EFTA01819037

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70

Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA00208682 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged Objection General Objections -- Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Government's Fiduciary Duty to Crime Victims Bars Privilege Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections - Privilege Not Properly Invoked Final Decision Exempted from Privilege Qualified Privilege Ove

EFTA02729648

Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res

THE PALM BEACH POST

THE PALM BEACH POST • WEDNESDAY, AUGUST 13.2008 Eclectic mix visits jailed tycoon A scientist, a stuntman and a reputed `sex slave visit Epstein By LARRY KELLER Palm Reach Past Staff WSJ". WEST PAIN BEACH -- TYcoon Jeffrey Epstein mingled with an eclectic mix of people, including beautiful young women, before he got into trouble for paying teen- age girls to give him sexual massages at his Palm Beach mansion. Not much has changed, even though he now resides in a dorm at the Palm Beach County Sheriff's Office 17-acre, 967-bed stockade near the fairgrounds. During his first month of confinement, Epstein was visited by the female assis- tant who, girls told police, had escorted them to the room at his mansion where they gave him naked massages. Also trekking to the jail was a young woman whom Epstein purportedly de- scribed as his Yugoslavian sex slave. The wealthy financier and science wonk also has been visited by an expert on artificial intelligence, as well as

CLAIM FOR DAMAGE,

CLAIM FOR DAMAGE, INJURY, OR DEATH INSTRUCTIONS: Please read carefully the instructions on the reverse side and supply information requested on both sides of this form. Use additional sheet(s) if necessary. See reverse side for additional instructions. FORM APPROVED OMB NO. 1105-0008 1. Submit to Appropriate Federal Agency: FTCA Claims Administrator do General Counsel FBI Headquarters, 935 Pennsylvania Avenue, NW Washington, D.C. 20535-0001 2. Name, address of claimant. and claimant's personal representative if any. (See instructions on reverse). Number. Street. City, State and Lp code. Go Jennifer reeman, Esq. Marsh Law Firm PLLC 3. TYPE OF EMPLOYMENT 4. DATE OF BIRTH 5. MARITAL STATUS single 6. TE ANb DAY ACCIDENT summer of 1996: before and after 7. TIME (AM. OR P.M.) 0 MILITARY X CIVILIAN B. BASIS OF CLAIM (State in detail the known fads and circumstances attending the damage. injuiy. or death. identifying persons and property involved, the place of ocamen