Text extracted via OCR from the original document. May contain errors from the scanning process.
www.flsb.uscourts.gov
IN RE:
Debtor.
CASE NO.: 09-34791-RBR
CHAPTER 11
PRIVILEGE LOG
LEHRMAN
Dated: February 23, 2011
Total of 159 pages
EFTA00310047
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
08076-08089 08/04/2009
Bradley Edwards 1 Spencer Kuvin
Transcript of Alfredo Rodriguez
Deposition
Joint W/P Priv.
08311-08318 05/26/2009
Bradley Edwards
Katherine Ezell
WPB-Confidential-General-
Joint W/P Priv.
Financial Disclosure/Discovery
08319-08324 10/16/2009
Bradley Edwards
Amy Ederi
WPB-General-Confidential
Joint W/P Priv.
08398
09/01/2009
Bradley Edwards
Kikka Claudio
C.M.A.
vs.
Epstein,
et
al.(File#:281849)
Joint W/P Priv.
08402
09/17/2009
Bradley Edwards
Paul Cassell
Report this as a parole violation
Joint W/P Priv.
08415
09/16/2009
Bradley Edwards
Margaret Berk
Scanned
document
from
Margaret Berk
Joint W/P Priv.
08422
08/11/2009
Bradley Edwards
Katherine Ezell
Subpoena
directed
to
the
investigators
Joint W/P Priv.
10060
08/03/2009
Adam Horowitz
Jacquie Johnson
Epstein-Depo-New York
Joint W/P Priv.
10069-10074 08/04/2009
Bradley Edwards
Spencer Kuvin
RE:Transcript
of
Alfredo
Rodriguez Deposition
Joint W/P Priv.
10077-10079 08/06/2009
Bradley Edwards
Mercedes Estrada
RE:Epstein vs. Jane Doe No.101
& Epstein vs. Jane doe No. 102
Joint W/P Priv.
10099-10102 08/27/2009
Bradley Edwards
Spencer Kuvin
RE: Epstein Depo
Joint W/P Priv.
10192
08/11/2009
Adam Horowitz
Jacquie Johnson
Trump Depo moved 08/18 to
9/24 in NY
Joint W/P Priv.
10194.10195 08/11/2009
Jacquie Johnson
Kikka Claudio
FW: Out of state subpoenas
Joint W/P Priv.
10264-10266 08/09/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein-Letter
regarding
Leslie Wexner
Joint W/P Priv.
1
EFTA00310048
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
10279-10291 08/10/2009
Adam Horowitz
Jacquie Johnson
RE: Epstein-Notice of production
from non parties/depo of Jane
Doe
Joint W/P Priv.
10372-10373 09/17/2009
Bradley Edwards
Katherine Ezell
RE: Leslie Wexner
Joint W/P Priv.
10490-10493 09/21/2009
Bradley Edwards
Amy Ederi
FW: Epstein Depo
Joint W/P Priv.
10592-10593 09/29/2009
Bradley Edwards
Katherine Ezell
RE: Leslie Wexner
Joint W/P Priv.
10604-10620 10/01/2009
Bradley Edwards
Katherine Ezell
FW:meeting w/ any fr wexner
Joint W/P Priv.
10639-10643 10/06/2009
Bradley Edwards
Stuart Mermelstein Meeting w/Leslie Wexner
Joint W/P Priv.
10700-10702 10/13/2009
Adam Horowitz
Jacquie Johnson
Depo
Joint W/P Priv.
10724-1073
10/14/2009
Adam Horowitz
Jacquie Johnson
Epstein-depo of Alan Dershowitz
Joint w/P Priv.
10897
10/29/2009
Bradley Edwards
Stuart Mermelstein
Leslie Wexner
Joint W/P Priv.
10992.11005 06/22/2009
Bradley Edwards
Amy Ederi
RE:Regular Monthly Cong. Call
Joint W/P Priv.
11011-11021 06/23/2009
Bradley Edwards
Katherine Ezell
RE:Regular Monthly Cong. Call
Joint W/P Priv.
11026-11032 07/09/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
commissioner
appointees
Joint W/P Priv.
11072-11074 07/28/2009
Bradley Edwards
Katherine Ezell
Possible
witness
from
Switzerland
Joint W/P Priv.
11166-11169 06/23/2009
Katherine Ezell
Bradley Edwards
RE:Article:Bear Stearns
Joint W/P Priv.
2
EFTA00310049
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
11240-11245 06/22/2009
Katherine Ezell
Bradley Edwards
Article:Bear Stearns
Joint W/P Priv.
11248-11250 06/22/2009
Amy Ederi
Bradley Edwards
Article:Bear Stearns
Joint W/P Priv.
11255-11259 06/23/2009
Katherine Ezell
Bradley Edwards
USAO Chose Bradley Edwards
conversation
Joint W/P Priv.
11269-11281 06/30/2009
Stuart
Mermelstein
Bradley Edwards
RE:Epstein
Depo;possible
deponents
Joint W/P Priv.
11316.11319 06/28/2009
Katherine Ezell
Bradley Edwards
Discussion
about
possible
witness from Switzerland
Joint W/P Priv.
11332-11336 08/04/2009
Spencer Kuvin
Bradley Edwards
FW:Transcript
of
Alfrefo
Rodriguez Depo and Copperfeild
and Clinton's whereabouts
Joint W/P Priv.
11340-11341 08/05/2009
Mercedes
Estrada
Bradley Edwards
RE:Epstein vs.Jane Doe No.101 &
102
Joint W/P Priv.
11348-11358 08/06/2009
Adam Horowitz
Bradley Edwards
RE:Motion
for
protective
order/discussion
Joint w/P Priv.
11430-11434 08/27/2009
Spencer Kuvin
Bradley Edwards
Discussion
RE:Wexner
involvement
Joint W/P Priv.
11443
09/17/2009
Katherine Ezell
Bradley Edwards
Wexner served subpoena Oil
Joint W/P Priv.
11541-11542 09/29/2009
Katherine Ezell
Bradley Edwards
RE:Leslie Wexner & Bob
Joint W/P Priv.
11551-11559 10/01/2009
Spencer Kuvin
Bradley Edwards
RE:Meeting w.Stanely Arkin
Joint W/P Priv.
11585-11586 10/14/2009
Adam Horowitz
Bradley Edwards
RE:Epstein;Larry
Visoski
confirmed
Joint W/P Priv.
11675-11676 10/29/2009
Stuart
Mermelstein
Bradley Edwards
RE:Leslie Wexner attorney info
Joint W/P Priv.
3
EFTA00310050
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
15981.15988 08/04/2009
Spencer Kuvin
Jacquie Johnson
Attachment:Kellen
&
Trump
subpoena
Joint W/P Priv.
15999-16007 08/05/2009
Bert Patton
Jacquie Johnson
RE:Epstein Depo-New York
Joint W/P Priv.
16057-16065 08/06/2009
Mercedes
Estrada
Jacquie Johnson
Trump and Maxwell Dep dates
Joint W/P Priv.
15918-15949 08/04/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein Depo's 08/14,17,18 in
NY & OH
Joint W/P Priv.
16066-16069 08/06/2009
Adam Horowitz
Jacquie Johnson
Maxwell,Trump, Wexner convo
RE:Depo dates
Joint W/P Priv.
16095-16098 08/11/2009
Adam Horowitz
Jacquie Johnson
Maxwell,Trumo,Wexner
Convo
RE:Depo dates cont..
Joint W/P Priv.
15813-15814 10/29/2009
Stuart
Mermelstein
Bradley Edwards
Wexler Lawyer's info
Joint W/P Priv.
15856
08/03/2009
Adam Horowitz
Jacquie Johnson
Epstein Depo-NY;2 Attachments
Joint W/P Priv.
15866-15881 08/03/2009
Adam Horowitz
Jacquie Johnson
Epstein Depos 08/14,17,18 in
NY&OH/PDF of
Notice of Videotaped Depo
Joint W/P Priv.
15893-15901 08/03/2009
Kikka Claudio
Jacquie Johnson
Depo &subpoena notice for
Trump
Joint W/P Priv.
15360-15363 09/01/2009
Jacquie Johnson
Mercedes Estrada
RE:Alan Dershowitz;Harvard Law
Info
Joint W/P Priv.
15394-15397 09/09/2009
Jacquie Johnson
Katherine Ezell
RE:Epstein-Depos of
Joint W/P Priv.
&
15413-15428 09/10/2009
Adam Horowitz
Jacquie Johnson
RE:Esptein-Notice of Prodcution
from Non Parties
Joint W/P Priv.
15434-15437 09/10/2009
Jacquie Johnson
Katherine Ezell
Notice Of Production from Non-
Parties discussion
Joint W/P Priv.
4
EFTA00310051
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
15454-15475 09/15/2009
Adam Horowitz
Jacquie Johnson
Critton's notice of depo;Epstein
notice of hearing,Mark Epstein
notice of depo
Joint W/P Priv.
01465
07/13/2009
Katherine Ezell
Bradley Edwards
Epstein
Joint W/P Priv.
15485-15492 09/17/2009
Jacquie Johnson
Mercedes Estrada
RE:Epstein Depo
Joint W/P Priv.
15493-15500 09/18/2009
Jacquie Johnson
Katherine Ezell
RE:Deposition
of
Jean
Luc
Bruhnel
Joint W/P Priv.
15501.15555 09/18/2009
Jacquie Johnson
Adam Horowitz
RE:Epstein Depo
Joint W/P Priv.
15556-15564 09/22/2009
Jacquie Johnson
Margaret Berk
Epstein Depos
Joint W/P Priv.
15565-15575 09/25/2009
Jacquie Johnson
Lisa Rivera
FW:Deposition
of
Jean
Luc
Bruhnel
Joint W/P Priv.
15687-15688 10/01/2009
Jacquie Johnson
Lisa Rivera
Depo of David Hart Rogers
Joint W/P Priv.
15692-15707 10/01/2009
Jacquie Johnson
Katherine Ezell
FW:Meeting w/Sranley Arkin
Joint W/P Priv.
15708-15709 10/06/2009
Jacquie Johnson
Mercedes Estrada
RE:Jane Does 2-8v. Epstein-Cross
Nod's of Oct 6-8 depos
Joint W/P Priv.
15033-15032 08/05/2009
Jacquie Johnson
Mercedes Estrada
RE:Epstein-Depo for 8/17
Joint W/P Priv.
15087.15093 08/06/2009
Jacquie Johnson
Mercedes Estrada
RE:Epstein-Depo for 8/17
Joint W/P Priv.
15094-15100 08/06/2009
Jacquie Johnson
Kikka Claudio
RE:Epstein Depo-New York
Joint W/P Priv.
15109-15112 08/10/2009
Jacquie Johnson
Adam Horowitz
RE:Epstein
Depositions
for
8/14,17,18 in NY & OH
Joint W/P Priv.
5
EFTA00310052
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
15122-15125 08/11/2009
Jacquie Johnson
Kikka Claudio
RE:
Ms.
Maxwell
Depo
rescheduled
Joint W/P Priv.
15142-15158 08/11/2209
Bradley Edwards
Kikka Claudio
FW:out of state subpoenas
Joint W/P Priv.
15166-15170 08/11/2009
Jacquie Johnson
Kikka Claudio
RE:out of state subpoenas
Joint W/P Priv.
15171-15172 08/11/2009
Jacquie Johnson
Kikka Claudio
RE:Epstein
Joint W/P Priv.
15178-15182 08/12/2009
Jacquie Johnson
Kikka Claudio
RE:Epstein
Joint W/P Priv.
15306.15355 08/25/2009
Jacquie Johnson
Kikka Claudio
FW:Epstein Depo Notices & Subs
Joint W/P Priv.
14951-14952 08/03/2009
Jacquie Johnson
Kikka Claudio
RE:Epstein Depo-New York
Joint W/P Priv.
14954-14972 09/16/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein-Depo of Mark Epstein
on 9/21 in NY will take place as
scheduled
Joint W/P Priv.
14979.14981 08/03/2009
Jacquie Johnson
Kikka Claudio
RE:Epstein Depo-New York
Joint W/P Priv.
14983-15015 08/04/2009
Jacquie Johnson
Adam Horowitz
RE:Epstein Depositions 8/14.17,
&18 in NY & OH
Joint W/P Priv.
16501-16519 09/15/2009
Adam Horowitz
Jacquie Johnson
Epstein Hearing
Joint W/P Priv.
16520-16547 09/09/2009
Spencer Kuvin
Jacquie Johnson
RE:Epstein-Deposition of Jane
Doe-9/30/2009
Joint W/P Priv.
16355-16384 08/24/2009
Adam Horowitz
Jacquie Johnson
Epstein Depo Notices and Subs
Joint W/P Priv.
16554.16568 09/16/2009
Kikka Claudio
Jacquie Johnson
RE:Epstein Depo
Joint W/P Priv.
6
EFTA00310053
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
16574.16577 09/17/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein Depo
Joint W/P Priv.
16396-16398 09/01/2009
Margaret Estrada
Jacquie Johnson
Alan Dershowitz
Joint W/P Priv.
16578-16581 09/17/2009
Katherine Ezell
Jacquie Johnson
RE:Depo
Joint W/P Priv.
16582-16585 09/18/2009
Adam Horowitz
Jacquie Johnson
RE:Deposition
of
Jean
Luc
Bruhnel
Joint W/P Priv.
16585-16611 09/18/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein Depo
Joint W/P Priv.
16612.16439 09/18/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein Depo of Mark Epstein
Joint W/P Priv.
16440
08/18/2009
Spencer Kuvin
Jacquie Johnson
RE:Epstein Sub to Bear Steam
Joint W/P Priv.
16740.16753 09/22/2009
Margaret Berk
Jacquie Johnson
RE:Epstein Depos
Joint W/P Priv.
16443-16452 09/09/2009
Katherine Ezell
Jacquie Johnson
RE:Epstein-Depos of
Joint W/P Priv.
&
16777-16786 09/30/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein
Joint W/P Priv.
16793-16794
10/01/2009
Lisa Rivera
Jacquie Johnson
RE:Depo of David Hart Rogers
Joint W/P Priv.
16462-16477 09/10/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein-Notice of Production
from Non Parties
Joint W/P Priv.
16802.16823 10/02/2009
Margaret Berk
Jacquie Johnson
RE:Epstein depos
Joint W/P Priv.
16483-16486 09/10/2009
Katherine Ezell
Jacquie Johnson
RE:Epstein-Notice of Production
from Non Parties
Joint W/P Priv.
7
EFTA00310054
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
16874-16880 10/13/2009
Adam Horowitz
Jacquie Johnson
Depo
Joint W/P Priv.
16904-16905 10/14/2009
Spencer Kuvin
Jacquie Johnson
RE:Epstein
Joint W/P Priv.
16945
10/26/2009
Kikka Claudio
Jacquie Johnson
RE:Epstein depos on 10/28
Joint W/P Priv.
17033-17034 10/26/2009
Kikka Claudio
Jacquie Johnson
RE:Epstein depos on 10/28
Joint W/P Priv.
02065-02068 06/08/2009
Bradley Edwards
Mercedes Estrada
FW:Epstein-Confirming
AT&T
Dial Telephone Conference for
Joint W/P Priv.
Mon 6/8/09 at 2:00 p.m.
02070
09/02/2009
Jacquie Johnson
Spencer Kuvin
FW:E , stein-De os
of
&
Joint W/P Priv.
02071
08/18/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein Sub to Bear Sterns
Joint W/P Priv.
02072-02078 09/04/2009
Jacquie Johnson
Spencer Kuvin
FW:E .stein-De.
&
of Joint W/P Priv.
03466-03468 05/14/2009
Spencer Kuvin
Bradley Edwards
RE:Actvity
in
Case
9:08-cv-
80893-KAM Doe v. Epstein Order
on Motion to Stay
Joint W/P Priv.
02301.02302 09/09/2009
Paul Cassel
Bradley Edwards
FW:Epstein
Joint W/P Priv.
03122-03123 06/10/2009
Adam Horowitz
Bradley Edwards
FW: Motion to Dismiss
Joint W/P Priv.
02805-02806 05/26/2009
Susan Stirling
Katherine Ezell
RE:WPB-Confidential-Genereal-
Joint W/P Priv.
Financial Disclosure/Discovery
02670-02671 10/21/2009
Bradley Edwards
Spencer Kuvin
FW:Subpoena Info
Joint W/P Priv.
02517-02519 10/02/2009
Bradley Edwards
Katherine Ezell
FW:Meeting w/Stanley Arkin
Joint W/P Priv.
8
EFTA00310055
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
02614-02617 08/05/2009
Bradley Edwards
Kikka Claudio
FW:Proposal Request
Joint W/P Priv.
15702-15704 10/02/2009
Bradley Edwards
Katherine Ezell
FW:Meeting w/Stanley Arkin
Joint W/P Priv.
15581-15585 09/28/2009
Bradley Edwards
Amy Ederi
FW:Epstein Depo
Joint W/P Priv.
15431-15433 09/10/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein-Notice of Production
from Non Parties
Joint w/P Priv.
15797-15798 10/14/2009
Spencer Kuvin
Bradley Edwards
RE:Epstein
Joint W/P Priv.
11560-11562 10/02/2009
Bradley Edwards
Katherine
Jacquie FW:Meeting w/Stanley Arkin
Joint W/P Priv.
Johnson
11444-11448 09/28/2009
Bradley Edwards
Amy Ederi
FW:Epstein Depo
Joint W/P Priv.
05823
09/04/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein
Joint W/P Priv.
05832
09/08/2009
Adam Horowitz
Jacquie Johnson
RE:Epstein
Joint W/P Priv.
05838
09/08/2009
Jacquie Johnson
Jack Hill
RE:Epstein
Joint W/P Priv.
05847
09/09/2009
Jacquie Johnson
Katherine Ezell
RE:Epstein
Joint W/P Priv.
05859
07/23/2009
Bradley Edwards
Katherine Ezell
RE:Epstein
Joint W/P Priv.
05863.05864 07/23/2009
Bradley Edwards
Katherine Ezell
RE:Epstein
Joint W/P Priv.
05886-05887 07/24/2009
Bradley Edwards
Katherine Ezell
RE:Epstein
Joint W/P Priv.
9
EFTA00310056
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05902.05903 07/28/2009
Bradley Edwards
Katherine Ezell
RE:Epstein
Joint W/P Priv.
05906.05907 07/28/2009
Bradley Edwards
Katherine Ezell
RE:Epstein
Joint W/P Priv.
05912
08/27/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
Joint W/P Priv.
05928-05930 07/28/2009
Bradley Edwards
Katherine Ezell
RE:Epstein
Joint W/P Priv.
05933-05934 09/18/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
Joint W/P Priv.
05936
09/18/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
Joint W/P Priv.
05938
09/18/2009
Bradley Edwards
Adam Horowitz
RE:Epstein
Joint W/P Priv.
05940-05941 09/18/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
Joint W/P Priv.
05951
05/29/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
Joint W/P Priv.
05957-05960 09/09/2009
Bradley Edwards
Kikka Claudio
RE:Epstein
Joint W/P Priv.
05970-05971 10/21/2009
Jacquie Johnson
Margaret Berk
RE:Epstein
Joint W/P Priv.
05982-05983 10/28/2009
Bradley Edwards
Spencer Kuvin
RE:Epstein
Joint W/P Priv.
05993.05994 09/09/2009
Bradley Edwards
Adam Horowitz
RE:Epstein
Joint W/P Priv.
05997
08/06/2009
Bradley Edwards
Kikka Claudio
RE:Epstein
Joint W/P Priv.
10
EFTA00310057
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01029
10/08/2009
Bradley Edwards
Carolyn Edwards
Brian Ryalls
Joint W/P Priv.
07707
09/03/2009
BradleyEdwards
Kikka Claudio
RE:Regarding:C.M.A. vs. Epstein.
Et al.(File# 281849)
Joint W/P Priv.
07708-07709 06/22/2009
Bradley Edwards
Amy Ederi
RE:Regular Monthly Cong. Call
Joint W/P Priv.
07734
07/24/2009
Bradley Edwards
RE:Release
Joint W/P Priv.
07218-07219 10/02/2009
Bradley Edwards
Katherine Ezell
RE:Meeting w/Stanley Arkin
Joint W/P Priv.
06861-06863 05/12/2009
Bradley Edwards
Katherine Ezell
RE:Jane Doe II v. Epstein
Joint W/P Priv.
06876-06879 05/12/2009
Bradley Edwards
Stuart Mermelstein
RE:Jane Doe II v. Epstein
Joint W/P Priv.
06891-06897 05/12/2009
Bradley Edwards
Katherine Ezell
RE:Jane Doe II v. Epstein
Joint W/P Priv.
06901
09/11/2009
Bradley Edwards
Mercedes Estrada
Re:lane Doe No. 101 & Jane Doe
No. 102 vs. Epstein-Cross Notice
Of Depos
Joint W/P Priv.
06902
09/15/2009
Bradley Edwards
Mercedes Estrada
RE: Jane Doe No.101 & Jane Doe
NO.102 vs. Epstein
Joint W/P Priv.
06903
09/04/2009
Bradley Edwards
Mercedes Estrada
RE: Jane Doe No.101 & Jane Doe
NO.102 vs. Epstein-Cross-Notice
of Taking Video Deposition
Joint W/P Priv.
06806-06807 09/09/2009
Bradley Edwards
Adam Horowitz
RE:Epstein
Joint W/P Priv.
06712
10/19/2009
Bradley Edwards
Kikka Claudio
RE: Igor Zinoview depo
Joint W/P Priv.
06713.06714 09/15/2009
Bradley Edwards
Robert Josefberg
RE:Epstein
Joint W/P Priv.
11
EFTA00310058
Privilege Log— Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
06720-06727 10/14/2009
Bradley Edwards
Jack Hill
RE: Igor Zinoview depo
Joint W/P Priv.
06728
09/09/2009
Bradley Edwards
Kikka Claudio
RE:Epstein
Joint W/P Priv.
06711
09/09/2009
Kikka Claudio
Bradley Edwards
RE:Epstein
Joint W/P Priv.
06472
05/08/2009
Spencer Kuvin
Bradley Edwards
RE:FYI Epstein Depo
Joint W/P Priv.
06460-06464 05/08/2009
Bradley Edwards
Spencer Kuvin
RE:FYI Epstein Depo
Joint W/P Priv.
06455-06459 05/08/2009
Spencer Kuvin
Bradley Edwards
RE:FYI Epstein Depo
Joint W/P Priv.
06448.06452 05/08/2009
Spencer Kuvin
Bradley Edwards
RE:FYI Epstein Depo
Joint W/P Priv.
06420-06427 05/08/2009
Spencer Kuvin
Bradley Edwards
RE:FYI Epstein Depo
Joint W/P Priv.
06416-06419 05/08/2009
Spencer Kuvin
Bradley Edwards
RE:FYI Epstein Depo
Joint W/P Priv.
05925.05926 07/28/2009
Katherine Ezell
Bradley Edwards
FW:Epstein
Joint W/P Priv.
05883-05584 07/24/2009
Katherine Ezell
Bradley Edwards
RE:Epstein
Joint W/P Priv.
05022-05025 09/10/2010
Adam Horowitz
Jacquie Johnson
RE:Epstein-Notice of Production
from Non Parties
Joint W/P Priv.
04724-04725 05/27/2009
Bradley Edwards
Katherine Ezell
RE:Epstein Cases-depostions in
federal cases
Joint W/P Priv.
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
06990-07002 06/11/2009
Brad Edwards
Katherine W. Ezell
June
10th
hearing-WPB-
Confidential
Joint-privilege
07003-07006 06/26/2009
Amy Ederi
Brad Edwards
June
25th
hearing-WPB- Joint-privilege
12
EFTA00310059
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Confidential
07030
09/22/2009
Bradley
J.
Edwards
Spencer Kuvin
v. Epstein — defendant, Joint-privilege
Jeffrey Epstein's response to
plantiff
07090.07091 9/29/2009
Bradley
J.
Edwards
Katherine W. Ezell
Leslie Wexner
Joint-privilege
07092
10/29/2009
Stuart
Mermelstein
Bradley J. Edwards
Leslie Wexner
Joint-privilege
07093
09/17/2009
Bradley
J.
Edwards
Katherine W. Ezell
Leslie Wexner
Joint-privilege
01484
05/21/2009
Robert
C.
Josef sberg
Bradley J. Edwards
Epstein
Joint-privilege
01503
08/24/2009
Spencer Kuvin
Bradley J. Edwards
Epstein
Joint-privilege
01517
09/18/2009
Adam Horowitz;
Spencer Kuvin
Bradley J. Edwards
Epstein
Joint-privilege
01514
08/26/2009
Spencer Kuvin
Bradley J. Edwards
Epstein
Joint-privilege
01515
08/27/2009
Spencer Kuvin
Bradley J. Edwards
Epstein
Joint-privilege
01477
07/21/2009
Adam Horowitz;
Stuart
Mermelstein
Bradley J. Edwards
Epstein
Joint-privilege
01489
08/03/2009
Adam Horowitz
Bradley J. Edwards
Epstein
Joint-privilege
07110-07112 09/25/2009
Bradley
J.
Edwards
Spencer Kuvin
v EPSTEIN hearing 9/22/09
07113-07114 09/25/2009
Spencer Kuvin
Bradley J. Edwards
EPSTEIN hearing 9/22/09
Joint-privilege
07115-07116 09/25/2009
Bradley
J.
Edwards
Spencer Kuvin
EPSTEIN hearing 9/22/09
Joint-privilege
07145-07146 09/22/2009
Adam Horowitz
BradleyJ. Edwards
Mark Epstein
Joint-privilege
07211.07213 10/01/2009
Bradley
J.
Edwards
Spencer Kuvin
Meeting with Stanley Arkin
Joint-privilege
07210
10/06/2009
Stuart
Mermelstein;
Robert
c.
Josefsberg;
Katherine W. Ezell
Meeting with Leslie Wexner
Joint-privilege
13
EFTA00310060
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Bradley
J.
Edwards
07214-07215 10/01/2009
Robert
C.
Josefsberg
Katherine W. Ezell
Meeting with Stanley Arkin
Joint-privilege
07216-07217
10/02/2009
Bradley
J.
Edwards
Katherine W. Ezell
Meeting with Stanley Arkin
Joint-privilege
07220-07223 10/01/2009
Spencer Kuvin
Bradley J. Edwards
Meeting with Stanley Arkin
Joint-privilege
07224-07225 10/02/2009
Katherine
W.
Ezell
Bradley J. Edwards
Meeting with Stanley Arkin
Joint-privilege
07226-07227 10/01/2009
Robert
C.
Josefsberg
Spencer Kuvin
Meeting with Stanley Arkin
Joint-privilege
07228.07229 10/01/2009
Bradley
J.
Edwards
Robert
C.
Josefsberg
Meeting with Stanley Arkin
Joint-privilege
07280-07283 08/06/2009
Adam Horowitz
Bradley J. Edwards
Motion for protective order
Joint-privilege
07633-07634 08/06/2009
Bradley
J.
Edwards
Kikka M. Claudio
Proposal Request
Joint-privilege
07710-07733 06/23/2009
Katherine
W.
Ezell
Bradley J. Edwards
Regularly Monthly Cong. Call
Joint-privilege
07740-07746 09/18/2009
Bradley
J.
Edwards
Adam Horowitz
Report this as a parole violation
Joint-privilege
07748-07757 09/18/2009
Adam Horowitz
Bradley J. Edwards
Report this as a parole violation
Joint-privilege
07913-07915 08/27/2009
Bradley
J.
Edwards
Spencer Kuvin
Joint-privilege
07917.07918 08/27/2009
Spencer Kuvin
Jacquie Johnson
Joint-privilege
07965-07966 08/12/2009
Katherine
W.
Ezell
Bradley J. Edwards
Subpoena
directed
to
the
investigators
Joint-privilege
07977-07978 10/09/2009
Bradley
J.
Edwards
Spencer Kuvin
Subpoena Info
Joint-privilege
01716
09/15/2009
Adam Horowitz
Elizabeth Villar
Epstein: Forensics/Investigations
INVOICE
Joint-privilege
01768
07/13/2009
Richard Willits
Bradley J. Edwards
Epstein Investigator
Joint-privilege
01771-01772 08/06/2009
Adam Horowitz
Bradley J. Edwards
Epstein Investigator
Joint-privilege
01931
08/11/2009
Bradley
J.
Lisa Rivera
Alfredo Rodriguez
Joint-privilege
14
EFTA00310061
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Edwards
01998.01999 09/21/2009
Adam Horowitz
Margaret Berk
Correct
Number
—
Epstein
Deposition
Joint-privilege
02021
05/14/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Doe v. Epstein
Joint-privilege
02044
09/04/2009
Katherine
W.
Ezell
Bradley J. Edwards
Doe v. Epstein —
Joint-privilege
e er r m Bob Critton
02048
09/04/2009
Robert
C.
Josefsberg
Bradley J. Edwards
Doe v. Epstein —
Joint-privilege
Letter from Bob Critton
02054
05/12/2009
Spencer Kuvin
Bradley J. Edwards
Emailing
Epstein
deposition
revised
Joint-privilege
02062
10/05/2009
Bradley
J.
Edwards
Amy Ederi
Epstein — Confirming AT&T Dial
in
Tel. Conf.
for
Monday,
10/5/09 at 4:00 p.m.
Joint-privilege
02087
09/17/2009
Spencer Kuvin
Bradley J. Edwards
Epstein- Hearing
Joint-privilege
02140
08/04/2009
Spencer Kuvin
Bradley J. Edwards
Epstein Depo — New York
Joint-privilege
02147-02149 09/21/2009
Bradley
J.
Edwards
Amy Ederi
Epstein Depo
Joint-privilege
02174
07/20/2009
Adam Horowitz
Bradley J. Edwards
Epstein Matter — Cross Notice of
Alfredo Rodriguez Deposition
Joint-privilege
02209-02210 07/01/2009
Bert Patton
William J. Berger
Epstein v. State of Florida —
Emergency petition for Writ of
Certiorari; Emergency motion to
review denial of stay
Joint-privilege
02215-02217 07/24/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein
Joint-privilege
02290
09/18/2009
Bradley
J.
Edwards
Spencer Kuvin
Epstein
Joint-privilege
02355-02356 06/10/2009
Mercedes
C.
Estrada
Susan K. Stirling
Hearing
taken on 06/10/09
onmotion to unseal before Judge
Colbath
Joint-privilege
02362-02363 06/09/2009
Spencer Kuvin
Katherine W. Ezell
Hearing to Un-seal
Joint-privilege
02374.02375 09/15/2009
Jack Hill
Bradley J. Edwards
Igor Zinoview depo
Joint-privilege
15
EFTA00310062
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissint Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
02420-02421 05/08/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Jane Doe II v. Epstein
Joint-privilege
02435
09/15/2009
Bradley
J.
Edwards
Lisa Rivera
Jane Does v. Epstein
Joint-privilege
02438
09/18/2009
Bradley
J.
Edwards
Adam Horowitz
Jeffrey Epstein DUI W35755
Joint-privilege
02462
09/22/09
Spencer Kuvin
Bradley J. Edwards III
v. Epstein — Defendant,
Jeffrey Epstein"s Response to
Plantiff
Motion
for
Protective Order
Joint-privilege
02476-02477 09/25/2009
Spencer Kuvin
Bradley J. Edwards
LM v EPSTEIN hearing
Joint-privilege
02516
10/06/2009
Bradley
1.
Edwards
Katherine W. Ezell
Meeting with Leslie Wexner
Joint-privilege
02554.02559 08/03/2009
Adam Horowitz
Bradley J. Edwards
NEW
ASSIGNMENT
—
NEW
ALBANY — RUSH? — Fwd: Federal
Subpoena
Joint-privilege
02584
08/11/2009
Bradley
J.
Edwards
Kikka M. Claudio
Out of state subpoenas
Joint-privilege
02618
08/04/2009
Bradley
J.
Edwards
Kikka M. Claudio
Proposal Request
Joint-privilege
02627.02628 09/18/2009
Bradley
J.
Edwards
Adam Horowitz
Report this as a parole violation
Joint-privilege
02672-02673 10/09/2009
Spencer Kuvin
Bradley J. Edwards
Subpoena Info
Joint-privilege
02727
08/03/2009
Spencer Kuvin
Bradley J. Edwards
Transcript of Alfredo Rodriguez
deposition
Joint-privilege
02896
06/08/2009
Bradley
J.
Edwards
Spencer Kuvin
Hearing to Un-seal
Joint-privilege
03009-03010 08/07/2009
Adam Horowitz
Jacquie Johnson
Motion to stay
Joint-privilege
03028.03029 09/21/2009
Bradley
J.
Edwards
Adam Horowitz
Mark Epstein
Joint-privilege
03038
10/06/2009
Bradley
J.
Edwards
Stuart Mermelstein
Meeting with Leslie Wexner
Joint-privilege
03131.03132 08/06/2009
Adam Horowitz
Bradley J. Edwards
Epsteins assets
Joint-privilege
16
EFTA00310063
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
03243.03244 09/09/2009
Bradley
J.
Edwards
Adam Horowitz
EPSTEIN
Joint-privilege
03397-03400 09/29/2009
Adam Horowitz
Bradley J. Edwards
Activity in case 9:08-cv-80119-
Doe v. Epstein Response in
Opposition to Motion
Joint-privilege
03407-03414 09/29/2009
Bradley
J.
Edwards
Adam Horowitz
Activity in case 9:08-cv-80119-
woe v. Epstein Response in
Opposition to Motion
Joint-privilege
03451.03452 05/14/2009
Bradley
J.
Edwards
Spencer Kuvin
Activity in Case 9:08-cv-80893-
KAM Doe v. Epstein Order on
Motion to Stay
Joint-privilege
03477-03479 05/15/2009
Bradley
J.
Edwards
Spencer Kuvin
Activity in Case 9:08-cv-80893-
KAM Doe v. Epstein Order to
Motion to Stay
Joint-privilege
03619-03627 09/15/2009
Bradley
J.
Edwards
Spencer Kuvin
v. Epstein/EW v. Epstein
Joint-privilege
03631.03633 09/15/2009
Jacquie Johnson
William J. Berger
v. Epstein/EW v. Epstein
Joint-privilege
03646-03656 10/19/2009
Bradley
J.
Edwards
Katherine W. Ezell
Bill Riley's Subpoena & Depo
Notice
Joint-privilege
03677-03687 07/08/2009
Bradley
J.
Edwards
Adam Horowitz
Can
you
send
me
those
addresses?
Joint-privilege
03719-03736 09/04/2009
Bradley
J.
Edwards
Spencer Kuvin
CMA — depo notices attached.
Joint-privilege
03840-03847 08/02/2009
Stuart
Mermelstein
Bradley J. Edwards
Continuing Deposition of Alfredo
Rodriguez
Joint-privilege
03938-03939 09/29/2011
Katherine
W.
Ezell
Bradley J. Edwards
Deposition of Bill Riley
Joint-privilege
03943-03945 09/18/2009
Adam Horowitz
Jacquie Johnson
Deposition of Jean Luc Bruhnel
Joint-privilege
02911-02912 09/15/2009
Bradley
J.
Edwards
Jack P. Hill
Igor Zinoview depo
Joint-privilege
02939
07/14/2009
Bradley
J.
Edwards
Adam Horowitz
Jane Does 2-7 v. Epstein
Joint-privilege
02977
10/16/2009
Katherine
W. Bradley J. Edwards
Leslie Wexner
Joint-privilege
17
EFTA00310064
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Ezell
02978
10/29/2009
Bradley
J.
Edwards
Stuart Mermelstein
Leslie Wexner
Joint-privilege
02994
06/10/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Preservation of evidence
Joint-privilege
07060
10/16/2009
Sid Garcia
Bradley J. Edwards
L.M. v. Epstein
Joint-privilege
06202
07/13/2009
Richard Willits
Bradley J. Edwards
Scheduling various depositions
regarding Epstein
Joint-privilege
06409-06415 04/15/2009
Bradley
J.
Edwards
Katherine W. Ezell
FYI
Joint-privilege
06428-06447 05/06/2009
Spencer Kuvin
Bradley J. Edwards
FYI
Joint-privilege
06453.06454 04/15/2009
Spencer Kuvin
Bradley J. Edwards
FYI
Joint-privilege
06465-06471 04/15/2009
Katherine
W.
Ezell
Bradley J. Edwards
FYI
Joint-privilege
06476-06490 05/08/2009
Bradley
J.
Edwards
Spencer Kuvin
FYI
Joint-privilege
06630-06632 09/09/2009
Spencer Kuvin
Bradley J. Edwards
Hearing to Un-seal
Joint-privilege
06636.06639 09/09/2009
Bradley
J.
Edwards
Robert
C.
Josefsberg
Hearing to Un-seal
Joint-privilege
06702-06705 09/16/2009
Bradley
J.
Edwards
Kikka M. Claudio
Igor Zinoview & Tommy Matola
depos
Joint-privilege
06706-06708 10/14/2009
Bradley
J.
Edwards
Kikka M. Claudio
Igor Zinoview depo
Joint-privilege
06715-06719 10/09/2009
Jack P. Hill
Bradley J. Edwards
Igor Zinoview depo
Joint-privilege
06729-06735 10/13/2009
Bradley
J.
Edwards
Jack P. Hill
Igor Zinoview depo
Joint-privilege
06763
08/19/2009
Bradley
J.
Edwards
Stuart Mermelstein IME's
Joint-privilege
06764.06766 09/10/2009
Bradley
J.
Edwards
Stuart Mermelstein
IME's
Joint-privilege
06770-06781 09/10/2009
Stuart
Mermelstein
Bradley J. Edwards
IME's
Joint-privilege
06811-06812 08/20/2009
Katherine
W. Bradley J. Edwards
Is Mark Epstein JE's brother?
Joint-privilege
18
EFTA00310065
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Ezell
06817-06819 09/23/2009
Adam Horowitz
Bradley J. Edwards
Is your client being deposed
tomorrow?
Joint-privilege
06820-06822 07/02/2009
Bradley
J.
Edwards
Margaret Berk
Jane Doe 2 (Brinson) v. Epstein
Joint-privilege
06841.06860 05/12/2009
Bradley
J.
Edwards
Spencer Kuvin
Jane Doe II v. Epstein
Joint-privilege
06864.06875 05/12/2009
Spencer Kuvin
Bradley J. Edwards
Jane Doe II v. Epstein
Joint-privilege
06880-06890 05/12/2009
Bradley
J.
Edwards
Katherine W. Ezell
Jane Doe II v. Epstein
Joint-privilege
06898.06900 05/12/2009
Bradley
J.
Edwards
Stuart Mermelstein
Jane Doe II v. Epstein
Joint-privilege
06933-06934 07/14/2009
Adam Horowitz
Bradley J. Edwards
Jane Does 2.7 v. Epstein
Joint-privilege
06937-06938 10/05/2009
Spencer Kuvin
Jacquie Johnson
Jane Does 2-8 v. Epstein — Cross
NOD's of Oct. 6-8 depos
Joint-privilege
06944-06952 09/22/2009
Bradley
J.
Edwards
Adam Horowitz
Jeffrey Epstein DCI4 W35755
Joint-privilege
16107
08/11/2009
Adam Horowitz
Jacquie Johnson
Maxwells deposition
Joint-privilege
16123-16124 08/11/2009
Kikka M. Claudio
Jacquie Johnson
Maxwells deposition
Joint-privilege
16799.16801 10/02/2009
Robert
C.
Josefbergs
Jacquie Johnson
Meeting with Stanley Arkin
Joint-privilege
02947-02948 08/03/2009
Spencer Kuvin
Jacquie Johnson
Epstein Depo — New York
Joint-privilege
02891.20906 10/01/2009
Bradley
J.
Edwards
Katherine W. Ezell
Meeting with Stanley Arkin
Joint-privilege
20880.20882 10/02/2009
Bradley
J.
Edwards
Katherine W. Ezell
Meeting with Stanley Arkin
Joint-privilege
06042-06090 07/02/2009
William J. Berger
Spencer Kuvin
Ew 09-22784 cert.4th dca
Joint-privilege
06402-06403 06/10/2009
Bradley
J.
Edwards
Katherine W. Ezell
Hearing to Un-seal
Joint-privilege
01365-01366 09/15/2009
Adam Horowitz
Jacquie Johnson
Epstein Hearing
Joint-privilege
01340-01341 07/30/2009
Adam Horowitz
Jacquie Johnson
Epstein Depositions
Joint-privilege
01331
06/30/2009
Stuart
BradleyJ. Edwards
Epstein depositions
Joint-privilege
19
EFTA00310066
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Mermelstein
01319
08/11/2009
Adam Horowitz
Jacquie Johnson
Epstein Depo
Joint-privilege
01316
08/27/2009
Spencer Kuvin
Bradley J. Edwards
Epstein Depo
Joint-privilege
01314
10/30/2009
Stuart
Mermelstein
Jacquie Johnson
Epstein Depo of Wexner
Joint-privilege
01298
05/26/2009
Bradley
J.
Edwards
Adam Horowitz
Epstein cases — depositions in
federal cases
Joint-privilege
01294
08/10/2009
Jack P. Hill
Bradley J. Edwards
Epstein Assets
Joint-privilege
01273
07/13/2009
Katherine
W.
Ezell
Bradley J. Edwards
Epstein 2255 claims
Joint-privilege
01250
05/13/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein
Joint-privilege
01246
04/08/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Telephone Conference
Joint-privilege
01233-01234 07/31/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Monday, 8/3/09 —
Monthly
call
in
telephone
conference — AT&T Call in No:
(877) 468-2136
— participant
code: 775593. Kathy is the host.
Joint-privilege
01224
06/16/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Monday, 8/3/09 —
Monthly
call
in
telephone
conference — AT&T Call in No:
(877) 468-2136
— participant
code: 775593. Kathy is the host.
Joint-privilege
01185
10/30/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Confirming AT&T dial
in tel. conf. for Monday, 11/2/09
at 4:00 p.m.
Joint-privilege
01186
10/02/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Confirming AT&T Dial
in
Tel.
Conf.
for
Monday,
10/5/09 at 4:00 p.m.
Joint-privilege
01187
05/19/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Confirming AT&T Dial
in Telephone Conference for
Monday, 6/8/09 at 2:00 p.m.
Joint-privilege
20
EFTA00310067
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01188
05/12/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein — Confirming AT&T Dial
in Telephone Conference for
Tomorrow 5/13/09
Joint-privilege
01189
09/08/2009
Bradley
J.
Edwards
Iliana Yarzabal
Epstein — Confirming AT&T Dial
in Telephone Conference for
Wednesday, 9/9/09 at 3:00
Joint-privilege
01095-01096 04/15/2009
Spencer Kuvin
Bradley J. Edwards
Deposition of Epstein was set for
tomorrow
Joint-privilege
01045
07/23/2009
Bradley
J.
Edwards
Richard Willits
CMA vs. Epstein
Joint-privilege
01649
07/08/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein
Joint-privilege
01641
06/11/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein
Joint-privilege
01639
05/29/2009
Bradley
J.
Edwards
Mercedes
C.
Estrada
Epstein
Joint-privilege
01619
10/28/2009
Bradley
J.
Edwards
Spencer Kuvin
Epstein
Joint-privilege
01660
07/22/2009
Bradley
J.
Edwards
Adam Horowitz
Epstein
Joint-privilege
01666
04/20/2009
Spencer Kuvin
Bradley J. Edwards
Epstein
Joint-privilege
01671
07/23/2009
Katherine
W.
Ezell
Bradley J. Edwards
Epstein
Joint-privilege
01680
08/24/2009
Jack P. Hill
Bradley J. Edwards
Epstein
Joint-privilege
04355.04358 09/04/2009
Jack Scarola
Bradley J. Edwards
Epstein — Depos of
Joint-privilege
and
04446
09/03/2009
Bradley
J. 'liana Yarzabal
Epstein
— Monday 8/3/09 —
Monthly
Call
in
Telephone
Conference
Joint-privilege
Edwards
04200-04201 09/04/2009
Bradley Edwards
Katherine W. Ezell
Letter from Bob Critton
Joint W/P Privilege
04220—
04221
09/04/2009
Bradley Edwards
Spencer Kuvin
Letter from Bob Critton
Joint W/P Privilege
04222.04223 09/04/2009
Bradley Edwards
Barry Stone
Letter from Bob Critton
Joint W/P Privilege
21
EFTA00310068
Privilege Log — Dated 2-2 3-201 1
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
04264
05/12/2009
Bradley Edwards
Spencer Kuvin
Epstein Depo
Joint W/P Privilege
04298-04299 09/16/2009
Jacquie Johnson
Adam Horowitz
Depo of Epstein
Joint W/P Privilege
04304
09/08/2009
Jacquie Johnson
Adam Horowitz
Epstein
Joint W/P Priv.
04335
10/30/2009
Bradley Edwards
Robert Josefsberg
Epstein- Confirming AT&T Tel.
Joint W/P Priv.
Conf.
04359-04360 09/04/2009
Jacquie Johnson
Katherine Ezell
Depos of
&
Joint W/P Priv.
04365
09/15/2009
Jacquie Johnson
Adam Horowitz
Epstein- Depo in New York
Joint W/P Priv.
04417
09/17/2009
Bradley Edwards
Spencer Kuvin
Epstein- Hearing
Joint W/P Priv.
04423.04424 09/09/2009
Jacquie Johnson
Adam Horowitz
letter regarding Leslie Wexner
Joint W/P Priv.
04433-04436 06/16/2009
Spencer Kuvin
Bradley Edwards
Monthly Call in Tele. Conf.
Joint W/P Priv.
04447.04450 07/31/2009
Jacquie Johnson
Mercedes Estrada
Monthly Call in Tel. Conf.
Joint W/P Priv.
04491.04518 04/08/2009
Bradley Edwards
Jack Scarola
Epstein- Tel. Conf.
Joint W/P Priv.
04518
04/08/2009
Bradley Edwards
Robert Josefsberg
Epstein- Tel Conf.
Joint W/P Priv.
04524-04525 05/13/2009
Katherine Ezell
Bradley Edwards
Epstein Depo
Joint W/P Priv.
04580
10/14/2009
Jacquie Johnson
Adam Horowitz
Depo of Larry Visoski
Joint W/P Priv.
04640-04641 10/14/2009
Bradley Edwards
Adam Horowitz
Depo of Larry Visoski
Joint W/P Priv.
04723
05/26/2009
Bradley Edwards
Katherine Ezell
Epstein cases- Depos
Joint w/P Priv.
04726-04729 05/26/2009
Adam Horowitz
Bradley Edwards
Epstein cases- Witness depos
Joint W/P Priv.
04750-04754 08/04/2009
Spencer Kuvin
Bradley Edwards
Epstein depo- New York
Joint W/P Priv.
04763-04785 08/27/2009
Spencer Kuvin
Bradley Edwards
Epstein Depo Notice
Joint W/P Priv.
04797-04799 09/18/2009
Jacquie Johnson
Adam Horowitz
Epstein Depo
Joint W/P Priv.
04806-04813 07/28/2009
Jacquie Johnson
Adam Horowitz
Epstein Depos in New York
Joint W/P Priv.
04819
07/30/2009
Jack Scarola
Jacquie Johnson
Epstein Depos
Joint W/P Priv.
04831.04832 07/30/2009
Spencer Kuvin
Jacquine Johnson
Epstein Depos
Joint W/P Priv.
04835-04836 07/25/2009
Katherine Ezell
Bradley Edwards
Epstein Depos
Joint W/P Priv.
22
EFTA00310069
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
04711
08/10/2009
Bradley Edwards
Jack Hill
Epstein assests
Joint W/P Priv.
04855-04858 08/18/2009
Bradley Edwards
Kikka Claudio
Epstein Depos
Joint W/P Priv.
04861
07/24/2009
Lisa Rivera
Jacquie Johnson
Epstein Depos
Joint W/P Priv.
04876.04877 07/27/2009
Bradley Edwards
Spencer Kuvin
Epstein Depos
Joint W/P Priv.
04922-04923 09/16/2009
Adam Horowitz
Jacquie Johnson
Epstein Hearing
Joint W/P Priv.
04925-04926 09/15/2009
Adam Horowitz
Jacquie Johnson
Epstein Hearing
Joint W/P Priv.
04929-04934 09/25/2009
Bradley Edwards
Adam Horowitz
Epstein Hearing
Joint W/P Priv.
04937-04938 09/15/2009
Adam Horowitz
Jacquie Johnson
Epstein Hearing
Joint W/P Priv.
04969-04972 07/20/2009
Adam Horowitz
Bradley Edwards
Alfredo Rodriguez Depo
Joint W/P Priv.
05026-05027 09/10/2009
Adam Horowitz
Jacquie Johnson
Notice of Production from Non-
Parties
Joint W/P Priv.
05031
09/25/2009
Bradley Edwards
Spencer Kuvin
Epstein Order
Joint W/P Priv.
05037-05038 09/25/2009
Bradley Edwards
Spencer Kuvin
Epstein Order
Joint W/P Priv.
05042-05043 09/25/2009
Spencer Kuvin
Bradley Edwards
Epstein Order
Joint w/P Priv.
05046
09/25/2009
Bradley Edwards
Spener Kuvin
Epstein Order
Joint W/P Priv.
05074.05076 08/18/2009
Stuart
Mermelstein
Jacquie Johnson
Epstein Sub. To Bears Stern
Joint W/P Priv.
23
EFTA00310070
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05100-05102 08/05/2009
Mercedes
Estrada
Bradley Edwards
Improper Serving of Maxwell
Joint W/P Priv.
05105-05107 04/20/2009
Bradley Edwards
Spencer Kuvin
Hearing on Yellow Cab Objection
Joint W/P Priv.
05110
08/06/2009
Adam Horowitz
Kikka Claudio
Address for
Joint W/P Priv.
05118-05119 09/09/2009
Adam Horowitz
Bradley Edwards
Motion for Protective Order
Joint W/P Priv.
05157-05158 09/10/2009
Adam Horowitz
Bradley Edwards
Motion for Protective Order
Joint W/P Priv.
05167-05168 05/29/2009
Bradley Edwards
Margaret Berk
Spencer Cross-Examination
Joint W/P Priv.
05171-05172 05/29/2009
Bradley Edwards
Mercedes Estrada
Transcripts
Joint W/P Priv.
05201-05202 09/10/2009
Adam Horowitz
Bradley Edwards
Rules on Doe no. 4
Joint W/P Priv.
05222-05223 07/10/2009
Bradley Edwards
Katherine Ezell
File case
Joint W/P Priv.
05226
07/10/2009
Bradley Edwards
Spencer Kuvin
Epstein 5th Amendment rights
Joint W/P Priv.
05229
07/10/2009
Bradley Edwards
Adam Horowitz
Motions to Compel
Joint W/P Priv.
05232-05233 07/10/2009
Bradley Edwards
Adam Horowitz
Motions fully briefed
Joint W/P Priv.
05247
07/23/2009
Katherine Ezell
Bradley Edwards
Answers to the 1" set of ROGS
Joint W/P Priv.
05251-05252 07/24/2009
Katherine Ezell
Bradley Edwards
Depo dates
Joint W/P Priv.
05258
07/25/2009
Katherine Ezell
Bradley Edwards
Switzerland Witness regarding
Joint W/P Priv.
Epstein Egg Shaped 2 inch PENIS(
05265-05266 07/22/2009
Adam Horowitz
Spencer Kuvin
Alfredo Rodriguez depo
Joint W/P Priv.
24
EFTA00310071
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05286.05287 07/28/2009
Katherine Ezell
Bradley Edwards
Switzerland Witness regarding
training of little girls as sex traps
Joint W/P Priv.
05293-05294 07/28/2009
Katherine Ezell
Bradley Edwards
Calling Switzerland witness
Joint W/P Priv.
05326-05327 08/24/2009
Bradley Edwards
Spencer Kuvin
Emails searchable
Joint W/P Priv.
05331
08/06/2009
Kikka Claudio
Bradley Edwards
Epstein address
Joint W/P Priv.
05334-05335 05/29/2009
Bradley Edwards
Mercedes Estrada
TV Interview that is too explicit
Joint W/P Priv.
05347
08/24/2009
Bradley Edwards
Spencer Kuvin
Seeking Computers
Joint W/P Priv.
05350
08/10/2009
Kikka Claudio
Bradley Edwards
Current address for
Joint W/P Priv.
05353-05354 09/09/2009
Katherine Ezell
Bradley Edwards
Distribution of Costs
Joint W/P Priv.
05367
09/10/2009
Jacquie Johnson
Bradley Edwards
Voicemail
Joint W/P Priv.
05373-05374 08/10/2009
Kikka Claudia
Bradley Edwards
Supoenas for depos
Joint W/P Priv.
05391-05393 04/20/2009
Spencer Kuvin
Bradley Edwards
Yellow Cab stuff
Joint W/P Priv.
05400-05401 10/19/2009
Adam Horowitz
Bradley Edwards
Religious Dildo Washer
Joint W/P Priv.
05414-05415 08/10/2009
Kikka Claudio
Bradley Edwards
Sjoberg's current address
Joint W/P Priv.
05437-05439 04/20/2009
Bradley Edwards
Spencer Kuvin
Yellow Cab stuff
Joint W/P Priv.
05444-05445 08/10/2009
Bradley Edwards
Kikka Claudio
Setting Depos
Joint W/P Priv.
05451
05/29/2009
Mercedes
Estrada
Bradley Edwards
Motion for Status Conf.
Joint W/P Priv.
25
EFTA00310072
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05469
07/08/2009
Mercedes
Estrada
Bradley Edwards
Judge Marra's July 61" Order
Joint W/P Priv.
05476-05494 07/08/2009
Spencer Kuvin
Bradley Edwards
NPA from Marie Villafana
Joint W/P Priv.
05546
08/03/2009
Adam Horowitz
Bradley Edwards
Haley's affidavit
Joint W/P Priv.
05579.05581 08/24/2009
Spencer Kuvin
Bradley Edwards
Seeking all of Plaintiff's
Joint W/P Priv.
computer
05613-05618 09/18/2009
Spencer Kuvin
Bradley Edwards
Non-Pros Agreement
Joint W/P Priv.
05633
10/16/2009
Adam Horowitz
Bradley Edwards
Motion to freeze assets
Joint W/P Priv.
05638-05639 10/28/2009
Spencer Kuvin
Bradley Edwards
Daliah Weiss
Joint W/P Priv.
05647
07/09/2009
Adam Horowitz
Katherine Ezell
NPA under seal for in camera
review
Joint W/P Priv.
05656
08/10/2009
Bradley Edwards
Kikka Claudio
Supoenas for depo
Joint W/P Priv.
05659
08/27/2009
Bradley Edwards
Spencer Kuvin
Order
Joint W/P Priv.
05668
10/16/2009
Bradley Edwards
Adam Horowitz
Florida Science Foundation
Joint W/P Priv.
05705
09/09/2009
Mercedes
Estrada
Kikka Claudio
Video tape of Epstein
Joint W/P Priv.
05724
05/29/2009
Bradley Edwards
Jack Scarola
Motion for Status Conf.
Joint W/P Priv.
05727
05/29/2009
Bradley Edwards
Sid Garcia
Motion for Status Conf.
Joint W/P Priv.
05730-05731 08/14/2009
Adam Horowitz
Jacquie Johnson
Motion for Status Conf.
Joint W/P Priv.
05734
05/29/2009
Adam Horowitz
Jacquie Johnson
Motion for status conf.
Joint W/P Priv.
26
EFTA00310073
Privilege Log — Dated 2-23-2011
Farmer. Jaffe, Weissing. Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05737
08/12/2009
Adam Horowitz
Jacquie Johnson
NPNP and sub to Palm Beach
Natl Bank
Joint W/P Priv.
05750
05/29/2009
Mercedes
Estrada
Spencer Kuvin
Motion for status conf.
Joint W/P Priv.
05770
07/08/2009
Bradley Edwards
Spencer Kuvin
NPA in camera review
Joint W/P Priv.
05774-05776 09/04/2009
Katherine Ezell
Jacquie Johnson
being rescheduled
Joint W/P Priv.
05782.05783 07/09/2009
Bradley Edwards
Spencer Kuvin
Motion to appoint commissioner
Joint W/P Priv.
05788-05790 07/09/2009
Bradley Edwards
Spencer Kuvin
Notice and serve everyone
Joint W/P Priv.
05802
09/04/2009
Adam Horowitz
Jacquie Johnson
Bill being split up evenly
Joint W/P Priv.
05806
09/04/2009
Jacquie Johnson
Spencer Kuvin
Bill will be split evenly for each
case
Joint W/P Priv.
05812
09/04/2009
Adam Horowitz
Jacquie Johnson
Bill will be split evenly
Joint W/P Priv.
05814
08/03/2009
Bradley Edwards
Adam Horowitz
Haley's affidavit
Joint W/P Priv.
05818-05819 09/09/2009
Bradley Edwards
Robert Josefsberg
CMA Order
Joint W/P Priv.
01781
05/01/2009
Bradley Edwards
William Berger
Epstein Depo
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
07619
07/13/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
27
EFTA00310074
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
03181
09/14/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
03181
09/14/2009
William Berger
Paul Cassell
Litigation Strategy
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
03182-03185 07/14/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
0318643188 05/01/2009
William Berger
Bradley Edwards
Epstein Depo
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
13860-13874 05/28/2009
Elizabeth Kim
Christinia Fitch
Litigation Strategy
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
14173
10/21/2009
Gary Farmer
Bradley Edwards
Stanely Arkin
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
13419
08/11/2009
Denis Kleinfeld
Bradley Edwards
Trump's Depo
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
03087
06/29/2010
Investigators
Bradley Edwards
Litigation Strategy
Work
Productattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
03088
04/11/2009
Epstein Litigation Russell Adler
Litigation Strategy
Work
Productattorney
client
28
EFTA00310075
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Team
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
03089-03099 05/03/2009
Attorneys
and
Staff
Russell Adler
RE: Setting Depos
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
13445-13453 08/19/2009
Denis Kleinfeld
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
12281.12291 07/30/2009
Carl Under
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
09337-09340 08/10/2009
Barry Stone
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
09350
10/21/2009
Barry Stone
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
09335
08/06/2009
Barry Stone
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
11983
08/06/2009
Carl Linder
Jacquie Johnson
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
11984-11988 08/06/2009
Carl Under
Bradley Edwards
Litigation Strategy .
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
29
EFTA00310076
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
11995
08/19/2009
Carl Linder
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
12012
10/21/20009
Carl Linder
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
11879
10/21/2009
Cara Holmes
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
11868
08/19/2009
Cara Holmes
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
10938
05/28/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
13592
10/21/2009
Denis Kleinfeld
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
04421
05/21/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
25814
05/28/2009
William Berger
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
30
EFTA00310077
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
evidence;protected by privacy rights
25778-25782 07/30/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
25792-25797 05/28/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
25798
08/06/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
25799-25802 08/10/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
25773
10/21/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
25738
08/03/2009
William Berger
Beth Williamson
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence; protected by privacy rights
25739-25740 08/11/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
17940
07/30/2009
Jonathan
Birkman
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
31
EFTA00310078
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
17917-17927 08/03/2009
Jonathan
Birkman
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
17932-17934 05/28/2009
Jonathan
Birkman
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
17935
05/28/2009
Jonathan
Birkman
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
17936-17938 07/30/2009
Jonathan
Birkman
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00014
05/01/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00015
05/04/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00016
05/04/2009
Bradley Edwards
Paul Cassell
Litigation Stratgey
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00017
05/06/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00018
05/06/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
32
EFTA00310079
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00019-00021 05/07/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00022
06/23/3009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00023
07/13/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00024
07/13/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00025-00029 05/01/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00030
05/02/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00031
05/03/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00032
05/03/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
33
EFTA00310080
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00033-00034 05/03/3009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00035
05/05/2009
Bradley Edwards
Susan Sterling
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00036
05/06/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00037-00040 05/25/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00041
07/06/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00042
07/06/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
0043
05/05
/2009
Bradley Edwards
Susan Sterling
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00044
08/17/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
34
EFTA00310081
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
evidence;protected by privacy rights
00045
05/01/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00046
05/01/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00047-00049 05/01/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00050
05/05/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00051
05/05/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00052
05/05/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00053
05/05/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00054
05/05/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissibleevidence;protected by privacy rights
35
EFTA00310082
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
00055
04/29/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00056
05/05/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00057
05/05/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00058
05/05/2009
Bradley Edwards
Russell Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00059
05/05/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00060
05/05/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00061-0064
05/06/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00065
05/12/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00066
04/29/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
36
EFTA00310083
Privilege Loft— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00067
05/12/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00068
05/12/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00069-00070 05/13/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00071
05/13/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00072
05/15/2009
Bradley Edwards
Susan Sterling
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00073
05/15/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00074
05/18/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00075
05/18/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
37
EFTA00310084
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00076
05/18/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00077
04/04/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00078
05/18/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00079
05/19/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00080
05/19/2009
Bradley Edwards
Beth Williamson
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00081.00082 05/20/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00083-00085 05/21/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00086-00087 05/25/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
38
EFTA00310085
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
evidence;protected by privacy rights
00088
04/30/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00089
05/28/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00090
05/28/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00091
05/28/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence; protected by privacy rights
00092
05/28/2099
Bradley Edwards
Rob Buschell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00093
06/01/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00094-00095 06/23/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00096
07/06/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Prod uct;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
39
EFTA00310086
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
00097
07/06/2009
Bradley Edwards
Rob Buschel
litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00098-00100 07/07/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00101
07/09/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00102.00106 07/09/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00107
07/10/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00108
07/10/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00109
07/10/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence; protected by privacy rights
00110
07/10/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00111
07/11/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
40
EFTA00310087
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00112.00120 05/012009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00121
05/12/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00122
05/12/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00123
05/12/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00124-00125 05/12/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00126
05/22/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00127
05/26/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
41
EFTA00310088
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
00128.00131 5/26/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00132
5/21/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00133
06/23/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00134
06/03/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00135-00137 06/03/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00138-00140 06/08/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00141
06/12/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00142
06/13/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00143.00145 06/15/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
42
EFTA00310089
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00146
06/29/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00147
06/29/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00148
04/22/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00149
04/26/2009
Bradley Edwards
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00150
04/24/2009
Litigation Team
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
00151-00152 06/26/2009
Bradley Edwards
Rob Buschel
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
01036.01039 04/26/2009
Susan Sterling
Russell Adler
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
13313.13314 07/30/2009
Denis Kleinfeld
Bradley Edwards
Litigation Strategy
Work
Product;attorney
client
privilege;irrelevant & reasonably calculated to
43
EFTA00310090
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
lead
to
the
discovery
of
admissible
evidence; protected by privacy rights
13315
08/03/3009
Denis Kleinfeld
Beth Williamson
Litigation Strategy
Work
Prod uctattorney
client
privilege;irrelevant & reasonably calculated to
lead
to
the
discovery
of
admissible
evidence;protected by privacy rights
01080-01081 06/22/2009
Robert C. Buschel Bradley J. Edwards
Jane Doe brother
Attorney/Client privilege and/or work product
01077
05/28/2009
Robert C. Buschel Bradley J. Edwards
Doe family member
Attorney/Client privilege and/or work product
02445-02446 05/05/2009
Bradley
J.
Edwards
Susan K. Stirling
Jones v. Atlantic asphalt
Attorney/Client privilege and/or work product
03049
09/21/2009
Bradley
J.
Edwards
D.F.
New addition to the case
Attorney/Client privilege and/or work product
02425-02426 06/17/2009
Susan K. Stirling
Bradley J. Edwards
Jane Doe v. Dukenik
Attorney/Client privilege and/or work product
02669
09/24/2009
Bradley
J.
Edwards
Jacquie Johnson
Subpoena for
Attorney/Client privilege and/or work product
02647
08/06/2009
Mike Fisten
Bradley J. Edwards
a info
Attorney/Client privilege and/or work product
03688.03691 04/03/2009
Robin
T.
Kempner
Bradley J. Edwards
Case number assignments
Attorney/Client privilege and/or work product
03692-03693 05/06/2009
Bradley
J.
Edwards
Susan K. Stirling
Case list
Attorney/Client privilege and/or work product
15678.15680 09/29/2009
Jacquie Johnson
Bradley J. Edwards
Subpoena tot
Attorney/Client privilege and/or work product
15689
10/01/2009
Jacquie Johnson
Bradley J. Edwards
Client information
Attorney/Client privilege and/or work product
02546-02547 09/22/2009
D.F.
Bradley J. Edwards
Client communication
Attorney/Client privilege and/or work product
02809-02810 09/28/2009
N.R.
Bradley J. Edwards
Client communication
Attorney/Client privilege and/or work product
02262
07/23/2009
Jacquie Johnson
Bradley J. Edwards
Discussion
re:
client/victim
personal information
Attorney/Client privilege and/or work product
02807-02808 10/01/2009
N.R.
Bradley J. Edwards
Client communication
Attorney/Client privilege and/or work product
03760.03828 04/01/2009
RRA Personnel
RRA personnel
Client names/types of action/
client information
Attorney/Client privilege and/or work product,
privacy right privilege, not relevant
03759
04/01/2009
Russell Adler
Bradley J. Edwards
Conflict Check for Brad Edwards
files
Attorney/Client privilege and/or work product
08358.08359 09/14/2009
_ Pat Roberts
Bradley J. Edwards
Client info
Attorney/Client privilege and/or work product
44
EFTA00310091
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
08364-08368 10/01/2009
Jacquie Johnson
Bradley J. Edwards
Client Info
Attorney/Client privilege and/or work product
08370
09/14/2009
Bradley
J.
Edwards
Pat Roberts
Client info
Attorney/Client privilege and/or work product
08374-08375 10/01/2009
Bradley
J.
Edwards
Jacquie Johnson
Client info
Attorney/Client privilege and/or work product
03878
06/12/2009
Bradley
J.
Edwards
Robert C. Buschel
Curtis Rivera
Attorney/Client privilege and/or work product
02955
04/20/2009
Susan K. Stirling
Bradley J. Edwards
Juskowich
Attorney/Client privilege and/or work product
02932
07/17/2009
Christina Fitch
Bradley J. Edwards
Jane Doe v. Roe
Attorney/Client privilege and/or work product
11544-11545 09/28/2009
Jacquie Johnson
Bradley J. Edwards
Client info
Attorney/Client privilege and/or work product
07432-07435 09/25/2009
D.F.
Bradley J. Edwards
New addition to the case
Attorney/Client privilege and/or work product
06906-06909 07/17/2009
Christina Fitch
Bradley J. Edwards
Jane Doe v. Roe
Attorney/Client privilege and/or work product
06913.06914 06/22/2009
Bradley
J.
Edwards
Susan K. Stirling
Jane Doe v. Roe
Attorney/Client privilege and/or work product
06030-06031 05/04/2009
Susan K. Stirling
Bradley J. Edwards
Espina — Walmart case
Attorney/Client privilege and/or work product
05646
07/08/2009
Bradley
J.
Edwards
William J. Berger
Client meeting
Attorney/Client privilege and/or work product
05573
09/18/2009
Mike Fisten
Bradley J. Edwards
Client meeting
Attorney/Client privilege and/or work product
05540
07/31/2009
Amy Swan
Bradley J. Edwards
Client info
Attorney/Client privilege and/or work product
05273-05276 07/28/2009
Amy Swan
Bradley J. Edwards
Client info
Attorney/Client privilege and/or work product
05264
07/27/2009
Amy Swan
Bradley J. Edwards
Client info
Attorney/Client privilege and/or work product
05267-05270 07/27/2009
Amy Swan
Bradley J. Edwards
Client info
Attorney/Client privilege and/or work product
02933
06/17/2009
Bradley
J.
Edwards
M. G.
Jane Doe v. Roe
Attorney/Client privilege and/or work product
01292
09/18/2009
Bradley
J.
Edwards
M.G.
Epstein article
Attorney/Client privilege and/or work product
01068-01070 04/02/2009
All Staff
Robin T. Kempner
Current case list of Brad Edwards
Attorney/Client privilege and/or work product
01054-01055 04/02/2009
All Staff
Robin T. Kempner
Updated case list for Brad
Edwards
Attorney/Client privilege and/or work product
01033
05/06/2009
Susan K. Stirling
Bradley J. Edwards
case list
Attorney/Client privilege and/or work product
01030-01031 04/03/2009
Bradley
J.
Edwards
Robin T. Kempner
Case number assignments
Attorney/Client privilege and/or work product
45
EFTA00310092
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01118-01120 09/22/2009
Bradley
J.
Edwards
MG
Jane Doe v. Roe
Attorney/Client privilege and/or work product
01986.01989 04/02/2009
Bradley
J.
Edwards
Robin T. Kempner
Conflict check
Attorney/Client privilege and/or work product
01984-01985 04/02/2009
Bradley
J.
Edwards
Robin T. Kempner
Conflict check
Attorney/Client privilege and/or work product
25925
09/30/2009
All Staff
Robin T. Kempner
Conflict check
Attorney/Client privilege and/or work product
25874
09/30/2009
All Staff
Robin T. Kempner
Additional
name
added
to
conflict check
Attorney/Client privilege and/or work product
08356-08357 09/16/2009
Bradley Edwards
NR
Client Meeting
Attorney/Client privilege and/or work product
16760-16761 09/23/2009
Bradley Edwards
Jacquie Johnson
New Client
Attorney/Client privilege and/or work product
08005
06/05/2009
Bradley Edwards
MG
New Client
Attorney/Client privilege and/or work product
06915-06920 06/17/2009
MG
Bradley Edwards
Jane Doe v. Roe
Attorney/Client privilege and/or work product
08360-08363 09/16/2009
NR
Bradley Edwards
Client Meeting
Attorney/Client privilege and/or work product
04101-04107 09/28/2009
Bradley Edwards
MG
Jane Doe v. Roe
Attorney/Client privilege and/or work product
04708-04710 09/18/2009
Bradley Edwards
MG
Epstein Article
Attorney/Client privilege and/or work product
06910-06912 06/17/2009
MG
Bradley Edwards
Jane Doe v. Roe
Attorney/Client privilege and/or work product
07909
08/10/2009
Jane Doe
Bradley Edwards
Same silver car tag
Attorney/Client privilege and/or work product
07637.07642 09/10/2009
Bradley Edwards
NR
NR Interview
Attorney/ Client Privilege
06795-06799 08/19/2009
Anthony P
Bradley Edwards
Client Meeting
Attorney/Client privilege and/or work product
06542-06548 09/15/2009
Bradley Edwards
Pat Diaz
Client Meeting
Attorney/Client privilege and/or work product
06404-06408 09/10/2009
Bradley Edwards
Pat Diaz
NR Interview
Attorney/Client privilege and/or work product
08338.08339 09/16/2009
Bradley Edwards
NR
New Client
Attorney/Client privilege and/or work product
08505
09/14/2009
NR
Bradley Edwards
New Client Meeting
Attorney/Client privilege and/or work product
02241.02242 05/28/2009
Confidential
Source
Bradley Edwards
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02243-02244 07/07/2009
Bradley Edwards
Confidential Source
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02238-02240 05/28/20009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02204
07/14/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
46
EFTA00310093
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence
02298-02299 07/08/2009
Bradley Edwards
Confidential Source
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02291
06/04/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02442-02443 08/17/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02440-02441 10/02/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04318-04321 09/24/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05111
06/02/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05152
06/03/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05164
06/03/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05166
06/03/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05169-05170 06/03/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05173-05174 06/03/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05212-05213 06/23/2009
Confidential
Source
Bradley Edwards
Secret Plea Deal for Epstein
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05215-05217 06/23/2009
Confidential
Source
Bradley Edwards
Secret Plea Deal of Epstein
providing new witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05175-05189 07/02/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05194-05196 06/23/2009
Bradley Edwards
Confidential Source
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05204-05206 06/23/2009
Bradley Edwards
Confidential Source
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
47
EFTA00310094
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05227-05228 07/08/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05230-05231 07/08/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05303
08/06/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05344-05346 06/23/2009
Bradley Edwards
Confidential Source Secret Plea Deal for Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05408
07/06/2009
Bradley Edwards
Confidential Source
Secret Plea Deal for Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05425-05429 05/28/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05433-05436 05/29/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05433.05436 05/29/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05446
07/07/2009
Bradley Edwards
Confidential Source
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05452-05464 05/29/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05535-05536 07/30/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05538-05539 07/30/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05550-05551 08/11/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05577-05578 08/22/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05619-05620 09/18/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05650
08/06/200
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05688-05689 0/28/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
48
EFTA00310095
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence
05693-05695 05/28/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05698
08/21/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05706-05709 05/28/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05720-05721 05/29/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05738-05739 05/29/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05743-05745 05/29/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05754
08/03/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05759-05762 06/01/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05765-05768 06/23/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05771-05773 06/03/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05777-05779 06/03/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05784-05786 06/03/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05791-05794 06/03/2009
Bradley Edwards
Confidential Source Additional
Information
RE: W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
Epstein Molestations
05803
07/22/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05836-05837 07/08/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05842-05843 07/08/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
49
EFTA00310096
Privilege Log — Dated 2-2 3-201 1
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05848
07/28/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05852-05853 07/29/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05857-05858 07/31/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05952-05953 08/25/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06192-06197 06/23/2009
Bradley Edwards
Confidential Source Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06198-06201 06/24/2009
Confidential
Source
Bradley Edwards
Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06203
07/23/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06401
09/23/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06643-06651 09/17/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06788-06789 09/28/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06942.06943 09/26/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06953
08/14/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06955.06957 10/02/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06959-06961 08/11/2009
Bradley Edwards
Confidential Source Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06963-06980 08/11/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06986-06989 10/03/2009
Bradley Edwards
Confidential Source Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07010-07014 10/04/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
50
EFTA00310097
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence
07017-07018 09/04/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07143-07144 10/01/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07147-07150 09/18/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
075089-
07513
10/13/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07605-07615 09/07/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07646-07647 09/08/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07674-07697 09/08/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08376
10/04/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08380
09/18/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08427-08430 09/24/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08450
05/17/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
08507
10/03/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
10092-10098 08/31/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01610
06/03/3009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01612
06/04/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01451-01458 05/27/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
51
EFTA00310098
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01608
07/03/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01606
07/02/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01510
08/25/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01506
08/24/2009
Confidential
Source
Bradley Edwards
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01493
08/10/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01488
08/03/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01486
07/28/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01483
07/28/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01479
07/22/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01449
05/22/2009
Bradley Edwards
Confidential Source
Secret Plea Deal for Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01433
10/20/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
15207-15208 08/14/2009
Jacquie Johnson
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
19716-19719 09/25/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
19730-19731 10/02/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01683
08/06/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01693
08/21/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03011
09/17/2009
Bradley Edwards
Confidential Source
Additional
Information
RE: W/P Priv.; not reasonably calculated to lead to
52
EFTA00310099
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Epstein Molestations
discovery of admissible evidence
01755-01756 10/02/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01756
06/22/2009
Bradley Edwards
Confidential Source
Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
01770
10/08/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03126
09/18/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02006
06/23/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02060
09/23/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03487-03494 09/19/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02269
08/26/2009
Confidential
Source
Bradley Edwards
Other Rape Victims
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02322-02323 10/16/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02595-02596 09/07/2009
Bradley Edwards
Confidential Source Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02866-02867 09/25/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02895
08/31/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02901
09/16/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03032
09/18/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03057
10/13/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03070
07/28/2009
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
53
EFTA00310100
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
03081-03082 09/21/2009
Bradley Edwards
Confidential Source
Providing Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03144
10/08/2009
Confidential
Source
Bradley Edwards
Providing Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
03189-03190 10/14/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Strategies
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04015
09/08/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02913
09/28/2009
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02956-02957 08/31/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02975
10/21/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04031-04055 08/12/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04057
08/ 11/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04060
08/12/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02979.02980 10/02/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02998
07/21/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05626
10/12/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05630-05631 10/12/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05664-05665 10/12/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
07976
08/14/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
06655
06/09/2009
Confidential
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
54
EFTA00310101
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Source
discovery of admissible evidence
19986-19987 09/28/2009
Confidential
Source
Mike Fisten
Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04905-04906 07/15/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
04946-04951 10/28/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05148
05/22/2009
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05151
05/26/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05161
05/28/2009
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05203
06/23/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05207-05208 06/23/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05220.05221 06/23/2009
Confidential
Source
Bradley Edwards
Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05224-05225 06/24/2009
Confidential
Source
Bradley Edwards
Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05239
06/23/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05277-05278 06/23/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05324-05325 06/23/2009
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05368-05369 06/23/2009
Bradley Edwards
Confidential Source
Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05387-05388 06/23/2009
Bradley Edwards
Confidential Source
Secret Plea Deal For Epstein
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
02811-02812 10/03/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
55
EFTA00310102
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01280-01288 09/18/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
01131-01134 10/08/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
00988
04/25/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10163-10167 08/12/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10181-10188 08/12/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10245-10251 09/08/2009
Bradley Edwards
Confidential Source Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10364-10367 09/17/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
W/P Privilege; Not reasonably calculated to lead
Epstein Molestations
to discovery of admissible evidence.
10586.10591 09/24/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10625-10632 10/02/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10698-10699 10/13/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10718.10719 10/13/2009
Bradley Edwards
Confidential Source Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10927-10937 05/28/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10945-10954 05/29/2009
Bradley Edwards
Confidential Source
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10964-10978 06/02/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10991
06/22/2009
Bradley Edwards
Confidential Source
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11006-11010 06/23/2009
Bradley Edwards
Confidential Source
Additional
Information
RE: W/P Privilege; Not reasonably calculated to lead
56
EFTA00310103
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissine, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Epstein Molestations
to discovery of admissible evidence.
11075-11076 07/29/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11080-11082 07/31/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11085-11097 09/04/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11123-11136 09/17/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE: W/P Privilege; Not reasonably calculated to lead
Epstein Molestations
to discovery of admissible evidence.
11140-11142 10/04/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11150.11151 10/12/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
10390-10393 09/19/2009
Bradley Edwards
Confidential Source Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11157-11165 10/25/2009
Confidential
Source
Bradley Edwards
Providing New Witnesses
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11170-11174 06/23/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11184-11185 05/27/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11188-11195 05/28/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11198-11200 05/28/2009
Bradley Edwards
Confidential Source
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11208-11214 05/29/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11223-11236 06/01/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11260-11266 06/24/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11320-11325 07/30/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
57
EFTA00310104
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
11372-11373 08/11/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11380-11383 08/12/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11438-11442 09/17/2009
Confidential
Source
Bradley Edwards
Additional
Information
RE:
Epstein Molestations
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11549-11550 10/01/2009
Confidential
source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
11574-11579 10/13/2009
Confidential
Source
Bradley Edwards
Litigation Strategy
W/P Privilege; Not reasonably calculated to lead
to discovery of admissible evidence.
BOX 2
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
08029.08032
09/14/2009
Bradley Edwards
Tami Wolfe
litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08026.08028
05/01/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07738.07739
05/13/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07747
09/17/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07758-07759
05/05/2009
Jonathan
Birkman
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
58
EFTA00310105
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
07760-07765
09/11/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07766
10/11/2009
Jacquie Johnson
Attorneys at RRA
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07767-07784
05/01/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07785-07790
06/26/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07791
04/04/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07792-07793
04/01/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07794-07841
04/04/2009
Paul Cassell
Bradley Edwards
Full draft of motion to stay
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07842-07848
06/16/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
59
EFTA00310106
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privacy rights
07849-07852
04/10/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07853-07856
06/10/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07857.07862
09/11/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07863-07864
06/10/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07685-07874
05/14/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07875-07876
04/14/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07877-07884
08/03/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07886-07888
08/02/2009
Cara Holmes
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
60
EFTA00310107
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
07889-07892
05/01/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07893-07904
07/27/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07905-07908
07/22/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07910-07912
08/10/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07916
10/16/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07919
08/27/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
07920-07930
10/18/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05399
10/17/2009
William Berger
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05355.05357
09/09/2009
Russell Adler
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
61
EFTA00310108
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05375-05378
09/10/2009
Jacquie Johnson
Bradley Edward
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05372
04/20/2009
Marc Nurik
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05380-05381
09/11/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05384.05385
09/15/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05348
09/15/2009
Bradley Edwards
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05341
09/04/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05329-05330
04/09/2009
Beth Williamson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05332-05333
05/20/2009
William Berger
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
62
EFTA00310109
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
pfSCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
05320-05323
07/30/2009
Bradley Edwards
Amy Swan
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05312-05313
07/22/2009
Nora Batian
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05306.05307
07/22/2009
Nora Batian
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05302
07/22/2009
Attorney at RRA
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05281
08/03/2009
Bradley Edwards
Mike Fisten
Review of litigation materials
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05282-05283
04/09/2009
Beth Williamson
Bradley Edwards
Jane Doe v. Us
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05288-05291
07/22/2009
Bradley Edwards
William Berger
Dr. Swan
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05292
07/22/2009
Attorneys at RRA
Ken Jenne
RE: Epstein Meeting
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
63
EFTA00310110
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privacy rights
05295-05297
07/23/2009
Attorneys at RRA
Priscilla
Nascimento
RE: Epstein Conference Room
Reserved
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05298
08/03/2009
Mike Fisten
Bradley Edwards
Discussion of Epstein strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05261
07/23/2009
Amy Swan
Bradley Edwards
Victim Psychological Assessment
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18358-18359
07/24/2009
Bradley Edwards
Ken Jenne
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04431-04432
08/14/2009
Jacquie Johnson
Bradley Edwards
RE: Epstein-Maxwell Subpoena
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04419-04420
04/09/2009
Bradley Edwards
Paul Cassell
RICO Statement
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04403-04416
10/17/2009
Paul Cassell
Bradley Edwards
Punitive Damages
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04387-04402
08/19/2009
Paul Cassell
Bradley Edwards
Victim
Complaints,
Forensic
accountants,
&
Epstein's
Fraudulent Transfers
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
64
EFTA00310111
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01082
09/02/2009
Jacquie Johnson
Mike Fisten
Subpoenas
for
Epstein's
Housekeepers
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04363
09/14/2009
Jacquie Johnson
Bradley Edwards
LM
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04343-04344
09/04/2009
Bradley Edwards
Jacquie Johnson
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04340-04342
09/04/2009
Jacquie Johnson
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04339
09/03/2009
Mike Fisten
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
00989
09/04/2009
Bradley Edwards
William Berger
Alessi Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04325-04328
07/30/2009
Paul Cassell
Bradley Edwards
RE:
Epstein-
beneficiaries
&
response to asset freeze motion
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
00155
06/25/2009
Bradley Edwards
Paul Cassell
20 Cases & Bond
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04312.04313
05/26/2009
Bradley Edwards
Paul Cassell
RE: Epstein Accounting; Freezing W/P; Attorney Client Privilege; Irrelevant and
65
EFTA00310112
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
Assets
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04314-04317
09/11/2009
Paul Cassell
Bradley Edwards
RE: Epstein- Add to our motion
for a protective order '
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04307-04308
04/08/2009
Bradley Edwards
Paul Cassell
Motion
to
stay-response
&
motion to unseal Fed Civil Case
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04309-04311
05/26/2009
Paul Cassell
Bradley Edwards
Epstein
Assets
&
Forensic
Accounting
04295
09/11/2009
Jacquie Johnson
Bradley Edwards
thoughts on Epstein's Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04305.04306
04/08/2009
Paul Cassell
Bradley Edwards
Motion to Strike references to
the NPA & Revised response to
the motion to stay
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04274-04276
05/06/2009
William Berger
Bradley Edwards
Sandy Berger Telephone call
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18334-18336
07/24/2009
Ken Jenne
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04216-04219
09/08/2009
William Berger
Bradley Edwards
State Judge ordered no contact
with any underage girl
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
66
EFTA00310113
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
DBJECTION
04202.04206
09/08/2009
Bradley Edwards
William Berger
Epstein's
attorneys
&
Bob
Josephsberg have filed several
motions on limits of the no
contact order
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04207-04215
09/04/2009
Attorneys at RRA
Paul Cassell
Letter to Critton RE: Protective W/P; Attorney Client Privilege; Irrelevant and
Order
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04191-04193
09/04/2009
Paul Cassell
William Berger
Finding out who is protected by
the order
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04194-04195
09/04/2009
Attorneys at RRA
Steven Jaffe
Seek Court Intervention
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04196-04199
09/08/2009
Bradley Edwards
William Berger
Finding out who is protected by
the order
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25937
10/25/2009
Scott Rothstein
Ken Jenne
Epstein's house staff
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25923
09/09/2009
Attorneys at RRA
Maribel Matiska
legal opinion RE: Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25832-25838
06/01/2009
Bradley Edwards
William Berger
contact Information re: who is
pertinent to the case
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25825-25826
10/05/2009
Bradley Edwards
William Berger
Trial Prep Epstein
W/P; Attorney Client Privilege; Irrelevant and
67
EFTA00310114
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTIOa.
OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19649-19651
07/24/2009
Bradley Edwards
Ken Jenne
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19658.19661
08/03/3009
Bradley Edwards
Ken Jenne
Copperfield Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25809-25810
10/04/2009
William Berger
Bradley Edwards
Trail Prep
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04466-04469
08/18/2009
Bradley Edwards
Paul Cassell
Epstein Assets Subpoena
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01296
10/02/2009
Mike Fisten
Michael Wheeler
Subpoena of Detective Recarey
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04439-0442
09/16/2009
Bradley Edwards
Paul Cassell
RE: Epstein-Notice Of IME
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04445
07/31/2009
Jacquie Johnson
Bradley Edwards
RE:Epstein
Reminder-Mon
8/3/09-Monthly
Call
in
Telephone Conference
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04425-04428
09/18/2009
Paul Cassell
Bradley Edwards
Jane Doe Depo Set for the 30th
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
68
EFTA00310115
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
LO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
04429
10/07/2009
Bradley Edwards
Paul Cassell
Motion for Sanctions
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25770-25772
10/05/2009
William Berger
Bradley Edwards
Victims for Trial
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25768-25769
10/05/2009
Bradley Edwards
William Berger
Victims for Trail
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26716-26717
09/04/2009
Mike Fisten
Ken Jenne
NR as a victim
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26714-26715
10/13/2009
Attorneys at RRA
Russell Adler
Trial date procured
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20907.20908
10/05/2009
Bradley Edwards
William Berger
Victims for Trial
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19857-19860
10/17/2009
Mike Fisten
Pat Roberts
Epstein's Palm Beach Property
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19861-19862
10/23/2009
Paul Cassell
Bradley Edwards
Larry Visoski Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
69
EFTA00310116
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
MILS
DATE
TN
FROM
DESCRIPTION
OBJECTION
privacy rights
19713.19715
09/09/2009
Bradley Edwards
Jacquie Johnson
Copperfield Subpoena
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19720-19729
09/30/2009
Mike Fisten
Jacquie Johnson
Tentative Subpoena dates and
people list
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19706.19707
09/09/2009
Bradley Edwards
Jacquie Johnson
Dershowitz Subpoena ready to be
signed
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19693-19695
09/04/2009
Mike Fisten
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19696-19697
09/04/2009
Jacquie Johnson
Bradley Edwards
Setting Up Depo Times
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19698-19700
09/04/2009
Mike Fisten
Bradley Edwards
Investigation in Epstein's planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19685-19688
08/27/2009
Bradley Edwards
Ken Jenne
RE: Witness information that we
need to use
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19689-19690
09/02/2009
Mike Fisten
Jacquie Johnson
Awaiting dates for the 2 other
pilots, Dershowitz & Copperfield
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
70
EFTA00310117
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
19691-19692
09/02/2009
Mike Fisten
Pat Diaz
Bill Riley Subpoena
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19673-19674
08/10/2009
Jacquie Johnson
Bradley Edwards
Depo List
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19654-19655
08/03/2009
Mike Fisten
Bradley Edwards
Setting Up Copperfield Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19656-19657
08/03/2009
Mike Fisten
Bradley Edwards
List of people to subpoena
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19662-19663
08/03/2009
Mike Fisten
Bradley Edwards
Setting Up Copperfield Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19652-19653
08/26/2009
Jacquie Johnson
Bradley Edwards
Witness information that we
need to use
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18348-18349
08/27/2009
Bradley Edwards
Ken Jenne
RE: Witnesses information that
we need to use
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04272
06/30/2009
William Berger
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19683-19684
08/19/2009
Mike Fisten
Pat Diaz
Potential New Witnesses
W/P; Attorney Client Privilege; Irrelevant and
71
EFTA00310118
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
19856
10/17/2009
Mike Fisten
Mike Fisten
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20888
09/12/2009
Russell Adler
Bradley Edwards
Potential New witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20946
05/11/2009
Attorneys at RRA
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05807-05810
07/23/2009
Attorneys at RRA
Priscila
Nascimento
Conference room reserved
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05262.05263
07/22/2009
Bradley Edwards
Jacquie Johnson
Investigator information
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25829
05/11/2009
Bradley Edwards
William Berger
Motion to unseal criminal records W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25830-25831
05/11/2009
Attorneys at RRA
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25811-25813
05/11/2009
Attorneys at RRA
Bradley Edwards
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
72
EFTA00310119
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
IQ
FROM
DESCRI • TION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
25815.25822
06/01/2009
William Berger
Bradley Edwards
Depo information
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18358-18359
07/24/2009
Bradley Edwards
Ken Jenne
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05382
09/12/2009
Bradley Edwards
Mike Fisten
Potential new witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08033-08070
10/23/2009
Attorneys at RRA
Mike Fistos
Legal Research RE: Causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25997
10/23/2009
Scott Rothstein
Russell Adler
Legal Research
RE: causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26741-26763
10/23/2009
Attorneys at RRA
Bradley Edwards
Legal Research RE: causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
25774-25777
05/12/2009
Bradley Edwards
Susan Stirling
Filed Motions
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18177-18179
08/24/2009
Ken Jenne
Bradley Edwards
Epstein Probation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
73
EFTA00310120
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privacy rights
18174-18176
08/24/2009
Ken Jenne
Mike Fisten
Epstein Probation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18172-18173
08/24/2009
Mike Fisten
Bradley Edwards
Epstein Probation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18170
08/24/2009
Bradley Edwards
Mike Fisten
Epstein Probation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
03106
06/03/3009
Bradley Edwards
Shawn Gilbert
Epstein Case Info
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02593-02594
05/13/2009
Bradley Edwards
Shawn Gilbert
Discussion
with
secretary
regarding client information
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
08014
Undated
_
Unknown Staff
Bradley Edwards
Miscellaneous case info
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
27494
10/23/2009
Attorneys at RRA
Mike Fistos
Legal Research RE: Causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18166-18167
08/04/2009
Bradley Edwards
Mike Fisten
Copperfield Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
74
EFTA00310121
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
18164-18165
08/03/2009
Bradley Edwards
Mike Fisten
Copperfield Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the_
discovery of admissible evidence; protected by
privacy rights
18771-18773
04/27/2009
Marc Nurik
Bradley Edwards
Legal Research RE: causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18742-18744
09/10/2009
Jacquie Johnson
Bradley Edwards
Dershowitz Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
18737-18741
09/10/2009
Jacquie Johnson
Bradley Edwards
Depo technicalities
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20263-20282
10/14/2009
Pat
Roberts,
Mike Fisten
Ronald Wise
Vehicle Registrations-Visoski
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
20219-20262
10/14/2009
Pat
Roberts,
Mike Fisten
Ronald Wise
Visoski Research & Questions
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
17225-17230
07/22/2009
Bradley Edwards
Jacquie Johnson
Wayne Black Retainer
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
17038-17040
10/29/2009
Cara Holmes
Jacquie Johnson
RE:
Subpoenas for
Epstein's
attorneys
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16916.16928
10/19/2009
Bradley Edwards
Jacquie Johnson
Witness List
W/P; Attorney Client Privilege; Irrelevant and
75
EFTA00310122
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
PATE
TO
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16795.16796
10/01/2009
Bradley Edwards
Jacquie Johnson
Trump Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16455-16759
09.10/2009
Bradley Edwards
Jacquie Johnson
Depo Dates
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16436-16437
09/09/2009
Bradley Edwards
Jacquie Johnson
Dershowitz Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16400-16404
09/02/2009
Mike Fisten
Jacquie Johnson
Investigation
into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
16394-16395
08/31/2009
Bradley Edwards
Jacquie Johnson
Depo Dates
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01046
08/25/2009
Cara Holmes
Bradley Edwards
Computer information
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01048-01050
07/28/2010
William Berger
Bradley Edwards
Hard drive of Plaintiffs computer
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01052
09/09/2009
Attorneys at RRA
Maribel Matiska
legal Opinion RE: Epstein
WP; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
76
EFTA00310123
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
01100
10/19/2009
Russell Adler
Bradley Edwards
Dershowitz Involvement
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01105
08/11/2009
Bradley Edwards
Alan Garten
Potential New Witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01111
05/13/2009
Bradley Edwards
Paul Cassell
Legal research
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01112-01117
05/12/2009
Bradley Edwards
William Berger
Dr. Swan
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01139-01142
04/29/2009
Staff
Bradley Edwards
Epstein Depo revised
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01151
09/11/2009
Beth Williamson
Bradley Edwards
Motion for protective order final
draft
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01167
09/11/2009
Bradley Edwards
Jacquie Johnson
Epstein MP0
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01216
05/21/2009
Bradley Edwards
William Berger
Immunity for testimony about
prostitution
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
77
EFTA00310124
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privacy rights
01247
09/30/2009
Bradley Edwards
Jacquie Johnson
Therapy Notes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01268-01269
10/22/2009
Bradley Edwards
Marc Nurik
Epstein meeting
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01293
08/19/2009
Ken Jenne
Bradley Edwards
Epstein Assets
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01299
04/21/2009
Bradley Edwards
Carolyn Edwards
Order denying the motion to
reassign or transfer
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01305
08/24/2009
Paul Cassell
Bradley Edwards
Epstein Computers
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01313
09/02/2009
Attorneys at RRA
Jacquie Johnson
Epstein Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01333
08/03/3009
Jacquie Johnson
Bradley Edwards
Epstein Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01335
08/03/2009
Mike Fisten
Bradley Edwards
Investigation into Epstein planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
78
EFTA00310125
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
01337
08/10/2009
Jacquie Johnson
Bradley Edwards
Epstein Depo list
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01363
09/08/2009
Ken Jenne
Bradley Edwards
Motion to freeze assets
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01414-01416
98/18/2009
Bradley Edwards
& Ken Jenne
Mike Fisten
Epstein Potential Witness List
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01417
08/24/2009
Mike Fisten
Bradley Edwards
Potential Witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01429
09/09/2009
Attorneys at RA
Bradley Edwards
Epstein telephone conference
today
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01431
07/31/2009
Jacquie Johnson
Bradley Edwards
Epstein case info
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01432
09/15/2009
Bradley Edwards
Pat Diaz
New Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01434
10/19/2009
Marc Nurik
Bradley Edwards
Epstein Evidence
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01461
04/27/2009
Marc Nurik
Bradley Edwards
Epstein Info
W/P; Attorney Client Privilege; Irrelevant and
79
EFTA00310126
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
1MTE$
DATE
12
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01466
07/31/20009
William Berger
Bradley Edwards
Epstein Presentation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01471
07/18/2009
Wayne Black
Bradley Edwards
Investigation into
Epstein's
planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01480
07/22/2009
Attorneys at RRA
Bradley Edwards
Epstein Meeting
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01482
07/24/2009
Ken Jenne
Bradley Edwards
Investigation into Epstein planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01491
08/10/2009
Ken Jenne
Bradley Edwards
Investigative fees
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01492
08/10/2009
Jacquie Johnson
Bradley Edwards
The Mar-a-Lago Club Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01495
08/11/2009
Marc Nurik
Bradley Edwards
Potential Witness
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01498
08/17/2009
Marc Nurik
Bradley Edwards
Legal opinion re:Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
80
EFTA00310127
Privilege Log — Dated 2-23-2011
Farmer. Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
DATE
IQ
FROM
DESCRIPTION
OBJECTI9N
discovery of admissible evidence; protected by
privacy rights
01502
08/21/2009
Marc Nurik
Bradley Edwards
Epstein Evidence
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01513
08/25/2009
Jacquie Johnson
Bradley Edwards
Discovery for the girls
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01522
08/14/2009
Bradley Edwards
Marc Nurik
Legal opinion
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01522
10/08/2009
Ken Jenne
Bradley Edwards
New Victim
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01523.01524
10/26/2009
Marc Nurik
Bradley Edwards
Meeting on Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01527
04/27/2009
Marc Nurik
Bradley Edwards
New Victim
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01540
05/01/2009
William Berger
Bradley Edwards
Litigation Strategy on punitive
damages
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01553
09/10/2009
Bradley Edwards
Jacquie Johnson
Letter from JP Morgan Chase
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
81
EFTA00310128
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissinc Edwards, Fistos & Lehrman
GATES
DATE
12
FROM
DESCRIPTION
OBJECTION,
privacy rights
01566
05/11/2009
Wayne Black
Bradley Edwards
New Victim
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01586
05/26/2009
Paul Cassell
Bradley Edwards
Opposition to the continuance of
the trial date
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
15690.15691
10/01/2009
Jacquie Johnson
Bradley Edwards
Trump Depo
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01607
10/17/2009
Paul Cassell
Bradley Edwards
Litigation Strategy on motions
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01621
04/19/2009
Marc Nurik
Bradley Edwards
Potential New Witness
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01622
06/09/2009
Susan Stirling
Bradley Edwards
Important phone call due today
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01624
06/11/2009
Robert Buschel
Bradley Edwards
Motion for bond asset transfer
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01627
05/06/2009
Bradley Edwards
Marc Nurik
Dateline interest into epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
82
EFTA00310129
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
01628
06/15/2009
Robert Buschel
Bradley Edwards
Investigations
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01635
05/21/2009
Bradley Edwards
Carolyn Edwards
Personal Conversation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01636
06/23/2009
Susan Stirling
Bradley Edwards
Motion to unseal
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01638
06/29/2009
Paul Cassell
Bradley Edwards
Litigation Strategy RE: Motion to
unseal
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01644
07/06/2009
Confidential
Source
Bradley Edwards
Request for admission
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01646
07/06/2009
Confidential
Source
Bradley Edwards
Secret Plea deal for Bear Stearns
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01648
07/11/2009
Wayne Black
Bradley Edwards
Investigating Epstein's planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01650
07/13/2009
Carl Linder
Bradley Edwards
Epstein's Assets
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01658-01659
07/18/2009
Paul Cassell
Bradley Edwards
DOJ
W/P; Attorney Client Privilege; Irrelevant and
83
EFTA00310130
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01663
07/18/2009
Mike Fisten
Bradley Edwards
Epstein's cars
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01668
07/29/2009
Bradley Edwards
Wayne Black
number
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01764
07/31/2009
Bradley Edwards
Carolyn Edwards
Case Numbers
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01676
10/17/2009
Paul Cassell
Bradley Edwards
Motions
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01681
08/03/20009
Mike Fisten
Bradley Edwards
Positing
regarding
litigation
preparation
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01682
09/04/2009
Paul Cassell
Bradley Edwards
Litigation Strategy-Order 242
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01684
09/11/2009
Jacquie Johnson
Bradley Edwards
Plaintiff firms the notices of
depos
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01686
09/11/2009
Mike Fisten
Bradley Edwards
Potential new witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
84
EFTA00310131
Privilege Log— Dated 2-23-2011
Farmer. Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
01692
09/12/2009
William Berger
Bradley Edwards
Proposal for settlement
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01698
05/05/2009
Paul Cassell
Bradley Edwards
Epstein Victim Depos
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01702
09/17/2009
Paul Cassell
Bradley Edwards
Epstein Depos
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01705
05/14/2009
William Berger
Bradley Edwards
Statutory Rape
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01711
04/101/2009
Carolyn Edwards
Bradley Edwards
Third party subs
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01737
07/14/2009
Richard Wolfe
Bradley Edwards
Facebook/Myspace
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01564
05/11/2009
Attorneys at RRA
Bradley Edwards
Investigation Epstein's planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01603
10/15/2009
Bradley Edwards
Adam Horowitz
Testimony RE: Vehicles
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
85
EFTA00310132
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privacy rights
01742
10/12/2009
Beth Williamson
Bradley Edwards
Filing fee check
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01743
10/29/2009
Beth Williamson
&
Jacquie
Johnson
Bradley Edwards
New folder for Jane Doe Created
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
01745
10/15/2009
Bradley Edwards
Paul Cassell
Epstein's Cars
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05726
08/14/2009
Bradley Edwards
William Berger
Legal opinion
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
27395
08/13/2009
Marc Nurik
Scot Rothstein
Legal Research RE: causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
26356
08/13/2009
Scott Rothstein
Russell Adler
Legal Research RE: causes of
action against Epstein
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04225
06/15/2009
Bradley Edwards
Wayne Black
Epstein Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04229.04233
06/16/2009
Wayne Black
Bradley Edwards
Epstein secret plea deal with
Bear Stearns
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
86
EFTA00310133
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
04237-04242
06/15/2009
Bradley Edwards
Wayne Black
Epstein secret plea deal with
Bear Stearns
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04246
06/15/2009
Wayne Black
Bradley Edwards
Epstein secret plea deal for Bear
Stearns
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04250
06/15/2009
Wayne Black
Bradley Edwards
Epstein Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04255.04256
06/15/2009
Wayne Black
Bradley Edwards
Epstein secret plea deal for Bear
Stearns
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04260
06/15/2009
Bradley Edwards
Wayne Black
Epstein secret plea deal for Bear
Stearns
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
04523
05/14/2009
Bradley Edwards
Wayne Black
Investigating Epstein's planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05088-05090
10/27/2009
Attorneys at RRA
Ken Jenne
Epstein's assets
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05108
04/01/2009
Bradley Edwards
Carolyn Edwards
Victims employment
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
87
EFTA00310134
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
05145
05/21/2009
Bradley Edwards
Carolyn Edwards
Epstein Hearing
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
05237
07/20/2009
Wayne Black
Bradley Edwards
Investigating Epstein's planes
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
discovery of admissible evidence; protected by
privacy rights
02648-02650
08/10/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02651
07/29/2009
Bradley Edwards
Wayne Black
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02661-02662
05/12/2009
Russell Adler
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02674.02677
08/18/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02678-02679
04/10/2009
Russell Adler
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02682.02683
08/10/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02718-02720
06/25/2009
Bradley Edwards
Seth Lehman
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
88
EFTA00310135
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
ig
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02728-02729
08/04/2009
Bradley Edwards
Spencer Kuvin
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02746
07/22/2009
Bradley Edwards
Adam Steinberg
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02813-02814
08/26/2009
Bradley Edwards
Pat Diaz
Providing New Witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02817-02826
08/04/2009
Bradley Edwards
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02827-02832
05/12/2009
Attorneys at RRA
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02833-02835
08/23/2009
Bradley Edwards
Pat Diaz
Other Rape Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02874-02876
05/23/2009
Bradley Edwards
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02887.02888
08/26/2009
Bradley Edwards
Pat Diaz
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
89
EFTA00310136
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OWE
'N
discovery of admissible evidence; protected by
privacy rights
02889-02890
10/14/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02891
10/12/2009
Bradley Edwards
Paul Cassell
litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02892
08/03/2009
Bradley Edwards
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02894
09/09/2009
Mike Fisten
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02899
09/29/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03001-03002
05/15/2009
Susan Stirling
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03003
04/15/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03004
06/23/2009
Wayne Black
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
90
EFTA00310137
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
privacy rights
03005-03006
08/03/2009
Mike Fisten
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03007
10/07/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03008
04/23/2009
Susan Stirling
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03013
05/25/2009
Bradley Edwards
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03014
10/08/2009
Bradley Edwards
Cara Holmes
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03015
04/24/2009
Steven Jaffe
Susan Stirling
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03017-03018
08/18/2009
Mike Fisten
Bradley Edwards
Providing New witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03019
09/19/2009
Bradley Edwards
Pat Diaz
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
91
EFTA00310138
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
lo
FROM
DESCRIPTION
OBJECTION
03020
09/16/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
VV/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03021-03027
09/19/2009
Bradley Edwards
Pat Diaz
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03031-03034
09/18/2009
Pat Diaz
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03035
09/29/2009
Russell Adler
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03039
06/05/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03040
09/04/2009
Mike Fisten
William Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03044
09/09/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03045.03047
09/30/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03048
04/21/2009
Paul Cassell
Susan Stirling
Litiation Strategy
W/P; Attorney Client Privilege; Irrelevant and
92
EFTA00310139
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03050-03052
10/16/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03053
10/17/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03054
10/13/2009
Attorneys at RRA
Grant Smith
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03056
09/04/2009
Bradley Edwards
Mike Fisten
Other Rape Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03072
06/22/2009
Bradley Edwards
Wayne Black
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03073
09/01/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03074-03075
10/28/2009
Jacquie Johnson
Michael Wheeler
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03100
10/15/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
93
EFTA00310140
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
03102.03103
07/21/2009
Bradley Edwards
Paul Cassell
Other Rape Victims
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03107-03113
07/24/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03114
08/04/2009
Bradley Edwards
Mike Fisten
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03115-03118
05/16/2009
Bradley Edwards
Susan Stirling
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03124
06/23/2009
Bradley Edwards
Wayne Back
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03125
09/08/2009
William Berger
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03127-03128
05/19/2009
Susan Stirling
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03135.03136
08/04/2009
Mike Fisten
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
94
EFTA00310141
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
PATES
DATE
12
FROM
DESCRIPTION
OBJECTION
privacy rights
03137
08/22/2009
Wayne Black
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03138
10/08/2009
Beth Williamson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03145
10/30/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03146
08/22/2009
Bradley Edwards
Wayne Black
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03147-03154
10/07/2009
Bradley Edwards
Beth Williamson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03155-03155
10/08/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03158-3159
04/28/2009
Bradley Edwards
Susan Stirling
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03191.03196
10/14/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
95
EFTA00310142
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
RATE
12
FROM
DESCRIPTION
OBJECTION
03197-03199
08/14/2009
Attorneys at RRA
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03205.03211
09/13/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03212
08/11/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03213
10/28/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03214-03218
10/27/2009
Paul Cassell
Ronald Wise
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03223-03232
04/15/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03233-03242
09/28/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03245
06/01/2009
William Berger
Bradley Berger
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03251-03252
09/24/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
96
EFTA00310143
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
'IQ
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03303
07/30/2009
Bradley Edwards
Beth Williamson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03306-03307
09/04/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03308-03309
09/04/2009
Beth Williamson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03310-03314
09/04/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03389
07/30/2009
Beth Williamson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03392-03393
09/04/2009
Bradley
Williamson
Beth Williamson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03461-03463
09/19/2009
Bradley Edwards
Susan Stirling
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03464-03465
06/14/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
97
EFTA00310144
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
discovery of admissible evidence; protected by
privacy rights
03469.03486
06/15/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03495
08/27/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03496-03501
10/28/2O09
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03502-03506
10/27/2009
Paul Cassell
Ronald Wise
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03507-03510
10/28/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03511-03513
10/28/20O9
Bradley Edwards
Ronald Wise
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03514-03516
10/26/2009
Paul Cassell
Ronald Wise
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03520-03523
07/04/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
98
EFTA00310145
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
privacy rights
03524
09/04/2009
William Berger
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03525-03530
09/05/2009
William Berger
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03532
08/24/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03536
07/19/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03539.03540
08/26/2009
Pat Diaz
Bradley Edwards
Providing New Witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03541-03544
10/12/2009
Attorneys at RRA
Ronald Wise
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03545-03547
06/26/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03548-03549
04/11/2009
Wayne Black
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
99
EFTA00310146
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
03550-03574
09/09/2009
Attorneys at RRA
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03575-03588
10/19/2009
Kendall Coffey
Bradley Edwards
Providing New Witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03589-03604
04/11/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03605-03606
10/16/2009
Attorneys at RRA
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03607-03610
10/16/2009
William Berger
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03611-03612
10/16/2009
Attorneys at RRA
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03613-03615
10/29/2009
Bradley Edwards
Cara Holmes
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03616-03618
10/01/2009
Pat Diaz
Bradley Edwards
Providing New Witnesses
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03628-03637
09/15/2009
Jacquie Johnson
Bradley Edwards
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
100
EFTA00310147
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
MTES
DATE
TO
FROM
DESCRIPTION
OBJECTION
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
03638-03641
09/08/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
08454
10/23/2010
Attorneys at RRA
Mark Fistos
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
08118-08123
10/23/2009
Attorneys at RRA
Russell Adler
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
08124-08156
10/23/2009
Attorneys at RRA
Steven Jaffe
Litigation Strategy
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to
lead to the
discovery of admissible evidence; protected by
privacy rights
02411-02413
05/12/2009
Attorneys at RRA
Bradley
J.
Edwards
Jane Doe II v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01913-01914
06/15/2009
Susan K. Stirling
Bradley
J.
Edwards
Activity in case 9:08-cv-80893-
Doe v. Epstein Motion to
Dismiss
—
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01918- 01919
04/15/2009
Attorneys at RRA
Bradley
J.
Edwards
Activity in case 9:08-cv-80893- Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
OS Doe v. Epstein Motion to
Compel
01920-01924
05/20/2009
Paul Cassell
Bradley
J.
Edwards
Activity in case 9:08-cv-80994-
KAM Jane Doe No. 6 v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
101
EFTA00310148
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Motion to Strike
to the discovery of the admissible evidence;
protected by privacy rights
01925
08/26/2009
Jacquie Johnson
Bradley
J.
Edwards
Adriana Surveillance/Interview
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01928-01929
08/03/2009
Jacquie Johnson
Bradley
J.
Edwards
Alfredo Rodriguez address
work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01930
09/05/2009
Bradley
J.
Edwards
William J. Berger
Client info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01940
09/10/2009
Russell Adler
Bradley
J.
Edwards
Witness Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01944-01952
04/10/2009
Russell Adler
Bradley
J.
Edwards
Epstein assets
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01969
05/04/2009
Susan K. Stirling
Bradley
J.
Edwards
Call from sources of information
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01971-01972
05/13/2009
Attorneys at RRA
Bradley
J.
Edwards
Cassell Draft
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01973-01974
07/23/2009
Mike Fisten
Bradley
J.
Edwards
CMA
vs.
Epstein
—
new
investigator info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
102
EFTA00310149
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
RATES
DATE
12
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
01975
08/10/2009
Jacquie Johnson
Bradley
J.
Edwards
Computers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01976-01978
07/06/2009
Bradley
J.
Edwards
Paul Cassell
Conference Call
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01981-01982
04/01/2009
Bradley
J.
Edwards
Russell Adler
Conflict check for Brad Edwards
files
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01990
05/14/2009
Bradley
J.
Edwards
Paul Cassell
Consolidation order
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02000
09/03/2009
Jacquie Johnson
Bradley
J.
Edwards
Dates for Subpoena — Epstein's
housekeepers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02001-02003
10/09/2009
Jacquie Johnson
Bradley
J.
Edwards
David Copperfield
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02009-2010
09/09/2009
Pasquale Diaz
Bradley
J.
Edwards
Deposition of Bill Riley
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02017-02018
05/18/2009
William J. Berger
Bradley
J.
Edwards
Doe v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
103
EFTA00310150
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
y_Q
FROM
DESCRIPTION
OBJECTION
02023
05/14/2009
Attorneys at RRA
Bradley
J.
Edwards
Sid's deposition of Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02045.02046
09/04/2009
Attorneys at RRA
Bradley
J.
Edwards
E.W., L.M. Doe v. Epstein — Letter
from Bob Critton
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02049.02053
09/04/2009
Paul Cassell
Bradley
J.
Edwards
E.W., L.M. Doe v. Epstein — Letter
from Bob Critton
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02063-02064
05/19/2009
William J. Berger
Bradley
J.
Edwards
Epstein — Confirming AT&T Dial in
Telephone
Conference
for
Monday , 6/8/09 at 2:00 p.m.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02089.02090
09/17/2009
Paul Cassell
Bradley
J.
Edwards
Epstein hearing
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02091-02092
06/16/2009
Attorneys at RRA
Bradley
J.
Edwards
Epstein
—
Monthly
Call
in
Telephone Conference
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02106-02108
04/29/2009
Susan K. Stirling
Bradley
J.
Edwards
Epstein — Telephone Conference
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02109
05/13/2009
Wayne Black
Bradley
J.
Edwards
Epstein info — List of Plaintiff
lawyers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02110.02111
09/15/2009
Bradley
J.
Jacquie Johnson
Epstein - Cancelling depositions Work
product;
attorney/client
privilege;
104
EFTA00310151
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATES
DATE
12
FROM
DESCRIPTION
OBJECTION
Edwards
in New York for the following
week
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02112.02116
09/10/2009
Bradley
J.
Edwards
Jacquie Johnson
Epstein — Yearbook picture of
Epstein rape victims
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02117-02118
10/23/2009
Jacquie Johnson
Bradley
J.
Edwards
Epstein (AUSA)
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02119-02121
09/08/2009
Beth
S.
Williamson
Bradley
J.
Edwards
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02130-02137
05/26/2009
Susan K. Stirling
Bradley
J.
Edwards
Epstein cases- depositions in
federal cases
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02138-02139
08/04/2009
Jacquie Johnson
Bradley
J.
Edwards
Epstein depo — New York
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02143-02146
09/28/2009
Jacquie Johnson
Bradley
J.
Edwards
Epstein Depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02229
05/05/2009
Paul Cassell
Bradley
J.
Edwards
Epstein Depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02236-02337
05/20/2009
Attorneys at RRA
Bradley
J.
Edwards
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
105
EFTA00310152
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
02256-02257
07/22/2009
Jacquie Johnson
Bradley
J.
Edwards
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02260-02261
07/22/2009
Nora Batian
Bradley
J.
Edwards
Epstein — coordinating meetings
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02263-02265
07/23/2009
Attorneys at RRA
Nora Batian
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02266
07/30/2009
Jacquie Johnson
Bradley
J.
Edwards
Epstein — Video Deposition of S.K.
in NY
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02273.02276
09/18/2009
Jacquie Johnson
Bradley
J.
Edwards
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02278-02279
07/23/2009
Priscila
A.
Nascimento
Nora Batian
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02284-02855
05/11/2009
Susan K. Stirling
Bradley
J.
Edwards
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01769
10/30/2009
Mike Fisten
Bradley
J.
Edwards
Barbara Berg info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
106
EFTA00310153
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
AT
m
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
01780
09/14/2009
Bradley
J.
Edwards
William J. Berger
Discussion of belief that Epstein
is transferring assets to avoid
judgments
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01787.01788
09/04/2009
Ken Jenne
Bradley
J.
Edwards
1. Accountants 2. Motion for IME
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01799.01801
10/14/2009
Bradley
J.
Edwards
Paul Cassell
Activity in case 9:08-cv-80119-
Moe
v. Epstein Notification
of ninety days expiring
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01804-01805
09/04/2009
Beth
S.
Williamson
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
Doe v. Epstein — Order on
motion for Medical Exam
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01806-01807
09/09/2009
Paul Cassell
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
oe v. Epstein — Motion for
protective order
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01808-01809
09/10/2009
Paul Cassell
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
Doe v. Epstein - Order on
otion for Extension of Time to
File Response/Reply/Answer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01810-01816
09/09/2009
Attorneys at RRA
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
Doe v. Epstein — Response
to Motion
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01817.01818
06/11/2009
Paul Cassell
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
■
Doe v. Epstein — Response
to motion
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
107
EFTA00310154
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
N
FROM
DESCRIPTION
OBJECTION
01840-01841
07/16/2009
Paul Cassell
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
KAM Doe v. Epstein — Order on
Motion to Stay
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01867-01868
09/28/2009
Paul Cassell
Bradley
J.
Edwards
Activity in case 9:08-cv-80119-
KAM Doe v. Epstein — Notice
(Other)
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03662-03663
08/10/2009
Attorneys at RRA
Bradley
J.
Edwards
Meeting with clients
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03664.03668
09/18/2009
Paul Cassell
Bradley
J.
Edwards
Litigation
strategy
and
preparation
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08166.08168
10/28/2009
Paul Cassell
Bradley
J.
Edwards
Weds filing
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08169-08170
08/06/2009
Bradley
J.
Edwards
Jacquie Johnson
Wexner deposition for 14th
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08190-08196
04/07/2009
Bradley
J.
Edwards
Paul Cassell
Motion to unseal/Motion to stay
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08265-08300
09/04/2009
Attorneys at RRA
Bradley
J.
Edwards
Witness Information
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08377-08378
10/02/2009
Bradley
J. Paul Cassell
Zorro Trust research info.
Work
product;
attorney/client
privilege;
108
EFTA00310155
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
L
Edwards
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08381-08383
09/06/2009
Bradley
J.
Edwards
Paul Cassell
Epstein — complaint
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08384.08388
04/13/2009
Bradley
J.
Edwards
Paul Cassell
Epstein fraudulent transfer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08389-08397
05/14/2009
Bradley
J.
Edwards
Paul Cassell
Revisited sexual history memo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08401
07/22/2009
Bradley
J.
Edwards
Paul Cassell
Reply memo on asset transfers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08409-08410
08/01/2009
Bradley
J.
Edwards
Cara L. Holmes
Rodriguez Deposition
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08421
06/02/2009
Bradley
J.
Edwards
William J. Berger
Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08423-08425
10/09/2009
Bradley
J.
Edwards
Mike Fisten
Subpoena info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08426
08/10/2009
Bradley
J.
