FOR PUBLICATION

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT IN RE: STAKE CENTER LOCATING, INC., Crime Victim. STAKE CENTER LOCATING, INC., Petitioner, v. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA, LAS VEGAS, Respondent, DEBORAH A. DIFRANCEScO, Defendant-Real Party in Interest, UNITED STATES OF AMERICA, Plaintiff-Real Party in Interest. No. 13-73267 D.C. No. 2: 13-cr-00089- JCM-GWF-1 OPINION Petition for Writ of Mandamus to the United States District Court for the District of Nevada James C. Mahan, District Judge, Presiding EFTA00179613 2 IN RE: STAKE CENTER LOCATING, INC. Submitted September 20, 2013* Filed September 26, 2013 Before: A. Wallace Tashima, Milan D. Smith, Jr., and Sandra S. Ikuta, Circuit Judges. Per Curiam Opinion SUMMARY** Criminal Law A motions panel issued a per curiam opinion denying a crime victim's petition for a writ of mandamus seeking reversal of the district court's denial of the victim's motion for forfeiture under the Crime Victims' Rights Act. The panel explained that the Crime Victims' Rights Act and the Mandatory Victim Restitution Act give victims a right to restitution, not a right to criminal forfeiture. The panel also explained that the Crime Victims' Rights Act expressly does not impair the government's broad discretion to seek forfeiture of assets implicated in an offender's wire fraud. * The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader. EFTA00179614 IN RE: STAKE CENTER LOCATING, INC. 3 COUNSEL Kenneth P. Childs, Stake Center Locating, Inc., Salt Lake City, Utah, for Petitioner. Elizabeth Olson White, Appellate Chief and Assistant United States Attorney, District of Nevada, Reno, Nevada, for Plaintiff-Real Party in Interest. Mark B. Bailus, Bailus Cook & Kelesis, Ltd., Las Vegas, Nevada, for Defendant-Real Party in Interest. OPINION PER CURIAM: Petitioner Stake Center Locating, Inc. ("Stake Center") petitions for a writ of mandamus reversing the district court's denial of its motion for forfeiture under 18 U.S.C. § 3771, the Crime Victims' Rights Act ("CVRA").1 In the underlying criminal action, Deborah DiFrancesco, a former employee of Stake Center, was charged with crimes stemming from her embezzlement of funds from Stake Center and other victims, and pleaded guilty to one count of tax evasion and three counts of wire fraud. Pursuant to her plea agreement, DiFrancesco agreed to make restitution to Stake ' Stake Center previously petitioned this court for mandamus, and we denied this petition as premature. See Stake Ctr. Locating, Inc. v. U.S. Dist. Court (lit re Stake Ctr. Locating, Inc.), 717 F.3d 1089, 1090 (9th Cir. 2013) (per curiam). The district court has now completed sentencing DiFrancesco, and Stake Center's renewed petition is properly before us. EFTA00179615 4 IN RE: STAKE CENTER LOCATING, INC. Center in the amount of $763,846. Stake Center moved the district court to compel the government to institute criminal forfeiture proceedings and to obtain property allegedly traceable to DiFrancesco's crimes and thus subject to forfeiture from third parties. The district court denied this motion. We have jurisdiction under 18 U.S.C. § 3771(d)(3). In reviewing a CVRA mandamus petition, we need not balance the usual factors under Bauman v. United States District Court, 557 F.2d 650, 654-55 (9th Cir. 1977), but rather "must issue the writ whenever we find that the district court's order reflects an abuse of discretion or legal error." Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1017 (9th Cir. 2006). Here, the district court did not abuse its discretion or commit a legal error in denying Stake Center's motion for forfeiture. First, the CVRA and Mandatory Victim Restitution Act ("MVRA") give victims a right to restitution, not a right to criminal forfeiture. The CVRA provides that a crime victim has the "right to full and timely restitution as provided in law." 18 U.S.C. § 3771(a)(6). The Mandatory Victim Restitution Act ("MVRA") requires that a "defendant make restitution to the victim" of certain offenses. 18 U.S.C. § 3663A(a)(1). Criminal forfeiture is not, as petitioner contends, a type of restitution; "[c]riminal forfeiture is . . . separate from restitution, which serves an entirely different purpose." United States v. Newman, 659 F.3d 1235, 1241 (9th Cir. 2011). Among other differences between restitution and forfeiture, only the criminal defendant is subject to restitution, not third parties. See 18 U.S.C. § 3663A(a)(1), (b)(1) (requiring that "defendant make restitution" and "defendant" return property). EFTA00179616 IN RE: STAKE CENTER LOCATING, INC. 5 Nor did the district court err in declining to order the U.S. Attorneys' Office to commence criminal forfeiture proceedings against the Internal Revenue Service and other non-parties alleged to possess assets implicated in DiFrancesco's criminal activities. Contrary to Stake Center's argument, forfeiture is mandatory for wire fraud only if the government exercises its discretion to seek such forfeiture. See 28 U.S.C. § 2461(c); Fed. R. Crim. P. 32.2(a); United States v. Liquidators of European Fed. Credit Bank, 630 F.3d 1139, 1144 (9th Cir. 2011) (describing procedure for forfeiture). "[T]he Government retains broad discretion as to whom to prosecute." Wayte v. United States, 470 U.S. 598, 607 (1985) (quotation omitted). The CVRA expressly does not impair that broad discretion. See 18 U.S.C. § 3771(d)(6) ("Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction.").2 Accordingly, Stake Center's petition for writ of mandamus is denied. DENIED. 