EFTA00179646¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 26 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims' Objections |
| Box #2P-008538ThruP-008516 | File folder containing March 18, 2008 grand jury presentation materials, including operation chart by victim" grand jury materials, draft indictments, victim reference list, grand jury subpoena log | Work product6(e)Investigative privilegeDeliberative processAlso 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 Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2P-008517ThruP-008535 | 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie[pursuant to Court's Order, not being withheld as privileged - will be produced to opposing counsel upon lift of stay by 11th Circuit] | N/A | |
| Box #2P-008536ThruP-008542 | Handwritten attorney notes to prepare for interview of Jane Doe #2 | Work productInvestigative PrivilegeContains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty: Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims |
| Box #2P-008543ThruP-008549 | Handwritten attorney notes regarding May 8, 2007 grand jury presentation | Work product6(e)Investigative privilegeContains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty: Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
Page 25 of 69¶
EFTA00179647¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 27 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-008550 Thru P-008615 | File folder entitled “Most Recent Indictment & Good Cases” containing draft indictment and legal research | Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty: Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(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-008616 Thru P-008686 | File folder entitled “FBI Summary Charts” containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment | Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty: Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable ; Redaction; No Assertion by Victims |
| Box #2 P-008687 Thru P-008776 | File folder entitled “[Victim name]/Jane Doe #4” containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information and documents subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty: Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
Page 26 of 69¶
EFTA00179648¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 28 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-008777 Thru P-008808 | File folder entitled “[Victim name]/Jane Doe #5” containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-008809 Thru P-008847 | File folder entitled “[Victim name]/Jane Doe #6” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-008848 Thru P-008862 | File folder entitled “[Victim name]/Jane Doe #7” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
Page 27 of 69¶
EFTA00179649¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 29 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-008863 Thru P-008890 | File folder entitled “[Victim name]/Jane Doe #8” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
| Box #2 P-008891 Thru P-009103 | File folder entitled “Certified Copy of State Case” containing certified copy of Epstein state criminal cases and change of plea transcript [not being withheld as privileged – copy provided to opposing counsel] | N/A | |
| Box #2 P-009104 Thru P-009111 | File folder entitled “Meeting Timeline” containing Villafafa typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate | Work product Deliberative process | Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue |
| Box #2 P-009112 Thru P-009113 | 11/26/2008 Email from Roy Black to A. Marie Villafafa and Karen Atkinson re Jeffrey Epstein (work release)[pursuant to Court’s Order, not being withheld as privileged – will be produced to opposing counsel upon lift of stay by 11th Circuit] | N/A |
Page 28 of 69¶
EFTA00179650¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 30 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-009114 Thru P-009115 | 7/3/2008 Email from A. Marie Villafana to Col. M. Gauger at PBSO re Epstein work release with attachment [not being withheld as privileged – produced to opposing counsel] | N/A | |
| Box #2 P-009116 Thru P-009125 | 12/6/2007 Letter from Jeffrey Sloman to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursuant to Court’s Order, not being withheld as privileged – will be produced to opposing counsel upon lift of stay by 11th Circuit] | N/A | |
| Box #2 P-009126 Thru P-009134 | File folder entitled “[Victim name]/Jane Doe #9” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(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-009135 Thru P-009141 | File folder entitled “[Victim name]/Jane Doe #13” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
Page 29 of 69¶
EFTA00179651¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 31 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-009141A Thru P-009141C | File folder entitled “[Victim name]/Jane Doe #12” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Inherited 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-009142 Thru P-009152 | File folder entitled “containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(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-009153 Thru P-009156 | File folder entitled containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
Page 30 of 69¶
EFTA00179652¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 32 of¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-009157 Thru P-009208 | File folder entitled “[Victim name]/Jane Doe #1” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(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-009209 Thru P-009213 | File folder entitled “[Victim name]/Jane Doe #2” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(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-009214 Thru P-009271 | File folder entitled “[Victim name]/Jane Doe #3” containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation | Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims |
Page 31 of 69¶
EFTA00179653¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 33 of¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-009272 Thru P-009354 | File folder entitled “Purpose of Travel Cases” containing attorney research and handwritten notes | Work product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-009355 Thru P-009403 | File folder entitled “Interstate Commerce Cases” containing attorney research and handwritten notes | Work product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-009404 Thru P-009536 | File folder entitled “Attorney Conflict Research” containing attorney research and handwritten notes | Work product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-009537 Thru P-009574 | File folder entitled “Mann Act/Travel to Have Sex w/Minor” containing attorney research and handwritten notes | Work product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-009575 Thru P-009603 | File folder entitled “Travel Act” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-009604 Thru P-009711 | File folder entitled “Florida Prostitution/Lewness Statutes” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-009712 Thru P-009819 | Booklet entitled “Attorney General Guidelines for Victim and Witness Assistance” [not being withheld as privileged – produced to oppose counsel] | Work Product | N/A |
| Box #2 P-009820 Thru P-009965 | File folder entitled “Carpenter Liability Rsch” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
Page 32 of 69¶
EFTA00179654¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 34 of¶
| Bates Range | Description | Privilege(s) Asserted | Victims' Objections |
|---|---|---|---|
| Box #2 P-009966 Thru P-010096 | File folder entitled “Research re Knowledge of Age Unnecessary” containing attorney research and handwritten notes and copy of grand jury subpoena | Work Product 6(e) | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3(E)); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable |
| Box #2 P-010097 Thru P-010276 | File folder entitled “Money Laundering” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-010277 Thru P-010394 | File folder entitled “1960 & Aiding/Abetting” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-010395 Thru P-010488 | File folder entitled “18 USC § 2255 Cases” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-010489 Thru P-010509 | File folder entitled “Research re Overt Acts & Witness Testimony” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
| Box #2 P-010510 Thru P-010525 | File folder entitled “Extradition” containing attorney research and handwritten notes | Work Product | Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue |
Page 33 of 69¶