Privilege Lot— Dated 2-23-2011¶
Jaffe, weissing. tistos Bs tertrman¶
| DATE TO FROM DESCRIPTION | OBJECTION | ||||
|---|---|---|---|---|---|
| O0O55 04/29/2009 William Berger Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| O0056 05/05/2009 Paul Cassell Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00057 05/05/2009 Wiliam Berger Litigation Strategyr - | |||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00058 05/05/2009 Lit | |||||
| 49,tA 'o | |||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00O59 05/05/2009 Rob Buschel | |||||
| n Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00060 05/05/2009 Russell Adler | |||||
| Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00061-0064 05/06/2O09 Wiliiirm Berger | |||||
| Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00065 05/12/2009 ards Paul Cassell Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00066 04/29/2O09 Rob Buschel Litigation Strategy Work | Product:attorney | client |
Privilege Log — Dated 2-23-2011¶
Jaffe. Weissing. S Fistos & Lehrman¶
| DATE TO FROM DESCRIPTION | OBJECTION | ||||
|---|---|---|---|---|---|
| lead | to | the | discovery | of | admissible |
| 00067 05/12/2009 William Berger Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00068 05/12/2009 Rob Buschel Litigation Strategy | |||||
| ' Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00069-00070 05/13/2009 Paul Cassell Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00071 05/13/2009 Rob Buschel Litigation Strategy | |||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00072 05/15/2009 Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00073 05/15/2009 Adler Litintion Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00074 05/ 18/2009 William Berger Litigation Strategy Work | Product;attorney | dient | |||
| lead | to | the | discovery | of | admissible |
| 00075 05/ 18/2009 Paul Cassell Litigation Strategy Work | Product;attomey | client |
Privilege Los— Date 2-23-2011¶
Jaffe, Weissing. Flstos& Lehrman¶
| DATE TO 1 FROM DESCRIPTION | OBJECTION | ||||
|---|---|---|---|---|---|
| 00088 04/30/2009 Adler Litigation Strategy Work | Product;attomey | client | |||
| ,lead | to | the | discovery | of | admissible |
| evidence;protened | by privacy rights | ||||
| 00089 05/28/2009 Paul Cassell Litigation Strategy | |||||
| ( 14/ | |||||
| 'Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00090 05/28/2009 William Berger Litigation Strategy | |||||
| / 14/ | evidence;protected | ||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00091 05/28/2009 Paul Cassell uteictrat | |||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00092 05/28/2099 Rob BuscheN | |||||
| I. nonStrategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00093 06/01/2009 William Berger litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00094-00095 06/23/2009 Edwards Paul Cassell Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00096 07/06/2009 William Berger Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
Jaffe WeIssin Fistos & Lehrman¶
PrivIle e Lo — Dated 2-2 201¶
| DATE TO FROM DESCRIPTION | OBJECTION | ||||
|---|---|---|---|---|---|
| 00097 07/06/2009 Rob Buschel ~ Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00098-00100 07/07/2009 Paul Cassell Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00101 07/09/2009 Mike Fisten Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00102.00106 07/09/2009 Paul Cassell Litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00107 07/ 10/2009 William Berger | |||||
| Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00108 07/10/2009 Paul Cassell | |||||
| C ) | |||||
| Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00109 07/10/2009 William Berger Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00110 07/10/2009 | |||||
| Paul Cassell Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00111 07/11/2009 William Berger Litigation Strategy Work | Product;attorney | client |
Privile e L — Dated 2-23-2011¶
_Jaffe Weissing, Fist95 & Lehrman¶
| DATE TO FROM DESCRIPTION | OBJECTION | ||||
|---|---|---|---|---|---|
| lead | to | the | discovery | of | admissible |
| I--00132-00120 05/012009 Paul Cassell litigation Strategy ( | |||||
| Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00121 05/12/2009 William Berger Litigation Strategy | |||||
| / fr14/ | |||||
| N i.,01Work | Product;attomey | client | |||
| .lead | to | the | discovery | of | admissible |
| 00122 05/12/2009 Rob Buschel Litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00123 05/12/2009 William Berger | |||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00124.00125 05/12/2009 William | |||||
| Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00126 05/22/2009 Russell Adler Litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00127 05/26/2009 William Berger Litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | of | admissible | |
| evidence;protected | by | privacy rights | |||
| \1/4 .) | discovery | ||||
| \ i 'm |
Privilege Log — Dated 2-2.3-2011¶
Jaffe WeissIn Fistos & Lehrman¶
| DATE TO FROM DESCRIPTION | OBJECTION | ||||
|---|---|---|---|---|---|
| 00128-00131 5/26/2009 Rob Buschel Litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00132 5/21/2009 William Berger Litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00133 06/23/2009 Paul Cassell Litigation Strategy | |||||
| , .6, ) | |||||
| Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00134 06/03/2009 Rob Buschel litigatiOn Strategyee | |||||
| ,.....HAS S c Id | |||||
| Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00135-00137 06/03/2009 Paul Cassell | |||||
| 1<i ) | |||||
| litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00138.00140 06/08/2009 WI Litigation Strategy Work | Product;attomey | client | |||
| lead | to | the | discovery | of | admissible |
| 00141 06/12/2009 hal litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00142 06/13/2009 | |||||
| Adler litigation Strategy Work | Product;attorney | client | |||
| lead | to | the | discovery | of | admissible |
| 00143-00145 06/15/2009 I Rob Buechel Litigation Strategy Work | Product;attorney | client |
Privilege Log— Dated 2-23-2011¶
M, Jaffe, Welssing. Fistos& Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|---|
| privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights | |||||
| 00146 | 06/29/2009 | █ █ █ | William Berger | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 00147 | 06/29/2009 | █ █ █ | Mike Fisten | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 00148 | 04/22/2009 | █ █ █ | Rob Buschel | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 00149 | 04/26/2009 | █ █ █ | █ Adler | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 00150 | 04/24/2009 | Litigation Team | Rob Buschel | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 00151-00152 | 06/26/2009 | █ █ █ | Rob Buschel | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 01036-01039 | 04/26/2009 | Susan Sterling | █ Adler | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights |
| 13313-13314 | 07/30/2009 | Denis Kleinfeld | █ █ █ | Litigation Strategy | Work Product;attorney client privilege;irrelevant & reasonably calculated to |
Jaffe. We issing. Plstos IA Lenriflaft¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|---|
| lead to 'Sthe discovery of admissible | |||||
| 13315 | 08/03/3009 | Denis Kleinfeld | Beth Williamson | Litigation Strategy | 1 |
| Work Product;attomey client | |||||
| lead to the discovery of admissible | |||||
| 01080-01081 06/22/2009 | Robert C. Buschel | J. | Jane Doe brother | Attomey/Cllent privilege and/or work product | |
| 01077 | 05/28/2009 | Robert C. Buschel | J. | Doe family member | ib iAttorney/Client |
| 02445-02446 | 05/05/2009 | J. Susan K. Stirling | Attorney/Client privilege and/or work product | ||
| 03049 | 09/21/2009 | J. D.F. | New addition t | Attomey/Client privilege and/or work product | |
| 02425-02426 | 06/17/2009 | Susan K. Stirling | J. | Jane Dort. | er)r Attorney/Client privilege and/or work product |
| 02669 | 09/24/2009 | 1. Jacquie | Subpoena for Adrian | Attomey/Client privilege and/or work product | |
| 02647 | 08/06/2009 | Mike Fisten | J. | Samantha Lee | info Attomey/Client privilege and/or work product |
| 03688-03691 04/03/2009 | Robin | T. | |||
| J. Edwards | Case number assignments | Attomey/Client privilege and/or work product | |||
| 03692-03693 | 05/06/2009 | J. Susan K. Stirling | Case list | Attorney/Client privilege and/or work product | |
| 15678-15680 | 09/29/2009 | Jacquie | J. Edwards | Subpoena for | Attorney/Client privilege and/or work product |
| 15689 | 10/01/2009 | Jacquie | J. Edwards | Client information | Attomey/Client privilege and/or work product |
| 02546-02547 | 09/22/2009 | D.F. | J. | Client communication | Attorney/Client privilege and/or work product |
| 02809.02810 | 09/28/2009 | N.R. | J. | Client communication | Attorney/Client privilege and/or work product |
| 02262 | 07/23/2009 | Jacquie | J. | Discussion re: | client/victim |
| 02807-02808 | 10/01/2009 | N.R. | J. | Client communication | Attomey/Olent privilege and/or work product |
| 03760-03828 | 04/01/2009 | RRA Personnel | RRA personnel | Client names/types of action/ | |
