EFTA00179641 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 21 of 70
| Bates Range | Description | Privilege(s) Asserted | Victims’ Ojections |
|---|---|---|---|
| Box #2 P-005915 Thru P-005977 | File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-005978 Thru P-006050 | File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-006051 Thru P-006065 | File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-006066 Thru P-006220 | File folder entitled “JANE DOE #4” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-006221 Thru P-006222 | File folder entitled “JANE DOE #12” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-006223 Thru P-006522 | File folder entitled “CORRECTED PHONE RECORDS 5/31/07” containing meta-analysis of all phone, travel, and grand jury data related to all victims/witnesses for indictment preparation | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-006523 Thru P-006802 | File folder entitled “[Victim Name] Phone Records” containing telephone records received in response to subpoena | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-006803 Thru P-006860 | File folder entitled “Lists of Identified Phone Numbers” containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-006861 Thru P-007785 | File folder entitled “EPSTEINKELLEN CELL PHONE RECORDS” containing documents received via subpoena with attorney handwritten notes and highlighting | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-007786 Thru P-008120 | Folder entitled “OLY GRAND JURY LOG: OLY-01 THROUGH OLY-50” containing subpoenaes, correspondence regarding same, 6(e) letters, attorney handwritten notes regarding records received in response to subpoenas | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-008121 Thru P-008139 | Handwritten flight logs received in response to subpoena | 6(e) Investigative privilege | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable |
| Box #2 P-008140 Thru P-008298 | Grand jury presentation folder containing attorney handwritten notes, typed outline with additional handwritten notes, complete indictment package dated 2/19/2008, victim list with identifying information, photographs, and summary of activity | Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-008299 Thru P-008363 | File folder entitled “FINAL AGREEMENTS” containing subfolder entitled “Agrmts Filed in State Court” (P-008300-P-008327 [not being withheld as privileged – have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez-Acosta letter (P-008328-P-008343 [not being withheld as privileged – have been produced to opposing counsel]); subfolder entitled “12/19/07 Acosta-Sanchez Lr” containing unredacted copies of that letter (P-008344-P-008363 [pursuant to Court’s Order, not being withheld as privileged – will be produced to opposing counsel upon lift of stay by 11th Circuit]) | N/A | |
| Box #2 P-008364 Thru P-008382 | File folder entitled “Lacera Immunity Request” containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request | 6(e) Work Product Deliberative Process Investigative privilege | Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable |