Draft: efta02772797

Privile e Lo — Dated 2- -2 11¶

M, Jaffe, Welsshg, Fls-tos&Lehrman¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
					privacy rights
01742	10/12/2009	Beth Williamson	[REDACTED]	Filing fee check	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
01743	10/29/2009	Beth Williamson & Jacquie	[REDACTED]	New folder for Jane Doe Created	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
01745	10/15/2009	[REDACTED]	Paul Cassell	Epstein's Cars	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
05726	08/14/2009	[REDACTED]	William Berger	Legal opinion	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
27395	08/13/2009	Marc Nurik	Scot Rothstein	Legal Research RE: causes of action against Epstein	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
26356	08/13/2009	Scott Rothstein	Russell Adler	Legal Research RE: causes of action against Epstein	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04225	06/15/2009	[REDACTED]	Wayne Black	Epstein Victims	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04229-04233	06/16/2009	Wayne Black	[REDACTED]	Epstein secret plea deal with Bear Stearns	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights

Vl O¶

Jaffe Weissin Fistos & Lehrman¶

		DATE	TO	FROM	DESCRIPTION	OBJECTION
04237-04242	06/15/2009	[REDACTED]	[REDACTED]	Wayne Black	Epstein secret plea deal with Bear Stearns	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04246	06/15/2009	Wayne Black	[REDACTED]	[REDACTED]	Epstein secret plea deal for Bear Stearns	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04250	06/15/2009	Wayne Black	[REDACTED]	[REDACTED]	Epstein Victims	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04255-04256	06/15/2009	Wayne Black	[REDACTED]	[REDACTED]	Epstein secret plea deal for Bear Stearns	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04260	06/15/2009	[REDACTED]	[REDACTED]	Wayne Black	Epstein secret plea deal for Bear Stearns	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
04523	05/14/2009	[REDACTED]	[REDACTED]	Wayne Black	Investigating Epstein's planes	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
05088-05090	10/27/2009	Attorneys at RRA	Ken Jenne	Epstein's assets	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
05108	04/01/2009	[REDACTED]	[REDACTED]	Carolyn	Victims employment	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights

M, Jaffe, Weissin Fistos & Lehrman¶

Mai DATE DESCRIPTION 2,11Jt5TION
05145 05/21/2009
fini Carolyn Epstein Hearing	W/P; Attorney Client Privilege; Irrelevant and
not reasonably	calculated to lead to the
05237 07/20/2009 Wayne Black Investigating Epstein's planes	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated	to lead to the
02648-02650 08/10/2009 Jacquie litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02651 07/29/2009 Wayne Black Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02661-02662 05/12/2009 Adler Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02674-02677 08/18/2009 Jacquie Edwards litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02678-02679 04/10/2009 Adler Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02682-02683 08/10/2009 la Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02718-02720 06/25/2009 Seth Lehman Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and

=, Jaffe; Weissing,S Fistos& Lehrman¶

patT "12 FROM DESCRIPTION Q4KBQN fL
not reasonably calculated to	lead to the
02728-02729 08/04/2009 Spencer Kuvin Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02746 07/22/2009 Adam Steinberg Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02813-02814 08/26/2009 Pat Providing New Witnesses
not reasonably calculated to	lead to the
02817-02826 08/04/2009 William Berger
litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02827-02832 05/12/2009 Attorneys at PRA William Bett s
C )
ation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02833-02835 08/23/2009 Pat Other Rape Victims	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02874-02876 05/23/2009 William Berger Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
discovery of admissible	evidence; protected by
02887-02888 08/26/2009 Bradley Pat litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated	to lead to the

M, Jaffe,Welssing,IIM, Fistos & Lehrman¶

RAILS mu ig FROM A! mmo,/ OlUfglON
02889-02890 10/14/2009 Mike Fisten Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02891 10/12/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
08/03/2009 William Berger Litigation StrategyNhix 1
'd\ ) 7
not reasonably calculated to	lead to the
02894 Mike Fisten LitigaN	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
02899 09/29/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03001-03002 05/15/2009 Susan Stirling Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03003 04/15/2009 Paul Cassell
N not
Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
	reasonably calculated to lead to the
03004 06/23/2009 Wayne BliKk Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the

