1251

PDF Document Uploaded Feb 2, 2026 by Unknown Updated by admin 1 views 6.34 MB
Court Records as described by folder names.
Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
Extracted Text

Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants I IN THE CIRCUIT COURT OF THE FIFTEENTH WDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO MOTION TO STRIKE EPSTEINS UNTIMELY SUPPLEMENTAL EXHIBITS AND TO STRIKE ALL EXHIBITS AND ANY REFERENCE TO DOCUMENTS CONTAINING PRIVILEGED MATERIALS LISTED ON EDWARDS PRIVILEGE LOG Counter-Plaintiff Edwards through undersigned counsel hereby files this Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log and in support states as follows Summary In a transparent attempt to either conduct trial by ambush or sufficiently muddy the waters to request yet another continuance Epstein has sporadically disclosed new trial exhibits over the past month in direct violation of multiple orders of this Court concerning both the deadline to disclose exhibits and the prohibition against general catch-all exhibit categories On February Edwards was required to file his General Objection to Untimely Composite Exhibits attached hereto as Exhibit A in order to preserve his objections to this highly prejudicial conduct FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Finally on February undersigned counsel sent the following communication to Epsteins counsel Your recent efforts to add documents not specifically identified to earlier listed categories prompts me to remind you that Judge Hafele has required that documents be identified in a manner that enables the opposing party to know in advance exactly which documents are intended to be offered in evidence We assume you have complied with that directive and are relying on that compliance On March only two days later and on the eve of trial Epstein disclosed for the first time new trial exhibits consisting of at least forty-nine privileged e-mails generated when Edwards was at Rothstein Rosenfeldt Adler RRA and engaged in actively prosecuting both civil claims against Epstein and the still-pending CVRA challenge to Epsteins extraordinary sweetheart plea deal These e-mails have been listed on Edwards privilege log since February Epstein filed Edwards privilege log with this Court on April and has not obtained an order either overruling these privilege assertions or compelling production of these documents At this time it is unknown exactly how Epstein obtained these privileged materials although it is clear that he did so in secret and has waited until the last possible moment to reveal that he is improperly in possession of Edwards privileged materials The late disclosure of these trial exhibits is in direct violation of the Courts July Order the Courts December oral ruling concerning trial exhibits not-yet-produced and prohibiting general catch-all exhibits and the Courts January ruling Furthermore despite the e-mail correspondence being listed on Edwards Privilege Log it is now clear that Epstein surreptitiously obtained these privileged communications years ago and his counsel failed to comply with their ethical obligations once coming into possession of clearly privileged materials listed on Edwards privilege log to immediately relinquish possession of those materials Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Undersigned counsel as well as Paul Cassell Esq as counsel for L.M E.W and Jane Doe has since notified Epsteins counsel Scott Link and Kara Rockenbach that they are in possession of privileged materials and has requested that counsel take all ethically appropriate steps to turn over this information That repeated request has been repeatedly denied Edwards requests that the Court strike all late disclosed trial exhibits including specifically but not limited to the privileged materials identified on Edwards Privilege Log which Epsteins counsel has acknowledged have been in the possession of Epstein lawyers for years since at least Edwards further requests that the Court strike and preclude Epsteins counsel from making any reference to materials that are clearly attorney-client and work-product privileged and which have been listed on Edwards privilege log for seven years In addition to the violation of multiple Court orders and the unethical possession of these materials not a single e-mail has any relevance whatsoever because Epstein did not have possession of them prior to instituting this malicious lawsuit against Edwards and therefore could not have relied on them to support probable cause Epstein has never testified that he relied upon them to continue this malicious lawsuit against Edwards and the communications generated in the course of the prosecution of claims against Epstein relate to conduct subject to the absolute protection of the litigation privilege Finally Edwards requests that the Court require Epsteins counsel to show cause why they should not be sanctioned for their attempt to conduct trial by ambush by using improperly obtained privileged materials and then unethically refusing to destroy or turn over all copies of the privileged materials once being put on notice of same Any subsequent sanction should include at a minimum an award of all costs and fees incurred in dealing with these issues Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log The Court Orders Violated by Epstein On July the Court entered its Order Specially Setting Trial which set the case for trial beginning on December In its Order the Court required that the Pre-Trial Stipulation include each partys numbered list of trial exhibits with specific objections if any to schedules attached to the stipulation emphasis added The Court made clear that the parties would be strictly limited to exhibits disclosed on the schedules attached to the Pre-Trial Stipulation absent agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause shown emphasis added Thus the Courts July Order limited the parties to only those trial exhibits that were specifically identified and disclosed on the Pre-Trial Stipulation In October and November the parties began exchanging Exhibit Lists and producing proposed exhibits in connection with the Courts Order Epsteins Exhibit List listed as Exhibit miscellaneous the broadest catch-all provision possible All documents produced by any party or non-party in this matter At the December hearing the Court instructed that any identified exhibits not previously produced must be provided to opposing counsel by no later than December See e.g Tr at The Court also cautioned that general catch-all exhibit categories would not be permitted and that instead the specific documents covered by Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log such exhibits must be separately identified and produced See e.g Tr at The message to the parties was clear trial by ambush would not be permitted On December Epstein produced copies of certain listed exhibits pursuant to that directive Epsteins Exhibit contained twenty-seven RRA emails None of these emails were listed on Edwards April Privilege Log On December the parties filed the Pre-Trial Stipulation Epsteins Exhibit List was attached to the Pre-Trial Stipulation Thus pursuant to the Courts December ruling and the December exhibit exchange Epsteins Exhibit was comprised of the emails that had been specifically identified and produced Moreover pursuant to the Courts July Order Specially Setting Trial Epstein was strictly limited to those specific documents absent a showing of good cause which would necessarily require the filing of some motion seeking relief from the Court Epstein as has been consistent over the past few months chose to ignore these Court Orders and instead began piecemeal producing additional proposed exhibits throughout the month of February which finally prompted undersigned counsel to send correspondence to Epsteins counsel objecting to these flagrant violations of the Courts rulings See Ex A The Courts oral ruling was memorialized on January when the Court entered its Order on Epsteins Revised Omnibus Motion in Limine Section Edwards Trial Exhibits This Order required Edwards to produce all trial exhibits that had not already been produced by December and to produce all specific exhibits to a general catch-all category by no later than January Although the Order did not specifically require Epstein to do the same the reason was straightforward Epstein claimed that he already produced all specific trial exhibits on December Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Epsteins continued violation of the Courts Orders culminated on March with the eve-of-trial production of new emails under Exhibit which include at least forty nine privileged emails that are listed on Edwards Privilege Log This improper prejudicial and unethical conduct should not be permitted by the Court Timeline of the Privileged Materials at Issue In order to orient the Court regarding Edwards Privilege Log Edwards has compiled the following timeline concerning the privileged e-mail communications at issue Because the privileged materials at issue are e-mail communications from RRA Epstein originally sought these records in the Bankruptcy Court to be produced by the Trustee appointed to oversee the RRA bankruptcy proceeding Edwards has highlighted the key State Court docket entries for the Courts convenience Bankruptcy April Epstein propounded a broad subpoena to the Trustee for RRA as an interested Court party in the bankruptcy case of In re Rothstein Rosenfeldt Adler RBR requesting tens of thousands of emails the subpoena was directed to the bankruptcy trustee because the trustee was in possession of all RRA emails Epstein filed a Motion to Compel that production from the trustee DE Bankruptcy July LM one of Epsteins victims filed an objection and amended motion for Court protective order DE explaining that the emails requested were barred from disclosure based on privilege and relevance grounds Bankruptcy August Judge Rey in the bankruptcy action entered an order regarding production of Court the emails to a special master Judge Camey appointed to oversee the emails produced and to prepare a privilege log DE Bankruptcy September After having received emails Special Master Camey moved for Court clarification of the Order and made suggestions that LMs attorneys which included Edwards were in a better position to create a privilege log Copy attached hereto as Exhibit Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Bankruptcy September Edwards moved for protective order through counsel Jack Scarola adopting Court LMs arguments for a protective order and invoking work-product privilege DE Bankruptcy September LM joined in that DE motion and requested further clarification DE Court Bankruptcy October Hearing on Motion to Clarify before Robert Camey Court Bankruptcy October The bankruptcy court entered an Order which clarified its earlier Order DE Court requiring that the trustee provide the emails at issue to Farmer Jaffe Weissing Edwards Fistos Lehrman Edwardss firm at the time which was representing LM and requesting FJWEFL prepare the log The order also provided a procedure for the special master to hold a hearing about assertions of privilege Bankruptcy October Bankruptcy court cancelled the hearing on the motion for protective order Court DE State Court November Epstein files his amended privilege log Bankruptcy December LM filed a motion requesting a stay of the Order directing the preparation of Court a privilege log until after the time when the State court ruled on the then pending Motion for Summary Judgment DE Bankruptcy December Bankruptcy court entered an order extending the time for production of the Court privilege log until January DE State Court January FJWEFL produced pages of non-privileged documents to Epstein Bankruptcy January FJWEFL served a privilege log and the sufficiency of that log was challenged Court by Epstein in the bankruptcy court DE State Court February Epstein filed a Motion to Compel/Motion to Determine if Privilege Claims are Waived for failure to provide a privilege log Bankruptcy February FJWEFL filed a privilege log in the Bankruptcy Court Court Bankruptcy February FJWEFL filed an updated privilege log the current privilege log Court detailing the emails where privilege was being maintained In addition to filing the privilege log FJWEFL produced to counsel for Epstein pages of documents divided into two separate categories respectively labeled attorneys eyes only and Farmer Jaffe Irrelevant E-Mails Two boxes of attorneys eyes only documents were produced containing pages of documents in the first box and pages of documents in the second box Two Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log additional boxes of Farmer Jaffe Irrelevant E-Mails were also produced containing pages of documents in the first box and pages of documents in the second box State Court March Judge Crow entered an order staying the subpoena to the trustee State Court May Order setting hearing on all motions relating to discovery and privilege issues for July State Court July Epsteins Motion for Leave to Use Attorneys Eyes Only Documents produced under confidentiality agreement State Court July Edwards protective order granted Epstein request for all emails is overbroad and not necessarily calculated to lead to admissible evidence State Court March Epstein Motion to Compel and Amend Protective Order relating to the subpoena to the Bankruptcy Trustee State Court April Order requiring Edwards to produce any non-privileged documents as identified in paragraph of Edwardss Motion to Compel and Amend Protective Order State Court April Epstein files Edwards February Privilege Log from the Bankruptcy Court in this case This Privilege Log identifies many of the privileged materials that Epstein is now attempting to use at trial State Court April Epstein Motion to Compel production of documents from Edwards and for Sanctions State Court April Fowler White Motion to Withdraw State Court May Agreed Order on Fowler White Withdraw State Court May Edwards produces pages of additional responsive documents compliance with April Order State Court May Crow Order Requiring Better Privilege Log State Court May Edwards Motion for Clarification on Discovery Issues To clarify the scope of the May Order State Court May Epstein Motion to Compel Discovery Responses and for Sanctions State Court May Epstein Amended Motion to Compel Discovery Responses and for Sanctions Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log State Court June Order Setting hearing on Motion for Clarification State Court August Hearing on Motion for Clarification on Discovery Issues State Court August Scarola letter to Judge Crow enclosing proposed Order on Motion for Clarification on Discovery Issues Provided before Epsteins voluntarily dismissed his claims against Edwards State Court August Epstein voluntarily dismisses case against Edwards without prejudice State August Judge Crow grants Edwards Motion for Clarification and Court vacates his May Order requiring an amended privilege log Edwards April Privilege Log remained in full force and effect Epstein never challenged the sufficiency of that privilege log or made any attempt to overrule Edwards privilege assertions or compel production of these privile,:e materials To summarize Edwards was provided with a total emails to evaluate On January Edwards produced pages of non-privileged emails to Epstein On February Edwards produced an additional pages of emails which included pages of emails that were designated Attorneys Eyes Only Between the January and February productions Edwards turned over pages of emails to Epstein Edwards properly listed the remaining pages of emails on his privilege log filed on February in the Bankruptcy Court Pursuant to Epsteins July Motion for Leave to Use Attorneys Judge Crows Order also required Edwards to file a written response specifically addressing the production sought in Paragraph of Epsteins Motion to Compel and Amend Protective Order ofMarch the response shall identify in a proper privilege log as referenced in the Courts May Order responsive documents withheld from production on the basis of any assertion of privilege Paragraph of Epsteins Motion to Compel concerned e-mails between RRA laWYers and either the Federal Government Conchita Sarnoff and any news reporters Because Epstein had already voluntarily dismissed his action against Edwards Edwards did not produce any written response to Paragraph or any e-mails between RRA and these third-parties And Epstein made no effort to seek production of these e-mails at least not through legitimate means Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Eyes Only Documents Produced Under Confidentiality Agreement the Attorneys Eyes-Only documents are governed by a confidentiality agreement On April Epstein filed Edwards privilege log in this case Pursuant to Judge Crows August Order vacating his prior Order requiring Edwards to file a better privilege log the February Privilege Log filed in this case on April remains in full force and effect As referenced in the chart above in May Epstein argued that Edwards privilege log was insufficiently descriptive resulting in his inability to question the various assertions of privilege Based on this contention alone it is clear that Epstein was not in possession of the documents listed on Edwards privilege log Therefore Epstein could not possibly have relied on these privileged documents at any time before the filing or during the continuation of his lawsuit against Edwards which was voluntarily dismissed only three months later on August After voluntarily dismissing his claims against Edwards Epstein never sought to overrule any of these privilege assertions or to compel production of the privileged materials listed on the log Epstein has obviously been on notice of the privileged nature of those documents knew they had been withheld from production and knew that it was unethical to retain the privileged documents regardless of how he had acquired them Epsteins attempt to confirm with David Vitale Esq who only recently appeared in this case that no confidentiality agreement exists further demonstrates the trial by ambush strategy of Epsteins counsel The attorney to discuss that issue with and to specifically identify that it related to RRA emails was Jack Scarola Esq who has been handling the case since its inception Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Yet Epstein now seeks to use at least forty-nine clearly privileged emails listed on the February Privilege Log and has refused repeated requests to identify how he came into possession of the privileged materials as well as repeated requests to turn over and to destroy the privilege materials as his counsel is ethically required to do A Comparison of Edwards Privilege Log and Epsteins March Untimely Exhibits Epstein and his counsel are knowingly in possession of at least forty-nine privileged e-mails that are designated on Edwards Privilege Log Number of Privileged Emails Bates Numbers from Epsteins Bates Number/Range on in Epsteins Possession Untimely Supplemental Edwards February TOTAL Exhibit Privilege Log Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Summary of Relief Sought by Edwards Edwards respectfully requests entry of an Order for the following relief a Striking all exhibits produced by Epstein after December in violation of the Courts July Order December Oral Ruling and January Order Striking all proposed Epstein exhibits that contain or reference privileged materials specifically listed on Edwards Privilege Log Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Striking any and all pleadings motions and portions of deposition transcripts in which Epsteins counsel improperly utilized privileged materials to drive the nature of that discovery Precluding Epsteins counsel from making any mention or use of any struck exhibits or pleadings including the privileged materials Ordering Epstein and his counsel to show cause as to how and when they came into possession of materials listed on Edwards Privilege Log Awarding Edwards his attorneys fees and costs from the date Epstein first came into possession of privileged materials used them in defending his case and failed to properly disclose his possession of these materials to Edwards and the Court and Any such further relief as the Court deems just and proper given the circumstances WHEREFORE Counter-Plaintiff respectfully requests that the Court enter an Order granting this Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log as requested herein Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this th day of March ttorney E-Mails jsx searcylaw.com and mmccann searcylaw.com Primary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Scott Link Esq Link Rockenbach P.A Scott linkrocklaw.com Kara linkrocklaw.com Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Bradley Edwards Esquire staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL Phone Fax IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant GENERAL OBJECTIONS TO UNTIMELY COMPOSITE EXHIBITS Counter-Plaintiff Bradley Edwards by and through undersigned counsel hereby files this General Objections to Untimely Composite Exhibits and as grounds therefor states as follows At the December special-set hearing the Court ordered Counter-Plaintiff to produce copies of any exhibits that had not previously been produced by no later than December Tr That ruling was memorialized the Courts January Order on Plaintiff/Counter-Defendant Jeffrey Epsteins Revised Omnibus Motion in Limine Section Edwards Trial Exhibits as follows On or before December Edwards shall produce to Epstein all trial exhibits that have not been previously produced in the form to be introduced at trial Yet on February undersigned counsel received letter correspondence from Epsteins counsel which enclosed a flash drive containing additional documents for Epsteins EXHIBIT A Case No General Objection to Untimely Composite Exhibits Page2 of4 trial Exhibit Nos and We are still obtaining additional public records and will provide those to you upon our receipt The numbered exhibits are catch-alls as follows a Court docket and all court filings referenced therein for L.M Jeffrey Epstein case no Court docket and all court filings referenced therein for E.W Jeffrey Epstein case no Court docket and all court filings reference therein for Jane Doe Jeffrey Epstein case no All public records and news articles relating to Scott Rothstein Rothstein Rosenfeldt Adler Bradley Edwards and any witnesses listed by either party All court dockets and filings in all matters against Jeffrey Epstein relating to any victims claims Edwards objects to all such late produced exhibits whether contained in the February flash drive or intended to be produced in the future as violative of the Courts December ruling and January order Additionally the Court has previously ruled that with regard to any catch-all exhibits listed on either partys exhibit list the party must separately identify and list individually each exhibit sought to be relied upon by the listing party Edwards therefore reserves all objections to all composite exhibits that fail to comply with this order by the Court Case No General Objection to Untimely Composite Exhibits Page of4 I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this th day of February JAc?s iAROLA Flo_rld Bar No DAVID VITALE JR Florida Bar No Attorney E-Mail jsx searcylaw.com and mmccann searcylaw.com Primary E-Mail ScarolaTeam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorney for Plaintiff Case No General Objection to Untimely Composite Exhibits Page of5 Bradley Edwards Esquire staff.efile pathtojustice.com Andrews Avenue Suite Fort Lauderdale FL Phone Fax COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Case No General Objection to Untimely Composite Exhibits Page of5 Phone Fax Attorneys for Scott Rothstein IN THE,CIRCUIT COURT OF THE th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION AG CASE NO Judge David Crow JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROT STEIN individually artd BRADLEY EDWARDS individually Defen ants/Counter-Plaintiffs PLAIN FF JEFFREY EPSTEINS NOTICE OF FILING PRIVILEGE LOG OF RMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN DATED FEBRUARY IN SUPPORT OF PLAINTIFFS OTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plainti Jeffrey Epstein by and through his undersigned counsel and pursuant to the Florida Rules of Civil Procedure hereby gives notice of filing the Privilege Log of Farmer Jaffe Weissing Ed ards Fistos Lehrman Dated February attached hereto as Exhibit in Support of aintiff Motion to Compel Production of Documents From Defendant Bradley Edwards and or Sanctions Dated April seph Ackerman Jr Florida Bar No FOWLERWHITE Epstein Rothstein and Edwards Case No AG FOWLER WHITE INRE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A Debtor CASE NO CHAPTERll I PRIVILEGE LOG FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN Dated February Total of pages EXHIBIT Privilege Log Dated Farmer Jaffe Weissing Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Spencer Kuvin Transcript of Alfredo Rodriguez Joint W/P Priv Deposition Bradley Edwards Katherine Ezell WPS-Confidential-General Joint W/P Priv Financial Disclosure/Discovery Bradley Edwards Amy Ederi WPB-General-Confidential Joint W/P Priv Bradley Edwards Kikka Claudio C.M.A vs Epstein et Joint W/P Prlv al File Bradley Edwards Paul Cassell Report this as a parole violation Joint W/P Priv Bradley Edwards Margaret Berk Scanned document from Joint W/P Priv Margaret Berk Bradley Edwards Katherine Ezell Subpoena directed to the Joint W/P Priv investigators Adam Horowitz Jacquie Johnson Epstein-Depa-New York Joint Priv Bradley Edwards Spencer Kuvin RE:Transcript of Alfredo Joint W/P Priv Rodriguez Deposition Bradley Edwards Mercedes Estrada RE:Epstein vs Jane Doe Joint W/P Priv Epstein vs Jane doe No Bradley Edwards Spencer Kuvin RE Epstein Depo Joint W/P Priv Adam Horowitz Jacquie Johnson Trump Depo moved to Joint W/P Priv in NY Jacquie Johnson Kikka Claudio FW Out of state subpoenas Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Letter regarding Joint W/P Priv Leslie Wexner Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson RE Epstein-Notice of production Joint Priv from non parties/depo of Jane Doe Bradley Edwards Katherine Ezell RE Leslie Wexner Joint W/P Priv Bradley Edwards Amy Ederi FW Epstein Oepo Joint W/P Priv Bradley Edwards Katherine Ezell RE Leslie Wexner Joint W/P Priv Bradley Edwards Katherine Ezell FW:meeting atty fr wexner Joint W/P Priv Bradley Edwards Stuart Mermelstein Meeting w/Leslie Wexner Joint W/P Priv Adam Horowitz Jacquie Johnson Depo Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein-depo of Alan Dershowitz Joint Priv Bradley Edwards Stuart Mermelstein Leslie Wexner Joint W/P Priv Bradley Edwards Amy Ederi RE:Regular Monthly Cong Call Joint W/P Priv Bradley Edwards Katherine Ezell RE:Regular Monthly Cong Call Joint Priv Bradley Edwards Spencer Kuvin RE:Epstein commissioner Joint W/P Priv appointees Bradley Edwards Katherine Ezell Possible witness from Joint W/P Priv Switzerland Katherine Ezell Bradley Edwards RE:Article:Bear Stearns Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Katherine Ezell Bradley Edwards Article:Bear Stearns Joint W/P Priv Amy Ederi Bradley Edwards Article:Bear Stearns Joint W/P Priv Katherine Ezell Bradley Edwards USAO Chose Bradley Edwards Joint W/P Priv conversation Stuart Bradley Edwards RE:Epstein Depo;possible Joint W/P Priv Mermelstein deponents Katherine Ezell Bradley Edwards Discussion about possible Joint W/P Priv witness from Switzerland Spencer Kuvln Bradley Edwards FW:Transcript of Alfrefo Joint W/P Priv Rodriguez Depo and Copperfeild and Clintons whereabouts Mercedes Bradley Edwards RE:Epstein vs.Jane Doe Joint Priv Estrada Adam Horowitz Bradley Edwards RE:Motion for protective Joint W/P Priv order/discussion Spencer Kuvin Bradley Edwards Discussion RE:Wexner Joint W/P Priv involvement Katherine Ezell Bradley Edwards Wexner served subpoena OH Joint W/P Priv Katherine Ezell Bradley Edwards RE:Leslie Wexner Bob Joint W/P Priv Spencer Kuvin Bradley Edwards RE:Meeting w.Stanely Arkin Joint W/P Priv Adam Horowitz Bradley Edwards RE:Epstein;Larry Visoski Joint W/P Priv confirmed Stuart Bradley Edwards RE:Leslie Wexner attorney info Joint W/P Priv Mermelstein Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Spencer Kuvin Jacquie Johnson Attachment:Kellen Trump Joint W/P Priv subpoena Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint Priv Mercedes Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv Estrada Adam Horowitz Jacquie Johnson RE:Epstein Depos in Joint W/P Priv NV OH Adam Horowitz Jacquie Johnson Maxwell,Trump Wexner convo Joint W/P Priv RE:Depo dates Adam Horowitz Jacquie Johnson Maxwell,Trumo Wexner 267convo Joint W/P Priv RE:Depo dates cont Stuart Bradley Edwards Wexler Lawyers info Joint W/P Priv Mermelstein Adam Horowitz Jacquie Johnson Epstein Oepo-NY;2 Attachments Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Depos in Joint W/P Priv NV OH/PDF of Sarah Kellen Notice of Videotaped Depo Kikka Claudio Jacquie Johnson Depo subpoena notice for Joint W/P Priv Trump Jacquie Johnson Mercedes Estrada RE:Alan Dershowitz;Harvard Law Joint Priv Info Jacquie Johnson Katherine Ezell RE:Epstein-Oepos of Marcinkova Joint W/P Priv Sarah Kellen Adam Horowitz Jacquie Johnson RE:Esptein-Notice of Prodcution Joint W/P Priv from Non Parties Jacquie Johnson Katherine Ezell Notice Of Production from Non Joint W/P Priv Parties discussion Privilege Log Dated I I I Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson Crittons notice of depo;Epstein Joint W/P Priv notice of hearing,Mark Epstein notice of depo Katherine Ezell Bradley Edwards Epstein Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Epstein Depo Joint W/P Priv Jacquie Johnson Katherine Ezell Rf Deposition of Jean Luc Joint W/P Priv Bruhnel Jacquie Johnson Adam Horowitz RE:Epstein Depo Joint Priv Jacquie Johnson Margaret Berk Epstein Depos Joint W/P Priv Jacquie Johnson Lisa Rivera FW:Deposition of Jean Luc Joint W/P Priv Bruhnel Jacquie Johnson Lisa Rivera Depo of David Hart Rogers Joint Priv Jacquie Johnson Katherine Ezell FW:Meeting w/Sranley Arkin Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Jane Does Epstein-Cross Joint W/P Prlv Nods of Oct depos Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for Joint Priv Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Jacquie Johnson Adam Horowitz RE:Epstein Depositions for Joint W/P Priv in NY OH I Privilege Log Dated Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jacquie Johnson Kikka Claudio RE Ms Maxwell Depo Joint W/P Priv rescheduled Bradley Edwards Kikka Claudio FW:out of state subpoenas Joint W/P Priv Jacquie Johnson Kikka Claudio RE:out of state subpoenas Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv Jacquie Johnson Kikka Claudio RE:E.pstein Joint Prlv Jacquie Johnson Kikka Claudio FW:Epstein Depo Notices Subs Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Depo of Mark Epstein Joint W/P Priv on in NV will take place as scheduled Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Jacquie Johnson Adam Horowitz RE:Epsteln Depositions Joint W/P Priv in NV OH Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv Spencer Kuvin Jacquie Johnson RE:Epstein-Deposition of Jane Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Depo Notices and Subs Joint W/P Priv Kikka Claudio Jacquie Johnson RE:Epsteln Depo Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv Margaret Estrada Jacquie Johnson Alan Dershowitz Joint W/P Priv Katherine Ezell Jacquie Johnson RE:Depo Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Deposition of Jean Luc Joint W/P Priv Bruhnel Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Prlv Adam Horowitz Jacquie Johnson RE:Epstein Depo of Mark Epstein Joint W/P Priv Spencer Kuvin Jacquie Johnson RE:Epstein Sub to Bear Stearn Joint W/P.Priv Margaret Berk Jacquie Johnson RE:Epstein Depos Joint W/P Priv Katherine Ezell Jacquie Johnson RE:Epstein-Depos of Marcinkova Joint Priv Sarah Keller Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv Lisa Rivera Jacquie Johnson RE:Depo of David Hart Rogers Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv from Non Parties Margaret Berk Jacquie Johnson RE:Epstein depos Joint W/P Priv Katherine Ezell Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv from Non Parties Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Flstos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson Depo Joint W/P Priv Spencer Kuvin Jacquie Johnson RE:Epstein Joint W/P Priv Kikka Claudio Jacquie Johnson RE:Epstein depos on Joint W/P Priv Kikka Claudio Jacquie Johnson RE:Epstein depos on Joint W/P Priv Bradley Edwards Mercedes Estrada FW Epstein-Confirming AT Joint W/P Priv Dial Telephone Conference for Mon at p.m Jacquie Johnson Spencer Kuvin FW Epste in-Depos of Joint W/P Priv Marcinkova Sarah Kellen Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns Joint W/P Priv Jacquie Johnson Spencer Kuvin FW:Epstein-Depos of Joint W/P Priv Marcinkova Sarah Kellen Spencer Kuvin Bradley Edwards RE:Actvity in Case Joint W/P Priv Doe Epstein Order on Motion to Stay Paul Cassel Bradley Edwards FW:Epstein Joint W/P Priv Adam Horowitz Bradley Edwards FW Motion to Dismiss Joint W/P Priv Susan Stirling Katherine Ezell RE:WPB-Confidential-Genereal Joint Priv Financial Disclosure/Discovery Bradley Edwards Spencer Kuvin FW:Subpoena Info Joint W/P Priv Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Kikka Claudio FW:Proposal Request Joint W/P Priv Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv from Non Parties Spencer Kuvin Bradley Edwards RE:Epstein Joint W/P Priv Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv Johnson Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv Jacquie Johnson Jack Hill RE:Epstein Joint W/P Priv Jacquie Johnson Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Prlv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv Jacquie Johnson Margaret Berk RE:Epstein Joint W/P Prlv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissin.r Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Carolyn Edwards Brian Ryalls Joint W/P Priv BradleyEdwards Kikka Claudio RE:Regarding:C.M.A vs Epstein Joint W/P Priv Et al File Bradley Edwards Amy Ederi RE:Regular Monthly Cong Call Joint W/P Priv Jessica Caldwell Bradley Edwards RE:Release Joint W/P Priv Bradley Edwards Katherine Ezell RE:Meetlng w/Stanley Arkin Joint W/P Priv Bradley Edwards Katherine Ezell RE:Jane Doe II Epstein Joint W/P Priv Bradley Edwards Stuart Mermelstein RE:Jane Doe II Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Jane Doe II Epstein Joint W/P Priv Bradley Edwards Mercedes Estrada Re:Jane Doe No Jane Doe Joint W/P Priv No vs Epstein-Cross Notice Of Depos Bradley Edwards Mercedes Estrada RE Jane Doe Jane Doe Joint W/P Prlv vs Epstein Bradley Edwards Mercedes Estrada RE Jane Doe Jane Doe Joint W/P Priv vs Epstein-Cross-Notice of Taking Video Deposition Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv Bradley Edwards Kikka Claudio RE Igor Zinoview depo Joint W/P Priv Bradley Edwards Robert Josefberg RE:Epstein Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Jack Hill RE Igor Zinoview depo Joint W/P Prlv Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv Kikka Claudio Bradley Edwards RE:Epstein Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv Bradley Edwards Spencer Kuvin RE:FYI Epstein Depo Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv Katherine Ezell Bradley Edwards FW:Epstein Joint W/P Priv Katherine Ezell Bradley Edwards RE:Epstein Joint Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint Priv from Non Parties Bradley Edwards Katherine Ezell RE:Epstein Cases-depostions in Joint W/P Priv federal cases BATES DATE TO FROM DESCRIPTION OBJECTION Brad Edwards Katherine Ezell June 1otn hearing-WPS Joint-privilege Confidential Amy Ederi Brad Edwards June 2stn hearing-WPS Joint-privilege Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Confidential Bradley Spencer Kuvin L.M Epstein defendant Joint-privilege Edwards Jeffrey Epsteins response to plantiff Bradley Katherine Ezell Leslie Wexner Joint-privilege Edwards Stuart Bradley Edwards Leslie Wexner Joint-privilege Mermelstein Bradley Katherine Ezell Leslie Wexner Joint-privilege Edwards Robert Bradley Edwards Epstein Joint-privilege Josefsberg Spencer Kuvin Bradley Edwards Epstein Joint-privilege Adam Horowitz Bradley Edwards Epstein Joint-privilege Spencer Kuvin Spencer Kuvin Bradley Edwards Epstein Joint-privilege Spencer Kuvin Bradley Edwards Epstein Joint-privilege Adam Horowitz Bradley Edwards Epstein Joint-privilege Stuart Mermelstein Adam Horowitz Bradley Edwards Epstein Joint-privilege Bradley Spencer Kuvin LM EPSTEIN hearing Edwards Spencer Kuvin Bradley Edwards LM EPSTEIN hearing Joint-privilege Bradley Spencer Kuvin LM EPSTEIN hearing Joint-privilege Edwards Adam Horowitz Bradley Edwards Mark Epstein Joint-privilege Bradley Spencer Kuvin Meeting with Stanley Arkin Joint-privilege Edwards Stuart Katherine Ezell Meeting with Leslie Wexner Joint-privilege Mermelstein Robert Josefsberg Privilege Log Dated I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Robert Katherine Ezell Meeting with Stanley Arkin Joint-privilege Josefsberg Bradley Katherine Ezell Meeting with Stanley Arkin Joint-privilege Edwards Spencer Kuvin Bradley Edwards Meeting with Stanley Arkin Joint-privilege Katherine Bradley Edwards Meeting with Stanley Arkin Joint-privilege Ezell Robert Spencer Kuvin Meeting with Stanley Arkin Joint-privilege Josefsberg Bradley Robert Meeting with Stanley Arkin Joint-privilege Edwards Josefsberg Adam Horowitz Bradley Edwards Motion for protective order Joint-privilege Bradley Kikka Claudio Proposal Request Joint-privilege Edwards Katherine Bradley Edwards Regularly Monthly Cong Call Joint-privilege Ezell Bradley Adam Horowitz Report this as a parole violation Joint-privilege Edwards Adam Horowitz Bradley Edwards Report this as a parole violation Joint-privilege Bradley Spencer Kuvin Sarah Kellen Joint-privilege Edwards Spencer Kuvin Jacquie Johnson Sarah Kellen Joint-privilege Katherine Bradley Edwards Subpoena directed to the Joint-privilege Ezell investigators Bradley Spencer Kuvin Subpoena Info Joint-privilege Edwards Adam Horowitz Elizabeth Villar Epstein Forensics/Investigations Joint-privilege INVOICE Richard Willits Bradley Edwards Epstein Investigator Joint-privilege Adam Horowitz Bradley Edwards Epstein Investigator Joint-privilege Bradley Lisa Rivera Alfredo Rodriguez Joint-privilege Privilege Log Dated I I I I Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Edwards Adam Horowitz Margaret Berk Correct Number Epstein Joint-privilege Deposition Bradley Mercedes Doe Epstein Joint-privilege Edwards Estrada Katherine Bradley Edwards E.W L.M Doe Epstein Joint-privilege Ezell Letter from Bob Critton Robert Bradley Edwards E.W L.M Doe Epstein Joint-privilege Josefsberg Letter from Bob Critton Spencer Kuvln Bradley Edwards Emailing Epstein deposition Joint-privilege revised Bradley Amy Ederi Epstein Confirming AT Dial Joint-privilege Edwards in Tel Conf for Monday at p.m Spencer Kuvin Bradley Edwards Epstein Hearing Joint-privilege Spencer Kuvin Bradley Edwards Epstein Depo New York Joint-privilege Bradley Amy Ederi Epstein Depo Joint-privilege Edwards Adam Horowitz Bradley Edwards Epstein Matter Cross Notice of Joint-privilege Alfredo Rodriguez Deposition Bert Patton William Berger Epstein State of Florida Joint-privilege Emergency petition for Writ of Certiorari Emergency motion to review denial of stay Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Spencer Kuvin Epstein Joint-privilege Edwards Mercedes Susan Stirling Hearing taken on Joint-privilege Estrada onmotion to unseal before Judge Colbath Spencer Kuvin Katherine Ezell Hearing to Un-seal Joint-privilege Jack Hill Bradley Edwards Igor Zinoview depo Joint-privilege Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Mercedes Jane Doe II Epstein Joint-privilege Edwards Estrada Bradley Lisa Rivera Jane Does Epstein Joint-privilege Edwards Bradley Adam