PREFACE No Court not this Court or the Special Master appointed by the Bankruptcy Court has ever conducted an in camera inspection of the documents identified on Edwards February privilege log ruled by this Court to be legally deficient and in violation of Florida Rules of Civil Procedure and binding legal precedent Now that the appellate court has made this time available to address pending matters it is up to this Court to determine whether Edwards may continue to conceal and withhold from the jury clearly relevant case-ending evidence that makes it impossible for Edwards to satisfy his heavy burden to establish a cause of action against Epstein for malicious prosecution Although Epstein is asking the Court to conduct a limited in camera review of documents4 none of the documents in fact are attorney-client communications and Edwards has waived his work-product protections with regard to those documents Once this Court confirms as it should that none of the documents reflect communications between Edwards and his clients and therefore that they are not subject to the attorney-client privilege these documents should be permanently unsealed deemed produced and ruled to be admissible and Epstein should be permitted to introduce them as evidence at trial INTRODUCTION The documents referred to as e-mails that Epstein asks this Court to review in camera directly relate to the strength of Edwards clients cases against Epstein Edwards The February privilege log was prepared by Edwards when he was working at the law firm of Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Farmer Jaffe which is now dissolved While the privilege log is entitled in the name of that firm for purposes of this Motion it will be referred to as Edwards privilege log Epstein has segregated the newly identified e-mails from his March Clerks Trial Exhibit List which include the documents Edwards claims are privileged as well as other documents over which a privilege has not been claimed Pursuant to the Courts direction at the March hearing to preserve his appellate rights Epstein will file those exhibits under seal upon the Courts entry of a sealing order To assist the Court the exhibits for the Courts in camera review are identified on Exhibit A association and interaction with Scott Rothstein Rothstein Edwards damages claim and the overall credibility of Edwards allegations against Epstein These e-mails are not only relevant and material they eviscerate Edwards case making it impossible for him to satisfy his heavy burden to prove the absence of probable cause for Epstein to have filed suit against him Epstein is entitled to have the Court and jury consider these e-mails as it determines whether Epstein exceeded the wide latitude which the law confers on all plaintiffs to use their best judgment in prosecuting a lawsuit without fear of having to defend their actions in a subsequent civil action for misconduct Echevarria McCalla Raymer Barrett Frappier Cole So 2d Fla quoting from Levin Middlebrooks Mabie Thomas Mayes Mitchell P.A United States Fire Ins Co So 2d Fla As explained fully below Edwards has improperly withheld these undeniably relevant mails from valid discovery requests for more than eight years after having waived any even remotely arguable protection that might apply to them Further in order to ensure that the e-mails would never see the light of day Edwards concealed their existence by hiding them within a deceptively worded 159-page privilege log that this Court found was insufficient on its face and did not comply with the requirements of Florida Rule of Civil Procedure and TIG Ins Corp Johnson So 2d Fla 4th DCA Despite Edwards efforts however the e-mails have been discovered albeit inadvertently Lacking any legal justification for withholding them in the first place and having concealed this misconduct through a deceptively vague and non-compliant privilege log designed to ensure that the existence of these documents would never be detected Edwards is now left with no choice but to protest wildly with unfounded Florida Rule of Civil Procedure has been amended since the Courts Order and privilege claims are now addressed in subsection of that Rule allegations of stolen e-mails hoping that this will distract this Court from its duty to conduct an examination of the documents Edwards has so improperly withheld and concealed This Court has repeatedly expressed its intention to maintain a level playing field between the parties in order to ensure a fair trial This Court has correctly recognized that in his malicious prosecution cause of action against Epstein Edwards has an onerous burden to establish a total absence of probable cause for Epstein to have commenced and continued his lawsuit In that regard the elements of a malicious prosecution claim are deliberately onerous It is the only cause of action in Florida that escapes application of the litigation privilege and the absolute immunity that privilege affords to plaintiffs and their counsel so that they may feel free to use their best judgment to prosecute their claims without fear of a retaliatory civil lawsuit Echevarria at The heavy burdens built into the elements of malicious prosecution are imposed in lieu of the absolute litigation privilege so that a malicious prosecution claim may not be used as a tool to chill putative plaintiffs such as Epstein from bringing suit It is not automatically available to all who are able to defend against a lawsuit without a resulting recovery against them Rather it is only available in those extremely rare instances in which a successful defendant can prove that the plaintiff had absolutely no basis to file suit against him in the first place Thus in order for Edwards to recover against Epstein for filing suit against him Edwards is put to the substantial task of demonstrating that Epstein had no probable cause for filing suit against him Because Edwards must demonstrate a complete absence of probable cause to recover against Epstein all Epstein need show to defeat Edwards counterclaim is the barest showing of probable cause the standard for which has been aptly described as extremely low and easily satisfied Gill Kostroff Supp 2d M.D Fla Epstein maintains that See Wright Yurko So 2d 5th DCA Probable cause in the context of a civil suit is measured by a lesser standard than in a criminal suit But obviously less in the way of grounds he has already established probable cause as a matter of law based upon among other things a undisputed extrinsic evidence of Rothstein Ponzi scheme a third-party lawsuit alleging the use of case files from Edwards client cases against Epstein to support the Ponzi scheme and the identification of specific litigation misconduct by Edwards that corroborates the third-party allegations that the purpose of the litigation misconduct was to enhance the value of those cases to more effectively use them to lure investors into the Ponzi scheme Edwards disputes none of the evidence proffered by Epstein and provides no direct evidence of Epsteins state of mind Instead he asserts that Epstein could not have relied on this evidence for probable cause As support for this assertion Edwards sets up as the central issues in the trial of his counterclaim against Epstein a the strength of his clients cases against Epstein the lack of any association between Rothstein and either Edwards or Edwards clients cases against Epstein and the legitimacy of Edwards litigation conduct in his clients cases against Epstein Edwards further claims that he has suffered and continues to suffer damages arising out of his anxiety from Epsteins complaint that was filed more than eight years ago and dismissed six years ago because it a falsely characterized Edwards cases as weak indicated that Edwards knew or should have known of Rothsteins Ponzi scheme and alleged that Edwards engaged in litigation conduct to support the Ponzi scheme This Court has already given Edwards substantial latitude to present to the jury circumstantial evidence bearing on Epsteins criminal history his non-prosecution agreement with for belief will be required to justify a reasonable man in bringing a civil rather than a criminal suit The instigator need not have the same degree of certainty as to the facts or even the same belief in the soundness of his case and that he is justified in bringing a civil suit when he reasonably believes that he has a good chance of establishing it to the satisfaction of the court or jury He may for example reasonably submit a doubtful issue oflaw where it is uncertain which view the court will take the government settlements with Edwards three clients and the existence and settlement of other civil claims against Epstein in order to aid Edwards in disputing specific allegations in Epsteins original complaint and positing ulterior motives for Epsteins lawsuit against Edwards For the playing field to be level if there is evidence regarding Edwards conduct that has a direct bearing on whether Epstein had probable cause to commence or continue the lawsuit whether Edwards in fact incurred any damages as a result of Epsteins lawsuit or indeed whether Edwards allegations against Epstein are at all credible it is imperative that such evidence be laid bare before the jury To bring to life this Courts intention to level the playing field in a trial where the law imposes an onerous burden on Edwards to recover against Epstein for exercising the right that all plaintiffs have to seek legal redress through the courts this Court must allow the jury to review these e-mails and fully evaluate Edwards misconduct the true value of his clients cases and the anxiety damages claimed by Edwards to justify recovery against Epstein THIS COURT MUST FIND THAT NO WORK-PRODUCT PROTECTION EXISTS OR THAT IT WAS WAIVED I Edwards Expressly Waived Work Product Obiections for All but New and Ongoing Cases against Epstein Edwards expressly and on multiple occasions waived work-product protections In negotiating the preparation of the privilege log on February Farmer Jaffe informed Epsteins counsel and the Special Master that it would omit from the log any work product objections that related to closed cases All work product materials will be turned over to Plaintiff except for materials related to new or ongoing cases AND on the condition that they be produced For Attorneys Eyes Only Exhibit Farmer Jaffe told the Special Master he would then only need to review and make privilege determinations as to work product materials for existing cases and attorney-client privilege materials Id Farmer Jaffe confirmed this agreement more than once February We also have more boxes that contain work product materials what we will tum over subject to the agreement that Plaintiff will not assert any privilege has been waived by turning them over now and further subject to the agreement that they be produced For Attorneys Eyes Only Exhibit February Farmer Do you still want to do the attorneys eyes only Do you want to speed it up or not Youll get work-product stuff if you agree to the attorneys-eyes only Epsteins counsel confirmed their agreement Exhibit This representation was significant At the time Farmer Jaffe made this representation to Epstein the three cases Edwards had been litigating against Epstein while he was Rothsteins partner at Rothstein Rosenfeldt Adler RRA had long been settled in July Thus based on Farmer Jaffes representation Edwards was supposed to have produced all e-mails reflecting work product pertaining to the three closed Epstein cases because they did not pertain to new or ongoing cases While at the time of the production Edwards had other clients who had claims against Epstein those too have now long been settled and none of those claims remain pending against Epstein Although Edwards did in fact produce documents as attorneys eyes only in February it has now come to light that