EFTA00802968.pdf

Case 9:08-cv-80736-KAM Document 265-2 Entered on FLSD Docket 10/20/2014 Page 44 of 68 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Emails betwee Assistant Attorney-Client Privilege No Factual Underpinnings; Ordinary P-013248 General Counsel, Executive Office for Government Communication; No Attorney- Thru res Attorneys, and Client Relationship; Waiver P-013251 First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29. 2011 Box #3 Emails between Assistant Attorney-Client Privilege No Factual Underpinnings; Ordinary P-013252 General Counsel, Executive Office for Government Communication; No Attorney- Thru United States Attorneys, and Client Relationship; Waiver P-013253 First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Box #3 Emails between Assistant Attorney-Client Privilege No Factual Underpinnings; Ordinary P-013254 General Counsel, Executive Office for Government Communication; No Attorney- Thru United States Attorneys, and Client Relationship; Waiver P-013257 First Assistant U.S. Attorney. Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and Au,ust 29, 2011 Box #3 Emails between , Assistant Attorney-Client Privilege No Factual Underpinnings; Ordinary P-013258 General Counsel, Executive Office for Government Communication; No Attorney- Thru United States Attorneys, and Client Relationship; Waiver P-013259 First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Page 44 of 68 EFTA00802968  Case 9:08-cv-80736-KAM Document 265.2 Entered on FLSD Docket 10/20/2014 Page 45 of 68 Bates Range Description Privikge(s) Asserted Victims' Objections Box #3 Email from Assistant Attorney-Client Privilege No Factual Underpinnings; Ordinary P-013260 General Counsel, Executiv OM for Government Communication; No Attorney- Thru United States Attorneys, to Client Relationship; Waiver P-013262 (U.S. Attorney, SDFL), Robert O'Neill U.S. Attorney, MDFL), (FAUSA, SDFL), and (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 2011. CC's USAEO (USAEO), (USAEO Box #3 Ermils between Assistant Attorney-Client Privilege No Factual Underpinnings; Not in P-013263 General Counsel, Executive O Deliberative Process Anticipation of Litigation; Ordinary Thru United States Attorneys, and Work Product Government Communication; No Attorney- P-013271 First Assistant U.S. Attorney, Client Relationship; Overriding Need; Claims Southern District of Florida, regarding Against Public Prosecutor; Attorney Conduct recusal of Southern District of Florida, at Issue; Waiver dated July 29, 2011, with attached memorandum from A. Marie Villafatla to summarizing Jeffrey Epstein Investigation Box #3 Ermils between Executive Attorney-Client Privilege No Factual Underpinnings; Ordinary P-013272 Office for United States Attorneys, and Government Communication; No Attorney- Thru II, Southern District of Florida, Client Relationship; Factual Materials; Waiver P-013278 seeking advice regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Sunni. Box #3 8/15/08 Emails between A. Acosta and Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; Page 45 of 68 EFTA00802969  Case 9:08-cv-80736-KAM Document 265-2 Entered on FLSD Docket 10/20/2014 Page 57 of 68 Bates Range Description Privilege(s) Asserted Victims' Objections Thru several draft non- prosecution agreements Deliberative Process Government Communication; No Attorney- P-013810 some with handwritten notes by A. Marie Client Relationship; Overriding Need; Claims Villafana; plea sheet State Circuit Court; Against Public Prosecutor; Attorney Conduct copies of draft Information; draft plea at Issue; Factual Materials proffer; draft motion and order to seal; draft penalty sheet; draft plea agreement Suppl. Box 3 File folder entitled "Information Packet Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; P-013811 Drafts" containing several drafts of Work Product Not in Anticipation of Litigation; Ordinary Thru Informations, and complete draft Deliberative Process Government Communication; No Attorney- P-013833 Information packet Client Relationship; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Itippl. Box 3 P- Two pages of filed document, D.E. 62, Atty work-product Inadequate Log; No Factual Underpinnings; 013834 page 2 of 54 and page 6 of 54, Claims Against Public Prosecutor; Overriding Through P- containing handwritten attorney notes Need; Attorney Conduct at Issue 013835 Suppl. Box 3 Palm Beach Daily News Article, Atty work-product Inadequate Log; No Factual Underpinnings; P-013836 "Attorneys want Jeffrey Epstein Claims Against Public Prosecutor; Overriding Thru Agreement Thrown Out," with Need; Attorney Conduct at Issue P-013837 attorney's notes written on margin Suppl. Box 3 Letter from Paul Cassell to Wifredo A. Atty work-product Inadequate Log; No Factual Underpinnings; P-013838 Ferrer, December 10, 2010, Subject: Claims Against Public Prosecutor; Overriding Thru Request for Investigation of Jeffrey Epstein Need; Attorney Conduct at Issue P-013841 Prosecution, with underlines, written notes, and