JANE DOE v. UNITED STATES COURT FILE NO. 08-80736-CV-MARRA SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4¶
| Range | Description | Privilege(s) Asserted |
|---|---|---|
| 11/29/2006-12/1/2006 emails between Villafafia and prison | Work Product | |
| P-013972 | 5/18/2007 email from Villafafia to Matt Menchel informing him | Work Product |
| P-013973 | 5/18/2007 emails between Villafafia and expert witness regarding | Work Product |
| thru | securing pre-indictment consultation contract | 6(e) |
| P4113976 | Investigative Privilege | |
| P-013977 | 5/21/2007 email from Villafafia to Myesha (CEOS) it | Work Product |
| thru | 2423(b) charging question | 6(e) |
| P-013979 | Deliberative Process | |
| P-013980 | 5/21/2007 email from Villafafia to Matt Menchel and Jeff Sloman | Work Product |
| regarding guidance on grand jury presentation | 6(e) | |
| P4)13981 | 5/22/2007 email from Andy Lourie to Matt Menchel and Jeff Sloman | Work Product |
| (cc: Villafafia) re letter received from Gerald Lefcourt discussing | ||
| P-013982 | 5/23/2007 email from Jason Richards to Villafafia re extradition | Work Product |
| research | A/C privilege | |
| P-013983 | 5/23/2007 emails between Karen Atkinson and Villafafia | Work Product |
| thru | regarding decision to meet with counsel for Epstein | Deliberative Process |
| Ran e | Description | Privile e(s) Asserted |
|---|---|---|
| 6/14/2007-6/21/2007 emails between | Villafafia, Karen Atkinson, | 6(e) |
| meei th with counsel for Epstein | ||
| 6/26/2007 email from | to Jeff Sloman, Matt Menchel, | |
| 713/2007-7/4/2007 emails between | Villafafia and Andrew Lourie | |
| Ann | and possible resolution of case | |
| 6/12/2007-7/6/2007 series of emails between | Villafafia and | Work Product |
| 7/3/2007-7/13/2007 email chain between Matt Menchel and | 6(e) | |
| 7/16/2007 email from | Villafafia to Matt Menchel and Andrew | 6(e) |
| 7/18/2007 emails from | Villafafia to Andrew Lourie and Matt | 6(e) |
| 7/19/2007 email chain between | Villafafia, Andrew Lourie, Matt | 6(e) |
| Ran e | Description | Privile e(s) Asserted |
|---|---|---|
| P-014033 | 7/19/2007 email from Villafafia to Andrew Lourie and Matt | Work Product |
| Menchel regarding planned service of target letters | 6(e) | |
| P-014034 | 7/26/2007 email from Villafafia to Matt Menchel and Andrew | 6(e) |
| Lourie regarding proposed changes to the indictment | Work Product | |
| P-014035 | 7/31/2007 email from Villafafia to Jeff Sloman, Matt Menchel, | Work Product |
| P-014036 | 7/31/2007-8/2/2007 email chain between Jeff Sloman, Matt Menchel, | Work Product |
| Andrew Lourie, and Villafafia regarding plea negotiations | Deliberative Process | |
| P-014037 | 8/2/2007 email drom Villafafia to Jeff Sloman, Matt Menchel, | Work Product |
| P-014038 | 8/2/2007 emails between Matt Menchel, Jeff Sloman, Andy Lourie. and | Work Product |
| thru | Villafafia regarding letter received from Lilly Ann | Deliberative Process |
| P-014042 | 8/3/2007 Email from Villafafia to Matt Menchel, Andrew Lourie, | Work Product |
| P-014043 | Emails dated 8/6/2007 from Villafafia to Cyndee | Work Product |
| thru | Campos/Frederica Devlin and Jeff Sloman regarding Matt Menchel's | Deliberative Process |
| P-014044 | correspondence...EL)! to his departure. | |
| P-014045 | 8/7/2007 email chain between = Villafafia, Cyndee Campos, and | Work Product |
| thru | Alex Acosta regarding meeting to discuss Epstein matter | Deliberative Process |
| P-014046 | Investigative Privilege |
| Range | Description | Privilege(s) Asserted | |
|---|---|---|---|
| P-014047 | 8/7/2007 email from | Villafafia to Andy Lourie regarding deadline | Work Product |
| P-014048 | 8/7/2007 email from | Villafafia to Andrew Oosterbaan regarding | Work Product |
| P-014051 | 8/8/2007 emails between | Villafafia and Andrew Oosterbaan | Work Product |