| 03759 | 04/01/2009 | Russell Adler | J. | Conflict Check for Brad | Attorney/Client privilege and/or work product |
| 08358-08359 | 09/14/2009 | Pat Roberts | J. | Client info | Attomey/Client privilege and/or work product |
Jaffe. WelSsIn Fistos Leh an¶
| M | DATE | TO | FROM | DESCRIPTION | OBJECTION |
|---|---|---|---|---|---|
| 08364-08368 | 10/01/2009 | Jac uie | J. | Client info | Attomey/Client privilege and/or work product |
| 08370 | 09/14/2009 | J. | Pat | Client info | Attomey/Client privilege and/or work product |
| 08374-08375 | 10/01/2009 | J. | Jacquie | Client Info | /Client privilege and/or work product |
| 03878 | 06/12/2009 | J. | Robert C. Buschel | Curtiss | Attorney/Client privilege and/or work product |
| 02955 | 04/20/2009 | Susan K. Stirling | J. | Juskowich | Attorney/Client privilege and/or work product |
| 02932 | 07/17/2009 | Christina Fitch | J. | Jane Doe v. Roe | Attorney/Cliem privilege and/or work product |
| 12544-11545 | 09/28/2009 | Jacquie | J. | Client info | Attorney/Client privilege and/or work product |
| 07432-07435 | 09/25/2009 | O.F. | J. | New addition to the case | Attorney/Client privilege and/or work product |
| 06906-06909 | 07 17/2009 | Christina Fitch | 1. | Jane Doe v. Roe | Attomey/Client rivile e and/or workproduct |
| 06913-06914 | 06/22/2009 | J. | Susan K. Stirling | Jane • Roa | Attorney/Client privilege and/or work product |
| 06030-06031 05/04/2009 | Susan K. Stirling | J. | Espina — mart Use | Attorney/Client privilege and/or work product | |
| 05646 | 07/08/2009 | J. | William I. Berger | Client meeting | Attomey/Client privilege and/or work product |
| 05573 | 09/18/2009 | Mike Fisten | 1. Edwards | Client meeting | Attorney/Client privilege and/or work product |
| 05540 | 07/31/2009 | Amy Swan | 1. Edwards | Client info | Attorney/Client privilege and/or work product |
| 05273-05276 | 07/28/2009 | Amy Swan | Bradley!. Edwards | Client info | Attorney/Client privilege and/or work product |
| 05264 | 07/27/2009 | Amy Swan | Bradley J. Edwards | Client info | Attorney/Client privilege and/or work product |
| 05267.05270 | 07/27/2009 | Am Swan | Bradley J. | Client info | Attomey/Client privilege and/or work product |
| 02933 | 06/17/2009 | A1 | M. G. | Jane Doe v. Roe | Attorney/Client privilege and/or work product |
| 01292 | 09/18/2009 | A. J. | M.G. | Epstein article | Attorney/Client privilege and/or work product |
| 01068-01070 | 04/02/2009 | All St fr,.. | Robin T. Kempner | Current case list of Brad | Attorney/Client privilege and/or work product |
| All ff | |||||
| sr rt K. Stirling | |||||
| Robin T. Kempner | U. dated case list for Brad | Attorney/Client privilege and/or work product | |||
| = J. | case list | Attomey/Client privilege and/or work product | |||
| 01030-01031 | 04/03/2009 | J. | Robin T. Kempner | Case number assignments | Attorney/Client privilege and/or work product |
Privile e Lo — Dated 2-2 -2011¶
MJaffe, WeissinJt, Fistos & Lehrman¶
| DATE | TO FROM | DESCRIPTION | OftlECTiON | |
|---|---|---|---|---|
| 01118-01120 | 09/22/2009 | 1 MG | Jane Doe v. Roe | Attorney/Client privilege and/or work product |
| 01986-01989 | 04/02/2009 | J. Robin T. Kempner | Conflict check | Attorney/Client privilege and/or work product |
| 01984-01985 | 04/02/2009 | J. Robin T. Kempner | Conflict check | l Attorney/Client privilege and/or work product |
| 25925 | 09/30/2009 | All Staff Robin T. Kempner | Conflict check | Attorney/Client privilege and/or work product |
| 25874 | 09/30/2009 | All Staff Robin T. Kempner | Additional name | added •to |
| 08356-08357 | 09/16/2009 | NR | Client Meeting | |
| 16760-16761 | 09/23/2009 | Jacqu e | New Client | Attorney/Client privilege and/or work product |
| 08005 | 06/05/2009 | MG | New Client | Attorney/Client privilege and/or work product |
| 06915-06920 | 06/17/2009 | MG | Jane Doe v. Roe | Attorney/Client privilege and/or work product |
| 08360 08363 | 09/16/2009 | NR I | Client Meeting | Attorney/Client privilege and/or work product |
| 04101 04107 | 09/28/2009 | MG | Jane Doe v. Roe | Attorney/Client privilege and/or work product |
| 04708-04710 | 09/18/2009 | MG | Epstein Article | Attorney/Client privilege and/or work product |
| 06910-06912 | 06/17/2009 | MG Edw | Jane Doe v. Roe | Attorney/Client privilege and/or work product |
| 07909 | 08/10/2009 | Jane Doe | Same silver car tag | Attorney/Client privilege and/or work product |
| 07637-07642 | 09/10/2009 | NR | NR Interview | Attorney/ Client Privilege |
| 08/19/2009 | Anthony P | Client Meeting | Attorney/Client privilege and/or work product | |
| 09/15/2009 | Pat | Client Meeting | Attorney/Client privilege and/or work product | |
| 06404-06408 | 09/10/2009 | Edwards Pat | NR Interview | Attorney/Client privilege and/or work product |
| 08338-08339 | 09/16/2009 | NR | New Client | Attorney/Client privilege and/or work product |
| 08505 | 09/14/2009 | NR | New Client Meeting | Attorney/Client privilege and/or work product |
| 02241-02242 | 05/28/2009 | Confidential | ||
| ■ | Other Rape Victims | W/P Prlv.; not reasonably calculated to lead to | ||
| 02243-02244 | 07/07/2009 | Confidential Source | Other Rape Victims | W/P Priv.; not reasonably calculated to lead to |
| 02238-02240 | 05/28/20009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 02204 | 07/14/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
P ivleelo — Dat 2-23-2011¶
Jaffe. Weissine. Fistos& Lehrman¶
| DATE TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|
| 02298-02299 | 07/08/2009 | Confidential Source | Other Rape Victims | W/P Priv.; not reasonably calculated to lead to |
| 02291 | 06/04/2009 | Confidential Source | Additional | Information RE: |
| 02442-02443 | 08/17/2009 | Confidential Source | Litigation Strategy | -a•cil/P Priv.; not reasonably calculated to lead to |
| 02440.02441 | 10/02/2009 | Confidential Source | Litigation Strategy | amol dW/P Priv.; not reasonably calculated to lead to |
| 04318-04321 | 09/24/2009 | Confidential | ||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 05111 | 06/02/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 05152 | 06/03/2009 | Confidential | ||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||
| 05164 | 06/03/2009 | Confidential | ||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 05166 | 06/03/2009 | Confidential Source | Providing New Witnesses | W/P Prlv.; not reasonably calculated to lead to |
| 05169-05170 | 06/03/2009 | Confidential | ||
| Edwards Providing New Witnesses | W/P PS.; not reasonably calculated to lead to | |||
| 05173-05174 | 06/03/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 05212-05213 | 06/23/2009 | Confidential | ||
| Bradley | Secret Plea | Deal for Epstein | ||
| 05215-05217 | 06/23/2009 | Confidential | ||
| Bradley | Secret Plea | Deal of Epstein | ||
| 05175-05189 | 07/02/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 05194-05196 | 06/23/2009 | Bradl- Confidential Source | Other Rape Victims | W/P Priv.; not reasonably calculated to lead to |
| 05204.05206 | 06/23/2009 | Confidential Source | Other Rape Victims | W/P Priv.; not reasonably calculated to lead to |
Privile e Lo — D ted 2-23-2011¶
Jaffe. Weissin FiStos & Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|---|
| 05227-05228 | 07/08/2009 | Confidential Source | █ █ | Additional Information Epstein Molestations | RE: W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05230-05231 | 07/08/2009 | Confidential Source | █ █ | Additional Information Epstein Molestations | RE: W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05303 | 08/06/2009 | Confidential Source | █ █ | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05344-05346 | 06/23/2009 | █ █ | Confidential Source | Secret Plea Deal for Epstein | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05408 | 07/06/2009 | █ █ | Confidential Source | Secret Plea Deal for Epstein | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05425-05429 | 05/28/2009 | Confidential Source | █ █ | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05433-05436 | 05/29/2009 | Confidential Source | █ █ | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05433-05436 | 05/29/2009 | Confidential Source | █ █ | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05446 | 07/07/2009 | █ █ | Confidential Source | Other Rape Victims | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05452-05464 | 05/29/2009 | Confidential Source | █ █ Edwards | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05535-05536 | 07/30/2009 | Confidential Source | █ █ | Additional Information Epstein Molestations | RE: W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05538-05539 | 07/30/2009 | Confidential Source | █ █ | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05550-05551 | 08/11/2009 | Confidential Source | █ █ | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05577-05578 | 08/22/2009 | Confidential Source | █ █ | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05619-05620 | 09/18/2009 | Confidential Source | █ █ | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05650 | 08/06/200 | █ █ | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence |
| 05688-05689 | 07/28/2009 | █ █ | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
Privilege Lo — Dated 2-23-201¶