Horowitz Jeffrey Epstein DC Joint-privilege Edwards Spencer Kuvin Bradley Edwards L.M Epstein Defendant Joint-privilege Jeffrey Epstein"s Response to Plantiff L.M."s Motion for Protective Order Spencer Kuvin Bradley Edwards LM EPSTEIN hearing Joint-privilege Bradley Katherine Ezell Meeting with Leslie Wexner Joint-privilege Edwards Adam Horowitz Bradley Edwards NEW ASSIGNMENT NEW Joint-privilege ALBANY RUSH Fwd Federal Subpoena Bradley Kikka Claudio Out of state subpoenas Joint-privilege Edwards Bradley Kikka Claudio Proposal Request Joint-privilege Edwards Bradley Adam Horowitz Report this as a parole violation Joint-privilege Edwards Spencer Kuvin Bradley Edwards Subpoena Info Joint-privilege Spencer Kuvin Bradley Edwards Transcript of Alfredo Rodriguez Joint-privilege deposition Bradley Spencer Kuvin Hearing to Un-seal Joint-privilege Edwards Adam Horowitz latquie Johnson Motion to stay Joint-privilege Bradley Adam Horowitz Mark Epstein Joint-privilege Edwards Bradley Stuart Mermelstein Meeting with Leslie Wexner Joint-privilege Edwards Adam Horowitz Bradley Edwards Epsteins assets Joint-privilege Privilege Log Dated I I I I Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Adam Horowitz EPSTEIN Joint-privilege Edwards Adam Horowitz Bradley Edwards Activity in case Joint-privilege KAM Doe Epstein Response in Opposition to Motion Bradley Adam Horowitz Activity in case Joint-privilege Edwards KAM Doe Epstein Response in Opposition to Motion Bradley Spencer Kuvin Activity in Case Joint-privilege Edwards KAM Doe Epstein Order on Motion to Stay Bradley Spencer Kuvin Activity in Case Joint-privilege Edwards KAM Doe Epstein Order to Motion to Stay Bradley Spencer Kuvin BB Epstein/EW Epstein Joint-privilege Edwards Jacquie Johnson William Berger BB Epstein/EW Epstein Joint-privilege Bradley Katherine Ezell Bill Rileys Subpoena Depo Joint-privilege Edwards Notice Bradley Adam Horowitz Can you send me those Joint-privilege Edwards addresses Bradley Spencer Kuvin CMA depo notices attached Joint-privilege Edwards Stuart Bradley Edwards Continuing Deposition of Alfredo Joint-privilege Mermelstein Rodriguez Katherine Bradley Edwards Deposition of Bill Riley Joint-privilege Ezell Adam Horowitz Jacquie Johnson Deposition of Jean Luc Bruhnel Joint-privilege Bradley Jack Hilt Igor Zinoview depo Joint-privilege Edwards Bradley Adam Horowitz Jane Does Epstein Joint-privilege Edwards Katherine Bradley Edwards Leslie Wexner Joint-privilege Privilege Log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Ezell Bradley Stuart Mermelstein Leslie Wexner Joint-privilege Edwards Bradley Mercedes Preservation of evidence Joint-privilege Edwards Estrada Sid Garcia Bradley Edwards L.M Epstein Joint-privilege Richard Willits Bradley Edwards Scheduling various depositions Joint-privilege regarding Epstein Bradley Katherine Ezell FYI Joint-privilege Edwards Spencer Kuvin Bradley Edwards FYI Joint-privilege Spencer Kuvin Bradley Edwards FYI Joint-privilege Katherine Bradley Edwards FYI Joint-privilege Ezell Bradley Spencer Kuvin FYI Joint-privilege Edwards Spencer Kuvin Bradley Edwards Hearing to Un-seal Joint-privilege Bradley Robert Hearing to Un-seal Joint-privilege Edwards Josefsberg Bradley Kikka Claudio Igor Zlnoview Tommy Matola Joint-privilege Edwards depos Bradley Kikka Claudio Igor Zinoview depo Joint-privilege Edwards Jack Hill Bradley Edwards Igor Zinoview depo Joint-privilege Bradley Jack Hill Igor Zinoview depo Joint-privilege Edwards Bradley Stuart Mermelstein IMEs Joint-privilege Edwards Bradley Stuart Mermelstein IMEs Joint-privilege Edwards Stuart Bradley Edwards IMEs Joint-privilege Mermelstein Katherine Bradley Edwards Is Mark Epstein JEs brother Joint-privilege Privilege Log Dated I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Ezell Adam Horowitz Bradley Edwards Is your client being deposed Joint-privilege tomorrow Bradley Margaret Berk Jane Doe Brinson Epstein Joint-privilege Edwards Bradley Spencer Kuvin Jane Doe II Epstein Joint-privilege Edwards Spencer Kuvin Bradley Edwards Jane Doe II Epstein Joint-privilege Bradley Katherine Ezell Jane Doe II Epstein Joint-privilege Edwards Bradley Stuart Mermelstein Jane Doe II Epstein Joint-privilege Edwards Adam Horowitz Bradley Edwards Jane Does Epstein Joint-privilege Spencer Kuvin Jacquie Johnson Jane Does Epstein Cross Joint-privilege NODs of Oct depos Bradley Adam Horowitz Jeffrey Epstein DC Joint-privilege Edwards Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege Kikka Claudio Jacquie Johnson Maxwells deposition Joint-privilege Robert Jacquie Johnson Meeting with Stanley Arkin Joint-privilege Josefbergs Spencer Kuvin Jacquie Johnson Epstein Depa New York Joint-privilege Bradley Katherine Ezell Meeting with Stanley Arkin Joint-privilege Edwards Bradley Katherine Ezell Meeting with Stanley Arkin Joint-privilege Edwards William Berger Spencer Kuvin Ew cert.4 th dca Joint-privilege Bradley Katherine Ezell Hearing to Un-seal Joint-privilege Edwards Adam Horowitz Jacquie Johnson Epstein Hearing Joint-privilege Adam Horowitz Jacquie Johnson Epstein Depositions Joint-privilege Stuart Bradley Edwards Epstein depositions Joint-privilege Privilege Log Dated I I I I Farmer Jaffe Weissinj Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege Spencer Kuvin Bradley Edwards Epstein Depo Joint-privilege Stuart Jacquie Johnson Epstein Depo of Wexner Joint-privilege Mermelstein Bradley Adam Horowitz Epstein cases depositions in Joint-privilege Edwards federal cases Jack Hill Bradley Edwards Epstein Assets Joint-privilege Katherine Bradley Edwards Epstein claims Joint-privilege Ezell Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Mercedes Epstein Telephone Conference Joint-privilege Edwards Estrada Bradley Mercedes Epstein Monday Joint-privilege Edwards Estrada Monthly call in telephone conference AT Call in No participant code Kathy is the host Bradley Mercedes Epstein Monday Joint-privilege Edwards Estrada Monthly call In telephone conference AT Call in No participant code Kathy is the host Bradley Mercedes Epstein Confirming AT dial Joint-privilege Edwards Estrada in tel conf for Monday at p.m Bradley Mercedes Epstein Confirming AT Dial Joint-privilege Edwards Estrada in Tel Cont for Monday at p.m Bradley Mercedes Epstein Confirming AT Dial Joint-privilege Edwards Estrada in Telephone Conference for Mondav at p.m I Privilege Log Dated I Farmer Jaffe Weissln Edwards Flstos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Mercedes Epstein Confirming AT Dial Joint-privilege Edwards Estrada in Telephone Conference for Tomorrow Bradley Iliana Yarzabal Epstein Confirming AT Dial Joint-privilege Edwards in Telephone Conference for Wednesday at Spencer Kuvin Bradley Edwards Deposition of Epstein was set for Joint-privilege tomorrow Bradley Richard Willits CMA vs Epstein Joint-privilege Edwards Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Spencer Kuvin Epstein Joint-privilege Edwards Bradley Adam Horowitz Epstein Joint-privilege Edwards Spencer Kuvin Bradley Edwards Epstein Joint-privilege Katherine Bradley Edwards Epstein Joint-privilege Ezell Jack Hill Bradley Edwards Epstein Joint-privilege Jack Scarola Bradley Edwards Epstein Depos of Marcinkova Joint-privilege and Sarah Kellen Bradley Iliana Yarzabal Epstein Monday Joint-privilege Edwards Monthly Call in Telephone Conference Bradley Edwards Katherine Ezell Letter from Bob Critton Joint W/P Privilege Bradley Edwards Spencer Kuvin Letter from Bob Critton Joint W/P Privilege Bradley Edwards Barry Stone Letter from Bob Critton Joint W/P Privilege Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman I BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Spencer Kuvin Epstein Depo Joint W/P Privilege Jacquie Johnson Adam Horowitz Depa of Epstein Joint W/P Privilege Jacquie Johnson Adam Horowitz Epstein Joint W/P Priv Bradley Edwards Robert Josefsberg Epstein Confirming AT Tel Joint W/P Priv Conf Jacquie Johnson Katherine Ezell Depos of Marcinkova Sarah Joint W/P Priv Kellen Jacquie Johnson Adam Horowitz Epstein Depa ln New York Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein Hearing Joint W/P Priv Jacquie Johnson Adam Horowitz Letter regarding Leslie Wexner Joint W/P Prlv Spencer Kuvin Bradley Edwards Monthly Call in Tele Conf Joint W/P Priv Jacquie Johnson Mercedes Estrada Monthly Call in Tel Conf Joint W/P Priv Bradley Edwards Jack Scarola Epstein Tel Conf Joint W/P Priv Bradley Edwards Robert Josefsberg Epstein Tel Cont Joint W/P Priv Katherine Ezell Bradley Edwards Epstein Depa Joint W/P Priv Jacquie Johnson Adam Horowitz Depa of Larry Visoski Joint W/P Priv Bradley Edwards Adam Horowitz Depa of Larry Visoski Joint W/P Priv Bradley Edwards Katherine Ezell Epstein cases Depos Joint W/P Priv Adam Horowitz Bradley Edwards Epstein cases Witness depos Joint W/P Priv Spencer Kuvin Bradley Edwards Epstein depo New York Joint W/P Priv Spencer Ku".in Bradley Edwards Epstein Depa Notice Joint W/P Priv Jacquie Johnson Adam Horowitz Epstein Depa Joint W/P Priv Jacquie Johnson Adam Horowitz Epstein Depos in New.York Joint W/P Priv Jack Scarola Jacquie Johnson Epstein Depos Joint W/P Priv Spencer Kuvin Jacquine Johnson Epstein Depos Joint W/P Priv Katherine Ezell Bradley Edwards Epstein Depos Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Jack Hill Epstein assests Joint W/P Priv Bradley Edwards Kikka Claudio Epstein Depos Joint W/P Priv Lisa Rivera Jacquie Johnson Epstein Depos Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein Depos Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Hearing Joint Priv Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv Bradley Edwards Adam Horowitz Epstein Hearing Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv Adam Horowitz Bradley Edwards Alfredo Rodriguez Depo Joint W/P Priv Adam Horowitz Jacquie Johnson Notice of Production from Non JointW/P Priv Parties Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Prlv Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv Spencer Kuvin Bradley Edwards Epstein Order Joint W/P Priv Bradley Edwards Spener Kuvin Epstein Order Joint W/P Priv Stuart Jacquie Johnson Epstein Sub To Bears Stern Joint W/P Prlv Mermelstein Privilege Log Dated I I Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mercedes Bradley Edwards Improper Serving of Maxwell Joint W/P Priv Estrada Bradley Edwards Spencer Kuvin Hearing on Yellow Cab Objection Joint W/P Priv Adam Horowitz Kikka Claudio Address for Nadia Marcinkova Joint W/P Priv Adam Horowitz Bradley Edwards Motion for Protective Order Joint W/P Priv Adam Horowitz Bradley Edwards Motion for Protective Order Joint W/P Priv Bradley Edwards Margaret Berk Spencer Cross-Examination Joint W/P Priv Bradley Edwards Mercedes Estrada Transcripts Joint W/P Priv Adam Horowitz Bradley Edwards Rules on Doe no Joint W/P Priv Bradley Edwards Katherine Ezell File case Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein th Amendment rights Joint W/P Priv Bradley Edwards Adam Horowitz Motions to Compel Joint W/P Priv Bradley Edwards Adam Horowitz Motions fully briefed Joint W/P Priv Katherine Ezell Bradley Edwards Answers to the st set of ROGS Joint W/P Priv Katherine Ezell Bradley Edwards Depa dates Joint Priv Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv Epstein Egg Shaped inch PENIS Adam Horowitz Spencer Kuvln Alfredo Rodriguez depo Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv training of little girls as sex traps Katherine Ezell Bradley Edwards Calling Switzerland witness Joint W/P Priv Bradley Edwards Spencer Kuvin Emails searchable Joint W/P Priv Kikka Claudio Bradley Edwards Epstein address Joint W/P Priv Bradley Edwards Mercedes Estrada TV Interview that is too explicit Joint W/P Priv Bradley Edwards Spencer Kuvin Seeking Computers Joint W/P Priv Kikka Claudio Bradley Edwards Current address for Nadia Joint W/P Priv Marcinkova Katherine Ezell Bradley Edwards Distribution of Costs Joint W/P Priv Jacquie Johnson Bradley Edwards Voicemail Joint W/P Priv Kikka Claudio Bradley Edwards Supoenas for depos Joint W/P Priv Spencer Kuvin Bradley Edwards Yellow Cab stuff Joint W/P Priv Adam Horowitz Bradley Edwards Religious Dildo Washer Joint W/P Priv Kikka Claudio Bradley Edwards Sjobergs current address Joint W/P Priv Bradley Edwards Spencer Kuvin Yellow Cab stuff Joint W/P Priv Bradley Edwards Kikka Claudio Setting Depos Joint W/P Priv Mercedes Bradley Edwards Motion for Status Conf Joint W/P Priv Estrada llf Privilege Log Dated I I I Farmer Jaffe Welsslm Edwards Flstos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION I Mercedes Bradley Edwards Judge Marra July Order Joint W/P Priv Estrada Spencer Kuvin Bradley Edwards NPA from Marie Villafana Joint W/P Priv Adam Horowitz Bradley Edwards Haleys affidavit Joint W/P Priv Spencer Kuvin Bradley Edwards Seeking all of Plaintiffs Joint W/P Priv computer Spencer Kuvin Bradley Edwards Non-Pros Agreement Joint W/P Priv Adam Horowitz Bradley Edwards Motion to freeze assets Joint W/P Priv Spencer Kuvin Bradley Edwards Daliah Weiss Joint W/P Priv Adam Horowitz Katherine Ezell NPA under seal for in camera Joint W/P Priv review Bradley Edwards Kikka Claudia Supoenas far depo Joint W/P Priv Bradley Edwards Spencer Kuvin Order Joint W/P Priv Bradley Edwards Adam Horowitz Florida Science Foundation Joint W/P Priv Mercedes Kikka Claudia Video tape of Epstein Joint W/P Priv Estrada Bradley Edwards Jack Scarola Motion far Status Conf Joint W/P Priv Bradley Edwards Sid Garcia Motion for Status Canf Joint W/P Priv Adam Horowitz Jacquie Johnson Motion far Status Conf Joint W/P Priv Adam Horowitz Jacquie Johnson Motion far status canf Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson NPNP and sub to Palm Beach Joint W/P Priv Natl Bank Mercedes Spencer Kuvin Motion for status conf Joint W/P Priv Estrada Bradley Edwards Spencer Kuvin NPA in camera review Joint Priv Katherine Ezell Jacquie Johnson Marcinkova being rescheduled Joint W/P Priv Bradley Edwards Spencer Kuvln Motion to appoint commissioner Joint W/P Priv Bradley Edwards Spencer Kuvin Notice and serve everyone Joint W/P Priv Adam Horowitz Jacquie Johnson Bill being split up evenly Joint W/P Priv Jacquie Johnson Spencer Kuvin Bill will be split evenly for each Joint W/P Priv case Adam Horowitz Jacquie Johnson Bill will be split evenly Joint W/P Priv Bradley Edwards Adam Horowitz Haleys affidavit Joint W/P Prlv Bradley Edwards Robert Josefsberg CMAOrder Joint W/P Priv Bradley Edwards William Berger Epstein Depo Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Privilege Log Dated Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Bradley Edwards Epstein Depo Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Elizabeth Kim Christinia Fitch Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Gary Farmer Bradley Edwards Stanely Arkin Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Bradley Edwards Trumps Depo Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Investigators Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Epstein Litigation Russell Adler Litigation Strategy Work Product;attorney client Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Team privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Attorneys and Russell Adler RE Setting Depos Work Product;attorney client Staff prlvilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Bradley Edwards litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Barry Stone Bradley Edwards Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Barry Stone Bradley Edwards Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Barry Stone Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Carl Linder Jacquie Johnson Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible I evidence;protected by privacy rights Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privllege;irrelevant reasonably calculated to Privilege Log Dated Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privllege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Cara Holmes Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Cara Holmes Bradley Edwards Litigation Strategy Work Product;attorney client privllege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION evidence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights William Berger Beth Williamson Litigation Strategy Work Product;attorney client privllege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights William Berger Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client Birkman privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client Birkman privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client Birkman privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Jonathan Paul Cassell Litigation Strategy Work Product;attorney client Birkman privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Jonathan Bradley Edwards Litigation Strategy Work Product;attorney client Birkman privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Stratgey Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client priviiege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client Privilege Log Dated Farmer Jaffe Weissing Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to Privilege Log Dated I I Farmer Jaffe Weissim Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Susan Sterling Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible ev dence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Susan Sterling Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admisslbleevidence;protected by privacy rights Privilege Log Dated Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privllege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards Russell Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Susan Sterling Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Beth Williamson Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculate i to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible Privilege Log Dated Farmer Jaffe Weissin,i Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client prlvilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschell Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Prod uct;attorney client prlvllege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Rob Buschel Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Mike Flsten Litigation Strategy Work Product;attorney client privllege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Prod uct;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman I BATES DATE TO FROM DESCRIPTION OBJECTION privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Prod uct;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client prlvilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Welssln Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privllege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privllege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards WIiam Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards RobBuschel litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client Privilege Log Dated Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Mike Fisten Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Litigation Team Rob Busche Litigation Strategy Work Product;attorney client prlvllege;irrelevant reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Susan Sterling Russell Adler Litigation Strategy Work Product;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Bradley Edwards Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Beth Williamson Litigation Strategy Work Product;attorney client privilege;lrrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Robert Busche Bradley Edwards Jane Doe brother Attorney/Client privilege and/or work product Robert Buschel Bradley Edwards Doe family member Attorney/Client privilege and/or work product Bradley Susan Stirling Jones Atlantic asphalt Attorney/Client privilege and/or work product Edwards Bradley D.F New addition to the case Attorney/Client privilege and/or work product Edwards Susan Stirling Bradley Edwards Jane Doe Dukenik Attorney/Client privilege and/or work product Bradley Jacquie Johnson Subpoena for Adriana Mucinska Attorney/Client privilege and/or work product Edwards Mike Fisten Bradley Edwards Samantha Lee Rivera info Attorney/Client privilege and/or work product Robin Bradley Edwards case number assignments Attorney/Client privilege and/or work product Kempner Bradley Susan Stirling Case list Attorney/Client privilege and/or work product Edwards Jacquie Johnson Bradley Edwards Subpoena for Adriana Mucinska Attorney/Client privilege and/or work product Jacquie Johnson Bradley Edwards Client information Attorney/Client privilege and/or work product D.F Bradley Edwards Client communication Attorney/Client privilege and/or work product N.R Bradley Edwards Client communication Attorney/Client privilege and/or work product Jacquie Johnson Bradley Edwards Discussion re client/victim Attorney/Client privilege and/or work product personal information N.R Bradley Edwards Client communication Attorney/Client privilege and/or work product RRA Personnel RRA personnel Client names/types of action Attorney/Client privilege and/or work product client information privacy right privilege not relevant Russell Adler Bradley Edwards Conflict Check for Brad Edwards Attorney/Client privilege and/or work product files Pat Roberts Bradley Edwards Client info Attorney/Client privilege and/or work product Privilege Log Dated I I Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jacquie Johnson Bradley Edwards Client info Attorney/Client privilege and/or work product Bradley Pat Roberts Client info Attorney/Client privilege and/or work product Edwards Bradley Jacquie Johnson Client info Attorney/Client privilege and/or work product Edwards Bradley Robert Buschel Curtis Rivera Attorney/Client privilege and/or work product Edwards Susan Stirling Bradley Edwards Juskowich Attorney/Client privilege and/or work product Christina Fitch Bradley Edwards Jane Doe Roe Attorney/Client privilege and/or work product Jacquie Johnson Bradley Edwards Client info Attorney/Client privilege and/or work product D.F Bradley Edwards New addition to the case Attorney/Client privilege and/or work product Christina Fitch Bradley Edwards Jane Doe Roe Attorney/Client priVilege and/or work product Bradley Susan Stirling Jane Doe Roe Attorney/Client privilege and/or work product Edwards Susan Stirling Bradley Edwards Espina Walmart case Attorney/Client privilege and/or work product Bradley William Berger Client meeting Attorney/Client priVilege and/or work product Edwards Mike Fisten Bradley Edwards Client meeting Attorney/Client priVilege and/or work product Amy Swan Bradley Edwards Client info Attorney/Client privilege and/or work product Amy Swan Bradley Edwards Client info Attorney/Client privilege and/or work product Amy Swan Bradley Edwards Client Info Attorney/Client privilege and/or work product Amy Swan Bradley Edwards Client info Attorney/Client privilege and/or work product Bradley M.G Jane Doe Roe Attorney/Client privilege and/or work product Edwards Bradley M.G Epstein article Attorney/Client privilege and/or work product Edwards All Staff Robin Kempner Current case list of Brad Edwards Attorney/Client privilege and/or work product All Staff Robin Kempner Updated case list for Brad Attorney/Client privilege and/or work product Edwards Susan Stirling Bradley Edwards case list Attorney/Client privilege and/or work product Bradley Robin Kempner Case number assignments Attorney/Client privilege and/or work product Edwards Privilege Log Dated I I I I Farmer Jaffe Welssln Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley MG Jane Doe Roe Attorney/Client privilege and/or work product Edwards Bradley Robin Kempner Conflict check Attorney/Client privilege and/or work product Edwards Bradley Robin Kempner Conflict check Attorney/Client privilege and/or work product Edwards All Staff Robin Kempner Conflict check Attorney/Client privilege and/or work product All Staff Robin Kempner Additional name added to Attorney/Client privilege and/or work product conflict check Bradley Edwards NR Client Meeting Attorney/Client privilege and/or work product Bradley Edwards Jacquie Johnson New Client Attorney/Client privilege and/or work product Bradley Edwards MG New Client Attorney/Client privilege and/or work product MG Bradley Edwards Jane Doe Roe Attorney/Client privilege and/or work product NR Bradley Edwards Client Meeting Attorney/Client privilege and/or work product Bradley Edwards MG Jane Doe Roe Attorney/Client privilege and/or work product Bradley Edwards MG Epstein Article Attorney/Client privilege and/or work product MG Bradley Edwards Jane Doe Roe Attorney/Client privilege and/or work product Jane Doe Bradley Edwards Same silver car tag Attorney/Client privilege and/or work product Bradley Edwards NR NR Interview Attorney Client Privilege Anthony Bradley Edwards Client Meeting Attorney/Client privilege and/or work product Bradley Edwards Pat Diaz Client Meeting Attorney/Client privilege and/or work product Bradley Edwards Pat Diaz NR Interview Attorney/Client privilege and/or work product Bradley Edwards NR New Client Attorney/Client privilege and/or work product NR Bradley Edwards New Client Meeting Attorney/Client privilege and/or work product Confidential Bradley Edwards Other Rape Victims W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Other Rape Victims W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence Bradley Edwards Confidential Source Other Rape Victims W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discoverv of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discoverv of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Secret Plea Deal for Epstein W/P Priv not reasonably calculated to lead to Source Providing New Witnesses discovery of admissible evidence Confidential Bradley Edwards Secret Plea Deal of Epstein W/P Priv not reasonably calculated to lead to Source providing new witnesses discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Other Rape Victims W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Other Rape Victims W/P Priv not reasonably calculated to lead to discovery of admissible evidence Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Confidential Bradley Edwards Additional Information RE W/P Priv not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Priv not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Prlv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal for Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal for Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Other Rape Victims W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Priv not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Prlv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Conficlential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to Privilege Log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discoverv of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Prlv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Privilege Log Dated Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Prlv not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Provi ing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence I Privilege Log Dated I I I I Farmer Jaffe Welsslni Edwards Flstos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Other Rape Victims W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admlsslble evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Priv not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal for Epstein W/P Priv not reasonably calculated to lead to discoverv of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Jacquie Johnson Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Prlv not reasonably calculated to lead to Privilege Log Dated Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Priv not reasonably calculated to lead to Source Epstein Strategy discovery of admisslble evidence Confidential Bradley Edwards Litigation Strategy W/P Prlv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Other Rape Victims W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Prlv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Add it Iona I Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Privilege Log Dated Farmer Jaffe Weissin2 Edwards Fistos Lehrman I BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Confidential Source Providing Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing Witnesses Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Strategies discoverv of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discoverv of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Prlv not reasonably calculated to lead to Privilege Log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Source discovery of admissible evidence Confidential Mike Fisten Additional Information RE W/P Priv not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admlsslble evidence Bradley Edwards Confidential Source Litigation Strategy Prlv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Prlv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege Not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses Privilege Not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege Not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege Not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Privilege Not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege Not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Privilege Not reasonably calculated to lead ta discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Nat reasonably calculated ta lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE Privilege Not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weisslne Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Privilege Not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards litigation Strategy W/P Privilege Not reasonably calculated to lead source to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence BOX2 BATES Qm IQ FROM DESCRIPTION OBJEQIQN Bradley Edwards 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 Paul Cassell Bradley 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 Paul Cassell Bradley 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 Paul Cassell Bradley 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 Jonathan William Berger Litigation Strategy W/P Attorney Client Privilege Irrelevant and Birkman not reasonably calculated to lead to the Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES Qfil TO FROM DESCRIPTION OBJECTIQN discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson 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 Paul Cassell Bradley 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 Paul Cassell Bradley Edwards Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley 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 Bradley Edwards 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 Paul Cassell Bradley Edwards 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 Bradley Edwards Paul Cassell Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION privacy rights Bradley Edwards 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 Bradley Edwards Paul Cassell Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley 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 Bradley Edwards 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 Paul Cassell Bradley 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 Bradley Edwards 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 Jacquie Johnson Bradley 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 Cara Holmes Bradley 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 Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman PATES DATE IQ FROM DESCRIPTION OBJECTIQN Bradley Edwards 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 Paul Cassell Bradley 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 Jacquie Johnson Bradley Edwards Litigation Strategy W/P Attorney Client PrivHege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley 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 Jacquie Johnson Bradley 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 Paul Cassell Bradley 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 William Berger Bradley 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 Russell Adler Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman ill DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edward Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley 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 Jacquie Johnson Bradley 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 Jacquie Johnson Bradley 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 Bradley Edwards 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 Jacquie Johnson Bradley 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 Beth Williamson Bradley 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 WIiam Berger Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION Bradley Edwards Amy Swan Litigation Strategy Nora Batian Bradley Edwards Litigation Strategy Nora Batian Bradley Edwards Litigation Strategy Attorney at RRA Bradley Edwards Litigation Strategy Bradley Edwards Mike Fisten Review of litigation materials Beth Williamson Bradley Edwards Jane Doe Us Bradley Edwards William Berger Dr Swan Attorneys at RRA Ken Jenne RE Epstein Meeting OBJECTION discovery of admissible evidence protected by privacy rights Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calcula ed to lead to the discovery of admissible evidence protected by Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO fRQ.M DESCRIPTION OBJECTION privacy rights Attorneys at RRA Priscilla RE Epstein Conference Room W/P Attorney Client Privilege Irrelevant and Nascimento Reserved not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Discussion of Epstein strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Amy Swan Bradley Edwards Victim Psychological Assessment W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Ken Jenne Investigation into Epsteins Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards RE Epstein-Maxwell Subpoena W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell RICO Statement W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Punitive Damages W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Victim Complaints Forensic Attorney Client Privilege Irrelevant and accountants Epsteins not reasonably calculated to lead to the Fraudulent Transfers discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jacquie Johnson Mike Fisten Subpoenas for Epsteins W/P Attorney Client Privilege Irrelevant and Housekeepers not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards LM W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigation into Epsteins Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Alessi Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards RE Epstein beneficiaries W/P Attorney Client Privilege Irrelevant and response to asset freeze motion not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Cases Bond W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell RE Epstein Accounting Freezing W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe WeisslnJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN Assets not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards RE Epstein Add to our motion W/P Attorney Client Privilege Irrelevant and for a protective order not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Motion to stay-response W/P Attorney Client Privilege Irrelevant and motion to unseal Fed Civil Case not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein Assets Forensic Accounting Jacquie Johnson Bradley Edwards thoughts on Epsteins Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motion to Strike references to Attorney Client Privilege Irrelevant and the NPA Revised response to not reasonably calculated to lead to the the motion to stay discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Sandy Berger Telephone call W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards State Judge ordered no contact W/P Attorney Client Privilege Irrelevant and with any underage girl not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe WeissinR Edwards Fistos Lehrman I i TO FROM DESCRIPTION OBJECTION Bradley Edwards William Berger Epsteins attorneys Bob W/P Attorney Client Privilege Irrelevant and Josephsberg have filed several not reasonably calculated to lead to the motions on limits of the no discovery of admissible evidence protected by contact order privacy rights Attorneys at RRA Paul Cassell Letter to Critton RE Protective W/P Attorney Client Privilege Irrelevant and Order not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell William Berger Finding out who is protected by W/P Attorney Client Privilege Irrelevant and the order not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Steven Jaffe Seek Court Intervention W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Finding out who is protected by W/P Attorney Client Privilege Irrelevant and the order not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Scott Rothstein KenJenne Epsteins house staff W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Maribel Matiska legal opinion RE Epstein W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger contact Information re who is W/P Attorney Client Privilege Irrelevant and pertinent to the case not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Trial Prep Epstein W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards KenJenne Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Ken Jenne Copperfield Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Trail Prep W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Epstein Assets Subpoena W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Michael Wheeler Subpoena of Detective Recarey W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell RE Epstein-Notice Of IME W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards RE:Epstein Reminder-Mon W/P Attorney Client Privilege Irrelevant and 8/3/09-Monthly Call in not reasonably calculated to lead to the Telephone Conference discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Jane Doe Depo Set for the W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTIQN OBJECTION discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Motion for Sanctions W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Victims for Trial W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Victims for Trail W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten KenJenne NR as a victim W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Russell Adler Trial date procured W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Victims for Trial W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Pat Roberts Epsteins Palm Beach Property W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Larry Visoski Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION privacy rights Bradley Edwards Jacquie Johnson Copperfield Subpoena W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Jacquie Johnson Tentative Subpoena dates and W/P Attorney Client Privilege Irrelevant and people list not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Dershowitz Subpoena ready to be W/P Attorney Client Privilege Irrelevant and signed not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Setting Up Depo Times W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigation in Epsteins planes W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards KenJenne RE Witness information that we W/P Attorney Client Privilege Irrelevant and need to use not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Jacquie Johnson Awaiting dates for the other W/P Attorney Client Privilege Irrelevant and pilots Dershowitz Copperfield not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weisslnt Edwards Flstos Lehrman BATES Mm TO FROM DESCRIPTION OBJECTION Mike Fisten Pat Diaz Bill RIiey Subpoena W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Depo List W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Setting Up