| P-014052 | 8/8/2007 email chain between Andrew Oosterbaan, Alex Acosta, | Work Product | |
| P-014053 | 8/8/2007 email from | Villafafia to Drew Oosterbaan regarding | Work Product |
| P-014054 | 8/8/2007 email from | Villafafia to Alex Acosta, Cyndee Campos, | Work Product |
| P-014055 | 8/10/2007 Electronic correspondence from | Villafafia to expert | Work Product |
| witness reg. | topics for expert testimony | ||
| P-014056 | 8/10/2007 email from | Villafafia to Andrew Lourie regarding | |
| target letters and stain | to compel production of computers | ||
| P4314057 | 8/30/2007 email from m | Villafafia to Jeff Sloman, Andrew Lourie, | |
| P-014058 | 9/4/2007-9/6/2007 emails between | Villafafia and Jeff Sloman | Work Product |
| regarding planned participation of FBI ASAIC at 9/7/2007 meeting with | Deliberative Process |
| Range | Description Privilege(s) Asserted |
|---|---|
| 9/6/2007 emails between | Villafafia. Jeff Sloman, Andrew Lourie Work Product |
| Drew Oosterbaan, and Rolando | regarding status of plea Deliberative Process |
| 9/10/2007-9/14/2007 emails between | Villafafia, Andrew Lourie, |
| Jeff Sloman, Karen Atkinson, Rolando | Shawn Ball, and Alex |
| P-014069 9/10/2007 email from | Villafafia to Jeff Sloman and John Work Product |
| grand proceeding | |
| 9/11/2007 emails between | Villafafia, John McMillan, Drew |
| 9/10/2007-9/11/2007 emails between | Villafafia, Alex Acosta, and Work Product |
| Jeff Sloman regarding modifications to the proposed Non-Prosecution | Deliberative Process |
| 9/13/2007 emails from | Villafafia to Andrew Lourie, Alex Acosta, |
| Jeff Sloman, Rolando | , and Karen Atkinson regarding plea to |
| cha e | |
| 9/13/2007-9/14/2007 emails regarding | Villafafia research Work Product |
| 9/17/2007-9/19/2007 emails between | Villafafia, Rolando Work Product |
| Andrew Lourie, Alex Acosta, Karen Atkinson, and John McMillan | Deliberative Process |
| Range | Description Privilege(s) Asserted |
|---|---|
| 9/19/2007-9/20/2007 emails between | Villafafia, Andrew Lourie, Work Product |
| and Rolando regarding plea negotiations with counsel for | Deliberative Process |
| l in | |
| 9/20/2007 emails between = | Villafafia and Andrew Lourie |
| 9/21/2007 emails between | Villafafia and Andrew Lourie, Rolando Work Product |
| Karen Atkinson, and John McMillan regarding revisions to the | Deliberative Process |
| P-014161 9/21/2007 email from | Villafafia to Alex Acosta, Rolando Work Product |
| Karen Atkinson, and Andrew Lourie regarding review of Epstein | Deliberative Process |
| P4114170 prosecution | |
| 9/24/2007 series of emails between = | Villafafia, Alex Acosta, and |
| 9/23/2007-9/24/2007 series of emails between Alex Acosta, | Work Product |
| Villafafia, Andrew Lourie, Rolando =, | and Jeff Sloman regarding Deliberative Process |
| 9/20/2007-9/24/2007 emails between Alex Acosta, = | Villafafia, and |
| 9/24/2007 emails between | Villafafia and Rolando Work Product |
| regarding notifying Palm Beach Police Chief and victims about | Deliberative Process |
| 9/24/2007-9/25/2007 emails between Alex Acosta, | Villafafia, Work Product |
| Andrew Lourie, and Rolanda | regarding Lefkowitz email about Deliberative Process |
| in a ement | |
| 10/5/2007-10/16/2007 emails between | Villafafia, Jeff Sloman, |
| and Alex Acosta re selection of Special | and negotiation of |
| Range | Description | Privilege(s) Asserted |
|---|---|---|
| 10/18/2007 emails between | Villafaha and Jeff Sloman regarding | Work Product |
| Epstein's request to delay his change of plea | Deliberative Process | |
| 10/19/2007 emails between Jeff Sloman and | Villafaha regarding | Work Product |
| Special | Selection of Attorney Representative | Deliberative Process |
| P-014276 10/31/2007 email from Nesbitt Kurykendall to | Villafaila | Work Product |
| 11/2/2007-11/5/2007 emails between | Villafaha and Jeff Sloman | Work Product |
| regarding drafting 11/5/2007 letter from Sloman to Lefkowitz | Deliberative Process | |
| 11/5/2007-11/7/2007 emails from | Villafaha to Jeff Sloman | Work Product |
| inquiring about status of matter and contact by Epstein investigators | Deliberative Process | |
| 11/8/2007-11/14/2007 emails between | Villafaiia, Jeff Sloman, | Work Product |
| 11/14/2007-11/19/2007 emails between | Villafaiia, Jason | |
| Richards, Jeff Sloman, Rolando | Alex Acosta, and Karen |
| Range Description | Privilege(s) Asserted |
|---|---|
| 11/19/2007 emails between | Villafafia, Jeff Sloman, and Rolando Work Product |
| about efforts by Epstein's counsel to change date for change of | Deliberative Process |
| 11/19/2007-11/28/2007 emails between | Villafafia, Nesbitt Work Product |
| 11/28/2007 correspondence between | Villafafia, Andrew Lourie, |
| Drew Oosterbaan, and Rolando | regarding Lefkowitz 11/27/2007 |
| 11/29/2007-12/1/2007 emails between | Villafafia, Alex Acosta, Work Product |
| Jeff Sloman, Cyndee Campos, and Andrew Lourie regarding draft | Deliberative Process |
| 12/3/2007 emails between | Villafafia, Alex Acosta, and Jeff Work Product |
| Sloman regarding history of plea negotiations and drafting response to | Deliberative Process |
| Sloman, | Villafafia, Nesbitt Kuyrkendall, Cyndee Campos, and |
| 12/6/2007 emails between | Villafafia, Andrew Lourie, Cyndee Work Product |
| Campos, Jeff Sloman, Alex Acosta, Karen Atkinson, and Nesbitt | Deliberative Process |
| 12/6/2007-12/7/2007 emails between | Villafafia, Cyndee Campos, Work Product |
| Karen Atkinson, Jeff Sloman, and Alex Acosta regarding draft victim | Deliberative Process |
| Ran e | Description | Privile e(s) Asserted | |
|---|---|---|---|
| P-014421 | 12/6/2007-12/7/2007 emails between | Villafaila, Nesbitt | Work Product |
| thru | Kuyrkendall, Jason Richards, Jeff Sloman, Cyndee Campos, Annette | Deliberative Process | |
| P-014428 | Castillo, Karen Atkinson, and Shawn Ball regarding request from State | 6(e) | |
| Attorney's Office for draft plea proffer | Attorney-Client Privilege | ||
| P-014429 | 12/9/2007-12/12/2007 emails between | Villafafia, Jeff Sloman, | Work Product |
| thru | Jason Richards. Nesbitt Kuyrkendall, Annette Castillo, Karen Atkinson, | Deliberative Process | |
| P-014439 | and Rolando | regarding drafting response to personal attacks and | |
| upcomin meeting with Ken Starr | |||
| P-014440 | 12/11/2007 email from | Villafafia to Jeff Sloman and Alex Acosta | Work Product |
| regarding call with lawyer for Jane Doe #2 (T.M.) | Deliberative Process | ||
| P-014441 | 12/12/2007 emails between | Villafafia, Frederica Devlin, and Bob | Work Product |
| Senior regarding planning indictment review | Deliberative Process | ||
| P-014442 | 12/14/2007 email from | Villafafia to Jeff Sloman, Alex Acosta, | Work Product |
| P-014443 | 12/14/2007 email from | Villafafia to Alex Acosta, Jeff Sloman, | Work Product |
| Rolando | and Karen Atkinson with draft letters to State | ||
| P-014444 | 12/17/2007 email from | Villafafia to Jeff Sloman inquiring about | Work Product |
| P-014445 | 12/19/2007 email from | Villafafia to Alex Acosta and Jeff Sloman | Work Product |
| thru | summarizing research into other cases where individuals were charged | Deliberative Process | |
| P-014447 | with violating 2422(b) based upon the use of a telephone | 6(e) | |
| P-014448 | 12/19/2007 emails between | Villafafia, Alex Acosta, and Jeff | Work Product |
| thru | Sloman regarding drafting response to concerns raised during December | Deliberative Process | |
| P-014454 | 14, 2007 meeting between Epstein counsel Alex Acosta, Jeff Sloman, | ||
| the FBI SAIC, and Villafafia |
| Ran e Description | Privile e(s) Asserted |
|---|---|
| 12/19/2007 email from Villafafia to Alex Acosta, Jeff Sloman, | Work Product |
| 12/20/2007 emails between Villafafia and Jeff Sloman regarding | Work Product |
| 12/18/2007-12/21/2007 emails between | Villafafia and other Work Product |
| AUSAs regarding other instances of charging 2422(b) based on the use | 6(e) |
| P-014486 12/21/2007 email from Villafafia to Jeff Sloman with thoughts on | Work Product |
| recent correspondence from Jay Lefkowitz raising concerns about | Deliberative Process |
| interpretation of the Non rosecution A | eement |
| P-014487 12/27/2007 email from Villafafia to Alex Acosta and Jeff Sloman | Work Product |
| regarding proposed approach to providing potential notice of breach of | Deliberative Process |
| Karen Atkinson, Rolando and | Villafafia regarding Jay |
| P-014500 1/2/2008 email from Jeff Sloman to Alex Acosta and | Villafafia Work Product |
| regarding telephone conversation with State Attorney's Office about | Deliberative Process |
| 1/2/2008 emails between Alex Acosta, | Villafafia, and Jeff Sloman |
| regarding requests from Alex Acosta to | Villafaha for information |
| Range | Description | Privilege(s) Asserted | |
|---|---|---|---|
| P-014507 | 1/2/2008 emails from | Villafafia to Alex Acosta and Jeff Sloman | Work Product |
| thru | regarding renewed plea negotiations for federal plea agreement | Deliberative Process | |
| P-014508 | 6(e) | ||
| P-014509 | 1/3/2008 emails between | Villafafia, Alex Acosta, and Jeff Sloman | Work Product |
| thru | regarding Alex Acosta telephone conference with Jay Leflcowitz where | Deliberative Process | |
| P-014519 | Lefkowitz admitted that he never intended to have Epstein plead guilty | ||
| P-014520 | 1/3/2008 email from | Villafafia to Nesbitt Kuyrkendall and Jason | Attorney client privilege |
| Richards regarding renewed plea negotiations and press coverage of | Deliberative Process | ||
| .p stein matter. | Investigative Privilege | ||
| P-014521 P-014521 | 1/7/2008 email from | to Alex Acosta, Jeff Sloman, | Work Product |
| thru | Robert Senior, Karen Atkinson, and Rolando | regarding proposed | Deliberative Process |
| P-014522 | additional investigative steps in Epstein case. | 6(e) | |
| P-014523 | 1/9/2008 email from Jeff Sloman to Drew Oosterbaan, Alex Acosta, and | Work Product | |
| P-014524 | I/9/2008-1/14/2008 emails between | Villafafia, Drew Oosterbaan, | Work Product |
| thru | Myesha | , Nesbitt Kuyrkendall, and Jason Richards regarding | Deliberative Process |
| P-014550 | assigning a CEOS attorney to the investigation, meeting with the CEOS | Attorney-client privilege | |
| P-014551 | 1/17/2008 email from Nesbitt Kuyrkendall to | Villafafia regarding | Attorney-client privilege |
| P-014552 | 1/23/2008 email from | Villafaria to Jeff Sloman and Alex Acosta | Work Product |
| regarding FBI involvement in meeting in DC | Deliberative Process |
| Range | D isciirion | Privileges) Asserted |
|---|---|---|
| 1/25/2008 emails between | Villafafia and Myesha | Work Product |
| P-014557 1/25/2008 email from Nesbitt Kuyrkendall to | Villafafia and | 6(e) |
| P-014558 1/29/2008 email from | Villafafia to Drew Oosterbaan and Myesha | Work Product |
| 1/28/2008-1/29/2008 emails between | Villafafia and Myesha | Work Product |
| 1/30/2008 emails between | Villafafia, Alex Acosta, and Jeff | Work Product |
| Range | Description | Privilege(s) Asserted |
|---|---|---|
| 1/31/2008 emails between | Villafaha and Nesbitt Kuyrkendall | Work Product |
| 1/31/2008-2/1/2008 emails between | Villafafia, Jeff Sloman. Alex | Work Product |
| 2/20/2008-2/21/2008 emails between Drew Oosterbaan, | Work Product | |
| Atkinson, Alex Acosta, Rolando | and Myesha | regarding |
| 2/12/2008-2/22/2008 emails between | Villafafia, Nesbitt | |
| Kuyrkendall, Jason Richards, and Myesha | analyzing facts | |
| 2/25/2008 emails between | Villafafia and Caroline Heck | Work Product |
| P-014628 2/25/2008 email from | Villafafia to Jeff Sloman, Robert Senior, | Work Product |
| Rolando Karen Atkinson, andilisha | regarding result | |
| of consultation with Caroline Heck | about grand jury question |
| Range | Description | Privilege(s) Asserted |
|---|---|---|
| P-014629 2/26/2008 email from | Villafafia to Myesha regarding | Work Product |
| CEOS review and draft indictment package | Deliberative Process | |
| 2/26/2008 email from | Villafafia to Jeff Sloman regarding Jeff | Work Product |
| 2/21/2008-2/27/2008 emails between | Villafafia, David Weinstein, | Work Product |
| Robert Senior, Karen Atkinson, and Rolando | regarding notifying | |
| 2/28/2008 emails between | Villafafia and Susan Roe regarding | Work Product |
| 2/27/2008-2/28/2008 emails between | Villafafia, Nesbitt | Work Product |
| 2/29/2008 emails between Jeff Sloman, | Villafafia, Robert Senior, | Work Product |
| Ran e | Description | Privile e(s) Asserted |
|---|---|---|
| 3/5/2008-3/6/2008 emails between | Villafafia, Alex Acosta, Jeff | Work Product |
| Sl_oman t | Drew Oosterbaan, Robert Senior, Myesha | Rolando |
| M, | and Karen Atkinson regarding meeting in DC, additional | |
| 3/10/2008-3/12/2008 emails between | Villafafia, Robert Senior, | Work Product |
| Myesha | Krishna Patel, Nesbitt Kuyrkendall, E.J. Yera, and | |
| 3/12/2008 emails between | Villafafia, Drew Oosterbaan, and | Work Product |
| Myesha | regarding CEOS meeting with Epstein counsel | |
| 3/14/2008 emails between | Villafafia, Rolando | Karen Work Product |
| 3/12/2008-3/17/2008 emails between Villafafia, Nesbitt | Work Product | |
| 3/14/2008-3/17/2008 emails between Villafafia, Nesbitt | Work Product | |
| parties to this litigation |
| Range | Description | Privilege(s) Asserted |
|---|---|---|
| 3/14/2008-3/19/2008 emails between | Villafafia, Nesibtt | Work Product |
| Atkinson, and Rolando | about Epstein attempts to contact victims | |
| 3/19/2008-3/21/2008 emails between | Villafafia, Drew Oosterbaan | Work Product |
| Atkinson, Rolando | , Nesbitt Kurykendall, and Jason Richards | |
| them in connection with the de | sitions | |
| 3/28/2008 emails between | Villafafia, Nesbitt Kuyrkendall, Jeff | Work Product |
| 3/31/2008 emails between | Villafalia, Jeff Sloman, Robert Senior, | 6(e) |
| 4/2/2008 emails between | Villafaila, Alex Acosta, Jeff Sloman, | Deliberative Process |
| Karen Atkinson, Robert Senior, Rolando | and Nesbitt | |
| with Alex Acosta and instructions to direct question to | Villafafia |
| Range | Description | Privilege(s) Asserted |
|---|---|---|
| 4/4/2008-4/7/2008 emails between | Villafafia, Robert Senior, | Work Product |
| 4/10/2008-4/18/2008 emails between | Villafaha, Robert Senior, | 6(e) |
| 4/11/2008-4/23/2008 emails between | Villafaha, Jeff Sloman, and | Work Product |
| P-014865 4/29/2008 email from | Villafaila to Robert Senior, Jeff Sloman, | Work Product |
| Karen Atkins, on Rolando | re grand jury presentation | |
| 4/21/2008-5/1/2008 emails between | Villafaiia, Robert Senior, Jeff | 6(e) |
| re are for | nd u presentation | |
| 5/2/2008 emails between Robert Senior, | Villafafia, Karen | 6(e) |
| 4/29/2008-5/2/2008 emails between | Villafafia and Jeff Sloman | 6(e) |
| Ran e | Description | Privlie e(s) Asserted |
|---|---|---|
| 517/2008-5/9/2008 emails between | Villafafia, Robert Senior, Jeff | Work Product |
| 5/15/2008-5/16/2008 emails between Jeff Sloman, | Villafafia, and | Work Product |
| Robert Senior regarding receiving final approval from DC | Deliberative Process | |
| 5/19/2008-5/22/2008 emails between | Villafafia, Karen Atkinson, | 6(e) |
| negotiations; and status of | investigation | |
| 5/23/2008-5/27/2008 emails between | Villafafia, Robert Senior, | |
| 8/15/2008 email from | Villafafia to Alex Acosta, Jeff Sloman, | Work Product |
| Robert Senior, Karen Atkinson, and Dexter Lee containing draft | Deliberative Process |