MJaffe Weissin Fistos & Lehrman¶
| DATE TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|
| 05693-05695 | 05/28/2009 | Confidential Source | Litigation Strategy | W/P Priv; not reasonably calculated to lead to |
| 05698 | 08/21/2009 | Confidential Source | Litigation Strategy | |
| 05706-05709 | 05/28/2009 | Confidential Source | litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05720-05721 | 05/29/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 05738-05739 | 05/29/2009 | Confidential Source | Providing New WitnesseS | W/P Priv.; not reasonably calculated to lead to |
| 05743.05745 | 05/29/2009 | Confidential Source | Litigation Strategy/ | W/P Priv.; not reasonably calculated to lead to |
| 05754 | 08/03/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05759-05762 | 06/01/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 05765-05768 | 06/23/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05771-05773 | 06/03/2009 | Confidenti | ut,ie) | |
| Additional Information | RE: | |||
| 05777-05779 | 06/03/2009 | ConfidentialSource | Additional Information | RE: |
| 05784-05786 | 06/03/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 05791.05794 | 06/03/2009 | Confidential Source | Additional information | RE: |
| 05803 | 07/22/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05836-05837 | 07/08/2009 Bradley | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| OS842-05843 | 07/08/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
Privile e Lo — Dated 2-23-2 11¶
M, Jaffe Welssintt, Fistos & Lehrman¶
| DATE TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|
| 05848 | 07/28/2009 | Confidential Source | litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05852-05853 | 07/29/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05857-05858 | 07/31/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05952-05953 | 08/25/2009 | Confidential Source | litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06192-06197 | 06/23/2009 | Confidential Source | Secret Plea Deal For Ep | W/P Priv.; not reasonably calculated to lead to |
| 06198-06201 | 06/24/2009 Confidential | |||
| Secret Plea Deal | W/P Priv.; not reasonably calculated to lead to | |||
| 06203 | 07/23/2009 | Confidential Source | litigatiodSlAtegy h | W/P Priv.; not reasonably calculated to lead to |
| 06401 | 09/23/2009 | Confidential Source | Provlatlew Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 09/17/2009 | Confidential Sour | Litqaition Strategy | W/P Priv.; not reasonably calculated to lead to | |
| 06788.06789 | 09/28/2009 | Confidend | ||
| ,Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 06942-06943 | 09/26/2009 Confidential | |||
| Edwa | Additional Information | RE: | ||
| ) | discovery of admissible evidence | |||
| 06953 | 08/14/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06955-06957 | 10/02/2009 | ential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06959.06961 | 08/11/2009 | EMI Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to |
| 06963-06980 | 08/11/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06986-06989 | 10/03/2009 | Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to |
| 07010.07014 | 10/04/2009 | I Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
— Dated 2-23-2011¶
Fistos &Lehrman¶
| DATE | TO FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|
| 07017-07018 | 09/04/2009 | Confidential | ||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||
| 07143-07144 | 10/01/2009 | Confidential | ||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 07147-07150 | 09/18/2009 | |||
| Confidential Source | Providing New Witnesses | ---"- .W/P Priv.; not reasonably calculated to lead to | ||
| Litigation Strategy | 14/ " | |||
| " milk | ||||
| 07605-07615 | 09/07/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 07646-07647 | 09/08/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 07674-07697 | 09/08/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 08376 | 10/04/2009 | Confidential | ||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||
| 08380 | 09/18/2009 | Confidential Sou | itigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 08427-08430 | 09/24/2009 | ConfidentiaBArtier | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 08450 | 05/17/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 08507 | 10/03/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 10092-10098 | 08/31/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 01610 | 06/03/3009 | Confidential | ||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 01612 | 06/04/2009 | Confidential | ||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 01451-01458 | 05/27/2009 | Confidential | ||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