Copperfield Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards List of people to subpoena W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Setting Up Copperfield Oepo Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Witness information that we W/P Attorney Client Privilege Irrelevant and need to use not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Ken Jenne RE Witnesses information that W/P Attorney Client Privilege Irrelevant and we need to use not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Pat Diaz Potential New Witnesses W/P Attorney Client Privilege Irrelevant and Privilege Log Dated I I I Farmer Jaffe Weissinj Edwards Fistos Lehrman Mill DATE TO FROM DESCRIPTION OBJECTIQN not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Mike Fisten Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Russell Adler Bradley Edwards Potential New witnesses W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Investigation Into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Priscila Conference room reserved W/P Attorney Client Privilege Irrelevant and Nascimento not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Investigator information W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards WIiam Berger Motion to unseal criminal records W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the Privilege Log Dated I I I Farmer Jaffe WeisslnR Edwards Flstos Lehrman BATES nm IQ FROM DESCRIPTION QBJECTIQN discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Depo information W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards KenJenne Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mlkefisten Potential new witnesses W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Mike Fistos Legal Research RE Causes of W/P Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Scott Rothstein Russell Adler Legal Research RE causes of W/P Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Legal Research RE causes of Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Filed Motions Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Epstein Probation Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated Farmer Jaffe WelsslnR Edwards Flstos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION privacy rights Ken Jenne Mike Fisten Epstein Probation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Epstein Probation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Epstein Probation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Shawn Gilbert Epstein Case Info Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Shawn Gilbert Discussion with secretary W/P Attorney Client Privilege Irrelevant and regarding client information not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Undated Unknown Staff Bradley Edwards Miscellaneous case info W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Mike Fistos Legal Research RE Causes of W/P Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Copperfield Depa W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Mike Fisten Copperfield Depa W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Legal Research RE causes of W/P Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Dershowitz Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Depa technicalities W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Pat Roberts Ronald Wise Vehicle Registrations-Visoski W/P Attorney Client Privilege Irrelevant and Mike Fisten not reasonably calculated to lead to the discovery of admissib,le evidence protected by privacy rights Pat Roberts Ronald Wise Visoskl Research Questions W/P Attorney Client Privilege Irrelevant and Mike Fisten not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Wayne Black Retainer W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Cara Holmes Jacquie Johnson RE Subpoenas for Epsteins Attorney Client Privilege Irrelevant and attorneys not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Witness List W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Weissin2 Edwards Flstos Lehrman BATES DATE TO FROM DEStRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Trump Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Depo Dates W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Dershowitz Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Jacquie Johnson Investigation into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Depo Dates W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Cara Holmes Bradley Edwards Computer information W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Hard drive of Plaintiffs computer Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Maribel Matiska legal Opinion RE Epstein W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated I I I I Farmer Jaffe Weissim Edwards Fistos Lehrman DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence protected by privacy rights Russell Adler Bradley Edwards Dershowitz Involvement Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Alan Garten Potential New Witnesses W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Legal research W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Dr Swan W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Staff Bradley Edwards Epstein Depo revised W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Beth Williamson Bradley Edwards Motion for protective order final W/P Attorney Client Privilege Irrelevant and draft not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Epstein MPO W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards William Berger Immunity for testimony about W/P Attorney Client Privilege Irrelevant and prostitution not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated I I I I Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION privacy rights Bradley Edwards Jacquie Johnson Therapy Notes W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Epstein meeting W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacv rights Ken Jenne Bradley Edwards Epstein Assets W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Carolyn Edwards Order denying the motion to W/P Attorney Client Privilege Irrelevant and reassign or transfer not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein Computers W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Jacquie Johnson Epstein Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigation into Epstein planes Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissim Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jacquie Johnson Bradley Edwards Epstein Depo list Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Motion to freeze assets W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Epstein Potential Witness List W/P Attorney Client Privilege Irrelevant and Ken Jenne not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Potential Witnesses W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Epstein telephone conference W/P Attorney Client Privilege Irrelevant and today not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein case info W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Pat Diaz New Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Epstein Evidence W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Epstein Info W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman PATES DATE TO EBQM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Epstein Presentation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Investigation Into Epsteins W/P Attorney Client Privilege Irrelevant and planes not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Epstein Meeting W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Investigation into Epstein planes Attorney Client Pfivllege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Investigative fees W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards The Mar-a-Lago Club Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Potential Witness W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Legal opinion re:Epstein W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION discovery of admissible evidence protected by privacy rights Marc Nurlk Bradley Edwards Epstein Evidence W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Discovery for the girls W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Legal opinion W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Ken Jenne Bradley Edwards New Victim Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Meeting on Epstein W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards New Victim W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Litigation Strategy on punitive W/P Attorney Client Privilege Irrelevant and damages not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Letter from JP Morgan Chase W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discoverv of admissible evidence protected by Privilege Log Dated I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTIQN QBJECTION privacy rights Wayne Black Bradley Edwards New Victim W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Opposition to the continuance of W/P Attorney Client Privilege Irrelevant and the trial date not reasonably calculated to lead to the discovery of admissible evidence protected by orivacy rights Jacquie Johnson Bradley Edwards Trump Depo W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy on motions W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Potential New Witness W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Important phone call due today W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Robert Busche Bradley Edwards Motion for bond asset transfer W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Dateline interest into epstein W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinr Edwards Flstos Lehrman BATES DATE TO FROM DESCRIP!IQN OBJECTION Robert Buschel Bradley Edwards Investigations W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Carolyn Edwards Personal Conversation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Motion to unseal W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy RE Motion to W/P Attorney Client Privilege Irrelevant and unseal not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Confidential Bradley Edwards Request for admission W/P Attorney Client Privilege Irrelevant and Source not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Confidential Bradley Edwards Secret Plea deal for Bear Stearns W/P Attorney Client Privilege Irrelevant and Source not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Investigating Epsteins planes W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Carl Linder Bradley Edwards Epsteins Assets Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards DOJ W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Weissina Edwards Fistos Lehrman BATES MU TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Epsteins cars W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Wayne Black Sarah Kellen number Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Carolyn Edwards Case Numbers W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motions W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Flsten Bradley Edwards Positing regarding litigation W/P Attorney Client Privilege Irrelevant and preparation not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy-Order Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Plaintiff firms the notices of W/P Attorney Client Privilege Irrelevant and depos not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Potential new witnesses W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEalON discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Proposal for settlement W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein Victim Depos W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein Depos W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Statutory Rape W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards Third party subs W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Richard Wolfe Bradley Edwards Facebook/Myspace W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Investigation Epsteins planes W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Adam Horowitz Testimony RE Vehicles W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated Farmer Jaffe Welsslnf Edwards Fistos Lehrman BATES TO ffiQM DESCRIPTION OBJECTION privacy rights Beth Williamson Bradley Edwards 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 Beth Williamson Bradley Edwards New folder for Jane Doe Created W/P Attorney Client Privilege Irrelevant and Jacquie not reasonably calculated to lead to the Johnson discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Epsteins Cars W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Marc Nurik Scot Rothstein Legal Research RE causes of W/P Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Scott Rothstein Russell Adler Legal Research RE causes of Attorney Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Wayne Black Epstein Victims Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Epstein secret plea deal with W/P Attorney Client Privilege Irrelevant and Bear Stearns not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weisslnt Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Wayne Black Epstein secret plea deal with W/P Attorney Client Privilege Irrelevant and Bear Stearns not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Epstein secret plea deal for Bear W/P Attorney Client Privilege Irrelevant and 267stearns not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Epstein Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Epstein secret plea deal for Bear W/P Attorney Client Privilege Irrelevant and Stearns not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Wayne Black Epstein secret plea deal for Bear W/P Attorney Client Privilege Irrelevant and Stearns not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Wayne Black Investigating Epsteins planes W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Ken Jenne Epsteins assets W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Carolyn Edwards Victims employment W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissfni Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Carolyn Edwards Epstein Hearing W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Wayne Black Bradley Edwards Investigating Epsteins planes W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley 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 Bradley Edwards Wayne Black Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Russell Adler Bradley 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 Jacquie Johnson Bradley 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 Russell Adler Bradley 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 Jacquie Johnson Bradley 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 Bradlev Edwards Seth Lehman Litigation Strategy W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Weissinl Edwards Flstos Lehrman Mm Mn TO FROM DESCRIPTION OBJECTIQN not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Spencer Kuvin Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Adam Steinberg Litigation Strategy W/P Attorney Client Privilege Irrelevant _and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Pat Diaz 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 Bradley Edwards 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 Attorneys at RRA 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 Bradley Edwards Pat Diaz Other Rape Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Bradley Edwards Pat Diaz Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated I I I I Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Bradley Edwards 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 Mike Fisten Bradley 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 Bradley Edwards Paul Cassell Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Susan Stirling Bradley 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 Paul Cassell Bradley 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 Wayne Black Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES QA TO FROM DESCRIPTION OBJECTION privacy rights Mike Fisten Bradley 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 Paul Cassell Bradley 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 Susan Stirling Bradley Edwards Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Bradley 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 Bradley Edwards Cara Holmes Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Steven Jaffe Susan Stirling Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Providing New witnesses Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Pat Diaz Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Jacquie Johnson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Pat Diaz Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Pat Diaz Bradley 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 Russell Adler Bradley 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 Bradley Edwards 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 Mike Fisten 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 Bradley Edwards Jacquie Johnson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Paul Cassell Susan Stirling Litiation Strategy Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO fB.QM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Bradley Edwards Mike Fisten Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorneys at RRA Grant Smith Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Other Rape Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Wayne Black Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Michael Wheeler Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated Farmer Jaffe Weissim Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Other Rape Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Bradley Edwards Mike Flsten Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Wayne Back Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley 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 Susan Stirling Bradley 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 Mike Fisten Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION privacy rights Wayne Black Bradley Edwards Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Beth Williamson Bradley Edwards Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley 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 Bradley Edwards Wayne Black Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculat to lead to the discovery of admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEQ:ION Attorneys at RRA Bradley Edwards Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Bradley Edwards Jacquie Johnson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley 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 Paul Cassell Ronald Wise Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 Bradley Edwards Paul Cassell Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights William Berger Bradley 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 Bradley Edwards Paul Cassell Litigation Strategy W/P Attorney Client Privilege Irrelevant and Privilege Log Dated I I Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley 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 Beth Williamson Bradley 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 Paul Cassell Bradley 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 Beth Williamson Bradley 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 Bradley Beth Williamson Litigation Strategy W/P Attorney Client Privilege Irrelevant and Williamson not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman MU TO FROM DESCRIPTION OBJECTION discovery of admissible evidence protected by privacy rights Paul Cassell Bradley 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 Bradley Edwards Jacquie Johnson Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Bradley 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 Paul Cassell