2 Because we decide this issue on these grounds, we do not reach the other arguments advanced by the government why forfeiture proceedings cannot be commenced in this case. EFTA00179617 EFTA00179618 Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to give notice of their filing of objections to the Government's two privilege logs (DE 212 and DE 216). The objections are attached hereto. The victims are filing these objections concurrently with a motion to compel production of the materials at issue. DATED: August 16.2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad©pathtojustice.com and Paul G. Cassell Pro Hac Vice 1 EFTA00179619 Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 2 of 3 S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: eassellp©law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 2 EFTA00179620 Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on August 16, 2013, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee®usdoj.gov E-mail: ann.marie.c.villafana®usdoi.gov Attorneys for the Government Roy Black, Esq. Jackie Perezek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300 Miami, FL 33131 Email: pleading®royblack.com (305) 37106421 Jay P. Leflcowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: lefkowitz@kirkland.com (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Email: owlmgw®att.net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00179621 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 EFTA00179622 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08116/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Privileged) 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 Overridden By the Victims' Need for the Documents Investigative Privilege - Privilege Not Properly Invoked Qualified Privilege Overridden By the Victims' Need for the Documents Work Product Doctrine No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Qualified Privilege Overridden By the Victims' Need for the Documents Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(eX3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand Jury Materials Page 1 of 69 Abbreviation Inadequate Log No Factual Underpinnings Waiver Fiduciary Duty Crime-Fraud-Misconduct Factual Materials Not in Anticipation of Litigation Ordinary Government Communication No Attorney-Client Relationship Improper Invocation Final Decision Overriding Need Improper Invocation Overriding Need Claims Against Public Prosecutor Overriding Need Attorney Conduct at Issue Court Authorized Under 6(eX3)(E) Court Inherent Power to Release Proper Victim's Petition CVRA-authorized release EFTA00179623 ease 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 3 of 70 Grand Jury Materials Can Be Severed from Other Materials The Privacy Rights of Other Victims Government Redaction Can Resolve Privacy Concerns No Assertion of Privacy Rights by Other Victims Privacy Act The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Material Severable Redaction No Assertion by Victims Court-Compelled Disclosure Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 File folder entitled "CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings; P-000001 SUBPOENAS" containing correspondence Work Product Fiduciary Duty; Not in Anticipation of thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor; P4)00039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Overriding Need Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings; P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper P-000549 related to enforcement of same, documents subject to investigative Invocation; Overriding Need; Claims Against produced in response to some subpoenas; privilege Public Prosecutor; Attorney Conduct at Issue; and attorney (Villafafia) handwritten notes Also contains documents subject to privacy rights of victims who are not parties to this litigation Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims; Overriding Need Page 2 of 69 EFTA00179624 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 4 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-000550 thru P-000621 File folder entitled "Ritz Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-000622 thru P-000693 File folder entitled "PNY Technologies Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents 6(e) Contains information subject to investigative privilege Also contains information subject to privacy tights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-000694 thru P-000781 File folder entitled "JE Corporations" containing attorney research on Epstein- owned corporations and prior litigation Work Product Contains information subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Overriding Need Box #1 P-000782 thru P-000803 File folder entitled "Capital One" containing subpoena and correspondence 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 3 of 69 EFTA00179625 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-000804 thru P-000854 File folder entitled "DTG Operations/Dollar Rent-a-Car" containing subpoena and responsive documents 6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-000855 thru P-000937 File folder entitled "JP Morgan Chase" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 P-000938 thru P-000947 File folder entitled "Washington Mutual" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victiit's Petition; CVRA- authorized release; Material Severable Box #1 P-000948 thru P-000982 File folder entitled "Computer Search &" containing legal research on computer search and handwritten notes on indictment preparation Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Redaction; No Assertion by Victims Page 4 of 69 EFTA00179626 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/1612013 Page 6 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafaila) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafaila) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P401057 thru P-001959 File folder entitled "Colonial Bank Records" containing records received in response to grand jury subpoena 6(e) Contains information subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(eX3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 5 of 69 EFTA00179627 _ L./own-tent a4-1 Entered on FLSD Docket 08/16/2013 