Jaffe, Weissin Fistos & Lehrman¶

t1/1T. PATE j0 FROM LRSCI3RST I :f Oggicel
03005-03006 08/03/2009 Mike Fisten Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03007 10/07/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03008 04/23/2009 Susan Stirling Litigation Strategy N
AS ),,.
not reasonably calculated to	lead to the
03013 05/25/2009 UtiPti Y	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03014 10/08/2009 Cara LitSigat Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03015 04/24/2009 Steven Jaffe Susan Stirling Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably cakulated to	lead to the
03017.03018 08/18/2009 Mike Fitton /` Providing New witnesses	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03019 09/19/2009 Pat Litigation Strategy	W/P; Attorney Client Privilege; irrelevant and
not reasonably calculated to	lead to the

Jaffe, WeissIntS FIStOS & Lehrman¶

DATE 12 FROM SC-RI PT! ciaLEIG2N
03020 09/16/2009 Jacquie Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03021-03027 09/19/2009 Pat Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03031-03034 09/18/2009 Pat litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03035 09/29/2009 Adler Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03039 06/05/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03040 09/04/2009 Mike Fisten WilliamBerger
144) / )
litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03044 09/09/2009
Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03045-03047 09/30/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03048 04/21/2009 Paul Cassell Susan Stirling Litiation Strategy	W/P; Attorney Client Privilege; Irrelevant and

Jaffe Weissing. FIstos & Lehrman¶

BATES DATE /2 FROM DESCRIRTiois OBJECTION
not reasonably calculated to	lead to the
03050-03052 10/16/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03053 10/17/2009 Mike Fisten Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03054 10/13/2009 Attorneys at RRA Grant Litigation Sue	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03056 09/04/2009 Mike Chien
" < *Xese
" lic, ms	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03072 06/22/2009 Wayne filagS
Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03073 09/01/2009 ilte Fisten Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03074-03075 10/28/2009 lacquie John it
\ 14/ .)
Michael Wheeler litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03100 10/15/2009 Bradley Mike Fisten Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	Lead to the

Privilege L - Dated 2- 3-2011¶

Jaffe Welssindt, , Fistos & Lehrma¶

ME f2A11 is? FROM Q. ojggagri
discovery of admissible	evidence; protected by
03102.03103 07/21/2009 '. Paul Cassell Other Rape Victims	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03107-03113 07/24/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03114 08/04/2009 Mike Fisten Litigation Strategy
\ 9
not reasonably calculated to	lead to the
03115-03118 05/16/2009 Susan Stirling Litip
w/P;	Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03124 06/23/2009 Wayne Back Litigation Strategy w/P;	Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03125 09/08/2009 William Berger Litigation Strategy
W/P;	Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03127.03128 05/19/2009 Susan Stirling
Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03135-03136 08/04/2009 Miksetfisten Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the

Privilege Log— Dated 2-23-2011 Farmer. Jaffe. Weissings Fistos & Lehrman¶

TE 0EKBIPTION pM	i______________________
03137 08/22/2009 Wayne Black Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
priva a hts
03138 10/08/2009 Beth Williamson Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
•rlya r" hts
03145 10/30/2009 Jacquie Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
•nva rights
08/22/2009 Wayne Black Litigatlo	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
riv rights
Beth Williamson Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
iriva ri hts
Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03158-3159 04/28/2009 Susan Stirling Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03191-03196 10/14/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the

Privlle e Lo — Dated 2-23-201¶

Jdffe, Weissinrt. Fistos & Lehrman¶

RATES RA-T IQ aF pEscRirnord famo2N
03197-03199 08/14/2009 Attorneys at RRA n Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03205-03211 09/13/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03212 08/11/2039 lacquie Litigation Strategy
not reasonably calculated to	lead to the
03213 10/28/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03214-03218 10/27/2009 Paul Cassell Ronald Wise Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03223-03232 04/15/2009 Paul Cassell I Litigation Strategy	W/P; Attorney Client Privilege; irrelevant and
not reasonably calculated to	lead to the
03233-03242 09/28/2009 Paul Cassell
Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03245 06/01/2009 William Berger
Berger Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03251-03252 09/24/2009 I Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and