Ronald Wise Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy W/P Attorney Client Pri ilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Ronald Wise Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Paul Cassell Ronald Wise Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION privacy rights William Berger Bradley 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 William Berger Bradley 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 Jacquie Johnson Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacv rights Bradley Edwards 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 Pat Diaz Bradley Edwards 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 Attorneys at RRA Ronald Wise Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy W/P Attorney Client Privllegei Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacv rights Wayne Black Bradley 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 Privilege Log Dated Farmer Jaffe Weissini Edwards Flstos Lehrman PATES DATE TO FROM DESCRIPTION OBJECTION Attorneys at RRA Paul Cassell Litigation Strategy Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Kendall Coffey Bradley Edwards 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 Paul Cassell Bradley 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 Attorneys at RRA Bradley 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 William Berger Bradley 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 Attorneys at RRA Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated ta lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards Cara Holmes Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by 267privacy rights Pat Diaz Bradley Edwards 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 Jacquie Johnson Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe Welssim Edwards Fistos Lehrman BATES QAli IQ FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Bradley Edwards 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 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 Attorneys at RRA Russell 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 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 Attorneys at RRA Bradley Jane Doe II Epstein Work product attorney/client privilege Edwards Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Activity In case Work product attorney/client privilege Edwards KAM Doe Epstein Motion to irrelevant and not reasonably calculated to lead Dismiss to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Activity In case Work product attorney/client privilege Edwards KAM Doe Epstein Motion to irrelevant and not reasonably calculated to lead Compel to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Activity in case Work product attorney/client privilege Edwards KAM Jane Doe No Epstein Irrelevant and not reasonably calculated to lead BATES Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman TO FROM DESCRIPTION Motion to Strike Jacquie Johnson Bradley Adriana Surveillance/Interview Edwards Jacquie Johnson Bradley Alfredo Rodriguez address Edwards Bradley Edwards William Berger Client info Russell Adler Bradley Edwards Russell Adler Bradley Edwards Susan Stirling Bradley Edwards Attorneys at RRA Bradley Edwards Mike Fisten Bradley Edwards Witness Info Epstein assets Call from sources of information Cassell Draft CMA vs Epstein new investigator info OBJECTION to the discovery of the admissible evidence protected by privacy rights Work product attomey/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not re sonably calculated to lead to the discovery of the admissible evidence fl Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman I BATES DATE TO FROM DESCRIP!ION OBJECTIQN protected by privacy rights Jacquie Johnson Bradley Computers Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Paul Cassell Conference Call Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Russell Adler Conflict check for Brad Edwards Work product attorney/client privilege Edwards files irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Paul Cassell Consolidation order Work product attorney client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Dates for Subpoena Epsteins Work product attorney/client privilege Edwards housekeepers irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley David Copperfield Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Pasquale Diaz Bradley Deposition of Bill Riley Work product attorney client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Doe Epstein Work product attorney client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weisslne Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION QBJECTIQN Attorneys at RRA Bradley Sids deposition of Epstein Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley E.W L.M Doe Epstein Letter Work product attorney/client privilege Edwards from Bob Critton irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley E.W L.M Doe Epstein Letter Work product attorney/client privilege Edwards from Bob Critton irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Epstein Confirming AT Dial in Work product attorney/client privilege Edwards Telephone Conference for Irrelevant and not reasonably calculated to lead Monday at p.m to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Epstein hearing Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Epstein Monthly can In Work product attorney/client privilege Edwards Telephone Conference Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Epstein Telephone Conference Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Epstein info List of Plaintiff Work product attorney/client privilege Edwards lawyers irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Jacquie Johnson Epstein Cancelling depositions Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissing Edwards Fistos Lehrman I BATES PATE TO FROM DESCRIPTION OBJECTION Edwards in New York for the following irrelevant and not reasonably calculated to lead week to the discovery of the admissible evidence protected by privacy rights Bradley Jacquie Johnson Epstein Yearbook picture of Work product attorney/client privilege Edwards Epstein rape victims irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Epstein AUSA Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Beth Bradley Epstein info Work product attorney/client privilege Williamson Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Epstein cases depositions in Work product attorney/client privilege Edwards federal cases irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Epstein depo New York Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Epstein Depo Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Epstein Depo Work product attorney/client privilege Edwards Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Epstein info Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE IQ FROM DE CRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Epstein info Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Nora Batian Bradley Epstein coordinating meetings Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Nora Batian 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 Jacquie Johnson Bradley Epstein Video Deposition of S.K Work product attorney/client privilege Edwards in NY irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Epstein info Work product attorney/client privilege Edwards Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Priscila A Nora Batian Epstein info Work product attorney/client privilege Nascimento irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Epstein info Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Barbara Berg info Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN protected by privacy rights Bradley William Berger Discussion of belief that Epstein Work product attorney/client privilege Edwards is transferring assets to avoid irrelevant and not reasonably calculated to lead judgments to the discovery of the admissible evidence protected by privacy rights Ken Jenne Bradley Accountants Motion for IME Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Paul Cassell Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Notification Irrelevant and not reasonably calculated to lead of ninety days expiring to the discovery of the admissible evidence protected by privacy rights Beth Bradley Activity in case Work product attorney/client privilege Williamson Edwards KAM Doe Epstein Order on irrelevant and not reasonably calculated to lead motion for Medical Exam to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Motion for irrelevant and not reasonably calculated to lead protective order to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Order on irrelevant and not reasonably calculated to lead Motion for Extension of Time to to the discovery of the admissible evidence File Response/Reply Answer protected by privacy rights Attorneys at RRA Bradley Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Response irrelevant and not reasonably calculated to lead to Motion to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Response Irrelevant and not reasonably calculated to lead to motion to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Welssinf Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION Paul Cassell Bradley Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Order on irrelevant and not reasonably calculated to lead Motion to Stay to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Activity in case Work product attorney/client privilege Edwards KAM Doe Epstein Notice irrelevant and not reasonably calculated to lead Other to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Meeting with clients Work product attorney client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Litigation strategy and Work product attorney/client privilege Edwards preparation irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Weds filing Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by rlvacy rights Bradley Jacquie Johnson Wexner deposition for 14th Work product attorney/client privilege Edwards Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Paul Cassell Motion to unseal/Motion to stay Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Witness Information Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Paul Cassell Zorro Trust research info Work product attorney/client privilege BATES DATE TO Edwards Bradley Edwards Bradley Edwards Bradley Edwards Bradley Edwards Bradley Edwards Bradley Edwards Bradley Edwards Bradley Edwards Privilege Log Dated Farmer Jaffe Weissinl Edwards Fistos Lehrman ffi.QM DESCRIPTION Paul Cassell Epstein complaint Paul Cassell Epstein fraudulent transfer Paul Cassell Revisited sexual history memo Paul Cassell Reply memo on asset transfers Cara Holmes Rodriguez Deposition William Berger Strategy Mike Fisten Subpoena info Mike Fisten Synopsis OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissimt Edwards Fistos Lehrman BATES Qm IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA William Berger Trial Prep Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Brunel information Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Cf Response to Motion to File Work product attorney/client privilege Epstein Affidavit irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Cara Holmes Computers Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger Computers Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Hearing to Un-seal Criminal Plea Work product attorney/client privilege Transcript irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Igor Zinovlew depo Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights Mike Fisten Bradley Edwards Igor Zinoview depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Jane Doe II Epstein Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Jane Doe II Epstein Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards Epstein house arrest monitor Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Motion date Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Dr Lee Expert Bradley Edwards Pimp and His Game Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Forensics/Investigations Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger Confidential Agreement Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Susan Stirling Bradley Edwards Critton order Transcript Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Epstein Juan Alessi Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Epstein matter Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein Order Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein Order Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein State of Florida Work product attorney/client privilege Emergency Petition for Writ of Irrelevant and not reasonably calculated to lead Certiorari to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Witness of Epstein rapes from Work product attorney/client privilege Switzerland irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Witness List Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger RICO Enterprise Work product attorney/client privilege Privilege Log Dated I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards RICO Enterprise Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards RICO Enterprise Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacv rights Attorneys at RRA Bradley Edwards RICO Enterprise Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger Plaintiffs Witness list Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Serve Subpoenas Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Info on MC2 Workers Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Serve Subpoenas Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Retainer from the Firm Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to th discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Witness info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Disseminate letter from Wexner Work product attorney/client privilege attorney irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Zorro Trust research info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Discovery Cutoff Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards New Property Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Epstein Case info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Jail Visitors Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION protected by privacy rights William Berger Bradley Edwards Activity in Case Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Depo Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Epstein Article Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Info on MC2 workers Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Witness List revised Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Confidential Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Donald Trump depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Confidential Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO fB.QM DESCRIPTION OBJECTION Jacquie Johnson Bradley Edwards Epstein depos Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Trump depo info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissitile evidence protected by privacy rights Jacquie Johnson Bradley Edwards Issuing Subpoenas Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Witness depos Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Subpoenas for pilots Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Serving Alan Dershowitz Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Witness info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Meeting with Leslie Wexner Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Visoski Depo Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissim Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Witness List Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards 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 Jacquie Johnson Bradley Edwards Confidential info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Ken Jenne Confidential Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Cara Holmes Jacquie Johnson Subpoenas for Epsteins Work product attorney/client privilege Attorneys Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Total counts for E.W Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Trial Prep Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Pat Diaz Bradley Edwards Updated Witness List Work product attorney/client privilege Irrelevant and not reasonably calculated to lead Privilege Log Dated I I I I Farmer Jaffe Weissini Edwards Fistos Lehrman 247ATES DATE TO FROM QESCRIPTI0N 0BIEOI0N to the discovery of the admissible evidence protected by privacy rights Carla Martinez Bradley Edwards Vanity Fair Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected bv orivacy rights Attorneys at RRA Bradley Edwards Witness List Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Confidential Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Jacquie Johnson Witness Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA KenJenne Witness Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA KenJenne Meetings Confidential Info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carl Linder Bradley Edwards Epstein Sex Abuse Litigation Work product attorney/client privilege Forum Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Retainer for Investigator Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO EBQM DESCRIPTION OBJECTION protected by privacy rights Jacquie Johnson Cara Holmes Subpoenas for Epsteins Work product attorney/client privilege Attorneys irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Disseminate the letter from Work product attorney/client privilege wexner atty Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected bv privacv rights Attorneys at RRA Bradley Edwards Witness info Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Investigator Info Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Denis Kleinfeld Bradley Edwards Epstein information Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected bv privacy rights Attorneys at RRA Mike Fisten Meeting info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Subpoena for Adriana Mucinska Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Meeting with Wexner atty Work product attorney/client privilege irrelevant and not re sonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman BAT QAll TO FROM DESCRIPTION OBJECTION Bradley Edwards William Berger Trial Prep Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Mike Fisten Depositions Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell New Evidence of Epstein Work product attorney/client privilege Fraudulent Transfers irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Draft Motion to Strike Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Finances Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Larry Visoskl depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Disseminate the letter from Work product attorney/client pr:ivilege wexner irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Bradley Edwards Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Trump Depo Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissin2 Edwards Flstos Lehrman 247Alli DATE TO FROM DESCRIPTION OBJECTION Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Trump Depo Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger Depo of Alan Dershowitz Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys of RRA Jacquie Johnson Cooperfield Service Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards E.W L.M Doe Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards Litigation Strategy Work product attorney/client privilege Irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe WeissinJ Edwards Flstos Lehrman BATES DATE TO FROM DESCRIPTION Bradley Edwards William Berger Discovery Bradley Edwards Paul Cassell Motion to Strike Paul Cassell Bradley Edwards Conference Call Bradley Edwards Jacquie Johnson Cooperfield Service Paul