Page 7 of 70 Bates Range Description PrivideRe(s) Asserted Victims' Objections Box #1 P-001960 Thru P-002089 File folder entitled "OLY Grand Jury Log Vol 2: OLY-51 THROUGH" containing subpoenas numbered OLY-51 through OLY-81 with related correspondence 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P402090 Thru P-002169 File folder entitled "Epstein Corporate Records: OLY-51, OLY-52, OLY-53, OLY-54" containing subpoenas, records received in response to subpoenas, and related correspondence 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 P-002170 Thru P402246 File folder entitled "Colonial Bank" containing subpoenas, correspondence related to subpoenas, records received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition: CVRA- authorized release; Material Severable Box #1 P-002247 Thru P-002265 File folder entitled "JEGE & Hyperion from Goldberger OLY-46 & OLY-47" containing documents received in response to subpoenas 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 6 of 69 EFTA00179628 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings; P-002266 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue; investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under typed notes, of individuals listed as and documents subject to 6(eX3)(E); Court Inherent Power to Release; "Additional victims" privacy rights of victims who are not parties to this litigation Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings; P-002387 Grand jury subpoena log, evidence/activity 6(e) Fiduciary Duty; Factual Materials; Not in Thru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002769 contact list, attorney (Villafafta) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Prosecutor; Attorney Conduct at Issue; investigative file, attorney (Villafafia) Also contains information Factual Materials; Court Authorized Under typed notes, relevant pieces of grand jury and documents subject to 6(e)(3)(E); Court Inherent Power to Release; materials, telephone records/flight records privacy rights of victims Proper Victim's Petition; CVRA-authorized analysis charts, victim/witness who are not parties to this release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and related materials for persons identified as litigation Assertion by Victims Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Page 7 of 69 EFTA00179629 Labe v.vo-CV-ou db-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 9 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings; P-002770 witness/victim list with identifying 6(e) Fiduciary Duty; Factual Materials; Not in Thru information, sexual activity summary, Contains information and Anticipation of Litigation; Improper P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against (Villafazia) handwritten notes, 302s, portions of state investigative file, attorney (Villafiula) typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,8 investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings; P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in Thru telephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper P-003545 a number of victim/witnesses, Nadia documents subject to Invocation; Overriding Need; Claims Against Marcinkova, and Adriana Mucinska investigative privilege. Public Prosecutor, Attorney Conduct at Issue; Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 8 of 69 EFTA00179630 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 10 of 70 Bates Range Box #1 P-003546 Thru P-003552 Box #1 P-003553 Thru P-003555B Description FBI Reports of March 2008 interviews of additional witness/victim located in New York Printout of filenames from Federal Express subpoena response with Attorney notations Privilege(s) Asserted Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Victims' Objections Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 P-003556 Thru P-003562 Document entitled "Identified Numbers" with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records Work product 6(e) Contains information subject to investigative privilege Page 9 of 69 EFTA00179631 Lase sus-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 11 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box # I P403563 Thru P-003629 Folder entitled "Flight Manifests" containing manifests received pursuant to grand jury subpoena 6(e) Contains information and documents subject to investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 P-003630 Thru P-003633 File folder entitled "Recent Attorney Notes" containing handwritten attorney (Villafalla) notes regarding document review and case strategy Work product 6(e) Investigative privilege Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008, telephone activity report with attorney (Villafanafia) handwritten notes, related grand jury material Work product Attorney-client privilege 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 10 of 69 EFTA00179632 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box III P-003647 Thru P-003651 File folder entitled "Summary of Sexual Activity" containing chart bearing handwritten title "Sexual Activity — Summary" with meta-analysis of information, sorted by name of each victim/witness, including name and identifying information of each victim/witness Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-003652 Thru P-003663 File folder entitled "Victim Civil Suits" Not privileged. Produced to counsel for Petitioners N/A Box #1 P-003664 Thru P-003678 File folder entitled "Research re JE Websites" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (Villafafia) handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney (Villafafla) memo to expert witness and handwritten attorney notes Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 11 of 69 EFTA00179633 too-KARA Document 224-1 Entered on FLSD Docket 08/16/2013 Page 13 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-003688 Thru P-003693 File folder