Edwards only produced select items and specifically withheld inculpatory e-mails pertaining to his closed cases against Epstein despite Edwards agreement not to withhold work product pertaining to the closed cases To the extent that the e-mails Edwards settled his last clients claims against Epstein in August To the extent that Edwards claims documents relating to L.M and E.W were not produced because of some tangential privilege based on the pending Crimes Victims Rights Act CVRA action against the United States Government this lacks merit None of the subject e-mails are communications between the government and Edwards clients or their counsel or implicate any issues relevant to the CVRA case Importantly other than filing a Notice of Change of Address in the CVRA action in April when Edwards joined RRA Edwards did nothing in that action while he was at RRA In fact the first filing Edwards made in the CVRA action after April was in September after the court administratively closed the case for inactivity almost a year after Edwards left RRA See excerpt of CVRA Court Docket attached as Exhibit identified for the Courts in camera review relate to actual cases Edwards litigated against Epstein they were closed cases If work-product protection ever even arguably applied to them the mails were not then work product from new or ongoing cases and should have been included in the production to Epsteins counsel that Edwards represented included all work product except for new or ongoing cases Moreover because all of Edwards clients claims against Epstein have now settled in reliance on Edwards previous waiver and agreement to produce the same Epstein is asking the Court to compel Edwards to produce all such e-mails withheld based on work product or at least to deem the e-mails to have been produced and unseal them In view of Edwards waiver regarding work product from closed cases an in camera review of those e-mails is unnecessary and the Court need not make any further determinations For the additional reasons explained below Epstein also asks that this Court rule the e-mails to be admissible at trial IL Work-Product Protection Was Waived by Sharing with Third Parties as Edwards Admittedly Did With Razorback Additionally Edwards counsel conceded on March that the e-mails were shared with the Conrad Scherer law firm counsel for Razorback Clearly Razorback sought their production to prove its allegations in the Razorback lawsuit that Rothstein used the three cases against Epstein in part to lure investors into the Ponzi scheme If Edwards provided the documents that he claims are privileged both attorney-client and work product in this case to Conrad Scherer then Edwards waived those privileges when Edwards produced the e-mails to Conrad Scherer As a result of that waiver none of the e-mails were properly withheld by Edwards on the basis of attorney-client privilege and all should now be deemed to have been produced unsealed and ruled admissible at trial I Work-Product Protection Was Waived by Edwards Issue Iniection Anxiety Damages for Being Sued Weak Cases I Did Nothing Wrong Among other things the e-mails relate directly to the strength or lack thereof of Edwards now-settled three clients cases against Epstein the extent ofRothsteins interaction with Edwards as it relates to those cases and the credibility of Edwards claims for damages based on anxiety he claims to have suffered and continues to suffer from Epsteins lawsuit Repeatedly Edwards has made these central issues in his malicious prosecution counterclaim against Epstein Because the e-mails directly relate to the very issues Edwards injected into his malicious prosecution counterclaim they are critical to a proper evaluation of its merits and any work-product protection that may have applied to them should be deemed to have been waived by reason of Edwards issue injection Both Edwards and Epsteins counsel are familiar with waiver of work-product protection by issue injection having litigated the issue previously See Tolz Geico General Ins Co No WL S.D Fla Jan In Tolz non-party Searcy Denney argued that the doctrine of waiver by issue injection did not apply to attorney-client privilege Id at After analyzing both the attorney-client privilege and the work-product doctrine the court concluded that the attorney-client privilege had not been waived Id at However the court cited federal case law recognizing that the work-product protection is not inviolate and may be invaded when the information contained within the work-product materials is directly at issue Id emphasis added In Tolz therefore the court did exactly what this Court should do ordered an in camera review to determine whether any privilege existed or had been waived by placing the information contained in the documents directly at issue in that action Id at Case law distinguishes between affirmatively injecting an issue rather than simply defending one Home Ins Co Advance Machine Co So 2d Fla 1st DCA no waiver in simply bringing or defending an action Exceptions to the general rule have been applied where the party seeking to avoid discovery has injected into the litigation issues going to the very heart of the litigation Id citing Hearn Rhay F.R.D E.D Wash Pitney-Bowes Inc Mestre F.R.D S.D Fla Here unlike in Tolz Edwards has repeatedly injected issues into this litigation in an attempt to satisfy Edwards burden to establish Epsteins lack of probable cause which goes to the very heart of Edwards malicious prosecution cause of action Edwards has therefore waived anywork product protection of evidence relevant to these issues The case for waiver by issue injection is even stronger because the content of the e-mails in question reflects admissions by Edwards and his co-counsel as to the very issues Edwards has injected in this case the evidence of which is simply unavailable through any other means IV Edwards Deceptive Concealment of the E-mails on a Legally Deficient Privilege Log in Violation of Florida Rules of Civil Procedure Binding Precedent and the Express Orders of this Court is a Further Waiver Edwards waiver is further mandated by his deliberate concealment of the e-mails in question on a 159-page privilege log that was determined by this Court on May to be legally deficient on its face and to have utterly failed to comply with the legal requirements of Florida Rule of Civil Procedure and TIG Ins Corp Johnson So 2d Fla 4th DCA Exhibit It was through this device that Edwards prevented the e-mails from ever seeing the light of day despite Edwards misrepresentations to Epsteins counsel that all mails qualifying as work product in closed cases against Epstein had been produced While thee mails remained concealed through Edwards improper device Edwards continued to prosecute his counterclaim against Epstein based on the very issues directly refuted by e-mails Edwards concealed from existence Edwards should not be rewarded for such unethical gamesmanship The TIG court denied a petition for a writ of certiorari seeking review of an order requiring TIG to produce documents for which objections on the basis of attorney-client and work-product privileges were made The Fourth District Court of Appeal noted that Florida Rule of Civil Procedure now is identical to its federal counterpart Federal Rule of Civil Procedure whose Advisory Committee Notes state that To withhold materials without such notice is contrary to the rule subjects the party to sanctions under rule and may be viewed as a waiver of the privilege or protection TIG at The TIG court further observed that Local Rule of the United States District Court for the Southern District of Florida spelled out the requirements for a valid privilege log Where a claim of privilege is asserted in objecting to any interrogatory or document demand or sub-part thereof and an answer is not provided on the basis of such assertion i The attorney asserting the privilege shall in the objection to the interrogatory or document demand or sub-part thereof identify the nature of the privilege including work product which is being claimed and if the privilege is being asserted in connection with a claim or defense governed by state law indicate the states privilege rule being invoked and ii The following information shall be provided in the objection unless divulgence of such information would cause disclosure of the allegedly privileged information A For documents the type of document general subject matter of the document the date of the document such other information as is sufficient to identify the document for a subpoena duces tecum including where appropriate the author of the document the addressee of the document and where not apparent the relationship of the author and addressee to each other The Fourth District Court of Appeal also quoted with approval from Abbott Laboratories Alpha Therapeutic Corp No WL N.D Ill Dec in which the court stated that a privilege log should also describe the documents subject matter purpose for its production and a specific explanation of why the document is privileged or immune from discovery These categories especially this last category must be sufficiently detailed to allow the court to determine whether the discovery opponent has discharged its burden of establishing the requirements expounded upon in the foregoing discussion Accordingly descriptions such as letter re claim analysis of claim or report in anticipation of litigation"-with which we have grown all too familiar-will be insufficient This may be burdensome but it will provide a more accurate evaluation of a discovery opponents claims and takes into consideration the fact that there are no presumptions operating in the discovery opponents favor Any failure to comply with these directions will result in a finding that the plaintiff discovery opponents have failed to meet their burden to establish the applicability of the privilege Id at citations omitted Simply put a privilege log must be sufficient on its face to allow the reviewer to understand enough to determine whether a privilege claim should be challenged On August the Court vacated the May Order but did not relieve Edwards of the requirement to provide a new fully compliant privilege log In fact the Courts August Order provides in pertinent part EDWARDS shall file a written response specifically addressing the production sought in Paragraph of EPSTEINs Motion to Compel and Amend Protective Order of March as Ordered in this Courts April Order The response shall identify non-privileged responsive documents previously produced shall be accompanied by all non-privileged responsive documents not previously produced if any and shall identify in a proper privilege log as referenced in this Courts May Order responsive documents withheld from production on the basis of any assertion of privilege This response shall be filed within days from the date of this Order August Order emphasis added Exhibit Edwards failed to provide a compliant privilege log as required his February privilege log is clearly invalid and the protections asserted thereunder should be deemed to have been waived in light of Edwards failure to comply with the Courts Order Because Edwards blatantly disregarded the Courts Order as well as the requirements of Floridas Rules of Civil Procedure and the TIG case the February privilege log remains wholly deficient It misstates objections improperly identifies or altogether excludes the required identities of the document authors and recipients and its document descriptions are deceptively vague and misrepresent the true nature of the documents listed on the privilege log Had Edwards ever provided a legally sufficient privilege log Epstein would have been afforded the opportunity to identify as early as February the improper assertions of attorney-client privilege work-product protection and irrelevancy made by Edwards with respect to the e-mails Because the e-mails are under seal Epstein cannot specifically address the content of each to demonstrate how Edwards was able to conceal them through his legally deficient and non compliant privilege log However the following few examples of the numerous defects in the privilege log will enable this Court to readily confirm the complete deficiency of Edwards invalid privilege log both generally and particularly as it relates to the e-mails in question Individuals who were copied either by cc or bee on e-mails were not identified on the privilege log Throughout the privilege log Edwards also generally referred to the sender or recipients of the e-mails using unlawful group descriptions such as Attorneys at RRA or RRA Staff or identified them as Confidential Sources without any basis in law for such identification In fact entries refer to a Confidential Source to which a work product objection was asserted Such vague identification made it possible to conceal from Epstein the highly relevant fact that Rothstein was either the author or a recipient of the e-mails in question Edwards provided wholly insufficient document descriptions on his privilege log For example entries included the document description Litigation Strategy Many of these are included in the e-mails for the Courts review e.g Appendix 36/Trial Exhibit Appendix 70/Trial Exhibit As another example on page of the privilege log the description for Bates Appendix 3/Trial Exhibit is given as New Victim however the Courts cursory review of that document may demonstrate that description to be improperly vague false and misleading Exhibit A provides a comparison of the e-mails as identified on Epsteins Clerks Trial Exhibit List to Edwards privilege log entries Edwards complete privilege log is attached as Exhibit In May Edwards produced more than e-mails with Confidential Sources that he had previously withheld based on a work product privilege which are identified on his privilege log Those documents were identified on Epsteins November Exhibit List See Exhibit I Bates Bates Date To From Description Objection Marc Bradley New Victim Attorney Client Nurik Edwards Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Edwards objected to entries on the privilege log on the basis of the documents being irrelevant not reasonably calculated to lead to the discovery of admissible evidence The e-mails Epstein asks this Court to review in camera are highly relevant and do lead to the discovery of admissible evidence and the Courts review alone of this limited number of documents will confirm that In fact by just getting a flavor of the e-mails this Court already determined them to be detrimental to Edwards counterclaim and beneficial to Epsteins defense of the same The following is but one example of how the document shown to the Court at the March hearing Appendix I/Trial Exhibit is portrayed Date To From Description Objection Paul Bradley Punitive Damages Attorney Client Privilege Cassell Edwards irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Edwards objected to entries on the basis of work product and attorney-client privilege however only of those entries were with a client As set forth above Edwards work product objections throughout the privilege log if even remotely applicable were waived by reason of Farmer Jaffes express agreement to produce work product documents for claims that were no longer pending the prior production of the same documents to Razorbacks counsel or Edwards issue injection In addition the failure to identify the client as an author or recipient of the document coupled with a vague and misleading document description ensures that no specific claim of attorney-client privilege could ever be evaluated without seeking court review of every one of the entries on the privilege log as to which attorney-client privilege was asserted This Court should not countenance Edwards concealment of material evidence directly relevant to issues he has made central to this case in flagrant disregard for the Florida Rules of Civil Procedure established precedent and the orders of this Court Rather as authorized in TIG the Court should deem Edwards misconduct to have effected a waiver of objections with respect to the e-mails unseal that evidence deem it to have been produced to Epstein and rule it admissible at trial NO ATTORNEY-CLIENT PRIVILEGE EXISTS Despite Edwards and Paul Cassells counsel for the intervenors protestations to the contrary the e-mails are not attorney-client privileged communications between Edwards or any other co-counsel and his three tort clients L.M E.W or Jane Doe Rather the majority of the documents are e-mails among attorneys and staff within RRA with Mr Cassell and with media sources and do not qualify for that protection as codified in section of the Florida Statutes Under Floridas Evidence Code a client has a privilege to refuse to disclose and to prevent any other person from disclosing the contents of confidential communications when such other person learned of the communications because they were made in the rendition of legal services to the client Fla Stat A communication between lawyer and client is confidential if it is not intended to be disclosed to third persons other than Those to whom disclosure is in furtherance of the rendition oflegal services to the client Those reasonably necessary for the transmission of the communication Las Glas River House Condo Assn Inc Lorh LLC So 3d Fla 4th DCA Fla Stat The second exception applies to agents of the client-for example when a family member acts on behalf of an incapacitated relative Witte Witte So 3d Fla 4th DCA or when a messenger is needed for a client to contact counsel Gerheiser Stephens So 2d Fla 4th DCA Nothing in the description of the e-mails including the identification of the sender or recipients of the same or the description of the e-mails themselves provides any basis to conclude that the documents constitute or reflect attorney-client communications in the rendition of legal services to a client Furthermore the attorney-client privilege may be disregarded under certain circumstances For instance the privilege may be disregarded where client permission was granted to disclose a privileged communication to an adverse third party as was apparently true in the case of Edwards disclosure of the e-mails to Conrad Scherer or as was also true in the case of Edwards disclosure of attorney-client communications with L.M and E.W in filings in the CVRA action Additionally there is no privilege for an attorney-client communication if the lawyers services were sought or obtained to enable or aid anyone to commit or plan to commit what the client knew was a crime or fraud a Fla Stat This is known as the crime fraud exception to the privilege See Douberley Perlmutter So 3d Fla 4th DCA Thus several bases to challenge Edwards assertion of the attorney-client privilege were available to Epstein had there been a legally compliant and adequate description in the privilege log of any document as to which Edwards asserted that privilege This Courts in camera review of the e-mails will confirm that no attorney-client privilege applies Moreover in the event that this Court isolates an e-mail to which the attorney-client privilege might conceivably apply it may consider Edwards refusal to provide a privilege log in which that e-mail was sufficiently identified in a manner that complies with Florida Rules of Civil Procedure and the binding precedent of the TIG case As confirmed in TIG Edwards refusal to provide a G-compliant identification may be viewed as a waiver either as a concession by Edwards that no valid attorney-client privilege ever existed with respect to that e-mail or that if it ever did it was waived including under any of the circumstances described above IN CAMERA REVIEW IS MANDATED BY LAW WAS AGREED TO BY THE PARTIES AND IS APPROPRIATE UNDER THE CIRCUMSTANCES No court or special master has ever determined the relevancy privilege or waiver of thee mails identified on Edwards privilege log but it is well within this Courts jurisdiction to do so now Indeed if a party seeks to compel the disclosure of documents that the opposing party claims are protected by attorney-client privilege and/or work-product protection a trial courts in camera review of the documents prior to disclosure is required by law Bennett Berges So 3d Fla 4th DCA Old Holdings Ltd Taplin Howard Shaw Miller P.A So 2d Fla 4th DCA finding that where documents may be protected by both the attorney-client privilege and the work-product doctrine the petitioners are entitled to an in camera review of the documents by the trial court prior to disclosure Moreover Edwards has already agreed to an in camera review were not attempting to hide anything You want to conduct an in-camera inspection we want you to conduct an in-camera inspection because it will confirm that were not attempting to hide anything Aft Tr Scarola Excerpt Exhibit Epstein now expressly moves for the Court to conduct that review limited to the e-mails This entitlement to in camera inspection of materials claimed to be privileged is a two way street and a right that either party is entitled to under Florida law See Zanardi Zanardi So 2d Fla 3d DCA petition for writ of certiorari granted when trial court denied motion to copy computer diskettes on basis of attorney-client privilege and trial court did not determine in camera whether assertion of the privilege was valid This reciprocal approach is fair and logical because without the review the party objecting to disclosure of potentially privileged material can be irreparably harmed cat out of the bag and the party seeking disclosure of the non-privileged material will be denied the opportunity to present evidence that is material and goes to the heart of their case such that no other documents can be substituted for those remaining in respondents custody See Acevedo Doctors Hosp Inc So 3d Fla 3d DCA certiorari granted because denial of in camera review was departure from essential requirements of law and irreparable harm demonstrated by showing information critical to case would not be known or available to appellate court for review otherwise Here both parties seek in camera review but for different reasons Edwards claims he has nothing to hide and seeks review to confirm this Epstein believes these e-mails go to the heart of this case his probable cause for bringing the original civil proceeding and continuing it as well as and Edwards absence of damages and complete lack of credibility Additional equitable considerations make in camera review even more appropriate The Court has already recognized that some of the documents were detrimental to Edwards counterclaim and beneficial to Epsteins defense of the same And I understand what youre going to tell me because Ive gotten a flavor for some of these documents that have been provided And that is that they are detrimental to the position taken by Mr Edwards and that they are helpful to the position taken by Mr Epstein Aft Tr Excerpt Exhibit Without these e-mails Edwards will gain an unfair advantage in satisfying his heavy burden to establish the complete absence of probable cause for Epstein to have filed suit Epstein will be denied his right to present crucial evidence that goes to the very heart of the reasons for Epsteins lawsuit against Edwards as well as the veracity of Edwards disingenuous claims that Epstein lacked probable cause to sue Edwards and the false claim by Edwards that he was damaged as a result of this lawsuit It will tilt the playing field heavily against Epstein who is to be given the latitude afforded to all plaintiffs to use their best judgment in prosecuting a claim without the fear of a retaliatory lawsuit The in camera review is therefore necessary to confirm the relevance and admissibility of the e-mails