EFTA00185429 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18 SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4
Bates RangeDescriptionPrivilege(s) Asserted
P-013970 thru P-01397111/29/2006-12/1/2006 emails between employee regarding attempted contact with potential witness and prison employee regarding attempted contact with potential witnessWork Product Investigative Privilege Privacy Act
P-0139725/18/2007 email from of intent to subpoena Roy Black's private investigator and steps taken to obtain DOJ authorizationWork Product 6(e) Deliberative Process Investigative Privilege
P-013973 thru P-0139765/18/2007 emails between securing pre-indictment consultation contractWork Product 6(e) Investigative Privilege
P-013977 thru P-0139795/21/2007 email from 2423(b) charging questionWork Product 6(e) Deliberative Process Investigative Privilege
P-0139805/21/2007 email from regarding guidance on grand jury presentationWork Product 6(e) Deliberative Process
P-0139815/22/2007 email from Andy (cc:) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigationWork Product Deliberative Process
P-0139825/23/2007 email from research re extraditionWork Product A/C privilege Investigative Privilege
P-013983 thru P-0139845/23/2007 emails between regarding decision to meet with counsel for EpsteinWork Product Deliberative Process
Page 1 of 18 EFTA00185430 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 2 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-013985 thru P-0139896/14/2007-6/21/2007 emails between and regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein6(e)Work Product Deliberative Process Investigative Privilege
P-013990 thru P-0139916/26/2007 email from and addressing arguments regarding interstate nexus for 2422(b) chargesWork Product Deliberative Process
P-013992 thru P-0139947/3/2007-7/4/2007 emails between and regarding extension of time to respond to subpoenas requested by Lilly Ann Sanchez and possible resolution of case6(e)Work Product Investigative Privilege Deliberative Process
P-013995 thru P-0140106/12/2007-7/6/2007 series of emails between and AUSAs and are an earlier unrelated investigation of EpsteinWork Product Investigative Privilege Privacy Act
P-014011 thru P-0140257/3/2007-7/13/2007 email chain between and regarding disagreement on plea negotiations and written request for meeting between USAO management and victims6(e)Work Product Deliberative Process Investigative Privilege
P-014026 thru P-0140277/16/2007 email from and regarding correspondence from Roy Black and Motion to Quash6(e)Work Product Deliberative Process Investigative Privilege
P-014028 thru P-0140307/18/2007 emails from and regarding Motion to Quash grand jury subpoena and supporting affidavit filed by Roy Black6(e)Work Product Deliberative Process Investigative Privilege
P-014031 thru P-0140327/19/2007 email chain between and S/A service of target letters6(e)Work Product Deliberative Process Investigative Privilege Attorney-Client Privilege
Page 2 of 18 EFTA00185431 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 3 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-0140337/19/2007 email from regard planned service of target lettersWork Product6(e)Investigative PrivilegeDeliberative Process
P-0140347/26/2007 email from regard proposed changes to the indictment6(e)Work ProductDeliberative ProcessInvestigative Privilege
P-0140357/31/2007 email from and summarizing proposed plea terms as per recommendationWork ProductDeliberative ProcessInvestigative Privilege
P-0140367/31/2007-8/2/2007 email chain betweenand regarding plea negotiationsWork ProductDeliberative ProcessInvestigative Privilege
P-0140378/2/2007 email dromand with draft response to Epstein counsel regarding agreementWork ProductDeliberative ProcessInvestigative Privilege
P-014038thruP-0140418/2/2007 emails betweenregarding letter received from Lilly Ann SanchezWork ProductDeliberative Process
P-0140428/3/2007 Email fromand regarding draft response to correspondence from Epstein counsel and planned investigative steps if agreement cannot be reached.Work ProductDeliberative ProcessInvestigative Privilege
P-014043thruP-014044Emails dated 8/6/2007 fromand regarding correspondence prior to his departure.Work ProductDeliberative ProcessInvestigative Privilege
P-014045thruP-0140468/7/2007 email chain betweenAlex Acosta regarding meeting to discuss Epstein matterWork ProductDeliberative ProcessInvestigative Privilege
Page 3 of 18 EFTA00185432 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 4 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-0140478/7/2007 email from to Andy regarding deadline set for Epstein plea and Epstein’s plan to demand a meeting with CEOS.Work Product Deliberative Process Investigative Privilege
P-0140488/7/2007 email from regarding Epstein meetingWork Product Deliberative Process Investigative Privilege
P-014049 thru P-0140508/7/2007 email chain from to, and Alex Acosta regarding Epstein meetingWork Product Deliberative Process Investigative Privilege
P-0140518/8/2007 emails between and (CEOS) regarding case staffing and plea negotiationsWork Product Deliberative Process Investigative Privilege
P-0140528/8/2007 email chain between Alex Acosta, and “The meeting on Epstein”Work Product Deliberative Process Investigative Privilege
P-0140538/8/2007 email from to regarding plea negotiations, guideline calculations, and assistance in preparing case for trialWork Product Investigative Privilege Deliberative Process
P-0140548/8/2007 email from to Alex Acosta, and regarding planning meeting with Epstein counsel and service of target lettersWork Product 6(e) Investigative Privilege Deliberative Process
P-0140558/10/2007 Electronic correspondence from to expert witness regarding topics for expert testimonyWork Product
P-0140568/10/2007 email from to regarding target letters and staying motion to compel production of computersWork Product
P-0140578/30/2007 email from to, and regarding press coverage of meeting with Ken StarrWork Product
P-0140589/4/2007-9/6/2007 emails between and regarding planned participation of FBI ASAIC at 9/7/2007 meeting with Epstein defense teamWork Product Deliberative Process
Page 4 of 18 EFTA00185433 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 5 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014059 thru P-0140619/6/2007 emails between and negotiations, draft agreements, and need to confer with victimsWork Product Deliberative Process
P-014062 thru P-0140689/10/2007-9/14/2007 emails between and Alex Acosta regarding final plea negotiations, finalizing details with State Attorney's Office and final revisions to indictment packageWork Product Deliberative Process 6(e) Investigative Privilege
P-0140699/10/2007 email from to and regarding Acosta inquiry about FBI investigation into State grand lury proceedingWork Product 6(e) Investigative Privilege
P-014070 thru P-0140749/11/2007 emails between and regarding changes to the draft indictment and status of plea negotiationsWork Product Deliberative Process Investigative Privilege Attorney-Client Privilege
P-014075 thru P-0140899/10/2007-9/11/2007 emails between and regarding modifications to the proposed Non-Prosecution AgreementWork Product Deliberative Process
P-014090 thru P-0141029/13/2007 emails from to Alex Acosta, federal charges recommending 18 USC 403 or 1512(d), or 47 USC 223(6)(1)(B); response that Epstein was only willing to plead to assault on the plane; and rejection of facts supporting assault on the plane chargeWork Product Deliberative Process
P-014103 thru P-0141079/13/2007-9/14/2007 emails regarding victim trust fund set up in Alaska child exploitation caseWork Product
P-014108 thru P-0141349/17/2007-9/19/2007 emails between and regarding negotiations of a federal plea and a non-prosecution agreementWork Product Deliberative Process
Page 5 of 18 EFTA00185434 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 6 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014135 thru P-0141499/19/2007-9/20/2007 emails between and regarding plea negotiations with counsel for EpsteinWork Product Deliberative Process
P-014150 thru P-0141569/20/2007 emails between and regarding plea agreement to federal charges and factual profferWork Product Deliberative Process
P-014157 thru P-0141609/21/2007 emails between and regarding revisions to the non-prosecution agreementWork Product Deliberative Process
P-0141619/21/2007 email from to Alex Acosta, and regarding review of Epstein indictment packageWork Product Deliberative Process
P-014162 thru P-0141709/24/2007 series of emails between and regarding plea negotiations and revisions to non-prosecution agreementWork Production Deliberative Process
P-014171 thru P-0141749/23/2007-9/24/2007 series of emails between Alex Acosta, and regarding proposed revisions to non-prosecution agreementWork Product Deliberative Process
P-014175 thru P-0142039/20/2007-9/24/2007 emails between Alex Acosta, and regarding revisions to the non-prosecution agreementWork Product Deliberative Process
P-014204 thru P-0142059/24/2007 emails between and regarding notifying Palm Beach Police Chief and victims about agreementWork Product Deliberative Process
P-014206 thru P-0142169/24/2007-9/25/2007 emails between Alex Acosta, and regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreementWork Product Deliberative Process