P *vile Lo — Dated 2-23-2011¶
Jaffe Weissing. Fistos&Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | ||
|---|---|---|---|---|---|---|
| 01608 | 07/03/2009 | Confidential | ||||
| litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 01606 | 07/02/2009 | Confidential | ||||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||||
| 01510 | 08/25/2009 | Confidential | ||||
| 01506 | 08/24/2009 | Confidential | ||||
| 01493 | 08/10/2009 | Confidential | ||||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||||
| 01488 | 08/03/2009 | Confidential | ||||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 01486 | 07/28/2009 | Confidential | ||||
| 01483 | 07/28/2009 | Confidential | ||||
| Addition a - - Information | ||||||
| RE: | W/P Priv.; not reasonably calculated to lead to | |||||
| 01479 | 07/22/2009 | Confidential | ||||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 01449 | 05/22/2009 | Confidential Sour | et Plea Deal for Epstein | W/P Priv.; not reasonably calculated to lead to | ||
| 01433 | 10/20/2009 | Conceal | ||||
| Additional Information | ||||||
| RE: | W/P Priv.; not reasonably cakulated to lead to | |||||
| 15207-15208 | 08/14/2009 | lacquie | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |
| 19716-19719 | 09/25/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||
| 1973049731 | 10/02/2009 | Edwatc | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |
| 01683 | 08/06/2009 | Confiden | ||||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 01693 | 08/21/2009 | Confidential | ||||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 03011 | 09/17/2009 | Confidential Source | Additional Information | RE: | W/P Priv.; not reasonably calculated to lead to |
Jaffe. Weis in Flstcrs& Lehrman¶
r¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | ||
|---|---|---|---|---|---|---|
| Epstein Molestations | discovery of admissible evidence | |||||
| 01755-01756 | 10/02/2009 | Confidential Source | Additional Information | RE: | ||
| 017% | 06/22/2009 | Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to | ||
| 01770 | 10/08/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | ||
| 03126 | 09/18/2009 | Confidential | ||||
| Additional Information | RE: | |||||
| 02006 | 06/23/2009 | Confidential | ||||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 02060 | 09/23/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||
| 03487-03494 | 09/19/2009 | Confidential | ||||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||||
| 02269 | 08/26/2009 | Confidential | ||||
| Other Rape Victims | W/P Priv.; not reasonably calculated to lead to | |||||
| 02322-02323 | 10/16/2009 | Confidential | ||||
| E | *anon Strategy | W/P Priv.; not reasonably calculated to lead to | ||||
| 02595-02596 | 09/07/2009 | Confide | Secret Plea Deal for Epstein | W/P Priv.; not reasonably calculated to lead to | ||
| 02866-02867 | 09/25/2009 | Confidential | ||||
| Bradley | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||||
| 02895 | 08/31/2009 | Confidential Source | Additional Information | RE: | ||
| 02901 | 09/16/2009 | Confidential | ||||
| Bradley | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | ||||
| 03032 | 09/18/2009 | Confidential | ||||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||||
| 03057 | 10/13/2009 | Bradley Edwards | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |
| 03070 | 07/28/2009 | Bradley | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
Privilege Log— Dated 2-23-2011¶
Jaffe. WeLising.MIS Fisto& Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|---|
| 03081-03082 | 09/21/2009 | Confidential Source | Providing Witnesses | W/P Priv.; not reasonably calculated to lead to | |
| 03144 | 10/08/2009 | Confidential | |||
| Providing Witnesses | W/P Priv.; not reasonably calculated to lead to | ||||
| 03189-03190 | 10/14/2009 | ||||
| Confidential Source | Additional Information | ||||
| RE: | W/P Priv.; not reasonably calculated to lead to | ||||
| 04015 | 09/08/2009 | Confidential | |||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||||
| 02913 | 09/28/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably cakulated to lead to | |
| 02956-02957 | 08/31/2009 | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |
| 02975 | 10/21/2009 | Confidential | |||
| LitigatIonaiS81;y tr | W/P Priv.; not reasonably calculated to lead to | ||||
| 04031.04055 | 08/12/2009 | Confidential Source | Additional Information | ||
| RE: | W/P Priv.; not reasonably calculated to lead to | ||||
| 114057 | 08/11/2009 | Confidentla/ | |||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||||
| 04060 | 08/12/2009 | Confiden | |||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||||
| 02979-02980 | 10/02/2009 | Confidential %lice | Additional Information | ||
| RE: | W/P Priv.; not reasonably calculated to lead to | ||||
| 02998 | 07/21/2009 | Confidential Source | Litigation Strategy | W/P PrN.; not reasonably calculated to lead to | |
| 05626 | 10/12/2009 | Confidential | |||
| Bradley | Litigation Strategy | W/P Priv.; not reasonably cakulated to lead to | |||
| 05630-05631 | 10/12/2009 | Confiden I | |||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | ||||
| 05664-05665 | 10/12/2009 | rids | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 07976 | 08/14/2009 | i' ll fiat | |||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | ||||
| 06655 | 06/09/2009 | Confidential | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
Privilege log — Dated 2-23-2011¶
=, Jaffe Welssln Fistos & Lehrman¶
| DATE TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|
| Source | discovery of admissible evidence | |||
| 19986-19987 | 09/28/2009 | Confidential | ||
| Mike Fisten | Additional | Information RE: | ||
| 04905-04906 | 07/15/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 04946-04951 | 10/28/2009 | Confidential Source | Litigation Strategy | -14/ Nw/P Priv.; not reasonably cakulated to lead to |
| 05148 | OS/22/2009 | Confidential Source | Litigation Strategy | -Tfts,„„YIN/P Priv.; not reasonably calculated to lead to |
| 05151 | 05/26/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05161 | 05/28/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05203 | 06/23/2009 | Confidential | ||
| Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to | |||
| 05207-05208 | 06/23/2009 | Confidential | ||
| Litigation Strategy | W/P Priv.; not reasonably calculated to lead to | |||
| 05220-05221 | 06/23/2009 | Confidential | ||
| Edwards ' t Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to | |||
| 05224-05225 | 06/24/2009 | Confidential | ||
| Edwards t Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to | |||
| 05239 | 06/23/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05277-05278 | 06/23/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05324-05325 | 06/23/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05368-05369 | 06/23/2009 | Bradley Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to |
| 05387-05388 | 06/23/2009 | Bradley Edwards Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to |
| 02811-02812 | 10/03/2009 | Confidential Source | Additional | Information RE: |
Privilege Log — Dated 2-23-2011¶
M, Jaffe, Welssing, Edwards. Fistos & Lehrman¶
| DATE TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|
| 01280-01288 | 09/18/2009 | Confidential | ||
| litigation Strategy | W/P Privilege; Not reasonably calculated to lead | |||
| 01131-01134 | 10/08/2009 | Confidential Source | Additional | information |
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 00988 | 04/25/2009 | Confidential Source | Providing New Witnesses | W/P Privilege; Not reasonably calculated to lead |
| 10163-10167 | 08/12/2009 | Confidential Source | Providing New Witnesses | W/P Privilege; Not reasonably calculated to lead |
| 1018140188 | 08/12/2009 | Confidential Source | Providing New | tnesses W/P Privilege; Not reasonably calculated to lead |
| 10245-10251 09/08/2009 | Confidential Source | Providing Nelsfr | nesses W/P Privilege; Not reasonably calculated to lead | |
| 10360-10367 | 09/17/2009 | Confidential Source | AddltIcie Information | |
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 10586-10591 09/24/2009 | Confidential Source | Additional | Information | |
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 10625-10632 | 10/02/2009 | Confidential | ||
| Additional | Information | |||
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 10698-10699 | 10/13/2009 | Confidentia | Additional | Information |
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 10718-10719 | 10/13/2009 | ConfidentialSource | litigation Strategy | W/P Privilege; Not reasonably calculated to lead |
| 1092740937 | 05/28/2009 | Confidential Source | Providing New Witnesses | W/P Privilege; Not reasonably calculated to lead |
| 10905-10950 | 05/19/2009 | EMS Confidential Source | Providing New Witnesses | W/P Privilege; Not reasonably calculated to lead |
| 1096440978 | 06/02/2009 | Confidential Source | Additional | Information |
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 10991 | 06/22/2009 | Confidential Source | Additional | Information |