comments bSttoieir Suppl. Box 3 Email from to Atty work-product Inadequate Log; No Factual Underpinnings; P-013842 (OPR), February 25, 2011, Atty-client privilege Crime-Fraud-Misconduct; Factual Materials; 4:31 p.m., Re: request for OPR Ordinary Government Communication; No Investigation — Jeffrey Epstein Non- Attorney-Client Relationship; Claims Against Prosecution Agreement Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 E-mail, Marie Villafana to Andrew Lowrie, Atty work-product Inadequate Log; No Factual Underpinnings; Page 57 of 68 EFTA00802970  Case 9:08-cv-80736-KAM Document 265-2 Entered on FLSD Docket 10/20/2014 Page 64 of 68 Bates Range Description Privilege(s) Asserted Victims' Objections Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 E-mail Menchel to Villafana and Lourie, Any work-product No Factual Underpinnings; Crime-Fraud- P-013906 May 14, 2007, 10:52 a.m., RE: Misconduct; Claims Against Public Operation Leap Year, with e-mail from Prosecutor; Overriding Need; Attorney Villafana to Lourie and Menchel (May Conduct at Issue 14, 2007, 10:38 a.m.), attached Suppl. Box Inadvertently marked as privileged, will 3 P- be produced N/A 013907 Through P-013908 Suppl. Box 3 Memorandum, Assistant Deliberative Process Inadequate Log; No Factual Underpinnings; P-013909 Counsel, U.S. Department of Justice, Privilege; Atty work- Crime-Fraud-Misconduct; Factual Materials; Thru Office of Professional Res nsibility product Final Decision; Waiver; Claims Against Public P-013911 to = , Acting Prosecutor; Overriding Need; Attorney Associate Counsel, OPR, undated, Conduct at Issue Subject: Recommendat' n Suppl. Box 3 Memorandum, Assistant Deliberative Process Inadequate Log; No Factual Underpinnings; P-013912 Counsel, OPR, to Privilege, Atty work- Crime-Fraud-Misconduct; Factual Materials; Thru Acting Associate Counsel, OPR, Subject: product Waiver; Final Decision; Claims Against Public P-013914 Recommendation, with handwritten note Prosecutor; Overriding Need; Attorney dated 5/4/11 Conduct at Issue Suppl. Box 3 Memorandum, Assistant Deliberative Process Inadequate Log; No Factual Underpinnings; P-013915 Counsel, OPR. to Privilege; Atty work- Crime-Fraud-Misconduct; Factual Materials; Thru Acting Associate Counsel, OPR, Subject: product Waiver; Final Decision; Claims Against Public P-013918 Recommendation, with two post-it notes Prosecutor; Overriding Need; Attorney attached with handwritten attorney Conduct at Issue notations, and handwritten notations, underlines, and circled text throughout the body of the two page memorandum Suppl. Box 3 Draft letter, marked "Confidential", from Deliberative Process Inadequate Log; No Factual Underpinnings; Page 64 of 68 EFTA00802971  Case 9 08-cv-80736-KAM Document 265-2 Entered on FLSD Docket 10/20/2014 Page 67 of 68 Bates Range Description Privilege(%) Asserted Victims' Objections P-013946 May 4, 2011, 4:08 p.m., RE: FYI on the investigatory record, Atty Anticipation of Litigation; Overriding Need: Florida matter work product; deliberative Claims Against Public Prosecutor; Attorney process privilege Conduct at Issue; Final Decision; Waiver Suppl. Box 3 E-mail, Paul Cassell to May 3, Atty work product; law No Factual Underpinnings; Crime-Fraud- P-013947 2011,12:23 p.m., RE: OPR Inquiry — enforcement Misconduct; Factual Materials; Not in request for information, with post-it note investigatiory Anticipation of Litigation; Overriding Need: attached with handwritten attorney notes record Claims Against Public Prosecutor; Attorney on telephone call between and Conduct at Issue; Factual Materials; Final Howard with and Marie Decision; Not Within Investigative Privilege Villafana Suppl. Box 3 E-mail, to Howard and Robin Atty work-product No Factual Underpinnings; Crime-Fraud- P-013948 C. Ashton, May 3, 2011, 12:30 p.m., FW: Misconduct; Factual Materials; Claims Against Thru OPR Inquiry — request for information, Public Prosecutor; Overriding Need; Attorney P-013951 with attached c-maiI s. Handwritten Conduct at Issue attorney notes on margin Suppl. Box 3 E-mail, ■ to Atty work-product; Atty- No Factual Underpinnings; Ordinary P-013952 March 16, 2011, 10:52 a.m., RE: Referral client privilege Government Communication; No Attorney- Thru of Cassell Request for Invesialo with Client Relationship; Claims Against Public P-013953 e-mail from Paul Cassell to M • and Prosecutor; Overriding Need; Attorney Marie Villafana (March 15, 2011, 7:21 Conduct at Issue p.m.). attached Suppl. Box 3 E-mail, to OPR, Atty work-product, Atty- Inadequate Log; No Factual Underpinnings; P-013954 December 16, 2010, 10:59 a.m., FW: OPR client privilege Crime-Fraud-Misconduct; Factual Materials; Thru Referral — Allegation of Misconduct — Ordinary Government Communication; No P-013955 U.S. AttornellificiS.D.Fill Attorney-Client Relationship; Waiver; Claims mail from li to Against Public Prosecutor; Overriding Need; (December 16, 2010, 10:22 a.m.), Attorney Conduct at Issue attached. Handwritten attorney notations. Page 67 of 68 EFTA00802972