EFTA00179656¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 36 of¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-010660 Thru P-010757 | File folder entitled “Research re GJ Transcript” containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to 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 to Release 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable |
| Box #2 P-010758 Thru P-010793 | File folder entitled “Original Proposed Ind.” containing draft indictment | 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 |
| Box #2 P-010794 Thru P-010829 | File folder entitled “Epstein” containing sample indictments and attorney research re potential charges with attorney 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-010830 Thru P-010853 | File folder entitled “1591 & 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-010854 Thru P-010876 | File folder entitled “18 USC 2425” 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 35 of 69¶
EFTA00179657¶
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 37 of¶
| Bates Range | Description | Privilege(s) Asserted | Victims’ Objections |
|---|---|---|---|
| Box #2 P-010877 Thru P-010920 | File folder entitled “Knowledge of Age” 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-010921 Thru P-011049 | File folder entitled “2423(b) Constitutionality and Purpose of Travel” 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-011050 Thru P-011212 | File folder entitled “Mistake not a Defense” 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-011213 Thru P-011237 | File folder entitled “Research re ‘Pandering’ 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-011238 Thru P-011319 | File folder entitled “Research re Grand Jury Instructions” containing attorney research and handwritten notes | 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-011320 Thru P-011361 | File folder entitled “Telephone = Facility of Commerce” 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-011362 Thru P-011374 | File folder entitled “Def of Prostitution” 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 36 of 69¶