entitled "ID GO Interview" containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges Work product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Redaction; No Assertion by Victims Box #1 P-003694 Thru P-003711 File folder entitled "Research re Travel for Prostitution" containing attorney (Villafafta) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury information Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-003712 Empty file folder bearing name of victim/witness Investigative privilege Also contains information subject to privacy rights of victim who is not a party to this litigation N/A Box #1 P-003713 Thru P-003746 File folder entitled "TO MO" containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same 6(e) Documents under seal pursuant to court order Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 P-003747 Thru P-003751 File folder entitled "Adrian Ross" containing subpoena and correspondence regarding same 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 12 of 69 EFTA00179634 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-003752 Thru P-004295 File folder entitled "PBPD Investigative File" obtained via subpoena 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(eX3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-004296 Thru P404350 File folder bearing name of victim/witness containing meta-analysis chart showing telephone calls, travel, and grand jury materials relevant to possible charges Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-004351 Thu P-004381 File folder entitled "Daniel Gonzalez Documents 53909-004" containing attorney research related to bias issue Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #1 P-004382 Thru P-004478 File Folder entitled "FEDEX" containing documents obtained via subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 13 of 69 EFTA00179635 air VO-CV-dU fib -KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 15 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-004479 Thru P404551 File Folder entitled "State of Delaware Records" containing documents obtained in preparation for indictment 6(e) Investigative privilege Work product Inadequate Log No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 P-004552 Thru P-004555 File folder entitled "Jet Blue Records" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-004556 Thru P-004560 File folder entitled "FL EMPLOYMENT RECORDS" containing FDLE records on targets and witnesses obtained at attorney request Investigative privilege Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafla) handwritten notes of interview Work product Investigative privilege • Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 14 of 69 EFTA00179636 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 16 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-004717 Thru P-004722 File folder entitled "IGOR ZINOVIEV" containing attorney research regarding witness Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-004723 Thru P-004725 File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Box #1 P-004726 Thru P-004819 File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business litiLative practices Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Box #1 P-004820 Thru P-004959 Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships Work Product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 15 of 69 EFTA00179637 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 17 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-004960 Thru P-005059 File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005060 Thru P-005081 File folder bearing name of victim/witness containing correspondence with counsel for victim/witness, attorney witness outline with attorney handwritten notes, attorney handwritten notes regarding witness reports and case preparation Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue P-005084 thru P-005107 are non responsive documents and have been removed N/A Page 16 of 69 EFTA00179638 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 18 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-005108 Thu P-005193 File folder entitled "ANNA SALTER" containing attorney research on select expert, use of experts at trials in child exploitation cases, and additional research materials on offenders and victims Work product Investigative privilege Inadequate Log; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 P-005194 Thru P-005300 File folder entitled "Extra Copies" containing meta-analysis chart and 302's of victim/witnesses used in preparing indictment package Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005301 Thru P-005331 File folder entitled "JUAN ALESSI STATEMENT" containing transcript obtained via subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 P-005332 Thru P405341 File folder entitled "KEN LANNING" containing attorney research on select expert, including attorney handwritten notes Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Page 17 of 69 EFTA00179639 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 19 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-005342 Thru P-005387 File folder entitled "Info re Planes" containing correspondence regarding subpoenas and documents received in response to subpoenas 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 P-005388 Thru P-005442 File folder entitled "Police Reports & PC Affidavit" containing portions of police reports with attorney notes, related phone records, a list entitled "Victims" with identifying information and attorney handwritten notes, photographs and DAVID information, and additional attorney research regarding Epstein sexual activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005443 Thru P-005496 File folder entitled "[Victim name] Transcript of Interview & G.T Transcript" 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Page 18 of 69 EFTA00179640 