EFTA00179655¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 35 of 70¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-010526 Thru P-010641 | File folder entitled “Rsrch re Crime Victims Rights” containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher, and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010528 thru P-010530 and P-010556 thru P-010559). Pursuant to the Court’s Order, these will be produced to opposing counsel upon lift of stay by 11th Circuit) | Work Product Deliberative Process | Inadequate Log: No Factual Underpinnings; Fiduciary Duty: Crime-Fraud-Misconduct; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue |
| Box #2 P-010642 Thru P-01650 | File folder entitled “Immunity” containing attorney research on granting immunity to witnesses | 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-010651 Thru P-010659 | File folder entitled “Research re G.J. Transcript” containing attorney research and draft pleadings re compelling production of grand jury transcript with subpoena | Work Product 6(e) Deliberative process | 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 |
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