Jaffe, Weissing, fistos & Lehrman¶

PATE F$0 DECRIPTION °MECUM
not reasonably calculated to	lead to the
03303 07/30/2009 Beth Williamson Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03306-03307 09/04/2009 Paul Cassell Litigation Strategy
not reasonably calculated to	lead to the
03308-03309 09/04/2009 Beth Williamson Litigation Strategy'
-‘ 4% \
not reasonably calculated to	lead to the
03310.03314 09/04/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03389 07/30/2009 Beth Williamson Edwards Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03392-03393 09/04/2009
Beth Williamson Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03461-03463 09/19/2009 Susan Stirling Litigation Strategy	W/P; Attorney Client Privilege; irrelevant and
not reasonably calculated to	lead to the
03464-03465 06/14/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the

Privile e L — D ted 2-2 -2011¶

Jaffe. Weisslnfc, Fistos & Lehrman¶

PATE 12 FROM DEkCRI,TIpAl OBIESTIQN
03469-03486 06/15/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03495 08/27/2009 lacquie Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03496-03501 10/28/2009 Paul Cassell Litigation Strategy
\N "
not reasonably calculated to	lead to the
03502-03506 10/27/2009 Paul Cassell Ronald Wise Litlgati‘
not reasonably calculated to	lead to the
03507-03510 10/28/2009 Paul Cassell litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03511-03513 10/28/2009 Ronald Wise Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03514-03516 10/26/2009 Paul Cassel \
Ronald Wise Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03520-03523 07/04/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the

Jaffe, Welssing, Fistos&Lehrman¶

par.E4 DATA 12 an l P-figtlE110 OBJECTIpti
03524 09/04/2009 William Berger Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03525-03530 09/05/2009 William Berger Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03532 08/24/2009 Jacquie Litigation Strategy
not reasonably calculated to	lead to the
03536 07/19/2009 Paul Cassell
not reasonably calculated to	lead to the
03539-03540 08/26/2009 Pat Providing New Witnesses	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03541-03544 10/12/2009 Attorneys at RRA Ronald Wise Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03545-03547 06/26/2009 Paul Cassell Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the
03548-03549 04/11/2009 Wayne Black Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and
not reasonably calculated to	lead to the

EMI, Jaffe Fiftos & Lehrman¶

BATES	DATE	TO	FROM	DESCRIPTION	OBJECTION
03550-03574	09/09/2009	Attorneys at RRA	Paul Cassell	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03575-03588	10/19/2009	Kendall Coffey	█ █ █	Providing New Witnesses	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03589-03604	04/11/2009	Paul Cassell	█ █ █	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03605-03606	10/16/2009	Attorneys at RRA	█ █ █	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03607-03610	10/16/2009	William Berger	█ █ █	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03611-03612	10/16/2009	Attorneys at RRA	█ █ █	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03613-03615	10/29/2009	█ █ █	Cara	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03616-03618	10/01/2009	Pat █	█ █ █	Providing New Witnesses	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03628-03637	09/15/2009	Jacquie	█ █ █	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and

Jaffe. Welssin Fistos Lehrman¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
					not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
03638-03641	09/08/2009	[REDACTED] [REDACTED]	Paul Cassell	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
08454	10/23/2010	Attorneys at RRA	Mark Fistos	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
08118-08123	10/23/2009	Attorneys at RRA	[REDACTED] Adler	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
08124-08156	10/23/2009	Attorneys at RRA	Steven Jaffe	Litigation Strategy	W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
02411-02413	05/12/2009	Attorneys at RRA	[REDACTED] J.	Jane Doe II v. Epstein	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
01913-01914	06/15/2009	Susan K. Stirling	[REDACTED] J.	Activity in case 9:08-cv-80893-KAM Doe v. Epstein Motion to Dismiss	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
01918- 01919	04/15/2009	Attorneys at RRA	[REDACTED] J.	Activity in case 9:08-cv-80893-KAM Doe v. Epstein Motion to Compel	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
01920-01924	05/20/2009	Paul Cassell	[REDACTED] J.	Activity in case 9:08-cv-80994-KAM Jane Doe No. 6 v. Epstein	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead

Jaffe. Weissing. Finns& Lehrman¶

M.	PAH	12	FROM	DESCRIPTION	O_EuECTI	,
				Motion to Strike	to the discovery of the admissible evidence;
01925	08/26/2009	Jacquie	J.	Adriana Surveillance/Interview	Work	product;	attorney/client	privilege;
01928-01929	08/03/2009	Jacquie	J	Alfredo Rodriguez address	Work	product;	attorney/client	privilege;
01930	09/06/2009	J.	William J. Berger	Client info
				± ....-S	„
					Work	product;	attorney/client	privilege;
01940	09/10/2009	Adler	J.	Witness Info
				\ '8'
					Work	product;	attorney/client	privilege;
01944-01952	04/10/2009	Adler	J.	Epstein assets	Work	product;	attorney/client	privilege;
01969	OS/04/2009	Susan K. Stirling	J.	Call from sources of information	Work	product;	attorney/client	privilege;
01971-01972	05/13/2009	AttorneysatltRA	.1.	Cassell Draft	Work	product;	attorney/client	privilege;
01973-01974	07/23/2009		J.	CMA vs. Epstein	— new
					Work	product;	attorney/client	privilege;

Priv I e Lo — Date 2- 3-2011¶

Jaffe. Weissine. Fistos & Lehrman¶

	RATE	IR		FROM		pEsatirmoN	OBJECTION
01975	08/10/2009	Jacquie			1.	Computers	Work	product;	attorney/client	privilege;
01976-01978	07/06/2009		J.	Paul Cassell		Conference Call	Work	product;	attorney/client	privilege;
01981-01982	04/01/2009		J.	Adler		Conflict check for Brad
							Work	product;	attorney/client	privilege;
01990	05/14/2009		A	Paul Cassell		Consolidation order	Work	product;	attorney/client	privilege;
02000	09/03/2009	Jacquie			J.	Dates for Subpoena — Epstein's
							Work	product;	attorney/client	privilege;
02001-02003	10/09/2009	Jacquie		Bradley	J.
						David Copperfield	Work	product;	attorney/client	privilege;
02009-2010	09/09/2009	Pasquale			1.	Deposition of Sill'	Work	product;	attorney/client	privilege;
02017-02018	05/18/2009	William 1. Berger			1.	Doe v. Epstein	Work	product;	attorney/client	privilege;

Jaffe, Weissing,S Fistos & Lehrman¶

					DESCRIPTION	QBJECT1QN
					Sid's deposition of Epstein	Work	product;	attorney/client	privilege;
02045-02046	09/04/2009	Attorneys at RRA		1.	E.W., L.M. Doe v. Epstein — Letter
						Work	product;	attorney/client	privilege;
02049-02053	09/04/2009	Paul Cassell		1.	E.W., L.M. Doe v. Epstein —Letter
						Work	product;	attorney/client	privilege;
02063-02064	05/19/2009	William 1. Berger		1.	Epstein — Confirming AT&T Dial in
					Telephone Conference for
						Work	product;	attorney/client	privilege;
02089-02090	09/17/2009	Paul Cassell		J.	Epstein hearing	Work	product;	attorney/client	privilege;
02091-02092	06/16/2009	Attorneys at RRA	Bradley	1.
					Epstein Monthly Call in
						Work	product;	attorney/client	privilege;
02106-02108	04/29/2009	Susan K. Stirling	Bradley	1.	Epstein —Telephone Conference	Work	product;	attorney/client	privilege;
02109	05/13/2009	Waille(s*Nds
				1.	Epstein info — List of Plaintiff
						Work	product;	attorney/client	privilege;
02110-02111	09/15/2009	1.	lacqu le		Epstein - Cancelling depositions	Work	product;	attorney/client	privilege;