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 20 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #1 P-005557 Thru P-005576 U.S. Attorney's Office Criminal Case File Jacket containing file opening documents, expert witness payment documents Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Box #1 P-005578 Thru P-005583 U.S. Attorney's Office Asset Forfeiture Case File Jacket containing file opening and file closing documents Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Box #1 P-005584 Ulm P-005605 File folder entitled "6001 Immunity Request" containing internal memoranda seeking witness immunity and correspondence with counsel for witness regarding same 6(e) Work product and deliberative process (as to internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-005607 Thru P-005914 File folder entitled "MASTER PHONE RECORDS" containing meta-analysis of all phone, travel, and grand jury data for all victim/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 19 of 69 EFTA00179641 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 21 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-005915 Thru P-005977 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-005978 Thsu P-006050 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-006051 Thru P-006065 File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 20 of 69 EFTA00179642 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 22 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-006066 Thru P-006220 File folder entitled "JANE DOE #4" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-006221 Thru P-006222 File folder entitled ""JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-006223 Thru P-006522 File folder entitled "CORRECTED PHONE RECORDS 5/31/0? containing meta-analysis of all phone, travel, and grand jury data related to all victims/witnesses for indictment preparation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 21 of 69 EFTA00179643 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 23 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-006523 Thru P-006802 File folder entitled "[Victim Name] Phone Records" containing telephone records received in response to subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-006803 Thru P-006860 File folder entitled "Lists of Identified Phone Numbers" containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-006861 Thm P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents received via subpoena with attorney handwritten notes and highlighting Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 22 of 69 EFTA00179644 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 24 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-007786 Thru P-008120 Folder entitled "OLY GRAND JURY LOG: OLY-01 THROUGH OLY-50" containing subpoenas, correspondence regarding same, 6(e) letters, attorney handwritten notes regarding records received in response to subpoenas Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008121 Thru P-008139 Handwritten flight logs received in response to subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #2 P-008140 Thru P-008298 Grand jury presentation folder containing attorney handwritten notes, typed outline with additional handwritten notes, complete indictment package dated 2/19/2008, victim list with identifying information, photographs, and summary of activity Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 23 of 69 EFTA00179645 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 25 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 File folder entitled "FINAL P-008299 Thru AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P- N/A P-008363 008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non- Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez- Acosta letter (P-008328-P-008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanchez Ltr" containing unredacted copies of that letter (P-008344-P-008363 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit]) Box #2 File folder entitled "Lacerda Immunity 6(e) Inadequate Log; No Factual Underpinnings; P-008364 Thru Request" containing internal memoranda, Justice Department documentation, and Work Product Deliberative Process Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding P-008382 subpoena regarding immunity request Investigative privilege Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 24 of 69 EFTA00179646 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 26 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Inadequate Log, No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit] N/A Box #2 P408536 Thru P408542 Handwritten attorney notes to prepare for interview of Jane Doe #2 Work product Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims Box #2 P-008543 Thru P408549 Handwritten attorney notes regarding May 8, 2007 grand jury presentation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 25 of 69 EFTA00179647 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 27 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-008550 Thru P-008615 File folder entitled "Most Recent Indictment & Good Cases" containing draft indictment and legal research Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008616 Thru P-008686 File folder entitled "FBI Summary Charts" containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable ; Redaction; No Assertion by Victims Box #2 P-008687 Thru P-008776 File folder entitled "[Victim name)/Jane Doe #4" containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information and documents subject to privacy tights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 26 of 69 EFTA00179648 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 28 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P408777 Thru P408808 File folder entitled "[Victim name]/Jane Doe #5" containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008809 