and ensure a fair trial The Binger issue previously raised by the Court as a potential basis to deny an in camera review is inapplicable here where the e-mails were primarily authored or received by Edwards and/or in Edwards possession since Based on this Edwards an officer of the court who took an oath to never seek to mislead the judge or jury by any artifice or false statement of fact can certainly not claim surprise Only when all relevant facts regarding misconduct by Rothstein Edwards and his co counsel are before the judge and jury can the search for truth and justice be accomplished Katzman Rediron Fabrication Inc So 3d Fla 4th DCA Loureiro State So 3d Fla 4th DCA A trial must be a search for the truth Here the relevant facts exist in case-ending e-mails that go to the very heart of Epsteins probable cause Edwards lack of damages for Epsteins lawsuit against Edwards and Edwards credibility at issue in this action Accordingly this Court is equipped by the controlling law and equitable principles to perform the now substantially narrowed request for an in camera review of the sealed mails and to confirm the critically relevant nature of these e-mails and the absence or waiver of any attorney-client privilege or work-product protection for the same THE JURISDICTION OF THE BANKRUPTCY COURT IS NOT AN ISSUE BEFORE THIS COURT What is not before this Court and therefore not an issue upon which Edwards should be permitted to rely in seeking to prevent this Courts in camera review is the issue pertaining to the Oath of Admission to The Florida Bar content/uploads/2017 chain of custody and possession of the e-mails before Link Rockenbach appeared in this case At Edwards election upon motion filed by him Farmer Jaffe and the intervenors that issue is now being addressed in the Bankruptcy Court The Bankruptcy Court will determine if there has been a violation of one of its orders and if necessary the appropriate relief That review however has nothing to do with this Courts jurisdiction and duty to conduct an in camera inspection to determine the relevance absence or waiver of attorney-client privilege and work product protection and admissibility with respect to the e-mails How the Fowler White firm obtained the disc from where the e-mails originated is something which Edwards has decided that the Bankruptcy Court should sort out Epstein agrees that the Bankruptcy Court is the proper forum for that inquiry Clearly neither the Fowler White firm nor Epstein ever used the alleged privileged documents otherwise this case would have ended long ago Furthermore it has already been established how Link Rockenbach obtained the disc and this Court found all of Link Rockenbachs conduct once it discovered the information on the disc to be entirely proper CONCLUSION Epstein joined previously by Edwards is simply asking the Court to review in camera the e-mails to confirm that the attorney-client privilege is wholly inapplicable to all of them As for work-product protection to the extent that it ever applied to the e-mails this Courts in camera review will confirm that Edwards expressly waived it in February and he should be compelled to produce those documents now or such documents should be deemed to have been produced by him Epstein further asks this Court to conduct an in camera review of the e-mails During the appellate stay Edwards on behalf of Farmer Jaffe filed a Motion for Issuance of an Order to Show Cause in the Bankruptcy Court In re Rothstein Rosenfeldt Adler P.A U.S.D.C S.D Fla Case No BRD.E Exhibit w/o exs Edwards and the lntervenors then joined into that Motion individually BR D.E and Exhibits Land to confirm that they are relevant and admissible and that Epstein should be allowed to present the e-mails to the jury in order to ensure a fair trial of this matter Finally Epstein requests that he be allowed to conduct limited discovery of Edwards and Farmer Jaffe to determine why former work product documents were not produced contrary to the parties agreement and who authored the deceptive and misleading privilege log descriptions CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on April through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Rachel Glasser FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Rachel linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Karen Terry David Vitale Jr Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com dvitale searcylaw.com scarolateam searcylaw.com terryteam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL brad epllc.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Philip Burlington Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL pmb FLAppellateLaw.com njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Marc Nurik Law Offices of Marc Nurik One Broward Boulevard Suite Ft Lauderdale FL marc nuriklaw.com Counsel for Defendant Scott Rothstein Paul Cassell University Salt Lake City UT cassellp law utah edu Limited Intervenor Co-Counsel for L.M E.W and Jane Doe Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe Ex A I INDEX OF EXHIBITS TO EPSTEINS SUPPLEMENT TO MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS EXHIBIT A EXHIBIT A DOCUMENTS FROM EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST THAT EPSTEIN IS SEEKING AN IN CAMERA REVIEW OF COMPARED TO EDWARDS PRIVILEGE LOG EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Russell Adler p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Paul Cassell Bradley Response to Work product Edwards Motion to attorney/client privilege Consolidate irrelevant and not reasonably Cassell strategy calculated to lead to the Memo for Jay discovery of the admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Russell Adler to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Russell Adler Litigation Work Product attorney Edwards Strategy client privilege irrelevant not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Marc Nurik p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Marc Nurik Bradley New Victim W/P Attorney Client Edwards Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Katherine Ezell p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Jack Scarola Epstein Tel Joint W/P Priv Edwards Conf EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Rob to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Rob Buschel Litigation Work Product attorney client Edwards Strategy privilege irrelevant not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from William Berger to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley William Litigation Work Product attorney client Edwards Berger Strategy privilege irrelevant not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Paul Cassell to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Paul Cassell Litigation Work Product attorney Edwards Strategy client privilege irrelevant not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Wayne Black to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Wayne Black Getting Work product Edwards addresses for attorney/client privilege people for us to irrelevant and not reasonably serve subpoenas calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Paul Cassell to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Paul Cassell Litigation Work Product attorney client Edwards Strategy privilege irrelevant not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to William Berger p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Paul Cassell Asset movement Work product Edwards by Jeffrey Epstein attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Beth to Carl Linder a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Carl Linder Bradley Litigation Work product attorney Edwards Strategy client privilege irrelevant not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Marc Nurik to Scott Rothstein p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To I From Description Objection Attorneys at Ken Jenne Assistance on the Work product RRA Epstein Case attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Marc Nurik to Scott Rothstein p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys at Ken Jenne Assistance on the Work product RRA Epstein Case attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Russell Adler to Scott Rothstein p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Scott Russell Adler Legal Research W/P Attorney Client Rothstein RE causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Marc Nurik to Scott Rothstein p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Scott Marc Nurik Discussions Work product Rothstein about Epstein attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Spencer Kuvin p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Spencer CMA depo Joint-privilege Edwards Kuvin notices attached EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to red rum a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Pat Diaz NR Interview Attorney/Client privilege Edwards and/or work product EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Mike Fisten p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Mike Fisten Bradley Potential new W/P Attorney Client Edwards witnesses Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Dana Peterson a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Additional W/P Privilege Not Source Edwards Information RE reasonably calculated to lead Epstein to discovery of admissible Molestations evidence EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Dana Peterson a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Additional W/P Privilege Not Source Edwards Information RE reasonably calculated to lead Epstein to discovery of admissible Molestations evidence EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Robin Kempner to All Staff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection All Staff Robin Conflict check Attorney/Client privilege Kempner and/or work product EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Robin Kempner to All Staff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection All Staff Robin Additional name Attorney/Client privilege Kempner added to conflict and/or work product check EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to William Berger a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection William Bradley Discovery Work product Berger Edwards Cutoff attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Paul Cassel a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Paul Cassell Bradley Litigation W/P Attorney Client Edwards Strategy Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Paul Cassell p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Paul Cassell Bradley Victim W/P Attorney Client Edwards Complaints Privilege Irrelevant and not Forensic reasonably calculated to lead accountants to the discovery of admissible Epsteins evidence protected by Fraudulent privacy rights Transfers EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Paul Cassell p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Paul Cassell Bradley Punitive W/P Attorney Client Edwards Damages Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Matthew Weissing to Mark Fistos a.m Russell Adler Bradley Edwards Scott Rothstein and Steven Jaffe FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date I To From Description Objection Attorneys Bradley Legal Research W/P Attorney Client at RRA Edwards RE causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Matthew Weissing to Mark Fistos p.m and Bradley Edwards FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Mike Fistos Legal Research W/P Attorney Client Privilege at RRA RE Causes of Irrelevant and not reasonably action against calculated to lead to the Epstein discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Scott p.m Rothstein Steven Jaffe and Mark Fistos FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Bradley Legal Research W/P Attorney Client at RRA Edwards RE causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Matthew p.m Weissing FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Mike Fistos Legal Research W/P Attorney Client at RRA RE Causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Scott Rothstein p.m Steven Jaffe and Mark Fistos FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Bradley Legal Research W/P Attorney Client at RRA Edwards RE causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Bradley Edwards to Mark Fistos p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Mike Fistos Legal Research W/P Attorney Client at RRA RE Causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain Bradley Edwards to Russell Adler Scott p.m Rothstein and Mark Fistos FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Bradley Legal Research W/P Attorney Client Privilege at RRA Edwards RE causes of Irrelevant and not reasonably action against calculated to lead to the Epstein discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Matthew Weissing to Bradley p.m Edwards Russell Adler Mark Fistos and Steven Jaffe FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley William Dr Swan W/P Attorney Client Privilege Edwards Berger Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Mark Fistos to Bradley Edwards and p.m Russell Adler FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Russell Adler Litigation W/P Attorney Client at RRA Strategy Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Scott Rothstein to Bradley Edwards p.m Steven Jaffe and Mark Fistos FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Bradley Legal Research W/P Attorney Client at RRA Edwards RE causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Mark Fistos to Bradley Edwards and p.m Russell Adler FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Steven Jaffe Litigation W/P Attorney Client Privilege at RRA Strategy Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Russell Adler to Bradley Edwards p.m and Mark Fistos FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Russell Adler Litigation W/P Attorney Client at RRA Strategy Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Mark Fistos to Bradley Edwards and p.m Russell Adler FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Steven Jaffe Litigation W/P Attorney Client at RRA Strategy Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Steven Jaffe to Bradley Edwards p.m Mark Fistos and Russell Adler FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Steven Jaffe Litigation W/P Attorney Client at RRA Strategy Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Matthew Weissing to Bradley p.m Edwards Mark Fistos and Russell Adler FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Steven Jaffe Litigation W/P Attorney Client at RRA Strategy Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Mark Fistos to Steve Jaffe Scott p.m Rothstein Russell Adler Bradley Edwards and Matthew Weissing FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Mike Fistos Legal Research W/P Attorney Client at RRA RE Causes of Privilege Irrelevant and not action against reasonably calculated to lead Epstein to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Mark Fistos to Steven Jaffe Scott p.m Rothstein Russell Adler Bradley Edwards and Matthew Weissing FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Attorneys Bradley Legal Research W/P Attorney Client at RRA Edwards RE causes of Privilege Irrelevant and not action against reasonably calculated to Epstein lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Russell Adler to Scott Rothstein p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Scott Russell Adler Legal Research W/P Attorney Client Rothstein RE causes of Privilege Irrelevant and not action against reasonably calculated to Epstein lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Ken Jenne to Scott Rothstein p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Scott Ken Jenne Epsteins house W/P Attorney Client Rothstein staff Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Ken Jenne to Phaedra Xanthos p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Phaedra Ken Jenne Political Work product Xanthos Contributions/ad attorney/client privilege vertisement for irrelevant and not reasonably the rental on calculated to lead to the Little St James discovery of the admissible Island evidence protected by privacy rights EPSTEINS MARCH CLERKS TRIAL EXHIBIT LIST No Date Document Privilege Log E-mail chain from Paul Cassell to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Paul Cassell L.M and E.W Work product attorney/client Edwards Epstein Im on privilege irrelevant and not it reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights EXHIBIT Joseph Ackerman Jr From Sent To Subject Gary Farmer gary pathtojustice.com Wednesday February PM ROBERT CARNEY Jack Scarola Seth Lehrman Lilly Ann Sanchez Joseph Ackerman Jr Brad Edwards RE Its time to meet Judge I apologize for the delay in replying I was out of the office most of the day yesterday and could not get with my partners and our clients to discuss all issues We have now done so We are certainly happy to meet but maybe a conference call can accomplish the same thing But even before that,llefmelayout a proposal thafTtliinkshoulcfoe accepta6Ietoallparties Here is what we propose and it essentially includes the aye aye you requested with some additiona provisions We will agree to prepare a revised log in which we add dates for the emails and a description ofthe subject matter parties But we will also from the log any work product privilege objections subject to the following agreement Allworl rocJuct materialswilroe turnea over to PlaTiitiff except for materialsrelater.lro new or ongoing cases AND on tlie conaition tliat tney fie proaucecrFor Attorneys.-Eyes OnlW such that no copies or images will be made of them and Epstein will not see these documents unless and until such time as Judge Crow and/or Judge Ray has overruled any privilege claim following your recommended report or course If the objections are sustained the documents will be returned to us and no copies retained by Plaintiffs attorneys ifthe objections are overruled and the documents otherwise deemed discoverable Plaintiff gets them The Plaintiff and his attorneys will also agree that by entering into this agreement and producing these documents a described Plaintiff will not take the position that we have waived any privilege Th heonlyifemsYourRonor wilrtiave to review anamakeprivilegedeterminations woulffbeas to worl proauct materials for existing cases ancl attorneylclient privilege materials We should note at this point that many of the objections we have raised in the log are in fact relevancy objections We were forced to do so to also protect privacy rights of those not-a part of this case This is due in large part to the extremely broad scope of documents produced by the Trustee Many of these emails involve very personal matters or highly personal issues involving staff at RRA with no possible relevance to the case We can eliminate them from the log and argue relevance issues to Judge Crow which will speed things up but only if the Plaintiff will agree to a confidentiality order to protect privacy rights We simply cannot waive the privacy of these people and we had no idea that such Items would be included in the Trustees production when we previously appeared before Judge Ray If the Plaintiff feels that such a document is relevant to his case he can seek relief from the confidentiality order Regarding Judge Crow given his ruling this week in which he clearly indicated that while he will not interfere with Judge Ray 267but that he Judge Crow will be the sole and final arbiter of discover in the case before him including issues of privilege and relevance we believe it prudent to enter an agreed order appointing Judge Carney as special master in the state case too That way this whole process need not be repeated by another master and no further time is wasted believe we can get the revised and limited privilege-log limited to only attorney/client privilege matters as our clients will not waive same and will not agree to the attorneys eyes only limitation within days But that should not slow the process at all at this point since Judge Carney still needs to review all the remaining privilege claims and that will take significant time While we are preparing the revised log Judge Carney can begin his review of the privileged docum nts We will then produce the revised log and the Plaintiffs counsel can then raise any objections they have and can have one hearing before Judge Carney on all issues before.he enters his recommended order to Judge Ray finally with regard to your review Judge we think that itwill be an extreme Inconvenience to our firm to have to sit with you for a week even a few.days while you conduct the in camera inspection Instead we propose that we submit a list to you ih which we idehtify as niany people as possible Whose identities or connection to the privilege claims may not be apparent to aid you in your review We can make ourselves available by phone if someone else corrtes.up or for other questions Alternatively you could put questio11ed items in a pile and then call both sides.in for any qt1estions you h_ave about that pile This would greatly reduce the amount oftime the attorneys have to spend sitting around while Your Honor conducts.the review While Plaintiffs counsel is being paid by the hour in this case we are not and we can put the time spentsitting while Your Honor reviews to much more productive use Moreover if Plaintiff agrees to the prnposal above for work product the universe of documents in which Your Honor needs guidance should be significantly reduced I truly believe this to be a fair compromise that allows the process to proceed while we revise the log and preserves all arguments for both sides Please advise if this is acceptable Thank you Gary Farmer Jr Esq Civil Justice Attorney Farmer Jaffe Weissing JEdwards Fistos ft Lehrman P.L North Andrews Avenue Suite Fort Lauderdale Florida fax cell bathtojustice.corn Save a Tree I Please consider the envirorimenthefore prinUn_g this e-mail NOTICE THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT,Yot.J ARE HEREBY NOTIFIED THAT ANY DISSEMINATION DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE COLLECT AND present when make my inspection because Iafu going to have to have input on vyho is.who Because the log canrtotfirstbe culled by the Plaintiff in i!s pr sent form this is g?ingt9 be a laborio and ve3rtime consum!ng process so we need to block off appropnat time now dont thmk that a full week1s out oflme Judge Ray Ordergives this.phase one month seethls playing out as follows 1.Review of documents where privilege isclaimedto sedfthereis yfaciatreasori.forthat claim This means both sides beingptesent as I go thru all documents Many d6cimierits are sentto third parties Whether this waives the privilege depends on wllo the third partyis and how he or she fits into the case Where there is n9 privilege,,the documents would be 267eru.madced for release to thePlaintiff The Plaintiff as recently as one of Joeslastemails continuessrmder the belief that I am assistingthe Defendant in preparingthe log lam.not Iain the neutral Master ruling on log As such Lam not going to work withthe Defe11dant on this Both sides ate present or neither side is present duringthe review 2.After that process for those documents where there legitiniatelyis a privilege an evidentiaryhearingwm.ildbe conductedto see if the privilege has beeri abrogated in any way 3iPreparation of a Special Masterl.leport toJudgeR.ay outlining my findings Hadthe Defendantpreparedalog in compliancewith Tig we might have been abieto shorten this