P-014217 thru P-01423810/5/2007-10/16/2007 emails between and Alex Acosta selection of Special Master and negotiation of revision/addendum to Non-Prosecution AgreementWork Product Deliberative Process
Page 6 of 18 EFTA00185435 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 7 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014239 thru P-01424210/18/2007 emails between Epstein's request to delay his change of pleaWork Product Deliberative Process
P-014243 thru P-01425110/19/2007 emails between Special Master's Selection of Attorney RepresentativeWork Product Deliberative Process
P-014252 thru P-01427510/22/2007-10/31/2007 emails between Alex Acosta, and regarding negotiation of Addendum to Non-Prosecution Agreement and drafting of correspondence regarding scope of Special Master's duties and selection criteriaWork Product Deliberative Process
P-01427610/31/2007 email from regarding attempts to interview additional witnesses/victimsWork Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014277 thru P-01428211/2/2007-11/5/2007 emails between regarding drafting 11/5/2007 letter from Sloman to LeKowitzWork Product Deliberative Process
P-014283 thru P-01428411/5/2007-11/7/2007 emails from inquiring about status of matter and contact by Epstein investigators with victimsWork Product Deliberative Process
P-014285 thru P-01429811/8/2007-11/14/2007 emails between and regarding response to objections raised by Epstein counsel and efforts to change date for guilty pleaWork Product Deliberative Process Attorney-Client Privilege
P-014299 thru P-01430711/14/2007-11/19/2007 emails between regarding communications with State Attorney's Office and Sheriff's Office in an attempt to insure that Epstein was ineligible for work releaseWork Product Deliberative Process Attorney-Client Privilege
Page 7 of 18 EFTA00185436 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 8 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014308 thru P-01431011/19/2007 emails between about efforts by Epstein's counsel to change date for change of pleaWork Product Deliberative Process
P-014311 thru P-01432911/19/2007-11/28/2007 emails between and regarding drafting victim notification letter of upcoming pleaWork Product Deliberative Process Attorney-Client Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014330 thru P-01433711/28/2007 correspondence between and regarding Lefkowitz 11/27/2007 email discussing presentation to DAAGWork Product Deliberative Process
P-014338 thru P-01435411/29/2007-12/11/2007 emails between and regarding draft response to Jay Lefkowitz and victim notification lettersWork Product Deliberative Process
P-014355 thru P-01436112/3/2007 emails between Villafafa, Alex Acosta, and regarding history of plea negotiations and drafting response to correspondence from Jay Lefkowitz and Ken StarrWork Product Deliberative Process
P-014362 thru P-01440212/3/2007-12/5/2007 correspondence between Alex Acosta, and about drafting and sending the 12/4/2007 Acosta letter to Ken StarrWork Product Deliberative Process 6(e) Attorney-Client Privilege
P-014403 thru P-01441412/6/2007 emails between Alex Acosta, and regarding correspondence from Ken Starr, request for a meeting from Epstein counsel, and need to notify victims of upcoming pleaWork Product Deliberative Process
P-014415 thru P-01442012/6/2007-12/7/2007 emails between and Alex Acosta regarding draft victim notification letterWork Product Deliberative Process
Page 8 of 18 EFTA00185437 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 9 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014421 thru P-01442812/6/2007-12/7/2007 emails between Attorney's Office for draft plea profferWork Product Deliberative Process 6(e) Attorney-client Privilege Investigative Privilege
P-014429 thru P-01443912/9/2007-12/12/2007 emails between and regarding drafting response to personal attacks and upcoming meeting with Ken StarrWork Product Deliberative Process
P-01444012/11/2007 email from to and Alex Acosta regarding call with lawyer for Jane Doe #2(T.M.)Work Product Deliberative Process
P-01444112/12/2007 emails between and regarding planning indictment reviewWork Product Deliberative Process 6(e)
P-01444212/14/2007 email from to Alex Acosta, and regarding state cases mentioned by Epstein's counselWork Product Deliberative Process
P-01444312/14/2007 email from Villaafafa to Alex Acosta, and with draft letters to State Attorney's Office and victimsWork Product Deliberative Process
P-01444412/17/2007 email from to inquiring about case status and informing Sloman regarding agent concern about victim notificationsWork Product Deliberative Process