Pri vrle e Lo — Dated 2- 3-2011¶

=Jaffe Wei n Fistos&Lehrman¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
		[REDACTED]		in New York for the following week	irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02112-02116	09/10/2009	[REDACTED] J.	Jacquie Johnson	Epstein – Yearbook picture of Epstein rape victims	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02117-02118	10/23/2009	Jacquie [REDACTED]	[REDACTED] J.	Epstein (AUSA)	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02119-02121	09/08/2009	Beth S. Williamson	[REDACTED] J.	Epstein info	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02130-02137	05/26/2009	Susan K. Stirling	[REDACTED] J.	Epstein cases- depositions in federal cases	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02138-02139	08/04/2009	Jacquie [REDACTED]	[REDACTED] J.	Ep [REDACTED] depo – New York	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02143-02146	09/28/2009	Jacquie [REDACTED]	[REDACTED] J.	Epstein Depo	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02229	05/05/2009	Paul Cassell	[REDACTED] J.	Epstein Depo	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
02236-02337	05/20/2009	Attorneys at RRA	[REDACTED] J.	Epstein info	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead

Jaffe. We* si Fistos &Lehrman¶

BATES	RAIL	N	FROM		DESCRIPTION	121YLOSIN
02256-02257	07/22/2009			1.	Epstein info	Work	product;	attorney/client	privilege;
02260-02261	07/22/2009	Nora Batian		1.	E pstein — coordinating meetings	Work	product;	attorney/client	privilege;
02263-02265	07/23/2009	Attorneys at RRA	Nora Batian		Epstein info
						work	product;	attorney/client	privilege;
02266	07/30/2009	lacquie		1.	Epstein— Deposition of S.K.
					in NY S e
						Work	product;	attorney/client	privilege;
02273-02276	09/18/2009	lacouie		1.	Epstein info	Work	product;	attorney/client	privilege;
02278-02279	07/23/2009	Priscila A.
			Nora Batian		Epstein info	Work	product;	attorney/client	privilege;
02284-02855	05/11/2009	Susan K. Stirling
				1	Epstein into	Work	product;	attorney/client	privilege;
01769	10/30/2009	+sten		1.	Barbara Berg info	Work	product;	attorney/client	privilege;

Jaffe, WelssIng, Fistos & Lehrman¶

*Am	RATE	:r.g		FROM		DESCRIPTION	ODJECTIQN
01780	09/14/2009		J.	William J. Berger		Discussion of belief that Epstein
							Work	product;	attorney/client	privilege;
01787-01788	09/04/2009	Ken Jenne			1.	1. Accountants 2. Motion for IME	Work	product;	attorney/client	privilege;
01799-01801	10/14/2009		J.	Paul Cassell		Activity in case 9:08-cv-80119-
						of ninety d g
							Work	product;	attorney/client	privilege;
01804-01805	09/04/2009	Beth	S.
					3.	Activity in case 9:08-cv-80119-
							Work	product;	attorney/client	privilege;
01806-01807	09/09/2009	Paul Cassell			J.	Activity in case 9:08-cv-80119-
							Work	product;	attorney/client	privilege;
01808-01809	09/10/2009	Paul Cassell			1.
				'C 34/ te
							Work	product;	attorney/client	privilege;
01810-01816	09/09/2009	Attorneys at RRA			1.	Activity in case 9:08-cv-80119-
							Work	product	attorney/client	privilege;
01817-01818	06/11/2009	Paul Cassell			I	Activity in case 9:08-cv-80119-
							Work	product	attorney/client	privilege;

