling Bradley Edwards Hearing to Un-seal- Criminal Plea Work product; attorney/client privilege; Transcript irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02368-02373 10/14/2009 Bradley Edwards Jacquie Johnson Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 110 EFTA01118452  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATES j2 FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11861-11865 10/23/2009 Attorneys at RRA Bradley Edwards Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11870-11871 08/24/2009 Attorneys at RRA Bradley Edwards Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11874 08/24/2009 Jacquie Johnson Bradley Edwards Confidential info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11876 08/24/2009 Attorneys at RRA Ken Jenne Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11967-11972 10/29/2009 ( 7Cara Holmes' s -‘‘ Jacquie Johnson Subpoenas for Epstein's Work product; attorney/client privilege; Attorneys irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08072-08075 07/22/2009 Paul Cassell Bradley Edwards Total counts for E.W. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08090.08091 10/05/2009 William Berger Bradley Edwards Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08114.08117 08/18/2009 Pat Diaz Bradley Edwards Updated Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 117 EFTA01118453  Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE 19 FROM DESCRIPTION gBlEgION Th. protected by privacy rights 15820.15822 10/29/2009 Jacquie Johnson k,...Ca -- ra Holm, Subpoenas for Epstein's Work product; attorney/client privilege; Attorneys irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15401-15412 09/09/2009 Jacquie Johnson Bradley Edwards Disseminate the letter from Work product; attorney/client privilege; wexner atty irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15356-15359 08/26/2009 Attorneys at RRA Bradley Edwards Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 14934.14950 07/22/2009 lacquie Johnson Bradley Edwards Investigator Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 13413-13414 08/06/2009 Denis Kleinfeld Bradley Edwards Epstein information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 13908-13911 08/24/2009 Attorneys at RRA Mike Fisten Meeting info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10595-10597 09/29/2009 Bradley Edwards Jacquie Johnson Subpoena for Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10621-10624 10/02/2009 Bradley Edwards lacquie Johnson Meeting with Wexner atty Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 119 EFTA01118454  Privilege Log — Dated 2-23-2011