P-014445 thru P-01444712/19/2007 email from to Alex Acosta and summarizing research into other cases where individuals were charged with violating 2422(b) based upon the use of a telephoneWork Product Deliberative Process 6(e)
P-014448 thru P-01445412/19/2007 emails between Alex Acosta, and regarding drafting response to concerns raised during December 14, 2007 meeting between Epstein counsel, Alex Acosta, the FBI SAIC, andWork Product Deliberative Process
Page 9 of 18 EFTA00185438 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 10 of
Bates RangeDescriptionPrivilege(s) Asserted
P-014455 thru P-01445612/19/2007 email from and regarding challenge to state charge raised by Epstein counsel during 12/14/2007 meetingWork Product Deliberative Process 6(e)Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014457 thru P-01446412/20/2007 emails between and regarding inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state pleaWork Product Deliberative Process 6(e)Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014465 thru P-01448512/18/2007-12/21/2007 emails between and other AUSAs regarding other instances of charging 2422(b) based on the use of a telephone as a "facility of interstate commerce"Work Product 6(e)
P-01448612/21/2007 email from and with thoughts on recent correspondence from Jay Lefkowitz raising concerns about interpretation of the Nonprosecution AgreementWork Product Deliberative Process
P-01448712/27/2007 email from to Alex Acosta and regarding proposed approach to providing potential notice of breach of non-prosecution agreementWork Product Deliberative Process
P-014488 thru P-01449912/27/2007 emails between and regarding Alex Acosta, Lefkowitz letter of 12/26/2007Work Product Deliberative Process
P-0145001/2/2008 email from to Alex Acosta and regarding telephone conversation with State Attorney's Office about delay in Epstein state pleaWork Product Deliberative Process
P-014501 thru P-0145061/2/2008 emails between Alex Acosta, and regarding requests from Alex Acosta to for information related to the handling of the investigation by the State Attorney's OfficeWork Product Deliberative Process
Page 10 of 18 EFTA00185439 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 11 of 19
Bates RangeDescriptionPrivilege(s) Asserted
P-014507 thru P-0145081/2/2008 emails from to Alex Acosta and regarding renewed plea negotiations for federal plea agreementWork Product Deliberative Process 6(e)
P-014509 thru P-0145191/3/2008 emails between Alex Acosta, and regarding Alex Acosta telephone conference with Jay Lefkowitz where Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required sex offender registration.Work Product Deliberative Process Investigative Privilege
P-0145201/3/2008 email from to and regarding renewed plea negotiations and press coverage of Epstein matter.Attorney client privilege Deliberative Process Investigative Privilege
P-014521 thru P-0145221/7/2008 email from to Alex Acosta,and regarding proposed additional investigative steps in Epstein case.Work Product Deliberative Process 6(e) Privacy Act
P-0145231/9/2008 email from toAlex Acosta,and regarding informing Jay Lefkowitz that a CEOS attorney would join the SDFL team regarding the Epstein case and would review the prosecution and defense materials.Work Product Deliberative Process
P-014524 thru P-0145501/9/2008-1/14/2008 emails between and regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida,the results of the meetings and planned additional meetings,and revisions to the indictment in light of the meetings.Work Product Deliberative Process Attorney-client privilege Investigative Privilege 6(e)
P-0145511/17/2008 email from to regarding updated summary charts for indictment preparation,meetings with victims,and victim notification letters from FBIAttorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e)
P-0145521/23/2008 email from to and Alex Acosta regarding FBI involvement in meeting in DCWork Product Deliberative Process
Page 11 of 18 EFTA00185440 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 12 of
Bates RangeDescriptionPrivilege(s) Asserted
P-014555 thru P-0145561/25/2008 emails between regarding press coverage of case and strategic decisions regarding revisions to initial indictmentWork Product 6(e) Deliberative Process Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-0145571/25/2008 email from regarding research for purposes of issuing grand jury subpoenas.6(e) Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-0145581/29/2008 email from regarding status of meeting in DC and concerns regarding delay.Work Product Deliberative Process 6(e) Investigative Privilege