process Whethedhere has been an appropriate privilege log and 267what sanction if any should be imposed if there-has not can be addressed as we proceed but we are urider a.one month time limitation as of now We need to meet or conference not 1atfathail Wednesday as lindica.ted in my last email.Jf anyone has a better idea on how to _.1proceed I run all ears but I am not lookingto extend the Orcler We liaveone inonth and in the absence of complete agreement by both sides I amnotwaiving.therequirement that both sides be present asI review the documents EXHIBIT Joseph Ackerman Jr rom Sent To Subject Gary Farmer gary pathtojustice.com Wednesday February PM ROBERT CARNEY Joseph Ackerman Jr Lilly Ann Sanchez Jack Scarola CHRISTOPHER KNIGHT Seth Lehrman Brad Edwards RE Suggestion Hello all I wanted to provide and update and get written confirmation from the Plaintiffs counsel of the deal that was verbally agreed to on Friday and put into an email by me on Monday I have not received any reply to my Monday email I will resend it after this But by way of update I can tell you that we have four boxes of documents that are ready to be turned over now or when we get them back from a copy center that is scanning them under the ag eement To be specific we have boxes of documents that contain materials that we believe to be irrelevant but that implicate privacy rights of the parties or non-parties mostly staff at the old RRA These will be turned over subject to a confidentiality order and that needs to be drafted BTW s.uch that Plaintiff his counsel can immediately begin reviewing same Wealsohave2J ofe"boxestliat contain work"Vocuct materialsffiat we will turn over su6jecttol:lie agreement thaf Plaiirtiffwillnot1 assert tliat any_Rrivilege lias IJeen waivea oy turning tliem over now ana furtlier su6ject to tlie agreement tliat tliey_g i:1roclucea For AttorneysrEyes Only.J Should Plaintiff or his attorneys believe that a document is not confidential or privileged that objection will be brought before Judge Carney and he will issue a recommended order to both Judges Crow and Ray We have also completed what I would estimate to be of the revised privilege log and are prepared to make those pocuments available immediately for Judge Carney to begin reviewing and we will produce that portion of the privilege log to Plaintiff as well We estimate that the privilege log will be completed by Tuesday perhaps earlier but are also agreeable to a rolling production of revised log to Plaintiff and documents for review by Judge Carney subject to the agreement Judge I know that you are anxious to begin the review and I have spoken with Brad and he just had a trial in which he was supposed to start Monday get continued As such he would be available to sit with you and go through the privileged items this coming Monday Tuesday here in our office In fact as the log progresses we will have a constant flow of documents for you he to review such that you may be able to finish the review next week We are attempting to move this forward as quickly as possible and once we get written confirmation of the Agreement and draft the Confidentiality Order Plaintiff can have at review of the boxes immediately I would also remind everyone that these boxes are in addition to the boxes of over documents already produced for which our objection was withdrawn Thanks Gary Gary Farmer Jr Esq Civil Justice Attorney Farmer Jaffe Weissing Edwards Fistos Lehrman P.L North Andrews Avenue Suite 1ort Lauderdale Florida fax cell pathtojustice.com Save a Tree fil:J Please consider the environment before pririting this e-mail 267-_JNOTICE THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE COLLECT AND EXHIBIT I I I I I I I I I to Let me see if we can cut quickly to the chase here I The confidentiality can we get the confidentiality I worked out so that we get something in writing so everyone is happy in writing by next Friday at the latest MR ACKERMAN That will be fine MR FARMER How about this Friday MRS SANCHEZ The documents are ready to go Write up whatever you want and well we dont have a problem with that MR FARMER You guys have to have confidentiality orders done in other cases and you get paid by the hour to do this MRS SANCHEZ I dont have a problem but we will get an order to you by tomorrow and you can get the documents to us by Friday and thats done MR FARMER fuCvou still want to do th attorneys-eyes onlyj ou want to speed it up not Youll get work-product stuff if you agree to th attorneys-eyes only MRS SANCHEZ Yes MR KNIGHT We need to get the ball rolling MR ACKERMAN Lets do that MRS SANCHEZ Yes United Reporting Inc I EXHIBIT CM/ECF Live Database flsd Page of REF CM/ECF Live Database flsd Page of Clerks Notice of Docket Correction and Instruction to Filer re Response/Reply Other Response/Reply Other filed by Jane Doe Error Wrong Event Selected Correction Redocketed by Clerk as Reply to Response to Motion Instruction to Filer In the future please select the proper event It is not necessary to refile this document ls Entered Sealed Document rb Entered SYSTEM ENTRY Docket Entry restricted/sealed until further notice dj Entered Clerks Notice of Docket Correction re Sealed Document Error Sealed Document Filed in Wrong Case Correction Original document restricted and refiled in correct case rb Entered AFFIDAVIT signed by A Marie Villafana re Affidavit Ll Response/Reply Other Supplemental Declaration by United States of America Attachments Certification Certificate of Service Villafana Ann Marie Entered ORDER denying Motion to Unseal Document Signed by Judge Kenneth A Marra on ir Entered NOTICffoy Jane Doe of_CJiange oIFirm 74.Jjj_liation c:gawaras";"Braclley TEnterea:ff4i09i2009 Administrative Order Closing Case Signed by Judge Kenneth A Marra on tb Entered NOTICffoy Jane Doe re 38-Admistrative Order In ResRonse to Aamm1straflve Oraer Closing Case awaras Braclley Enterea ORDER TO SHOW CAUSE for lack of prosecution Show Cause Response due by Signed by Judge Kenneth A Marra on ir Entered STATUS REPORT by Jane Doe Edwards Bradley Modified to add missing event Response to Order to Show Cause on ls Entered RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe ls See Image at DE Entered Clerks Notice to Filer re Status Report Two or More Document Events Filed as One ERROR Only one event was selected by the Filer but more than one event was applicable to the document filed The docket entry was corrected by the Clerk It is not necessary to refile this document but in the future the Filer must select all applicable events ls Entered ORDER REOPENING CASE Signed by Judge Kenneth A Marra on ir Entered STATUS REPORT by United States of America Villafana Ann Marie Entered EXHIBIT IN THECIRCUIT COURT OF THE th JUDICIAL ClCUIT IN AND FORPALM BEACH:Cc UNTY FLORIDA I CIVIL DIVISION AG CASE Judge David Crow JEFFREY EPSTEIN Plaintiff/Cm..mter-Defend.ant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually An4 J7 6:Jif i..i Au Mz,:.L 4Usa wdu A PP s-J Tl Y1r.s 267Cfir iJ rs/4,i,;rn i Su CJ Fl 9-tl Jc-A Mo Epstein Rothstein and Edwards Case No 502009CA040800XMB/Division AG Order ori Epsteins Motion to Compel and for Sanctions Page of 7h aP olu Jde,1 if I DONE AND ORDERED in Chambers at.West Palm Beach Palm Beacli _Cqunty Florida this ay of ID.F CROW cf:Y Copies furnished to sepij AAennJH JtEsq ow"JeN!ll!lieBtlmelr,-tl.A AW 267aie i Esq Four Seaso11 Tower,,15!h Floor ill A JackScarola Esq rr Searcy Denney Scarola BaniliWhiple P.A Palm Beach Lakes Blvd __ we Palm Beach FL _JackA Goldbergf sq __ Atteroury Gol 265berger Weiss P.A AustrahanAvenue South,Suite V,,es elcH FL MW.c unk Esq Law Offices ofMarc Nurik One Broward Blvd Suite Fort Lauderdale FL BradleyJ Edwards Esq Farmer Jaffe Weissing Edwards Fistos Lehrman P.L 425,North AndrewsAven Sui Fort Lauderdale FL EXHIBIT TN.THE CIRCUIT COURT OF THE FIF.TEENT!I.JlJDICIAL 267CIRClliT,JNAND FOR PALM BEACH COUNTY!FLORIDA pASE NO JEJ FllEY;EPSTEIN i i Pfaintiff vs CO SCOTT ROTHSTEIN ind.ivid lly BRADLEY EDWARDS individually and t1:?c:;igV L.M individually Defendant ORDER ON OUSTAND:G DISC TIONS THIS CAUSE having conie to be consit gust on oiitstanding discovery motions and the Court having_A tlfo file and being fully advised in the premises it is hereby ORDERED and AD 9Z ARD Motion fo Clarification i GRANTED and this Courts Order of O.il:2 is vacated without preJudice EDWARDS shall file a mi en response spe cif daressifi Jhe production sought in Paragraph STEINs Motion to C:omP.:1 and end Protective Order of March as Ordered this Courts A ri I Th response identify non riyileged res onsive documents prev1ou prodfced shall be accompanied all non:-pnvileged responsive documents not prev oduced if any and shall identify in a proper priviiege iog as referenced iri this Coutts May Qrder sponsive documents withheld from production oriAhe basis of any assertion of privileg_e This response shall be filed within days,from th date of this Order Edwards aa.v.Epsteln Case No Order Qutstand!ng _Dls ov,ery Motions DONE AND ORDERED at We tlalm Beiich,Palm BeachCounty Florida this DA CROW CIRCUIT JUDGE pies have been furnished to all counsel on the attached counselib Edwards adv Epstein Case No Order on Outstanding Discovery Motions COUNSEL LIST Jack A Goldberger Esquire jgoldt,erger agwpa;coni 267stnahoney agwpa.com i tterlJury Goldberger Weiss A Australian Avenue South Suite 267west Palm Beach FL Phone Fa;,i Bn1dley Edwards Esquire brad pathtoJustice.co1ri Farmer Jaffe Weissing Edwards Fistos Lehnnan,EL North Andrews 267Avehue Suite ForiLauderdale FL Phone Fax Tonja Haddad Coleman Esquire tonja tonj ahaddadpa.cotn Andr.ewsAv e1e Suit.e Fort Lauderdale 3Ql Phone Fax Lilly.Ann.Sanche lirc 267lsanchez thelsfirm:com The L-S La ifrn I 4411Jl.ibkcill-:A enue 15th Floor Miip Eh c:1.lisi-so3-6so1 1k Scarola Esquire Searcy Denney Scarola Barnhart Shipley ar.c Nim Esq ir P.a Im Be.ach a es o.ulevard marc nuriklaw.com West Palrri 13each on Browar iB vd Suite Phone Fo 267rdale FL Fax Phone Attorneys for Edwards Fax EXHIBIT INRE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.tlsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A Debtor CASE NO CHAPTER PRIVILEGE LOG FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN Dated February Total of pages EXHIBITQ 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 WPB-Confidential-General Joint W/P Priv Financial Disclosure/Discovery Bradley Edwards Amy Ederi WPS-General-Confidential Joint W/P Priv Bradley Edwards Kikka Claudio C.M.A vs Epstein et Joint W/P Priv 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 W/P 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 Oepo Joint W/P Priv Adam Horowitz Jacquie Johnson Trump Depa 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 I Farmer Jaffe Weissin2 Edwards Fistos Lehrman SATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson RE Epstein-Notice of production Joint W/P 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 Depa 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-de po of Alan Dershowitz Joint W/P 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 W/P 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 Farmer Jaffe Weissin 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 Kuvin Bradley Edwards FW:Transcript of Alfrefo Joint W/P Priv Rodriguez Depo and Copperfeild and Clintons whereabouts Mercedes Bradley Edwards RE:Epstein vsJane Doe Joint W/P 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 I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Spencer Kuvin Jacquie Johnson Attach ment:Kellen Trump Joint W/P Priv subpoena Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P 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 NY OH Adam Horowitz Jacquie Johnson Maxwell,Trump Wexner convo Joint W/P Priv RE:Depo dates Adam Horowitz Jacquie Johnson Maxwell Trumo Wexner Convo Joint W/P Priv RE:Depo dates cont Stuart Bradley Edwards Wexler Lawyers