Cassell Bradley Edwards Accounts Motion for IME Attorneys at RRA Paul Cassell Litigation Strategy Susan Stirling Bradley Edwards Litigation Strategy Bradley Edwards Pat Diaz Mark Epstein Info OBJECTION to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected bv privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated I I I I Farmer Jaffe Weissini Edwards Fistos Lehrman M,TES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights Bradley Edwards Paul Cassell Memo of Assest Transfers Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Beth Williamson Bradley Edwards Federal Subpoena Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Federal Subpoena Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards New Times Article Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards New client Retainer Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Response to Motion to Work product attorney client privilege Consolidate Cassell strategy irrelevant and not reasonably calculated to lead Memo for Jay to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE IO FROM DESCRIPTION OBJECTION Jacquie Johnson Mike Fisten Subpoena on Epstein case Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Subpoenas for Pilots Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Releases for therapist Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson New client Retainer Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Answer to the C:omplaint Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Review of Notice of Taking Depo Work product attorney/client privilege RC Bear Sterns Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Questions from forensic Work product attorney/client privilege accountant detecting Epstein irrelevant and not reasonably calculated to lead fraudulent transfers to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Motion to Supplement with the Work product attorney client privilege Privilege Log Dated Farmer Jaffe Weissinj Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Overtime Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards 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 Attorneys at RRA Russell Adler New Times Article on epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Response to Motion to Work product attorney/client privilege Consolidate Cassell Strategy irrelevant and not reasonably calculated to lead Memo for Jay to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards New Trump Property Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Russell Adler Bradley Edwards New cases Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated I I I Farmer Jaffe Weissint Edwards Fistos Lehrman SATES DATE TO fB.QM DESCRIPTION OBJECTIQN to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Need Depo Transcript Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Draft Motion to Strike Work product attorney client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Draft Motion to Strike Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Multiple Counts Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Motion to Unseal Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Motion to Unseal Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motion to Unseal Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Beth Williamson Bradley Edwards Motion to Protect depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated Farmer Jaffe Weissim Edwards IFistos Lehrman DATE TO ffiQM DESCRIPTION OBJECTION protected by privacy rights Beth Williamson Bradley Edwards Motion to protect nd depo Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Motion to protect nd depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Motion to protect depo Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Motion to protect nd depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motion to Compel Photograph Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by prlvacv rights Bradley Edwards Paul Cassell Motion to Compel File this Work product attorney/client privilege week Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Motion for IME Accountant Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motion for IME Accountant Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I I Farmer Jaffe Weissint Edwards Fistos Lehrman DATE TO FROM DESCRIPTION OBJECTION Paul Cassell Bradley Edwards 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 Russell Adler Bradley Edwards RE Mark Schwartz Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motion for bond asset transfer Work product attorney/client privilege and memo final irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Letter to Critton RE Motions to Work product attorney/client privilege Compel irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell L.M and E.W Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Letter to Critton RE Motions to Work product attorney/client privilege Compel Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards LM.s Sons B-day Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell L.M.s Sons B-clay Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Evidence of Asset transfers Work product attorney/client privilege Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards fistos Lehrman BATES DATE IQ fRQM DESCRIPTION OBJECTION and/or liquidations irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell L.M and E.W Epstein Im on Work product attorney/client privilege it irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Beth WIiamson Bradley Edwards Jane Doe change of address Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Jane Doe change of address Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Jane Doe change of address Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Doe Epstein Motion for Work product attorney/client privilege Extension of Time to File irrelevant and not reasonably calculated to lead Response/Reply Answer to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Is Jeffrey Epstein the new Work product attorney/client privilege Madoff Running a giant Ponzi irrelevant and not reasonably calculated to lead scheme to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Is Jeffrey Epstein the new Work product attorney/client privilege Madoff Running a giant Ponzi irrelevant and not reasonably calculated to lead scheme to the discovery of the admissible evidence protected by privacy rights Mike Flsten Bradley Edwards Interesting Web Site Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissim Edwards Flstos Lehrman BATES DATE TO FROM DEStRIPTION OBJECTIO irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards RE Accountants Motion for Work product attorney/client privilege IME irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Paul Cassell IME Rules Work product attorney client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson IMEs Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Confidential Detailed Strategy Work product attorney/client privilege Memo on Asset Protection Issues Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Depo of Jeffrey Epstein Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Asset Protection Issue Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Igor Zinoview depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIP!ION OBJECTION Bradley Edwards Paul Cassell How many claims Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Hiding Assets Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Secretary Contact Info Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Hiding Assets Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Motion to Unseal Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell 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 Paul Cassell Bradley Edwards 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 Privilege Log Dated Farmer Jaffe Weisslni Edwards Flstos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION Bradley Edwards Paul Cassell Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Info on Maxwell Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Doe Jeffrey Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Doe Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Vlsoskl depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Financial discovery Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Federal First Amendment Work product attorney/client privilege Complaint irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Privilege Log Dated I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman 247ATES DATE TO FROM DESCBIPTION OBJECTION protected by privacy rights Seth Lehrman Bradley Edwards Farnsworth Macys case Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Richard Wolfe Facebook/Myspace Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Amy Swan William Berger Expert Witness Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Paul Cassell EW and LM Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epsteins Address and Position of Work product attorney/client privilege Critton on Motion Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein Forensics/Investigations Work product attorney/client privilege INVOICE irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Litigation Strategy Work product attorney client privilege Privilege Log Dated Farmer Jaffe Weissing Edwards Fistos Lehrman MI DATE TO FROM DESCRIPTION Bradley Edwards William Berger litigation Strategy William Berger Bradley Edwards Litigation Strategy Bradley Edwards Amy Swan Ryan Hall Psychiatrist Amy Swan Bradley Edwards Clients Cell Phone Number Bradley Edwards Amy Swari Clients Cell Phone Number Bradley Edwards Marc Nurik Litigation Strategy Bradley Edwards William Berger Litigation Strategy OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman 247ATES DATE TO FROM DESCRIPTION OBJECTIQN Bradley Edwards Amy Swan Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Amy Swan Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Amy Swan Litigation Strategy Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Litigation StratE!gy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by prlvacv rights Bradley Edwards KenJenne Epstein Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Maribel Matlska Litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissint Edwards Fistos Lehrman 247ATES Qfil TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Bradley Edwards KenJenne Plane Tail Numbers Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Witness Numbers Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards KenJenne Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Subpoena Clinton Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Russell Adler Epstein strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Alfredo Rodriguez Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Motion to Unseal Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger Subpoena Clinton Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Topics for Meeting Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Gary Farmer Assemble Epstein Litigation Work product attorney/client privilege meeting irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Law Enforcement cannot release Work product attorney/client privilege juvenile reports irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Amy Swan Bradley Edwards Preparing Motion to take an IME Work product attorney/client _privilege of Epstein irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Request for Copies Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Travel restrictions Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Welsslm Edwards Flstos Lehrman BATES DATE TO FROM DESCRIPIIQN OBJECTION Marc Nurik Bradley Edwards Alfredo Rodriguez Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Flsten Epstein strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Legal Opinion Work product attorney cllent privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Communication with legal expert Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards No objections from defense Work product attorney/client privilege counsel regarding depo for Sarah irrelevant and not reasonably calculated to lead Kellen to the discovery of the admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Flight logs for Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Assemble Epstein Litigation Work product attorney/client privilege meeting irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Priscila Nora Batian Assemble Epstein Litigation Work product attorney/client privilege Nascimento meeting irrelevant and not reasonably calculated to lead ǽ??M geyH9 Zo 뙈??X ab?"Β _ఈh V?B?qa Y?ezp??Y Z?CU?o?Fo p?!f H?u ƒmz l_ Z?yFo M?C R?r t?B Tb TGnJM 5M?H u0 N?MV P)XzYӳ??F?Y1?W 4Q bD..3I?A y?ZP In Ï??h??KFfu kM v2 I;o ĥ?ڽ G5 Y?a z5?XU q?v?E a a AL W?X 9X 3H?P_?I?bN Pu Zx Ft_L ax lM8 nƅ A SJ?2??eBQ?q?j O?Ͳ?l XtOt ny n?T?ߘ_C y?E wy䘘1Y?s"?co iwζ l??ѥQ 鿗ЧΧy gs?s?_a u??W Ĵ??d?m?a VP Zif/eD?4B??4 or 3I d2T x?屘,??kUp?پ Ɇ?sPS 1??UTgj z?p fT?6Խ??R wP Hu?Q Opu_ LP Ի:Y4 W?wC N??ߘ 6r?ږ J?ɻ"R y?P??r J??x H?r o2ڗ?t?k?;h QI??C?i ĸ?s Yޞ Q?G?o YI?3 OM,4 kc?xՁ a?n V?U I GZ dQ rk?A??!yr ym?/?y Y?M od?z Q!CZ U??JT?ꍧ?W?gZ5 c?,咝 e?q ԱV P?m l?0Tx f?d lH MFT?h a h?ߑ i b?r?A U??/б?g?Pg sd a ɳz?K 6;ll gϐ Oj nA H?h 1?mo?CҊW?P t!M??D S-?D?d jQg?a??X??uay?l?!;??dmIRԼ?P?g s?A?Ʃ n?1o T??O?L xE VP:I?ͽ 㶮?r a?P b2 ԭ_ A i YL 6lՋ??dN??G Bj a X?FA i Q1?Y RM T?S?zYfW-9 bg RƢ?su i yh4 A l8 BX ds?c4??m 謣?r zL?L k?h e?G??p f?IB Xd?VxS E?羥 ah?xo rNu 1q Z?f?d2 1,Uw?b DN rSU?5 n?V joV sچ??n s?n I3 1?VߌB ns uo 6KG BS?P ܜR0?f yQ GT?1T ܚK?-S?l?O ռ?u??ȯd i??s?oh ek,l xV dN O?Fw??h u,W I?iN Ƕ?郍?N?aO?Jj Jή.P??(?cj u?P U?Iq p??M G?F?T xҳQ Jf jE 2W s6 P??K?l 0a?x?eP h?JR mc?g si Dq?V?2 zXg?I vH ZI i YB"?M?J?ܠ g?mt g??T ggw31Z L?d?c?Iƞd?yp L??w WW A?j PN P?wG I?I Vq?D??V 6Wvl gWyBS?R?3n(?c R??J Z:?s b?O g?ě dY??M CSf G??wd m?M R_ ah yF?9 ӆ?B?3cC nU ɽ7v A p?n?.P k??U MY?xn8 RX Z7 ݦ?ln H0 ԓ?ɦdN f??wʍaR I Pr??T?R Hro 2w?t QŪL Z?w(b?4?bsݭIG?4 Ԥ??R?k ÔZ?X g??bQ BOu?D 9E?B d??EU?쿽Q P?qA f"7F q?ӟK?h a?KrIE?Z r?P KP?۶ 2D 5Eʳ H?p?K?M B??d R?Kc 7D Rܩ I pހ?I rӺi?J?h??A X?Ml RϺ ո?Gf a S?O KxR?E Zp D??m KC a A8?Ә W?B tl 1A?B Uj J?"b?õ ixcv p_ o?Ŀ 奖?L f?e??c a k?v t1SA"?dG Z73K B?X?v 9zkW6 K?E Tف?V Y1?b)e v?c膠?O ch?ۺ FIը I P??N j?XSF sA HGL?雰æt??2 D?l W?ZWاC Y?y v4J h?U o??g D?KE?F k?Z?S o?X 0S Œ?;B Ҕ?UC AMiX??3?r?;Y?E O?pʊ P.D t?yv??I ivM Q?r NyQ?f?nӣ J??g DD ӧD?ҥ vfl?k H??V nA vB5䌋 W6?N Ie RtS??1 O?s?Tu?M 0SC ϊLI b?q?f қ2M ʌ??v?g G??fT ʷEggf?b?CtV"8 a 3ӝBm4V?.j8 v?d?BV 閠?T5 a8Ң?dtmP s3 X??C a i?eҍG?M tk 0v q?g 3X g?Id x?X pˤ??n QHچ cmʞ rP DRX T1 wx Go W?t.e?Jbp??8a?x i pJ 5w U?t Qv?ڂ Ųw wP5 WL?b7 X0 Eg R?yFaͱ7?cK I?dGynh;?p ۀ?fcS f?b O?к Mۼ?x egu q٢ ƒJщ Vt۳ 4s M?yMʥ ܒ?T ܜ9 vJ?j p??D?K?n?nի t??wJ FKѐ??i q?g 3fZ sO SQ5 KQUt?0??K ﴙ??B?f e??M?T D?;?IH J?Ӿ U?X??J Tӡ??Hɧ X?Sg?c zrR Gj??V X?O r??s?ǔ dp?Dv2?_ BQ?P!my ߜ?X l?쫭vb 2?gA W,?j o?Ɯ Lяk ޙep?D RVxz4 h?/m??l?hR 9g qd__ vг?M dB0ҏ Zg KU 1z µ?c2 ٸ?r s??c Gx섓 ץ?I Z?y T?x NA 1?lg d?b?t3M??HU5 w?;P Z??ˡ F??E a1??MP R?c d?Җ υ2p b?5S иe?Yh?K?h px?7RWȻ_?Q fB Wܦ 6J SVp ٠?fxc r_ t?:t r?e NY c?!B O?iD P?gm?R6 qZ Cj Gm?_?v?LC?yH!?WX EiR k?S vGB Pv?S gN?xQ??yZ a I4cMu:?k?i1 A 6?Fp?Y a su??kv ǭ?J8 ehg i!Kq vBL k??l y?s?ۈ r,K x?z??D??D?TA?ĸ?NF?A:lť c??S Z?ڏ?"Zj K?G b?S RI?X??O w!9i dJ?s 㾏??C 5?JZT x?j?pT W?9V nS TF??r3l ds?HmR9?4T br??en Gкl d?m?cr LGB01?.Z?l i3 L?ƿG1C?z?oY A e??G6Tx QP ǰk f4m?ąq hD 9Smwi nf?Cu iJ:?ړ?O VI??A g?Gv Z?Bշ km??FO?صFD?2?U d?os nRa r??T mNO Wf?zL Ӿ??G lQ 0?iL?е VZ 0C ߡ1?M?B?E e?gl Ä?jAk v?T??ǉ i vl 1iV??A D?Kɷ-?n z7 ۳H?d?mA k?7B i lL?s Ј?zg 6n 9x Dz T7 QS i ꗮ?Xv o6 H?ZOP QF k?Y??B N?l o7 OJ6 C??ލ i K?C l?L?b G?Ÿ2 k?h Κ?L/a?y S??W C?3d??OG rƿ?X辦 Q)l D?v?ԋ v9ms?ʩ W?I?Ò4 a Mw O?Kl4Fh 4p q?1ؤ NI pvκ 4j Id ػ??Y?Qq l?g?x A Ďk lՆ?zFlJ Tr QC z?R I?gŁJ2 Zt?G?E?rH u??C Os i a0TG r?s?0e eҦ b?ZO 9G_C?P V6 3a?l?J n/ɥ?ΰ9Ɉ IG8?k?O?L pX?G 1Um xX!:d Do 4_ t?K Gl I WE 5I VK?l s??e ZL?F ɘ;?ۃ U?mm?2 z2lT kWǑ?i E?pc ş??j N?aW N?C RJ Vo?E 3W A Ӊ.ԍ u?r e?B 7P Ĩn?H u??h n5 9Ӵ Q5 yI?Ӛ QL??5T??xEt?v ŋ3Z?I p?rS Q3 u?rd S4W?do BU a?og 9x cV??vG?"T?ډ dN 뵗F H2R ݸ7?o K0 XV?0 k?O?W?F N?F G?m1X?2c?n d?f??pt s?N2 de?IO IP 1w?b bR a i V?Z FT el jɝ E?r P?4r?Vi 6y v6??skwґ9 qDF QHm3 E?k?s?i?7?PF?Z QD 0M cfO M?p MV XA Iw SB U臊z?c NH??J??Um c?Bp p?n h?SpN N?let?E??w i Ώ66h?fj S?d?z 5?V?SW vXx BC?P?p 1X da?8 lmK?N?;Z E?Ͼ2 GE C?)kՐ I Xo K8 5DyQ AQ?D?5 Wl J?J?k bߍ?6 A qjz?L Qc d?L Ě2?t Gs vW M0 H_ k??ѐ Q?K?p pL?kQ 1G?j jL??ߦ XV d?E A?-1Hĳ U?O?wHFg?q t?k w?3kJ-??ɖq l5 L.i r"R Z?ی 3?ZH A z5?d HS勐9D??6 u7 xي sk p3?J w?U I?VY?d Am a n??t I JʧV._ Yd mM V5?M S??fUx??U xR?x3 AȾ??H??ųY 9j d?V??f cw tTxŤbn hN??s KplPF?t(??yc _煺?"?Y?ӪZd??Yi lc?K iR xk?JH hl w?w r?_,?ok?ӣS a O??AphpI2?ǅ Ye??O Ly-Vp 3B oT s?Ꮒ?Mg a?m?v U3 1xSj 1ڶa Դ6q?7K xw E?u?ͳ fՔ 7F sI?kmEb Nr?6NGHU??"?e yJ?Zv 3U UD bz R?U?ӫ AC??y ĤF b1q EK Et UR?jR Z?r?XKr y?P Klgj?zz?.Մ ذ?z gA If BdgY a i?C N??YGe B?ae5 VB V/s 5x??l?En c?Y k?놡 mP WU i ꚸ?KD mG ZO/?H?C I?Q C?x I??JlKp Xފ?UV8R ʀ?gk T?y g?O s?ȳ a??I Q?Z I ܝr HZ?8 q?zH H?4X c9?L H8 ɚ?z?s I8f g?Ed H?V F??bv p?V5 F?x??p ˑQP?S n?sY_0 U0?NUs?d?F Ōx e??_Gߔ o?i S?M vζ?e??f?x I k??с 8M 7V ai?h?W a?u8?T HIL?W 3u i?j D?GZx??DD??p Г?k i 8m?u n?V h?!?wٿ db Re BZ k?h?t V?h0?0BZ6rL2٩kH ᢺض?b nQ ӘL tS?4"c ٣ʎ A?U t?l p?m_s d9 m7 lJ q??z uE R?XZ u?MFIb j?6Z?l?Ox?I V?A?2?CP 4s Ma_?d I _i I?G nț T?J o?J1 D?w Na?8 2?Ǆg R?X r4K?jn?6p?eF V?F X?b?7d mF3 ו?g5 A?Y t?o??i 2J G?5g 9r?MЙ yT i g?C ݔu5 b?Id?eI?Ҫ wu iX?A l韋 EGI W?K NK VKN o.Ge x?U A?p?e B3ヒ N?:upH ࢩ/?Bo e??T dT?Xӻ 3Q qf Pbs i?V?S A2 v??M ʔv s?Y kq x?k?W G?O?:5AO k迤?ur O??q 9ɵ HM U?Q?b ۉe gD 0N a eK?ge??d??;aGڷ c?V?Gq ሪ?x?Y p?kZ X_Jݺ 8b OQ x?e.?x lLȶ 2?Tb O?g Kq d?Et CJ Yu L?H h-z8 q?G??d dL z픸?q n??k?j ᑢև??68r?EBM,ĭp?gCB I ӓ4?H c?a?ߝ B.ʢ F?m sj?6Q??śu NY??Y??v ǯO?4DR??I?,R 9Gy VD Z8 F??M DDөl?J?!?ۮ1 t?e T??I Vf b?H tk?o Mm b7?g m?j v?PH R?P JO Ƞ?gR?8 Ȑ?Ǩ Uz ߺ?V l:?o v?uE ȫVx k?w 실?PXS7l?g q?ʼ7 IU 4?qq?m?OČL?L?ȓ Jj-?zP?gڂ B?DR Ek MX A v?S LÛ?wT 3E kW F?m Z8Y ݯvPi U??J v?K h?P pF?SW c?t aML?L??dQ?d Qs Q??p b1 ޣP o?b c1N6?H ȯ6o?5t v??H sIb?V?W??k TD 4?HO ぞ?v Co?H p?P?X OR Owu ݵ?d Df?BT cŚ g9 JS?2?N o?n fu e?W??k?J ؿ0?WlQx?D S?"EW c?O Sa y0 ti U?I??ϻ AT?O??vW ݠ?T Si U?X?O?Ws I F?0E w??k aYJ n8W??AiC A?D??q?k?f Uq??z cΧ 0?oyZ?l?Ƽ?dI?tk2!I5 U?ʬ x?6V??ePs?c0 PA s??S Q:?s bQs?1 az;?a?B?Pᅤ xj l?ζJ n?Rš R?ж?D7 G랂 a?O 浌??w D?x zX?".B?C F4 JQJ??8x _yk zP ᔿ?i gڣ?F A?F9 TW??1C s0p?UTg bN o?d Qh?P uf3b i?WK g8?m i qG ϒ?嘂 oA jh X?p c?y l_ K?H MI P?ע?J H?T??y 2?Ŏk?ޞ aN AI M??ܟ sn-I B:g iY Ϳ2 t?N??VN hC TYϾ L?P yi?Ma?M?w FX b5z uy?w??敭 Eh y5B v??V?v?N iC 9Lt?3K U?ݽ kR k?W aٶ?e x?l I kpNby?9?:?dM 3L j.T xu ɀ6h??E?.Du A a M?B H?W??h DoS?2?i ӷ_D X??e te ݮ?n?t _?Yb hĤ??VzE f?z ey 7J O??J x!s Ùb?V F?x2 B?o?k??Ǘ pp i عV WΖ ER i?J Uf t?M?o FI?S t2 ҠZ?Z_?r??US F?i vwg X?!R Oj m,?y J?m?X v?RX L?mi lN fݗѠ i?-abTM?_ _x X?t맹ԝ dZ H!?ob wj _Áp VG?u?"?E Lj 礻?,Y l8 3K U?WY?1?Nc w)?M I B??x S??M eq ʲ?X??1fU?dZ 4?EE ڟヹ?ER?w fjA?y U?Z?B Lf ʋ??XRnŻ k?Ta?"c8?R ht V?u?n?v?Z HRz AyC Vu cH Oy Z?D ЃD?W ޤ/?q i ԓ6 Ri OD??o g?ZcL?cA ɢǾ g??p bPs?-k ԡW v??Y I RP?LA u??X a 6Gm?e K??L lZ3 fe Ne??h?g??hU l?BhՃ Nh??ԇ 6akJ?J O??ݐ l2ƗKнt RL FL Z?W ە?N w?ĵ?9I ҙ?e R?Z4 bF dl o6??JRB1 iES 3Z 4?пj exxK T?e C?C?V sQ LP??zF b?U Џq km?Ǿ4I?4RZ c觉?lͱ 5㮶 h??J fE f߈ 6fz ɪƷ?6?P ii 6l a 0?t?MAI wW 0ɕ ia?X jW B?k Re i?G 0oPk i??g Wk?A?B3 I?s Q?D i5 篱pV?