Thru P408847 File folder entitled "[Victim name]/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008848 Thru P-008862 File folder entitled "[Victim name]/Jane Doe #7" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 27 of 69 EFTA00179649 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 29 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-008863 Thru P-008890 File folder entitled "[Victim name]/Jane Doe #8" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008891 Thru P-009103 File folder entitled "Certified Copy of State Case" containing certified copy of Epstein state criminal cases and change of plea transcript [not being withheld as privileged — copy provided to opposing counsel] N/A Box #2 P-009104 Thru P-009111 File folder entitled "Meeting Timeline" containing Villafaria typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to A. Marie Villafaria and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by Il th Circuit] N/A Page 28 of 69 EFTA00179650 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 30 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P409114 Tint P-009115 7/3/2008 Email from A. Marie Villafafia to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged — produced to opposing counsel] N/A Box #2 P409116 Thu P-009125 12/6/2007 Letter from Jeffrey Sloman to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit]) N/A Box #2 P-009126 Thru P-009134 File folder entitled "[Victim name]/Jane Doe #9" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-009135 Thru P409141 File folder entitled "[Victim name]/Jane Doe #13" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 29 of 69 EFTA00179651 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 31 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-009141A Thru P-009141C File folder entitled "[Victim name]/Jane Doe #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P4)09142 Thru P-009152 File folder entitled Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims containing meta-ana ysis of all phone, travel, and grand jury data related to that individual for indictment preparation Box #2 P-009153 Thru P-009156 File folder entitleatiall containing meta- ysis o phone, travel, and grand jury data related to that individual for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 30 of 69 EFTA00179652 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 32 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-009157 Thru P-009208 File folder entitled "[Victim name]/Jane Doe #1" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P409209 Thru P409213 File folder entitled "[Victim name]/Jane Doe #2" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-009214 Thru P-009271 File folder entitled "[Victim name]/Jane Doe #3" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 31 of 69 EFTA00179653 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLED Docket 08/16/2013 Page 33 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-009272 Thru P-009354 File folder entitled "Purpose of Travel Cases" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-009355 Thru P-009403 File folder entitled "Interstate Commerce Cases" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009404 Thru P-009536 File folder entitled "Attorney Conflict Research" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009537 Thru P-009574 File folder entitled "Mann Act/Travel to Have Sex w/Minor" containing attorney research and handwritten notes Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009575 Thru P-009603 File folder entitled "Travel Act" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-009604 Thru P-00971I File folder entitled "Florida Prostitution/Lewdness Statutes" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-009712 Thru P409819 Booklet entitled "Attorney General Guidelines for Victim and Witness Assistance" [not being withheld as privileged — produced to opposing counsel] N/A Box #2 P-009820 Thru P-009965 File folder entitled "Corporate Liability Rsrch" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Page 32 of 69 EFTA00179654 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08(16/2013 Page 34 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-009966 Thru P410096 File folder entitled "Research re Knowledge of Age Unnecessary" containing attorney research and handwritten notes and copy of grand jury subpoena Work Product 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 P-010097 Thru P410276 File folder entitled "Money Laundering" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor Overriding Need; Attorney Conduct at Issue Box #2 P-010277 Thru P410394 File folder entitled "1960 & Aiding/Abetting" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P410395 Thru P-010488 File folder entitled "18 USC § 2255 Cases" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P410489 Thru P-010509 File folder entitled "Research re Overt Acts & Witness Testimony" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P410510 Thru P410525 File folder entitled "Extradition" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Page 33 of 69 EFTA00179655 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 35 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-010526 Thru P-010641 File folder entitled "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher, and a November 29, 2007 letter Erom Jay Lefkowitz to IL Alexander Acosta (P- 010528 thru P-010530 and P-010556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by 11th Circuit) Work Product Deliberative Process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue Box #2 P-010642 Thm P-01650 File folder entitled "Immunity" containing attorney research on granting immunity to witnesses Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-010651 Thru P-010659 File folder entitled "Research re G.J. Transcript" containing attorney research and draft pleadings re compelling production of grand jury transcript with subpoena Work Product 6(e) Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 34 of 69 EFTA00179656 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 36 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-010660 Thm P410757 File folder entitled "Research re GJ Transcript" containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to subpoena Work Product 6(e) . Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box 42 P-010758 Thru P-010793 File folder entitled "Original Proposed Ind." containing draft indictment Work Product 6(e) Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 P-010794 Thru P-010829 File folder entitled "Epstein" containing sample indictments and attorney research re potential charges with attorney notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-010830 Thru P-010853 File folder entitled "1591 & Money Laundering" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-010854 Thru P410876 File folder entitled "18 USC 2425" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Page 35 of 69 EFTA00179657 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 37 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-010877 Thru P-010920 File folder entitled "Knowledge of Age" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-010921 Thru P-011049 File folder entitled "2423(b) Constitutionality and Purpose of Travel" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-011050 Thru P-011212 File folder entitled "Mistake not a Defense" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011213 Thru P-011237 File folder entitled "Research re `Pandering'" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-011238 Thru P-0I 1319 File folder entitled "Research re Grand Jury Instructions" containing attorney research and handwritten notes Work Product 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #2 P-011320 Thru P-011361 File folder entitled "Telephone = Facility of Commerce" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #2 P-011362 Thru P-011374 File folder entitled "Def of Prostitution" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Page 36 of 69 EFTA00179658 Case 9:08-cv-80736-KAM Document 2241 Entered on FLSD Docket 08/16/2013 Page 38 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #2 P-011375 Thru P411456 File folder entitled "Relevant Florida Statutes" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #2 P-011457 mm P411626 File folder entitled "Unit of Prosecution Research" containing attorney research and handwritten notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #3 P-011627 Thm P411662 File folder entitled "Attorney Notes" containing attorney handwritten and typed notes Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #3 P411663 Thm P-011698 and P-012189 thru P-012361 (gap was scanning error) File folder entitled "Drafts" containing draft indictments with attorney handwritten notes, draft internal memoranda, relevant witness interview reports and grand jury material and attorney handwritten notes 6(e) Work Product Deliberative Process Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 P411699 Thru P-011777 File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections 6(e) Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3XE); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 37 of 69 EFTA00179659 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 39 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 P-011778 Thru P-011788 File folder entitled "6/12/09 Victim Notil Log" containing chart with victim contact information and attorney notes regarding dates and type of contacts Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Box #3 P-011789 Thru P-011879 File folder entitled "Breach Memo" containing memorandum analyzing breach of Non-Prosecution Agreement with attachments Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials Box #3 P-011880 Thru P-011922 File folder entitled "Overt Act Lists" containing handwritten notes cross- checking all overt acts alleged in draft indictment by victim and typed overt act summary charts for indictment preparation Work product Attorney-client privilege Deliberative process 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 38 of 69 EFTA00179660 CasP 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 40 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in Anticipation of Litigation; P-011966 Sanchez to Andrew Lourie with handwritten attorney (Lourie) notes; Attorney-Client Privilege Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against ■ 6/25/2007 letter from Gerald Public Prosecutor, Attorney Conduct at Issue; Lefeourt to Jeffrey Sloman, Matt Factual Materials; Court Authorized Under Menchal, Andrew Lourie, and 6(e)(3)(E); Court Inherent Power to Release; Marie Vi Ilafarla with handwritten attorney (Villafarla) notes; Proper Victim's Petition; CVRA-authorized release; Material Severable ■ 6/25/2007 email from Andrew Lourie to Matt Menchel and Marie Villafafia entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney (Villafinia) notes regarding main themes raised by Epstein counsel Box #3 Composition book entitled "Operation Work product Inadequate Log; No Factual Underpinnings; P-011967 Leap Yea?' containing attorney Investigative privilege Fiduciary Duty; Factual Materials; Not in Thru handwritten notes regarding investigation 6(e) Anticipation of Litigation; Improper P412016 and case strategy Contains information subject to privacy rights of victims who are not parties to this litigation Invocation; Overriding Need; Claims Against Public Prosecutor, Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(eX3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 39 of 69 EFTA00179661 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 41 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Box #3 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual M