Case 9:08-cv-80736-KAM Document 265-2 Entered on FLSD Docket 10/20/2014 Page 44 of

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