info Joint W/P Priv Mermelstein Adam Horowitz Jacquie Johnson Epstein pepo-NY;2 Attachments Joint W/P Prlv Adam Horowitz Jacquie Johnson Epstein Oepos in Joint W/P Priv NY 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 W/P Priv Info Jacquie Johnson Katherine Ezell RE:Epstein-Depos 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 Farmer Jaffe Weissimt 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 RE:Deposition of Jean Luc Joint W/P Priv Bruhnel Jacquie Johnson Adam Horowitz RE:Epstein Depo Joint W/P Priv Jacquie Johnson Margaret Berk Epstein Depos Joint W/P Priv Jacqufe Johnson Lisa Rivera FW:Deposition of Jean Luc Joint W/P Priv Bruhnel Jacquie Johnson Lisa Rivera Depo of David Hart Rogers Joint W/P Priv Jacquie Johnson Katherine Ezell FW:Meeting w/Sranley Arkin Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Jane Does 2-Sv Epstein-Cross Joint W/P Priv Nods of Oct depos Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epsteln Depo-New York Joint W/P Priv Jacquie Johnson Adam Horowitz RE:Epstein Depositions for Joint W/P Priv in NY OH Privilege Log Dated I I Farmer Jaffe Weissinl 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:Epstein Joint W/P Priv 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 NY will take place as scheduled Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Jacquie Johnson Adam Horowitz RE:Epstein Depositions Joint W/P Priv 18inNY 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:Epstein Depo Joint W/P Priv Privilege Log Dated I I I Farmer Jaffe Weissint 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 Priv Adam Horowitz Jacquie Johnson RE:Epstein Depa 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 Oepos Joint Priv Katherine Ezell Jacquie Johnson RE:Epstein-Depos of Marcinkova Joint W/P 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 I Privilege Log Dated I I I Farmer Jaffe issing Edwards Fistos 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-Conflrming AT Joint W/P Priv Dial Telephone Conference for Mon at p.m Jacquie Johnson Spencer Kuvin FW:Epstein-Depos of Joint W/P Priv Marcinkova Sarah Kellen Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Stems 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 W/P 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 WeissinR 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 AmyEderi 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 AmyEderi 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:Epsteln Joint W/P Priv Jacquie Johnson Katherine Ezell RE:Epstein Joint 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 Weissin 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 Priv 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 Priv 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 Weissine Edwards Fistos Lehrman I 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 AmyEderi RE:Regular Monthly Cong Call Joint W/P Priv on34 Jessica Caldwell Bradley Edwards RE:Release Joint W/P Priv Bradley Edwards Katherine Ezell RE:Meeting 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 OfDepos Bradley Edwards Mercedes Estrada RE Jane Doe Jane Doe Joint W/P Priv vs Epstein Bradley Edwards Mercedes Estrada RE Jane Doe Jane Doe Joint W/P Priv vs Epstein-Cross-Notice ofTaking 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 Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Jack Hill RE Igor Zinoview depo Joint W/P Priv 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 Oepo 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 W/P 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 Priv Katherine Ezell Bradley Edwards RE:Epstein Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P 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-WPB Joint-privilege Confidential Amy Ederi Brad Edwards June 25tn hearing-WPB Joint-privilege Privilege Log Dated I I Farmer Jaffe Weissine 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 Farmer Jaffe Weissinl 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 Jo int-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 thls as a parole violatlon 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 Weissint Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Edwards Adam Horowitz Margaret Berl 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 Kuvin Bradley Edwards Emailing Epstein deposition Joint-privilege revised Bradley AmyEderi Epstein Confirming AT Dial Joint-privilege Edwards in Tel Cont for Monday at p.m Spencer Kuvin Bradley Edwards Epstein Hearing Joint-privilege Spencer Kuvin Bradley Edwards Epstein Depo New York Joint-privilege Bradley AmyEderi 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 Weissim 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 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 Jacquie 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 Farmer Jaffe Weissine 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 Hill 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 Weissin.r 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 LM 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 Zinoview 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 JE brother Joint-privilege Privilege Log Dated I Farmer Jaffe Weissing 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 IJ 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 NOD 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 Depo 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.4m 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 Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein Adam Horowitz Jacquie Johnson Epstein Oepo Joint-privilege Spencer Kuvin Bradley Edwards Epstein Depo Joint-privilege Stuart Jacquie Johnson Epstein Oepo 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 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 Monday at p.m Privilege Log Dated I I Farmer Jaffe Weissim Edwards Fistos 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-priVllege 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 I I Farmer Jaffe Weissinj Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Spencer Kuvin Epstein Depo Joint Privilege Jacquie Johnson Adam Horowitz Depo 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 Depo in 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 Priv 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 Conf Joint W/P Priv Katherine Ezell Bradley Edwards Epstein Depo Joint W/P Priv Jacquie Johnson Adam Horowitz Depo of Larry Visoski Joint Priv Bradley Edwards Adam Horowitz Depo 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 Priv Spencer Kuvin Bradley Edwards Epstein Depo Notice Joint W/P Priv Jacquie Johnson Adam Horowitz Epstein Depo Joint W/P Priv Jacquie Johnson Adam Horowitz Epstein Depos in New York Joint W/P Priv Jack Scarola Jacquie Johnson Epstein Oepos 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 Farmer Jaffe Weissing 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 W/P 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 Oepo Joint W/P Priv Adam Horowitz Jacquie Johnson Notice of Production from Non Joint W/P Priv Parties Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv Spencer Kuvin Bradley Edwards Epstein Order Joint Priv Bradley Edwards Spener Kuvin Epstein Order Joint W/P Priv Stuart Jacquie Johnson Epstein Sub To Bears Stern Joint W/P Priv Mermelstein Privilege Log Dated I I Farmer Jaffe Weissina 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 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 sm 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 JointW/P Priv Katherine Ezell Bradley Edwards Depo dates Joint W/P Priv Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv Epstein Egg Shaped inch PENIS Adam Horowitz Spencer Kuvin Alfredo Rodriguez depo Joint W/P Priv Privilege Log Dated I I Farmer Jaffe WeissinJ 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 1V 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 Cont Joint W/P Priv Estrada Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mercedes Bradley Edwards Judge Marras July 6m Order Joint W/P Priv Estrada Spencer Kuvin Bradley Edwards NPA from Marie Villafana Joint W/P Priv Adam Horowltz 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 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 Priv review Bradley Edwards Kikka Claudio Supoenas for 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 Claudio Video tape of Epstein Joint W/P Priv Estrada Bradley Edwards Jack Scarola Motion for Status Conf Joint W/P Priv Bradley Edwards Sid Garcia Motion for Status Conf Joint W/P Priv Adam Horowitz Jacquie Johnson Motion for Status Conf Joint Priv Adam Horowitz Jacquie Johnson Motion for status conf Joint W/P Priv BATES DATE Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman 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 JointW/P Priv Katherine Ezell Jacquie Johnson Mardnkova being rescheduled Joint W/P Priv Bradley Edwards Spencer Kuvin 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 JointW/P Priv 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 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 Weissinl Edwards Fistos Lehrman SATES 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 Prod uct;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 Bradley Edwards Epstein Depo work Prod uct;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 priVilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Bradley Edwards Trumps Depa 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;attomey client Privilege Log Dated I I Farmer Jaffe Weissim 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 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 earl Under 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 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 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 Carl Linder Jacquie Johnson 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 Privilege Log Dated I I Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Carl Under Bradley Edwards Litigation Strategy Work Prod uct;atto rney 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 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 rghts Cara Holmes 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 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 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 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 Privilege Log Dated I I Farmer Jaffe Weissin 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 Prod uct;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;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 Beth Williamson 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 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 Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jonathan Bradley Edwards Litigation Strategy Work Prod uct;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;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 Bradley Edwards Rob Busche Litigation Strategy Work Prod uct;atto rney 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;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Stratgey Work Prod uct;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 Prod uct;attorney client Privilege Log Dated I I I Farmer Jaffe Weissin 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 Prod uct;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 privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards William Berger Litigation Strategy Work Product;attomey 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 Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Buschel litigation Strategy Work roduct;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 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;attomey 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 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 