Text extracted via OCR from the original document. May contain errors from the scanning process.
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
±ar
nes ,
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
10938
08/19/2009 (
C.
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
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
EFTA01118445
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
LQ
iggig
wo
nn t_______
privacy rights
07849.07852
04/10/2009
Bradley Edwards
Paul Cassell
Litigation Strategy
WM 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
------b-=-1
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
EFTA01118446
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissinga 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 l 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
EFTA01118447
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
it
T
FROM
DESCRIPTION
OBJE
N
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 LC71-lolmes
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
W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to lead to the
76
EFTA01118448
Privilege Log — Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman
BATES
DATE
i
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 CC!ra Wilmer)
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
EFTA01118449
Privilege Log— Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman
BATES
DATE
TO
FROM
DESCRIPTION
OBJECT •
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 Privile e; Irrelevant and
100
EFTA01118450
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BAT kss
aea
12
FROM
DESCRIPTION
OBJECTION
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
.7.-------____,
'Cara L. Holmel-‘,
....
_--1
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
EFTA01118451
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing. Edwards. Fistos & Lehrman
DATES
DATE
IQ
FROM
DESCRIPTION
OBJECTION
to the discovery of the admissible evidence;
protected by privacy rights
08441.08446
10/05/2009
Attorneys at RBA
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 (Sara 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
EFTA01118452
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
j2
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'
s -‘‘
( 7
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 for E.W.
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
EFTA01118453
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES
DATE
19
FROM
DESCRIPTION
gBlEgION
--
...Cara
protected by privacy rights
15820.15822
10/29/2009
Jacquie Johnson k,
Th.
Holm,
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 atty
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
lacquie 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
lacquie 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
EFTA01118454
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES
DATE
LQ
FROM
PESCRIPTION
saggio
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;
by privacy rights
01013.01014
10/29/2009
Bradley Edwards C
protected
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
EFTA01118455