繭??v?D¾A a z?R lЯF-c ߄?Y?qJ Xpګ i Privilege Log Dated I I I Farmer Jaffe Weissint Edwards Fistos Lehrman Mm TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Wayne Blacks email Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights MarcNurik Bradley Edwards Call with Chris Hanson from Work product attorney/client privilege dateline irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Marc Nurik William Berger Legal expert regarding legal issue Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Marc Nurik William Berger Communication with legal expert Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Research on cases saying a judge Work product attorney/client privjlege can postpone one partys depo irrelevant and not reasonably calculated to lead until the other Is completed to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Legal opinion regarding Work product attorney/client privilege discovery irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman 8.ATE_S DATE TO FROM DESCRIPTION OBJE ION William Berger Bradley Edwards Proposal for settlement Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Proposal for settlement Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Depo Dates to take SR LM and Work product attorney/client privilege cw irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Investigator retainer Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger File a request to produce Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA KenJenne Judges order on the Epstein Work product attorney/client privilege probation Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Ken Jenne Michael Reiter info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Russell Adler Bradley Edwards Set Epsteins depo duces tecum Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Right to move to reconsider all Work product attorney/client privilege rulings irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Susan Stirling Bradley Edwards Epstein filed a motion to Work product attorney/client privilege continue the trial Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Epstein traveling Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards The response to the motion to Work product attorney client privilege continue is due Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Russell Adler Epstein litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Subpoena Clinton and others on Work product attorney/client privilege Sid Garcias witness list irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Phaedra Xanthos Final affidavit from forensic Work product attorney/client privilege accountant irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissinl Edwards Flstos Lehrman ATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Response to motion to compel all Work product attorney/client privilege the sex information of his clients irrelevant and reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Susan Stirling Epstein depos Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards VZdepo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights William Berger Bradley Edwards Reporter asking how the depo of Work product attorney/client privilege Epstein went irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Epstein State of Florida Work product attorney/client privilege Emergency Petition for Writ of irrelevant and not reasonably calculated to lead Certiorari Emergency Motion to to the discovery of the admissible evidence Review Denial of Stay protected by privacy rights Jacquie Johnson Bradley Edwards PFS Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Marc Nurik William Berger Epstein sealed records and TV Work product attorney/client privilege Irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman TES DATE TO FROM DESCRIPTION OBJECTIQN to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Epstein Potential witnesses Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Subpoenas for potential Work product attorney/client privilege witnesses Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Scott Goldstein Juan Alessi statement and Work product attorney/client privilege burglary report irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Paul Cassell Epstein injunction filing Work product attorney/client privilege accountant affidavit will be sent irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Epstein Invoice Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Elizabeth Villar Bradley Edwards Updates on of victims billing Work product attorney/client privilege amounts etc irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Epstein Discovery Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES Qm TO FROM DESCRIPTION OBJECTION Jacquie Johnson Bradley dwards Epstein Discovery Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein Discovery Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Epstein Discovery Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Ken Jenne Bradley Edwards Discussions about the Epstein Work product attorney/client privilege case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Epstein depo in 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 Bradley Edwards Paul Cassell Hearing regarding the Epstein Work product attorney client privilege computers Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Marc Nurik Epstein AUSA Attorneys Fees Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Beth Williamson Discussions about Brads Work product attorney/client privilege recovery Irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Holding Fed Subs until we get Work product attorney/client privilege response on form irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Two ideas regarding strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by prlvacv rights Bradley Edwards Paul Cassell Taking the 5tn Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Elizabeth Villar Bradley Edwards Getting the forensic aspect off Work product attorney client privilege the ground epsteins asset irrelevant and not reasonably calculated to lead transfers to the discovery of the admissible evidence protected by privacy rights Paul Cassell Bradley Edwards Epstein Subpoena Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Subpoenas for trial Work product attorney client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Flight Logs Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Alfredo Phone Numbers Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTIQN OBJECTION Rodriguez irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Addresses for people involved in Work product attorney/client privilege the case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards All depos in jane does case Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of _the admissible evidence protected by privacy rights Pat Diaz Bradley Edwards New developments that require Work product attorney/client privilege your expertise Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights0 Privilege Log Dated Farmer Jaffe Welssint Edwards Fistos Lehrman BATES DATE IQ ffiQM DESCRIPTION OBJECTION Work product attorney/client privilege Pat Diaz Bradley Edwards New Epstein victim irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Carolyn Edwards personal discussion Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Pat Diaz Litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Phone number for one of the Work product attorney/client privilege other girls on the list of irrelevant and not reasonably calculated to lead prospective clients to the discovery of the admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards Taking the depos of everyone Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Dates for depos of all witnesses Work product attorney client privilege in the case irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Paula Heil Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Dates for depos of all witnesses Work product attorney/client privilege In the case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black FBI has original flight logs and Work product attorney/client privilege they interviewed pilots irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Copies of the flight logs Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards Personal convo between Brad Work product attorney/client privilege and Mom irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carolyn Edwards Bradley Edwards Personal convo between Brad Work product attorney/client privilege and Mom irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Carolyn Edwards Third party subpoenas for Work product attorney client privilege Tatum/Courtney irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Ghisella Maxwell info Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by prlvacv rights Wayne Black Bradley Edwards Epstein litigation Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Pat Diaz Discussion about girls involved In Work product attorney/client privilege the case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Paul Cassell Ronald Wise New evidenc:e of Epstein Work product attorney client privilege Fraudulent transfers Affidavit irrelevant and not reasonably calculated to lead from you to the discovery of the admissible evidence protected by privacy rights Earleen Cote Bradley Edwards Cases against mansion nightclub Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Getting addresses for people for Work product attorney/client privilege us to serve subpoenas irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Bradley Edwards Plaintiffs Wltnim List Work product attorney client privilege Privilege Log Dated Farmer Jaffe Weissim Edwards Flstos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA KenJenne Assistance on the Epstein Case Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Steven Jaffe PACER entries Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Phaedra Xanthos KenJenne Political Work product attorney/client privilege Contributions/advertisement for irrelevant and not reasonably calculated to lead the rental on Little St James to the discovery of the admissible evidence Island protected by privacy rights Scott Rothstein MarcNurik Discussions about Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Jacquie Johnson Creation of another Doe file Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Shawn Gilbert Bradley Edwards Epstein Costs Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Shawn Gilbert Bradley Edwards Personal convo in regards to Work product attorney/client privilege moving offices irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Shawn Gilbert Personal convo in regards to Work product attorney/client privilege moving offices irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Shawn GIibert Bradley Edwards Office information Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Pat Diaz Updated Witness List Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Carla Martinez Bradley Edwards Vanity Fair Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Witness info that we need to use Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Wayne Black Bradley Edwards Info on a guy going to victims Work product attorney/client privilege boyfriends house irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Info on Former FHP trooper Work product attorney/client privilege subcontracted by Riley irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Epstein affidavit to the reply Work product attorney/client privilege memo irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissinl Edwards Fistos Lehrman llATES Mn TO FROM QE tBIPTIQN OBJECTION to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Russell Adler Flying epstein rape survivor to St Work product attorney/client privilege Louis to see expert irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Meeting with client Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Pat Roberts Serving Alan Deirshowltz Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Property purchased by Epstein In Work product attorney/client privilege Palm Beach irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Epsteins arrival at his building Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Research regarding Mr Visoski Work product attorney/client privilege and questions to consider during irrelevant and not reasonably calculated to lead the depo to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Ken Jenne Epstein travel Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman BATES 267DATE TO FROM DESCRIPTION OBJECTIQN Bradley Edwards Mike Fisten Questions from accountant Work product attorney client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Visoski Research and Questions Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Flsten Info on Copperfield Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA KenJenne Info on Copperfield Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Pilots depo 267work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards List of witness Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Serving Dershowitz Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman f!A DATE IQ ffiQM DESCRIPTION OBJECTION Attorneys at RRA Bradley Edwards Proof of him being out of FL Work product attorney/clie_nt privilege Violation of the agreement irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Mike Fisten Dave Rogers depo Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Mike Fisten Depositions Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Mike Fisten Serving Dershowitz Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Flsten Subpoenas for Pilots Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Working with the FBI to get some Work product attorney client privilege info irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Pat Roberts Bradley Edwards Personal emails regarding Brads Work product attorney/client privilege surgery irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA KenJenne Epstein travel Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Flight logs for Epstein Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Problem Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA Bradley Edwards Witness Info that we need to use Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Asset movement by Jeffrey Work product attorney/client privilege Epstein irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards cara Holmes Subpoenaing Epsteins attorneys Work product attorney/client privilege for their fees and accompanying irrelevant and not reasonably calculated to lead documents to the discovery of the admissible evidence protected by privacy rights Marc Nurik Bradley Edwards New Info that our investigators Work product attorney/client privilege obtained from current FBI agents irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Josh Roberts Bradley Edwards Personal conversation Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissint Edwards Fistos Lehrman BATES gm IQ FROM DESCRIPTION OBJECTION Josh Roberts Bradley Edwards Personal conversation Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Josh Roberts Personal conversation Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Carolyn Legal CW Personal Information Work product attorney/client privilege Asst to Jay irrelevant and not reasonably calculated to lead Howell Co to the discovery of the admissible evidence Counsel protected by privacy rights Edwards wife Bradley Edwards Regarding personal information Privileged document irrelevant and not calculated to lead to discovery of admissible evidence privacy rights of parties involved spouse privilege Marc Nurik Bradley Edwards Concerning the names of Work product attorney client privilege potential witnesses and the Irrelevant and not reasonably calculated to lead issuance of subpoenas for them to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Investigative information and Work product attorney/client privilege techniques on the Epstein case irrelevant and not reasonably calculated to lead are discussed to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman Mm DATE TO FROM DESCRIPTION OBJECTION KenJenne Bradley Edwards Investigative information and Work product att rney/client privilege techniques on the Epstein case irrelevant and not reasonably calculated to lead are discussed to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigative information and Work product attorney/client privilege techniques on the Epstein case irrelevant and not reasonably calculated to lead are discussed to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Concerning the names of Work product attorney/client privilege potential witnesses and the Irrelevant and not reasonably calculated to lead issuance of subpoenas for them to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Fisten Investigative information and Work product attorney/client privilege techniques on the Epstein case irrelevant and not reasonably calculated to lead are discussed to the discovery of the admissible evidence protected by privacy rights Pat Roberts KenJenne List of future depos in Epstein Work product attorney/client privilege case and names of potential Irrelevant and not reasonably calculated to lead witnesses to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigative Discussion re Work product attorney/client privilege finding of Epstein Assets irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mike Flsten Bradley Edwards Investigative Discussion re Work product attorney/client privilege finding of Epstein Assets irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigative Discussion re Work product attorney/client privilege finding of Epstein witnesses and irrelevant and not reasonably calculated to lead names of potential witnesses to the discovery of the admissible evidence protected by privacy rights Mike Fisten Bradley Edwards Investigative Discussion re Work product attorney/client privilege finding of Epstein witnesses and irrelevant and not reasonably calculated to lead names of potential witnesses to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Jacquie Johnson Discussion of potential witnesses Work product attorney/client privilege and the process of subpoena for Irrelevant and not reasonably calculated to lead depos to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Mike Flsten lnve stigative Discussion re Work product attorney/client privilege finding of Epstein witnesses and irrelevant and not reasonably calculated to lead names of potential witnesses to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Investigative Discussion re Work product attorney/client privilege strategy of case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Privilege Log Dated Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OftJ CTION Bradley Edwards Wayne Black Investigative Discussion re Work product attorney/client privilege strategy of case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Pat Roberts Investigative Discussion re Work product attorney/client privilege strategy of cast irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Investigative Discussion re Work product attorney client privilege strategy of case irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Wayne Black Investigative Discussion re Work product attorney/client privilege strategy of case Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights U?vO?OP?F3O G?M?tI?OO?G0 W?ii?W8x??I7 I K?K A o(o3oBz 4K 30KCb 2e p2t 2A A Q?8F JK TZ N?M?r NEeD?M rq A WS?nY?GE mR?d YBWY xy?u?u i hSKI YjnU?zy?h ZF?gj?_?Ґ y:1y E?ak?2 g6 EeD T?J Lf Kf??w k?հ F?R A EN NE_ _Ey sCyH C?H C?H C?I QIC9 4O L0L?L?L L?Sjz 6F I I 6K Jn EDb 2O I1 9Cv A ngq 31Fs_g d6 TZ 5_ jz qr A..AA?A..AA g6 X?a M?N q?M 10Cy J?tZ m?E9q6t ORA?豕ar A i A i A i A I 1z I q?M CTX qY CTX qr a nd blWF uq??Ԑgg?8 9A A I 0b qr h:?WB p?c O?H lOK8 A Og I M?q qr un i W!k CTX yN?hY W?Qsyzo KMu?m M??N q?M CTX Y10Cy شl a GF3IW O?ǉcప H?X?D?S G5 G5 CTX qr q0T3 o3z I_ 3j i jh3 A 0b l??9Lڱ?lVy 1x vff?516SP?ml V?rL?k?Nfq??yasZ??l OiwvO4h/??F zWH9j شl Ƨw??ơ ByMY?YA_ eݷ?y?j Na?x?wV g6 AA..AA,/AB..AA A..AA..A B..AA..B g6 jz AA..AA gq 1:K6Bg AA 31Fs_g CTX A W?n?jZ CTX A a qq 1M bWd aHA?A AB..AA qy R0 1SJq?xXkI?h?A/.AA./A a?F A?A A?V?E XP R_ A ABB3B OR1BA OA3 B?B Rg I?I I UV N?M?N 10Cy DK7 0GHFHEH It K7I H:Ct J8L l6L uA I Ӷ??t t:Z M?LM DGn??sCY KMqP;G 8I q?x HA8?j hqSEEn OtŐX?OX dBN CTX I O!Y rY b?UU 0Z g6 4D J4W 2P O3 P:c 0v sz B5 A4 CF4 B5 L_ E5 a qCX 10Cy rq Fa?3U M3 J?c _9??NºdPtq??V e?U wf Mw xO?T A I dc rM?N rqM??q 10Cy rq v현?y T?H I ac qr rM 10Cy rq 3V M3 2?Zs 5g t4 RU T0 t?(c AZ kP d6 ac qr UO ED Eej Ko?5OJ Vg lg _Y 6x P6p6 C1 I5d rM qr 10Cy a d6 a a Nqr qqr E1S lg z??g 10Cy qr E1S C?t z?i 6BT v0y5z6 PE CTX ED 9q A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz N?q qr NEeD K?i N?M?qr EeD k??O GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8
315,580 characters