Edwards
Mike Fisten
Synopsis
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
109
EFTA00310156
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPagli
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08441-08446
10/05/2009
Attorneys at RRA
William J. Berger
Trial Prep
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03672-03673
06/26/2009
Wayne Black
Bradley Edwards
Brunel information
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03706-03718
08/05/2009
Bradley Edwards
Paul Cassell
Cf. Response to Motion to File
Epstein Affidavit
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03737
08/25/2009
Bradley Edwards
Cara Holmes
Computers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03746.03753
08/02/2009
Bradley Edwards
William Berger
Computers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02335-02338
05/08/2009
William Berger
Bradley Edwards
Litigation strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02360-02361
06/09/2009
Susan Stirling
Bradley Edwards
Hearing to Un-seal- Criminal Plea
Transcript
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02368-02373
10/14/2009
Bradley Edwards
Jacquie Johnson
Igor Zinoview depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
110
EFTA00310157
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
02376.02392
10/14/2009
Mike Fisten
Bradley Edwards
Igor Zinoview depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02401.02410
05/08/2009
William Berger
Bradley Edwards
Jane Doe II v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02414-02419
05/12/2009
Attorneys at RRA
Bradley Edwards
Jane Doe II v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03669-03670
10/08/2009
Carolyn Edwards
Bradley Edwards
Epstein house arrest monitor
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02288.02289
05/26/2009
Susan Stirling
Bradley Edwards
Motion date
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02292-02293
05/19/2009
Dr. Lee (Expert)
Bradley Edwards
Pimp and His Game
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02304-02308
09/17/2009
Bradley Edwards
Jacquie Johnson
Forensics/Investigations
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02313-02316
07/01/2009
Bradley Edwards
William Berger
Confidential Agreement
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
111
EFTA00310158
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
02331-02334
05/08/2009
Susan Stirling
Bradley Edwards
Critton order Transcript
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02173
09/04/2009
Attorneys at RRA
Mike Fisten
Epstein Juan Alessi
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02187
07/26/2009
Bradley Edwards
Wayne Black
Epstein matter
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02195.02197
09/17/2009
Jacquie Johnson
Bradley Edwards
Epstein Order
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02199-02203
09/18/2009
Jacquie Johnson
Bradley Edwards
Epstein Order
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02211-02214
07/01/2009
Paul Cassell
Bradley Edwards
Epstein v. State of Florida-
Emergency Petition for Writ of
Certiorari
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02224
07/28/2009
Jacquie Johnson
Bradley Edwards
Witness of Epstein rapes from
Switzerland
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10787-10799
10/19/2009
Bradley Edwards
Jacquie Johnson
Witness List
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10901-10902
05/11/2009
Bradley Edwards
William Berger
RICO Enterprise
Work
product
attorney/client
privilege;
112
EFTA00310159
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10904.10905
05/11/2009
Attorneys at RRA
Bradley Edwards
RICO Enterprise
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10908-10909
05/11/2009
Attorneys at RRA
Bradley Edwards
RICO Enterprise
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10912-10913
05/11/2009
Attorneys at RRA
Bradley Edwards
RICO Enterprise
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10955-10963
06/01/2009
Bradley Edwards
William Berger
Plaintiffs Witness List
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10979-10981
06/03/2009
Bradley Edwards
Wayne Black
Serve Subpoenas
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11022.11025
06/26/2009
Bradley Edwards
Wayne Black
Info on 2 MC2 Workers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11036.11037
07/21/2009
Bradley Edwards
Wayne Black
Serve Subpoenas
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11039-11071
07/21/2009
Bradley Edwards
Wayne Black
Retainer from the Firm
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
113
EFTA00310160
Privilege bag— Dated 2-23-2011
Farmer, Jaffe, Weissine, Edwards. Fistos & Lehrman
BATES
DATE
m
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
11083-11084
09/04/2009
Attorneys at RRA
Bradley Edwards
Witness info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11105-11110
09/09/2009
Jacquie Johnson
Bradley Edwards
Disseminate letter from Wexner
attorney
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11137-11139
10/03/2009
Paul Cassell
Bradley Edwards
Zorro Trust research info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11143-11146
10/04/2009
William Berger
Bradley Edwards
11/28 Discovery Cutoff
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11155-11156
10/18/2009
Attorneys at RRA
Bradley Edwards
New Property
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11175-11183
04/27/2009
Marc Nurik
Bradley Edwards
Epstein Case info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11196-11197
05/28/2009
Susan Stirling
Bradley Edwards
Jail Visitors
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11205.11207
05/28/2009
Paul Cassell
Bradley Edwards
Litigation strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
114
EFTA00310161
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
11215
06/01/2009
William Berger
Bradley Edwards
Activity in Case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11238-11239
06/03/2009
Wayne Black
Bradley Edwards
Depo Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11246-11247
06/22/2009
Wayne Black
Bradley Edwards
Epstein Article
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11251-11254
06/23/2009
Wayne Black
Bradley Edwards
Info on 2 MC2 workers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11267-11268
06/30/2009
William Berger
Bradley Edwards
Witness List revised
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11282.11315
07/18/2009
Wayne Black
Bradley Edwards
Confidential Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11326-11331
08/03/2009
Jacquie Johnson
Bradley Edwards
Donald Trump depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11337-11339
08/04/2009
Mike Fisten
Bradley Edwards
Confidential Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
115
EFTA00310162
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
11359-11362
08/10/2009
Jacquie Johnson
Bradley Edwards
Epstein depos
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11366.11371
08/11/2009
Jacquie Johnson
Bradley Edwards
Trump depo info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11377-11379
08/12/2009
Jacquie Johnson
Bradley Edwards
Issuing Subpoenas
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11390-11395
08/17/2009
Jacquie Johnson
Bradley Edwards
Witness depos
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11400-11415
08/18/2009
Jacquie Johnson
Bradley Edwards
Subpoenas for pilots
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11420-11426
08/24/2009
Attorneys at RRA
Bradley Edwards
Serving Alan Dershowitz
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11428-11429
08/26/2009
Attorneys at RRA
Bradley Edwards
Witness info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11568
10/07/2009
Paul Cassell
Bradley Edwards
Meeting with Leslie Wexner
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11587
10/23/2009
Paul Cassell
Bradley Edwards
Visoski Depo
Work
product;
attorney/client
privilege;
116
EFTA00310163
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11861.11865
10/23/2009
Attorneys at RRA
Bradley Edwards
Witness List
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11870-11871
08/24/2009
Attorneys at RRA
Bradley Edwards
Epstein info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11874
08/24/2009
Jacquie Johnson
Bradley Edwards
Confidential info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11876
08/24/2009
Attorneys at RRA
Ken Jenne
Confidential Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11967.11972
10/29/2009
Cara Holmes
Jacquie Johnson
Subpoenas
for
Epstein's
Attorneys
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08072-08075
07/22/2009
Paul Cassell
Bradley Edwards
Total counts fo=
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08090-08091
10/05/2009
William Berger
Bradley Edwards
Trial Prep
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08114.08117
08/18/2009
Pat Diaz
Bradley Edwards
Updated Witness List
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
117
EFTA00310164
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08157-08159
06/03/2009
Carla Martinez
Bradley Edwards
Vanity Fair
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08499-08501
08/24/2009
Attorneys at RRA
Bradley Edwards
Witness List
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10063-10068
08/03/2009
Bradley Edwards
Mike Fisten
Confidential Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10090-10091
08/31/2009
Attorneys at RRA
Jacquie Johnson
Witness Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10103-10104
08/27/2009
Attorneys at RRA
Ken Jenne
Witness Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10106-10137
08/24/2009
Attorneys at RRA
Ken Jenne
Meetings/ Confidential Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
12569
07/30/2009
Carl Linder
Bradley Edwards
Epstein
Sex
Abuse
Litigation
Forum
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15827-15837
07/22/2009
Jacquie Johnson
Bradley Edwards
Retainer for Investigator
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
118
EFTA00310165
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
15820-15822
10/29/2009
Jacquie Johnson
Cara Holmes
Subpoenas
for
Epstein's
Attorneys
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15401-15412
09/09/2009
Jacquie Johnson
Bradley Edwards
Disseminate
the letter
from
wexner any
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15356-15359
08/26/2009
Attorneys at RRA
Bradley Edwards
Witness info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
14934-14950
07/22/2009
Jacquie Johnson
Bradley Edwards
Investigator Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
13413.13414
08/06/2009
Denis Kleinfeld
Bradley Edwards
Epstein information
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
13908-13911
08/24/2009
Attorneys at RRA
Mike Fisten
Meeting info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10595-10597
09/29/2009
Bradley Edwards
Jacquie Johnson
Subpoena for
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10621-10624
10/02/2009
Bradley Edwards
Jacquie Johnson
Meeting with Wexner atty
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
119
EFTA00310166
Privilege Log- Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
10633-10638
10/05/2009
Bradley Edwards
William Berger
Trial Prep
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10681-10692
10/07/2009
Jacquie Johnson
Mike Fisten
Depositions
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10777-10786
10/16/2009
Bradley Edwards
Paul Cassell
New
Evidence
of
Epstein
Fraudulent Transfers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04094.04100
04/07/2009
Bradley Edwards
Paul Cassell
Draft Motion to Strike
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02915
10/03/2009
Attorneys at RRA
Mike Fisten
Finances
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02971
10/14/2009
Jacquie Johnson
Bradley Edwards
Larry Visoski depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02976
09/09/2009
Jacquie Johnson
Bradley Edwards
Disseminate
the letter from
wexner
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02995
06/24/2009
Bradley Edwards
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10172-10178
08/12/2009
Bradley Edwards
Jacquie Johnson
Trump Depo
Work
product;
attorney/client
privilege;
120
EFTA00310167
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10193
08/11/2009
Bradley Edwards
Jacquie Johnson
Trump Depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10255
09/09/2009
Bradley Edwards
William Berger
Depo of Alan Dershowitz
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
10259-10263
09/09/2009
Attorneys of RRA
Jacquie Johnson
Cooperfield Service
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03876-03877
10/26/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03879.03884
07/13/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03886.03891
07/13/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy ri hts
03905.03920
09/08/2009
William Berger
Bradley Edwards
Doe v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03937
08/17/2009
Carolyn Edwards
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
121
EFTA00310168
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
04005-04011
05/13/2009
Bradley Edwards
William Berger
Discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04070-04093
04/07/2009
Bradley Edwards
Paul Cassell
Motion to Strike
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03754
07/08/2009
Paul Cassell
Bradley Edwards
Conference Call
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03848-03858
09/09/2009
Bradley Edwards
Jacquie Johnson
Cooperfield Service
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03642-03643
09/04/2009
Paul Cassell
Bradley Edwards
1. Accounts/ 2. Motion for IME
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03657-03661
09/04/2009
Attorneys at RRA
Paul Cassell
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02475
06/15/2009
Susan Stirling
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02494-02515
09/20/2009
Bradley Edwards
Pat Diaz
Mark Epstein Info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
122
EFTA00310169
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
m
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
02520-02543
06/06/2009
Bradley Edwards
Paul Cassell
Memo of Assest Transfers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02548-02553
08/03/2009
Beth Williamson
Bradley Edwards
Federal Subpoena
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02560-02565
07/31/2009
Bradley Edwards
Jacquie Johnson
Federal Subpoena
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02568-02570
10/13/2009
Jacquie Johnson
Bradley Edwards
New Times Article
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02578-02583
05/28/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02619-02622
09/09/2009
Jacquie Johnson
Bradley Edwards
New client Retainer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02633-02646
05/01/2009
Paul Cassell
Bradley Edwards
Response
to
Motion
to
Consolidate + Cassell strategy
Memo for Jay
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07959.07964
09/24/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
123
EFTA00310170
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
07967.07975
09/22/2009
Jacquie Johnson
Mike Fisten
Subpoena on Epstein case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07979-08000
08/18/2009
Bradley Edwards
Jacquie Johnson
Subpoenas for Pilots
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07735.07736
07/24/2009
Bradley Edwards
Jacquie Johnson
Releases for therapist
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07643-07645
09/09/2009
Bradley Edwards
Jacquie Johnson
New client Retainer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07698-07706
09/06/2009
Paul Cassell
Bradley Edwards
Answer to the Complaint
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07620-07632
08/14/2009
Jacquie Johnson
Bradley Edwards
Review of "Notice of Taking Depo
— RC — Bear Sterns"
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07635-07636
10/15/2009
Mike Fisten
Bradley Edwards
Questions
from
forensic
accountant
detecting
Epstein
fraudulent transfers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07617-07618
07/13/2009
Paul Cassell
Bradley Edwards
Epstein strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07550-07589
10/30/2009
Bradley Edwards
Paul Cassell
Motion to Supplement with the Work
product;
attorney/client
privilege;
124
EFTA00310171
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
Visoski depo
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07595-07604
05/20/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07616
07/22/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07530-07549
06/11/2009
Bradley Edwards
Susan Stirling
Overtime
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07470-07507
07/09/2009
Paul Cassell
Bradley Edwards
Motion to Compel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07447.07469
10/13/2009
Attorneys at RRA
Russell Adler
New Times Article on epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07444-07446
05/01/2009
Bradley Edwards
Paul Cassell
Response
to
Motion
to
Consolidate + Cassell Strategy
Memo for Jay
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07440
10/18/2009
Attorneys at RRA
Bradley Edwards
New Trump Property
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07436
04/11/2009
Russell Adler
Bradley Edwards
New cases
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
125
EFTA00310172
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATES
DATE
12
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
07424-07431
09/26/2009
Bradley Edwards
Paul Cassell
Need Depo Transcript
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07412-07423
04/08/2009
Bradley Edwards
Paul Cassell
Draft Motion to Strike
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07403-07411
04/08/2009
Paul Cassell
Bradley Edwards
Draft Motion to Strike
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07394.07402
07/10/2009
Bradley Edwards
Paul Cassell
Multiple 2255 Counts
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07386-07392
05/28/2009
William Berger
Bradley Edwards
Motion to Unseal
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07378-07385
04/07/2009
Bradley Edwards
Paul Cassell
Motion to Unseal
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07370-07377
04/07/2009
Paul Cassell
Bradley Edwards
Motion to Unseal
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07354-07369
10/28/2009
Beth Williamson
Bradley Edwards
Motion to Protect e d depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
126
EFTA00310173
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
07346
10/28/2009
Beth Williamson
Bradley Edwards
Motion to protect 2nd depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07337
10/28/2009
Bradley Edwards
Jacquie Johnson
Motion to protect 2nd depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07328
10/28/2009
Bradley Edwards
Beth Williamson
Motion to protect e d depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07319
10/28/2009
Bradley Edwards
Jacquie Johnson
Motion to protect r d depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07313-07318
04/10/2009
Paul Cassell
Bradley Edwards
Motion to Compel — Photograph
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07287.07301
07/08/2009
Bradley Edwards
Paul Cassell
Motion to Compel — File this
week?
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07252-07278
09/08/2009
Bradley Edwards
Paul Cassell
Motion for IME + Accountant
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07247-07251
09/08/2009
Paul Cassell
Bradley Edwards
Motion for IME + Accountant
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
127
EFTA00310174
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
PATES
DATE
1.Q
FROM
DESCRIPTION
OBJECTION
07230.07233
06/08/2009
Paul Cassell
Bradley Edwards
Memo on Asset Transfers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07157-07158
09/29/2009
Russell Adler
Bradley Edwards
RE: Mark Schwartz
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07128-07141
07/08/2009
Paul Cassell
Bradley Edwards
Motion for bond asset transfer
and memo final
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07094-07098
09/14/2009
Paul Cassell
Bradley Edwards
Letter to Critton RE: Motions to
Compel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07025.07027
10/29/2009
Bradley Edwards
Paul Cassell
v. Epstein —
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07099-07106
09/14/2009
Bradley Edwards
Paul Cassell
Letter to Critton RE: Motions to
Compel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07071-07078
07/23/2009
Paul Cassell
Bradley Edwards Ills
Son's B-day
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07066-07070
07/23/2009
Bradley Edwards
Paul Cassell
L.M.'s Son's B-day
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07015.07016
10/13/2009
Bradley Edwards
Paul Cassell
Evidence
of
Asset
transfers Work
product;
attorney/client
privilege;
128
EFTA00310175
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DAT€
TO
FROM
DESC • IPTION
OBJECTION
and/or liquidations
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07019-07024
10/29/2009
Bradley Edwards
Paul Cassell
v. Epstein — I'm on
it
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06837-06839
04/08/2009
Beth Williamson
Bradley Edwards
Jane Doe change of address
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06826-06836
04/08/2009
Bradley Edwards
Beth Williamson
Jane Doe change of address
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06823-06825
04/08/2009
Bradley Edwards
Beth Williamson
Jane Doe change of address
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06813-06816
07/02/2009
Paul Cassell
Bradley Edwards
Doe
v.
Epstein Motion for
Extension
of
Time
to
File
Response/Reply/Answer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06808-06810
09/13/2009
Bradley Edwards
Paul Cassell
"Is Jeffrey Epstein the new
Madoff — Running a giant Ponzi
schemer'
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06804-06805
09/13/2009
Paul Cassell
Bradley Edwards
"Is Jeffrey Epstein the new
Madoff — Running a giant Ponzi
schemer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06794
10/23/2009
Mike Fisten
Bradley Edwards
Interesting Web Site
Work
product;
attorney/client
privilege;
129
EFTA00310176
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATES
DATE
12
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06800-06803
09/06/2009
Paul Cassell
Bradley Edwards
RE: 1. Accountants 2. Motion for
IME
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06761-06762
08/19/2009
Attorneys at RRA
Paul Cassell
IME Rules
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06767-06769
09/10/2009
Bradley Edwards
Jacquie Johnson
IME's
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06782.06787
04/10/2009
Paul Cassell
Bradley Edwards
Confidential Detailed Strategy
Memo on Asset Protection Issues
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06744-06747
05/01/2009
Paul Cassell
Bradley Edwards
Depo of Jeffrey Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06736-06739
05/01/2009
Bradley Edwards
Paul Cassell
Asset Protection Issue
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06709-06710
10/14/2009
Bradley Edwards
Mike Fisten
Igor Zinoview depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
130
EFTA00310177
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATES
DATE
12
FROM
DESCRIPTION
OBJECTION
06691-06696
07/09/2009
Bradley Edwards
Paul Cassell
How many 2255 claims?
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06683.06686
07/08/2009
Paul Cassell
Bradley Edwards
Hiding Assets
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06654
07/24/2009
Paul Cassell
Bradley Edwards
Secretary Contact info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06599.06600
07/08/2009
Bradley Edwards
Paul Cassell
Hiding Assets
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06574-06590
04/07/2009
Paul Cassell
Bradley Edwards
Motion to Unseal
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06567.06570
07/09/2009
Bradley Edwards
Paul Cassell
Motion to Compel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06558-06561
07/09/2009
Paul Cassell
Bradley Edwards
Motion to Compel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
131
EFTA00310178
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissine, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
06554-06557
05/14/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06549.06553
05/14/2009
Paul Cassell
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06540-06541
09/21/2009
Bradley Edwards
Mike Fisten
Info on Maxwell
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06537
10/23/2009
Bradley Edwards
Paul Cassell
Doe v. Jeffrey Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06529-06530
10/23/2009
Paul Cassell
Bradley Edwards
Doe v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06496.06505
10/20/2009
Bradley Edwards
Paul Cassell
Visoski depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06177-06181
09/25/2009
William Berger
Bradley Edwards
Financial discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06149-06153
07/10/2009
Paul Cassell
Bradley Edwards
Federal
First
Amendment
Complaint
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
132
EFTA00310179
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman
BATES
DATE
LQ
FROM
DESCRIPTION
OBJECTION
protected by privacy rights
06118-06146
09/15/2009
Seth Lehrman
Bradley Edwards
Farnsworth v. Macys case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06113-06117
07/14/2009
Bradley Edwards
Richard Wolfe
Facebook/Myspace
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06106-06112
05/19/2009
Amy Swan
William Berger
Expert Witness
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06091
08/04/2009
William Berger
Paul Cassell
EW and LM v. Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06001-06011
07/18/2009
Paul Cassell
Bradley Edwards
Epstein's Address and Position of
Critton on Motion
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05996
04/08/2009
Bradley Edwards
Beth Williamson
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05998-06000
09/17/2009
Jacquie Johnson
Bradley Edwards
Epstein: Forensics/Investigations
INVOICE
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05992
04/19/2009
Bradley Edwards
Marc Nurik
Litigation Strategy
Work
product;
attorney/client
privilege;
133
EFTA00310180
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05968
10/17/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05944-05947
05/01/2009
William Berger
Bradley Edwards
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05927
09/18/2009
Bradley Edwards
Amy Swan
Ryan Hall Psychiatrist
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05931-05932
07/27/2009
Amy Swan
Bradley Edwards
Client's Cell Phone Number
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05919-05920
07/28/2009
Bradley Edwards
Amy Swan
Client's Cell Phone Number
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05915
04/22/2009
Bradley Edwards
Marc Nurik
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05911
05/28/2009
Bradley Edwards
William Berger
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
134
EFTA00310181
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
MIL
TO
FROM
DESCRIPTION
OBJECTION
05890
07/27/2009
Bradley Edwards
Amy Swan
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05893-05894
07/27/2009
Bradley Edwards
Amy Swan
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05898-05899
07/28/2009
Bradley Edwards
Amy Swan
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05885
09/15/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05874.05879
07/23/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05868
08/03/2009
Bradley Edwards
Ken Jenne
Epstein Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05865
09/10/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05860-05861
09/10/2009
Bradley Edwards
Maribel Matiska
Litigation strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
135
EFTA00310182
Privilege Log — Dated 2-23-2011
Farmer. Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
12
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05845
07/24/2009
Bradley Edwards
Ken Jenne
Plane Tail Numbers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05811
06/09/2009
Bradley Edwards
Susan Stirling
Witness Numbers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05813
08/15/2009
Bradley Edwards
Ken Jenne
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05748.05749
08/11/2009
Bradley Edwards
Jacquie Johnson
Litigation Strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05711
05/11/2009
Attorneys at RRA
Bradley Edwards
Subpoena Clinton
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05701.05704
04/20/2009
Bradley Edwards
Russell Adler
Epstein strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05687
08/21/2009
Bradley Edwards
Marc Nurik
Alfredo Rodriguez
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05690-05691
05/11/2009
Bradley Edwards
Susan Stirling
Motion to Unseal
Work
product;
attorney/client
privilege;
136
EFTA00310183
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05680-05682
05/11/2009
Bradley Edwards
William Berger
Subpoena Clinton
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05676
08/24/2009
Attorneys at RRA
Mike Fisten
Topics for Meeting
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05648
07/23/2009
Attorneys at RRA
Gary Farmer
Assemble
Epstein
Litigation
meeting
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05629
08/03/2009
Bradley Edwards
Mike Fisten
Law Enforcement cannot release
juvenile reports
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05621-05622
09/18/2009
Amy Swan
Bradley Edwards
Preparing Motion to take an IME
of Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05610-05612
04/27/2009
Susan Stirling
Bradley Edwards
Request for Copies
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05588-05590
08/24/2009
Attorneys at RRA
Bradley Edwards
Travel restrictions
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
137
EFTA00310184
Privilege Log — Dated 2-23-2011
Farmer. Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
QAI1
IQ
FROM
DESCRIPTION
OBJECTION
05575-05576
08/21/2009
Marc Nurik
Bradley Edwards
Alfredo Rodriguez
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05582
09/11/2009
Bradley Edwards
Mike Fisten
Epstein strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05569-05570
08/17/2009
Marc Nurik
Bradley Edwards
Legal Opinion
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05556-05558
08/14/2009
Attorneys at RRA
Bradley Edwards
Communication with legal expert
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05537
07/30/2009
Jacquie Johnson
Bradley Edwards
No objections
from
defense
counsel regarding depo for
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05534
07/24/2009
Ken Jenne
Bradley Edwards
Flight logs for Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05518
07/22/2009
Attorneys at RRA
Bradley Edwards
Assemble
Epstein
Litigation
meeting
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05512-05513
07/23/2009
Priscila
Nascimento
Nora Batian
Assemble
Epstein
Litigation
meeting
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
138
EFTA00310185
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATES
DATE
lig
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05502-05507
07/22/2009
Jacquie Johnson
Bradley Edwards
Wayne Black's email
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05475
04/21/2009
Marc Nurik
Bradley Edwards
Call with Chris Hanson from
dateline
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05471-05472
08/14/2009
Marc Nurik
William Berger
Legal expert regarding legal issue
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05447
08/14/2009
Marc Nurik
William Berger
Communication with legal expert
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05420-05423
05/20/2009
William Berger
Bradley Edwards
Research on cases saying a judge
can postpone one party's depo
until the other is completed
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05409-05412
08/17/2009
Bradley Edwards
Marc Nurik
Legal
opinion
regarding
discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05403-05405
04/27/2009
Marc Nurik
Bradley Edwards
Jeffrey Epstein Wikipedia page
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
139
EFTA00310186
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
PESCRIPTION
OBJECTION
05399
10/17/2009
William Berger
Bradley Edwards
Proposal for settlement
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05399
10/17/2009
William Berger
Bradley Edwards
Proposal for settlement
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05271-05272
07/22/2009
Bradley Edwards
Jacquie Johnson
Depo Dates to take SR, LM, and
CW
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05259-05260
07/22/2009
Bradley Edwards
Jacquie Johnson
Investigator retainer
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05238
07/14/2009
Bradley Edwards
William Berger
File a request to produce
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05240-05241
08/24/2009
Attorneys at RRA
Ken Jenne
Judge's order on the Epstein
probation
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05197-05199
08/24/2009
Attorneys at RRA
Ken Jenne
Michael Reiter info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
140
EFTA00310187
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05155-05156
04/20/2009
Russell Adler
Bradley Edwards
Set Epstein's depo duces tecum
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05159-05160
05/28/2009
William Berger
Bradley Edwards
Right to move to reconsider all
rulings
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05149-05150
05/27/2009
Susan Stirling
Bradley Edwards
Epstein
filed
a
motion
to
continue the trial
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05153
08/24/2009
Bradley Edwards
Mike Fisten
Epstein traveling
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05146-05147
05/26/2009
Paul Cassell
Bradley Edwards
The response to the motion to
continue is due 6/8
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05137-05144
05/20/2009
Attorneys at RRA
Russell Adler
Epstein litigation strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05133-05136
05/11/2009
William Berger
Bradley Edwards
Subpoena Clinton and others on
Sid Garcia's witness list
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01749.01751
10/28/2009
Bradley Edwards
Phaedra Xanthos
Final
affidavit
from
forensic
accountant
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
141
EFTA00310188
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
PATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05125-05132
05/05/2009
William Berger
Bradley Edwards
Response to motion to compel all
the sex information of his clients
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05115-05117
04/27/2009
Bradley Edwards
Susan Stirling
Epstein depos
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01699
09/15/2009
Jacquie Johnson
Bradley Edwards
depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05120-05121
05/04/2009
William Berger
Bradley Edwards
Reporter asking how the depo of
Epstein went
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05095.05098
07/01/2009
Bradley Edwards
Paul Cassell
Epstein v. State of Florida —
Emergency Petition for Writ of
Certiorari; Emergency Motion to
Review Denial of Stay
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01694
10/17/2009
Jacquie Johnson
Bradley Edwards
PFS
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05066-05067
05/06/2009
Marc Nurik
William Berger
Epstein sealed records and TV
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
142
EFTA00310189
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES
DATE
m
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05054-05065
08/18/2009
Attorneys at RRA
Mike Fisten
Epstein Potential witnesses
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05049-05053
08/18/2009
Mike Fisten
Bradley Edwards
Subpoenas
for
potential
witnesses
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04957-04964
09/04/2009
Bradley Edwards
Scott Goldstein
Juan
Alessi
statement
and
burglary report
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04952-04953
10/28/2009
Attorneys at RRA
Paul Cassell
Epstein
injunction
filing
—
accountant affidavit will be sent
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04955-04956
09/03/2009
Attorneys at RRA
Bradley Edwards
Epstein Invoice
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04916-04920
09/11/2009
Elizabeth Villar
Bradley Edwards
Updates on # of victims, billing
amounts, etc.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04899
09/10/2009
Bradley Edwards
Jacquie Johnson
Epstein Discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
143
EFTA00310190
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
04893-04896
09/10/2009
Jacquie Johnson
Bradley Edwards
Epstein Discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04890
09/10/2009
Jacquie Johnson
Bradley Edwards
Epstein Discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04884-04885
09/10/2009
Bradley Edwards
Jacquie Johnson
Epstein Discovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01469
07/17/2009
Ken Jenne
Bradley Edwards
Discussions about the Epstein
case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04745.04747
08/04/2009
Bradley Edwards
Jacquie Johnson
Epstein depo in New York
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04738.04744
08/25/2009
Bradley Edwards
Paul Cassell
Hearing regarding the Epstein
computers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04660
10/22/2009
Bradley Edwards
Marc Nurik
Epstein AUSA — Attorneys Fees
Work
product;
attorney/client
privilege;
irrelevant and not reasonably cakulated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04642.04646
09/11/2009
Bradley Edwards
Beth Williamson
Discussions
about
Brad's
recovery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
144
EFTA00310191
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
04607-04617
09/11/2009
Jacquie Johnson
Bradley Edwards
Holding Fed Subs until we get
response on form
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04526-04535
10/17/2009
Bradley Edwards
Paul Cassell
Two ideas regarding strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04488-04490
07/18/2009
Bradley Edwards
Paul Cassell
Taking the 5th
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01362
09/11/2009
Elizabeth Villar
Bradley Edwards
Getting the forensic aspect off
the ground
—epstein's
asset
transfers
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04481-04487
08/18/2009
Paul Cassell
Bradley Edwards
Epstein Subpoena
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05465-05467
06/26/2009
Wayne Black
Bradley Edwards
Subpoenas for trial
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05470
07/11/2009
Bradley Edwards
Wayne Black
Flight Logs
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05496-05497
08/10/2009
Bradley Edwards
Alfredo
Phone Numbers
Work
product;
attorney/client
privilege;
145
EFTA00310192
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
!SATES
DATE
12
FROM
DESCRIPTION
OBJECTION
Rodriguez
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05501
07/21/2009
Wayne Black
Bradley Edwards
Litigation strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05524-05533
07/23/2009
Wayne Black
Bradley Edwards
Addresses for people involved in
the case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05541
07/31/2O09
Carolyn Edwards
Bradley Edwards
All depos in jane doe's case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05635
10/22/2009
Pat Diaz
Bradley Edwards
New developments that require
your expertise
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights')
146
EFTA00310193
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES
DAM
TO
FROM
DESCRIPTION
OBJECTION
05640
10/29/2009
Pat 0iaz
Bradley Edwards
New Epstein victim
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05652-05653
04/01/2009
Bradley Edwards
Carolyn Edwards
personal discussion
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05671
10/22/2009
Bradley Edwards
Pat Diaz
Litigation strategy
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05696
05/11/2009
Bradley Edwards
Wayne Black
Phone number for one of the
other
girls on
the
list of
prospective clients
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05815-05816
04/01/2009
Carolyn Edwards
Bradley Edwards
Taking the depos of everyone
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05820-05821
07/23/2009
Bradley Edwards
Wayne Black
Dates for depos of all witnesses
in the case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
147
EFTA00310194
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
i2
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
05824-05825
07/23/2009
Bradley Edwards
Wayne Black
Paula Heil
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05828-05829
07/23/2009
Bradley Edwards
Wayne Black
Dates for depos of all witnesses
in the case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05833-05835
07/23/2009
Bradley Edwards
Wayne Black
FBI has original flight logs and
they interviewed pilots
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05839-05841
07/23/2009
Bradley Edwards
Wayne Black
Copies of the flight logs
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05869-05870
04/01/2009
Carolyn Edwards
Bradley Edwards
Personal convo between Brad
and Mom
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05913-05914
04/01/2009
Carolyn Edwards
Bradley Edwards
Personal convo between Brad
and Mom
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
148
EFTA00310195
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards. Fistos & Lehrman
BATES
DATE
Lq
FROM
DESCRIPTION
OBJECTION
05995
04/01/2009
Bradley Edwards
Carolyn Edwards
Third
party
subpoenas
for Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06513-06523
06/15/2009
Bradley Edwards
Wayne Black
Ghisella Maxwell info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06699-06701
06/17/2009
Wayne Black
Bradley Edwards
Epstein litigation
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07079-07089
09/03/2009
Bradley Edwards
Pat Diaz
Discussion about girls involved in
the case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07437-07439
10/19/2009
Paul Cassell
Ronald Wise
New
evidence
of
Epstein
Fraudulent transfers + Affidavit
from you
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07936-07958
04/28/2009
Earleen Cote
Bradley Edwards
Cases against mansion nightclub
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08006-08011
06/03/2009
Bradley Edwards
Wayne Black
Getting addresses for people for
us to serve subpoenas
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
11186.11187
08/19/2009
Bradley Edwards
Bradley Edwards
Plaintiffs Witness List
Work
product;
attorney/client
privilege;
149
EFTA00310196
Privilege Log— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DAT€
11Q
FROM
DESCRIPTION
OBJECTION
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
26479-26481
08/19/2009
Attorneys at RRA
Ken Jenne
Assistance on the Epstein Case
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
27155-27159
10/23/2009
Attorneys at RRA
Steven Jaffe
PACER entries
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
26604-26605
10/27/2009
Phaedra Xanthos
Ken Jenne
Political
Contributions/advertisement for
the rental on Little St. James
Island
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
26570
08/13/2009
Scott Rothstein
Marc Nurik
Discussions about Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
04954
10/28/2009
Attorneys at RRA
Jacquie Johnson
Creation of another Doe file
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06665-06670
08/12/2009
Shawn Gilbert
Bradley Edwards
Epstein Costs
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
06675-06676
08/26/2009
Shawn Gilbert
Bradley Edwards
Personal convo in regards to
moving offices
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
150
EFTA00310197
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
06679-06682
08/26/2009
Bradley Edwards
Shawn Gilbert
Personal convo in regards to
moving offices
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
07590-07594
05/13/2009
Shawn Gilbert
Bradley Edwards
Office information
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08451-08453
08/17/2009
Bradley Edwards
Pat Diaz
Updated Witness List
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08455-08456
06/03/2009
Carla Martinez
Bradley Edwards
Vanity Fair
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08466.08479
08/26/2009
Attorneys at RRA
Bradley Edwards
Witness info that we need to use
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01767
07/06/2009
Wayne Black
Bradley Edwards
Info on a guy going to victim's
boyfriends house
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08379
06/06/2009
Bradley Edwards
Wayne Black
Info on Former FHP trooper
subcontracted by Riley
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
08399
07/23/2009
Bradley Edwards
Paul Cassell
Epstein affidavit to the reply
memo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
151
EFTA00310198
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
RATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08406
10/30/2009
Attorneys at RRA
Russell Adler
Flying epstein rape survivor to St.
Louis to see expert
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05697
08/19/2009
Bradley Edwards
Mike Fisten
Meeting with client
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20330.20334
08/24/2009
Bradley Edwards
Pat Roberts
Serving Alan Dershowitz
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20327.20329
10/17/2009
Attorneys at RRA
Mike Fisten
Property purchased by Epstein in
Palm Beach
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20100-20102
08/24/2009
Attorneys at RRA
Bradley Edwards
Epstein's arrival at his building
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20283-20326
10/14/2009
Attorneys at RRA
Mike Fisten
Research regarding Mr. Visoski
and questions to consider during
the depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20092.20099
08/24/2009
Attorneys at RRA
Ken Jenne
Epstein travel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
152
EFTA00310199
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATA
TO
FROM
DESCRIPTION
OBJECTION
20085-20091
10/15/2009
Bradley Edwards
Mike Fisten
Questions from accountant
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19996-20084
10/14/2009
Attorneys at RRA
Mike Fisten
Visoski Research and Questions
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20217-20218
08/04/2009
Bradley Edwards
Mike Fisten
Info on Copperfield
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20213-20216
08/03/2009
Attorneys at RRA
Ken Jenne
Info on Copperfield
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20211.20212
08/03/2009
Mike Fisten
Bradley Edwards
Pilots depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20207-20210
08/10/2009
Jacquie Johnson
Bradley Edwards
List of witness
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20201-20204
08/24/2009
Attorneys at RRA
Bradley Edwards
Serving Dershowitz
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
153
EFTA00310200
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
20193-20200
08/24/2009
Attorneys at RRA
Bradley Edwards
Proof of him being out of FL —
Violation of the agreement
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19982-19985
09/03/2009
Jacquie Johnson
Mike Fisten
Dave Rogers depo
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19988
10/07/2009
Jacquie Johnson
Mike Fisten
Depositions
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19971-19981
08/24/2009
Attorneys at RRA
Mike Fisten
Serving Dershowitz
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19969-19970
08/18/2009
Bradley Edwards
Mike Fisten
Subpoenas for Pilots
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
19962-19968
08/03/2009
Bradley Edwards
Mike Fisten
Working with the FBI to get some
info
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20190-20192
08/24/2009
Pat Roberts
Bradley Edwards
Personal emails regarding Brad's
surgery
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
20187-20189
08/24/2009
Attorneys at RRA
Ken Jenne
Epstein travel
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
154
EFTA00310201
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
DATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
19959-19961
07/24/2009
Attorneys at RRA
Bradley Edwards
Flight logs for Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
00156.00157
07/09/2009
Bradley Edwards
Paul Cassell
2255 Problem
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
15366-15367
09/04/2009
Attorneys at RRA
Bradley Edwards
Witness info that we need to use
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01003-01005
10/12/2009
Bradley Edwards
Paul Cassell
Asset
movement
by
Jeffrey
Epstein
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01013-01014
10/29/2009
Bradley Edwards
Cara Holmes
Subpoenaing Epstein's attorneys
for their fees and accompanying
documents
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
01042
07/22/2009
Marc Nurik
Bradley Edwards
New Info that our investigators
obtained from current FBI agents
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03133-03134
06/09/2009
Josh Roberts
Bradley Edwards
Personal conversation
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
155
EFTA00310202
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
03129-03130
06/09/2009
Josh Roberts
Bradley Edwards
Personal conversation
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
03119.03121
06/09/2009
Bradley Edwards
Josh Roberts
Personal conversation
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05440-05441
04/01/2009
Bradley Edwards
Carolyn
(Legal
Asst.
to
Jay
Howell,
Co-
Counsel)
CW Personal information
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
02593-02594
05/13/2009
T. Edwards (wife)
Bradley Edwards
Regarding personal information.
Privileged document- irrelevant and not
calculated to lead to discovery of admissible
evidence, privacy rights of parties involved,
spouse privilege
18877-18879
09/10/209
Marc Nurik
Bradley Edwards
Concerning
the
names
of
potential
witnesses and
the
issuance of subpoena's for them.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18344-18347
08/24/2009
Bradley Edwards
Mike Fisten
Investigative
information
and
techniques on the Epstein case
are discussed.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
156
EFTA00310203
Privilege UDR— Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
18339-18340
08/24/2009
Ken Jenne
Bradley Edwards
Investigative
information
and
techniques on the Epstein case
are discussed.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18341-18343
08/24/2009
Mike Fisten
Bradley Edwards
Investigative
information and
techniques on the Epstein case
are discussed.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18853-18854
09/10/2009
Bradley Edwards
Jacquie Johnson
Concerning
the
names
of
potential
witnesses and
the
issuance of subpoena's for them.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18337-18338
08/03/2009
Bradley Edwards
Mike Fisten
Investigative
information
and
techniques on the Epstein case
are discussed.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18306
10/16/2009
Pat Roberts
Ken Jenne
List of future depo's in Epstein
case and names of potential
witnesses.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18307
10/17/2009
Mike Fisten
Bradley Edwards
Investigative
Discussion
re:
finding of Epstein Assets.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
157
EFTA00310204
Privilege Log — Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman
BATES
DATE
11Q
FROM
DESCRIPTION
OBJECTION
18308.18309
10/18/2006
Mike Fisten
Bradley Edwards
Investigative
Discussion
re:
finding of Epstein Assets.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18188-18189
09/04/2009
Mike Fisten
Bradley Edwards
Investigative
Discussion
re:
finding of Epstein witnesses and
names of potential witnesses.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18184-18185
08/26/2009
Mike Fisten
Bradley Edwards
Investigative
Discussion
re:
finding of Epstein witnesses and
names of potential witnesses.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18186-18187
08/31/2009
Bradley Edwards
Jacquie Johnson
Discussion of potential witnesses
and the process of subpoena for
depo's.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
18180-18183
08/24/2009
Bradley Edwards
Mike Fisten
Investigative
Discussion
re:
finding of Epstein witnesses and
names of potential witnesses.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05256-05257
07/21/2009
Bradley Edwards
Wayne Black
Investigative
Discussion
re:
strategy of case.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
158
EFTA00310205
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
RATES
DATE
TO
FROM
DESCRIPTION
OBJECTION
05253
08/24/2009
Bradley Edwards
Wayne Black
Investigative
Discussion
re:
strategy of case.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05279-05280
08/24/2009
Bradley Edwards
Pat Roberts
Investigative
Discussion
re:
strategy of case.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05315-05318
07/26/2009
Bradley Edwards
Wayne Black
Investigative
Discussion
re:
strategy of case.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
05209-05211
06/26/2009
Bradley Edwards
Wayne Black
Investigative
Discussion
re:
strategy of case.
Work
product;
attorney/client
privilege;
irrelevant and not reasonably calculated to lead
to the discovery of the admissible evidence;
protected by privacy rights
159
EFTA00310206