P-014559 thru P-0145621/28/2008-1/29/2008 emails between regarding scheduling victim interviews on 1/31/2008-2/1/2008Work Product 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014563 thru P-0145651/30/2008 emails between regarding Leftkowitz email about lawsuit filed against Epstein by one of the victims identified during the state investigation.Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 12 of 18 EFTA00185441 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014566 thru P-0145681/31/2008 emails between regarding interviews with victims.Work Product Investigative Privilege Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014569 thru P-0145731/31/2008-2/1/2008 emails between Acosta, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process alongWork Product Deliberative Process 6(e) Attorney-client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Investigative Privilege
P-014574 thru P-0145832/20/2008-2/21/2008 emails between Alex Acosta, Sigal Mandelker, and Alan Jacosta, and regarding status of CEOS plans to meet with counsel for Epstein and status of indictment reviewWork Product Deliberative Process 6(e)
P-014584 thru P-0146222/12/2008-2/22/2008 emails between and analyzing facts gathered from grand jury investigation and discussing strategy for drafting revised indictmentWork Product Attorney-client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014623 thru P-0146272/25/2008 emails between and Caroline Heck regarding ethical issue about whether or not to present proposed revised indictment to new grand juryWork Product Deliberative Process 6(e)
P-0146282/25/2008 email from Villafanta to and regarding result of consultation with Caroline Heck about grand jury questionWork Product Deliberative Process 6(e)
Page 13 of 18 EFTA00185442 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 14 of 10
Bates RangeDescriptionPrivilege(s) Asserted
P-0146292/26/2008 email from CEOS review and draft indictment packageWork Product Deliberative Process
P-014630 thru P-0146312/26/2008 email from 2/25/2008 correspondence to Jay Lefkowitz further extending the plea deadline for EpsteinWork Product Deliberative Process Investigative Privilege 6(e)
P-014632 thru P-0146462/21/2008-2/27/2008 emails between JOJ's Civil Rights Division regarding the status of the case and the planned indictment, and the draft written notificationWork Product Deliberative Process 6(e) Investigative Privilege
P-014647 thru P-0146492/28/2008 emails between and Susan Roe regarding related investigation, potential investigatory leads, and CEOs reviewWork Product Investigative Privilege 6(e)
P-014650 thru P-0146532/27/2008-2/28/2008 emails between and regarding review of evidence received pursuant to subpoenas and planned interviews of additional potential victim-witnessesWork Product Investigative Privilege Attorney-client privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014654 thru P-0146552/29/2008 emails between and regarding continuing investigation and status of CEOS reviewWork Product Deliberative Process Investigative Privilege 6(e)
P-014656 thru P-0146653/4/2008-3/5/2008 emails between and regarding search warrant and victim contact with attorneysWork Product Attorney-client privilege 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 14 of 18 EFTA00185443 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 15 of 10 18
Bates RangeDescriptionPrivilege(s) Asserted
P-014666 thru P-0146933/5/2008-3/6/2008 emails between Alex Acosta and regarding meeting in DC, additional information to prepare for meeting, and new information from ongoing investigationWork Product Deliberative Process 6(e) Investigative Privilege
P-014694 thru P-0147063/10/2008-3/12/2008 emails between Krishna Patel, E.J.Yera, and about Epstein attempts to contact victims and finding counsel for victimsWork Product Deliberative Process Attorney-client privilege
P-014707 thru P-0147113/12/2008 emails between and regarding CEOS meeting with Epstein counselWork Product
P-014712 thru P-0147163/14/2008 emails between and regarding complete indictment package for final reviewWork Product Deliberative Process 6(e)
P-014717 thru P-0147213/12/2008-3/17/2008 emails between and E.J.Yera regarding search warrant application and execution of search warrantWork Product Attorney client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014722 thru P-0147273/14/2008-3/17/2008 emails between and regarding corrections to indictment package and proposed grand jury presentationWork Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
Page 15 of 18 EFTA00185444 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 16 of