Jaffe, Welssing.S Fistos & Lehrman¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
01840-01841	07/16/2009	Paul Cassell	█	J. Activity in case 9:08-cv-80119-KAM Doe v. Epstein – Order on Motion to Stay	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
01867-01868	09/28/2009	Paul Cassell	█	J. Activity in case 9:08-cv-80119-KAM Doe v. Epstein – Notice (Other)	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
03662-03663	08/10/2009	Attorneys at RRA	█	J. Meeting with clients	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
03664-03668	09/18/2009	Paul Cassell	█	J. Litigation strategy and preparation	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08166-08168	10/28/2009	Paul Cassell	█	J. Weds filing	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08169-08170	08/06/2009	█	J. Jacquie Johnson	Wexner deposition for 14th	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08190-08196	04/07/2009	█	J. Paul Cassell	Motion to unseal/Motion to stay	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08265-08300	09/04/2009	Attorneys at RRA	█	J. Witness Information	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08377-08378	10/02/2009	█	J. Paul Cassell	Zorro Trust research info.	Work product; attorney/client privilege

Privilege Log - Dated 6-23-2011
J. Jaffe, Weissing, Fistos & Lehrman¶

	DATE	TO	FROM	DESCRIPTION	OBJECTION
		[REDACTED]			irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08381-08383	09/06/2009	[REDACTED]	J. Paul Cassell	Epstein - complaint	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08384-08388	04/13/2009	[REDACTED]	J. Paul Cassell	Epstein fraudulent transfer	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08389-08397	05/14/2009	[REDACTED]	J. Paul Cassell	Revisited sexual history memo	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08401	07/22/2009	[REDACTED]	J. Paul Cassell	Reply memo on asset transfers	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08409-08410	08/01/2009	[REDACTED]	J. Cara L. [REDACTED]	Rodriguez Deposition	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08421	06/02/2009	[REDACTED]	J. William J. Berger	Strategy	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08423-08425	10/09/2009	[REDACTED]	J. Mike Fisten	Subpoena info	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights
08426	08/10/2009	Bradley [REDACTED]	J. Mike Fisten	Synopsis	Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead

S Prlvll et f 2-n-2011 n¶

Jaffe. Weissln Fistos & Lehrman¶

			FROM	aE ln41	OW CTION
08441-08446	10/05/2009	Attorneys at MA	William 1. Berger	Trial Prep	Work	product;	attorney/client	privilege;
03672-03673	06/26/2009	Wayne Black		Brunel information	Work	product;	attorney/client	privilege;
03706-03718	08/05/ 2009		Paul Cassell	Cf. Response to Motion to File
					Work	product;	attorney/client	privilege;
03737	08/25/2009		Cara	Computer
					' Work	product;	attorney/client	privilege;
03746-03753	08/02/2009		William Berger	Computers	Work	product;	attorney/client	privilege;
02335-02338	05/08/2009	William Berger		Litigation strategy	Work	product;	attorney/client	privilege;
02360-02361	06/09/2009	Susan Stith		Hearing to Un-seal- Criminal Plea
					Work	product;	attorney/client	privilege'.
02368-02373	10/14/2009		lacquie	Igor Zinoview depo	Work	product;	attorney/client	privilege;

PrWi i 2-23-2011¶

ffe Weissina. . Fistos & Lehrman¶

PATES PAU IQ FROM DE RIPT1ON	OBJ€CTION
02376-02392 10/14/2009 Mike Fisten Igor Zinoview depo Work	product;	attorney/client	privilege;
02401-02410 05/08/2009 William Berger S Jane Doe II v. Epstein
Work	product;	attorney/client	privilege;
t		' the discovery of the admissible evidence;
02414-02419 05/12/2009 Attorneys at RRA S Jane Doe II v. Epstein 44 i
Work	product;	attorney/client	privilege;
03669-03670 10/08/2009 Carolyn I Epstein arrest monitor
4 \
Work	product;	attorney/client	privilege;
02288-02289 05/26/2009 Susan Stirling Mot
Work	product;	attorney/client	privilege;
02292-02293 05/19/2009 Dr. Lee (Expert) Brad Ova Pimp and His Game Work	product;	attorney/client	privilege;
02304-02308 09/17/2009 S Edwards lacquie Forensics/Investigations Work	product;	attorney/client	privilege;
02313-02316 07/01/2009 S William Berger Confidential Agreement Work	product;	attorney/client	privilege;