| RE: W/P Privilege; Not reasonably calculated to lead | ||||
| 11006-11010 | 06/23/2000 | Confidential Source | Additional | Information RE: W/P Privilege; Not reasonably calculated to lead |
Privilege Lo — Dated 2-23-2011¶
Jaffe, Weissint Fistos & Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|---|
| Epstein Molestations | to discovery of admissible evidence. | ||||
| 11075-11076 | 07/29/2009 | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | ||
| 11080-11082 | 07/31/2009 | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | ||
| 11085-11097 | 09/04/2009 | Confidential Source | Providing New Witnesses | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11123-11136 | 09/17/2009 | Confidential Source | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11140-11142 | 10/04/2009 | Confidential Source | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11150-11151 | 10/12/2009 | Confidential Source | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 10390-10393 | 09/19/2009 | Confidential Source | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11157-11165 | 10/25/2009 | Confidential Source | Providing New Witnesses | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11170-11174 | 06/23/2009 | Confidential Source | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11184-11185 | 05/27/2009 | Confidential Source | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11188-11195 | 05/28/2009 | Confidential Source | Bradley | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
| 11198-11200 | 05/28/2009 | Confidential Source | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11208-11214 | 05/29/2009 | Confidential Source | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11223-11236 | 06/01/2009 | Confidential Source | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11260-11266 | 06/24/2009 | Confidential Source | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. | |
| 11320-11325 | 07/30/2009 | Confidential Source | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
Privlle e lo — Dated 2-23-2011¶
Jaffe, Weissing. Fist s & Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | |
|---|---|---|---|---|---|
| 11372-11373 | 08/11/2009 | Confidential Source | [REDACTED] | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
| 11380-11383 | 08/12/2009 | Confidential Source | [REDACTED] | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
| 11438-11442 | 09/17/2009 | Confidential Source | [REDACTED] | Additional Information Epstein Molestations | RE: W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
| 11549-11550 | 10/01/2009 | Confidential source | [REDACTED] | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
| 11574-11579 | 10/13/2009 | Confidential Source | [REDACTED] | Litigation Strategy | W/P Privilege; Not reasonably calculated to lead to discovery of admissible evidence. |
| BOX 2 |
| BATES | DATE | TO | FROM | DESCRIPTION | OBJECTION |
|---|---|---|---|---|---|
| 08029-08032 | 09/14/2009 | [REDACTED] [REDACTED] | Tami Wolfe | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 08026-08028 | 05/01/2009 | Paul Cassell | [REDACTED] [REDACTED] | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 07738-07739 | 05/13/2009 | Paul Cassell | Bradley [REDACTED] | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 07747 | 09/17/2009 | Paul Cassell | [REDACTED] [REDACTED] | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 07758-07759 | 05/05/2009 | Jonathan Birkman | William Berger | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the |
Privilege Log — Dated 2-23-2011¶
M, Jaffe, Weissing,S Fistos&Lehrman¶
| DATE | TO | FROM | DESCRIPTION | OBJECTION | ||
|---|---|---|---|---|---|---|
| discovery of admissible evidence; protected by privacy rights | ||||||
| 07760-07765 | 09/11/2009 | █ █ █ | 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 | |
| 07766 | 10/11/2009 | Jacquie █ | 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 | |
| 07767-07784 | 05/01/2009 | 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 | |
| 07785-07790 | 06/26/2009 | 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 | |
| 07791 | 04/04/2009 | Paul Cassell | █ █ █ | Edwards | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 07792-07793 | 04/01/2009 | █ █ █ | 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 | |
| 07794-07841 | 04/04/2009 | Paul Cassell | █ █ █ | Full draft of motion to stay | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights | |
| 07842-07848 | 06/16/2009 | █ █ █ | Paul Cassell | Litigation Strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by |