Bates RangeDescriptionPrivilege(s) Asserted
P-014728 thru P-0147423/14/2008-3/19/2008 emails between Kuvkendall, about Epstein attempts to contact victims and finding counsel for victimsWork Product Deliberative Process Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation
P-014743 thru P-0147803/19/2008-3/21/2008 emails between (CEOS), Alexandra Geiber (CEOS), and about meeting between Epstein counsel and CEOS and follow-up questionsWork Product 6(e) Deliberative Process Investigative Privilege
P-014781 thru P-0148003/19/2008-3/27/2008 emails between regarding waiting for DC's decision regarding Epstein's challenges to NPA; status of ongoing investigation; problems with Epstein's counsel contacting victims in the guise of deposing them for the state criminal action; and securing pro bono counsel for those victims to represent them in connection with the depositionsWork Product Deliberative Process Investigative Privilege 6(e)
P-014801 thru P-0148103/28/2008 emails between and regarding status of DC review of case and preparing for grand jury presentationWork Product 6(e) Investigative Privilege Deliberative Process
P-014811 thru P-0148293/31/2008 emails between and regarding status of ongoing investigation, planned presentation to grand jury, continued delay in awaiting decision from Washington, DC, and problems with victims being harassedWork Product Deliberative Process Investigative Privilege
P-014830 thru P-0148374/2/2008 emails between Alex Acosta, and regarding efforts by Jay Lefkowitz and Ken Starr to speak with Alex Acosta and instructions to direct question to andDeliberative Process Work Product Attorney-Client Privilege
Page 16 of 18 EFTA00185445 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 17 of 10
Bates RangeDescriptionPrivilege(s) Asserted
P-014838 thru P-0148434/4/2008-4/7/2008 emails between and regarding status of CEOS review of Epstein matterWork Product6(e)Deliberative Process
P-014844 thru P-0148514/10/2008-4/18/2008 emails between about continued delay in presenting case to grand jury due to failure to receive decision from DC, status of grand jury presentation and ongoing investigation6(e)Work ProductDeliberative ProcessInvestigative Privilege
P-014852 thru P-0148644/11/2008-4/23/2008 emails between and regarding self-reporting to OPR false allegations of ethics violationsWork ProductDeliberative ProcessPrivacy Act
P-0148654/29/2008 email from to re grand jury presentationWork Product6(e)Deliberative ProcessInvestigative Privilege
P-014866 thru P-0148834/21/2008-5/1/2008 emails between and about continued delay in presenting case to grand jury due to failure to receive decision from DC, status of grand jury presentation and ongoing investigation, staffing of case for purposes of trial, and meeting to prepare for grand jury presentation6(e)Work ProductDeliberative ProcessInvestigative Privilege
P-014884 thru P-0148865/2/2008 emails between and regarding developments in Epstein investigation and impact on grand jury presentation6(e)Work ProductAttorney-Client PrivilegeInvestigative PrivilegeDeliberative Process
P-014887 thru P-0148944/29/2008-5/2/2008 emails between and regarding contact by Epstein counsel and victims and draft letter to counsel for Epstein6(e)Work ProductDeliberative ProcessInvestigative Privilege
Page 17 of 18 EFTA00185446 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 18 of
Bates RangeDescriptionPrivilege(s) Asserted
P-014895 thru P-0149005/7/2008-5/9/2008 emails between and regarding awaiting approval from DC and status of ongoing investigationWork Product6(e)Deliberative ProcessAttorney-Client PrivilegeInvestigative Privilege
P-014901 thru P-0149065/15/2008-5/16/2008 emails between and regarding receiving final approval from DCWork ProductDeliberative Process
P-014907 thru P-0149115/19/2008-5/22/2008 emails between and regarding preparation for grand jury presentation; communication with S/A Kuykendall regarding plea negotiations; and status of ongoing investigation6(e)Work ProductDeliberative ProcessInvestigative Privilege
P-014912 thru P-0149195/23/2008-5/27/2008 emails between(FBI), and Jason Richards(FBI) re status of investigation, indictment review, grand jury preparation, and Epstein's attempt to revisit plea negotiationsWork Product6(e)Deliberative ProcessInvestigative Privilege
P-014920 thru P-0149238/15/2008 email from to Alex Acosta,and containing draft response to 8/15/2008 email from lay Leftkowitz regarding implementation of the NPA.(Redacted version produced to opposing counsel)Work ProductDeliberative Process
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