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 Privilege Log Dated I I I I Farmer Jaffe Weissine 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 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 Prod uct;atto rney 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 Prod uct;atto rney 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;attomey client privilege;irrelevant reasonably calculated to lead to the discovery of admissibleevidence;protected by privacy rights Privilege Log Dated I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards William Berger Litigation Strategy Work Product;attomey 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;irrelevant reasonably calculated to lead to the discovery of admissible evidence;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 Busche 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 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 lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Rob Busche Litigation Strategy Work Prod uct;attorney client Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman SATES 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 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 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 Susan Sterling 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 Russell Adler Litigation Strategy Work Prod uct;atto rney 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 I I I Farmer Jaffe Weissin,z 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 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 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 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 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 Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible Bradley Edwards William Berger Litigation Strategy evidence;protected by privacy rights 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 I I Farmer Jaffe Weissine 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 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 Buschell 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 Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights __ Privilege Log Dated I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Rob Busche Litigation Strategy Work Prod uct;attorney client privilege;irrelevant reasonably calculated to lead to the discovery of admlssible evidence;protected by privacy rights Bradley Edwards Paul Cassell litigation Strategy Work Product;attomey client privilege;irrelevant reasonably cakulated 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 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 ct;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;attomey 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 Prod uct;atto rney 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 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 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;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 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 Privilege Log Dated I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 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;attomey client privi!ege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Bradley Edwards Paul Cassell Litigation Strategy Work Product;attomey 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 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;atto rney 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 Busche Litigation Strategy Work Product;attorney client Privilege Log Dated I I I I Farmer Jaffe Weissin,z Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION 0BJEOI0N 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 Busche Litigation Strategy Work Prod uct;atto rney 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 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 Rob Busche Litigation Strategy Work Prod uct;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;irrelevant reasonably calculated to Privilege Log Dated I I I I Farmer Jaffe Weissinaz 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;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights Robert Buschel Bradley Edwards Jane Doe brother Attorney/Client privilege and/or work product Robert Busche Bradley Edwards Doe family member Attorney/Client privilege and/or work product Bradley Susan Stirling Jones Atlantic asphalt Attorney/CUent 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 I I Farmer Jaffe Weissin2 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 Farmer Jaffe WeissinJ 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 I I I I Farmer Jaffe Weissin2 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 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 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 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 Prlv 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 W/P Priv not reasonably calculated to lead to Bradley Edwards Confidential Source discovery of admissible evidence Other Rape Victims W/P Priv not reasonably calculated to lead to Bradley Edwards Confidential Source discovery of admissible evidence Other Rape Victims W/P Priv not reasonably calculated to lead to discovery of admissible evidence Privilege Log Dated I Farmer Jaffe Weissim 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 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 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 Confide ntia I 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 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 Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to Privilege Log Dated I I I I Farmer Jaffe Weissine 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 W/P Priv not reasonably calculated to lead to discovery 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 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 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 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 Priv not reasonably calculated to lead to Epstein Molestations 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 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 I I I I Farmer Jaffe Weissine 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 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 Secret Plea Deal For Epstein 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 Farmer Jaffe Weissina 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 admiss 260lble 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 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 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 Privilege Log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos 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 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 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 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 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 Priv not reasonably calculated to lead to Privilege log Dated I I I I Farmer Jaffe Weissine 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 Priv 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 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 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 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 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 Additional 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 BATES DATE Privilege Log-Dated I I Farmer Jaffe Weissin.1 Edwards Fistos Lehrman TO FROM DESCRIPTION OBJECTION Bradley Edwards Confidential Source Providing Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidentlal Bradley Edwards Providing Witnesses 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 Strategies discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses 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 admisslble 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 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 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 Priv not reasonably calculated to lead to Privilege Log Dated I I I I Farmer Jaffe Weissine 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 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 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 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 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 Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence Privilege Log Dated I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECflON 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 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 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 Additional Information RE W/P Privilege Not reasonably calculated to lead Epstein Molestations to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy 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 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 Privilege Log Dated I I I I Farmer Jaffe Weissinf 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 W/P Privilege Not reasonably calculated to lead Source Epstein Molestations 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 Privllege Not reasonably calculated to lead Source to discovery of admissible evidence Bradley Edwards Confidential Source Additional lnformatlon 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 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 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 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 Confidential Bradley Edwards Litigation Strategy Privilege Not reasonably calculated to lead Source to discovery of admissible evidence Privilege Log Dated Farmer Jaffe Weissine 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 Privilege Not reasonably calculated to lead Source Epstein Molestations to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy Privilege Not reasonably calculated to lead source to discovery ofadmissible evidence Confidential Bradley Edwards Litigation Strategy W/P Privilege Not reasonably calculated to lead Source to discovery of admissible evidence BOX2 Rm TO FROM DESCRIPTION OBJECTION 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 I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE TO fBQM DESCRIPTION OBJECTIQN 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 Attorneys at RRA 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 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 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 I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES Qfil TO fBQM 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 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 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 I I a I Farmer Jaffe Weissimi Edwards Fistos Lehrman ATES DATE TO fB.QM 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 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 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 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 Weissine Edwards Fistos Lehrman BATES 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 MarcNurik 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 tead 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 William Berger Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated I I Farmer Jaffe Weissim Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence protected by privacy rights Bradley Edwards Amy Swan litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Nora Batian 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 Nora Batian 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 Attorney 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 Bradley Edwards Mike Fisten Review of litigation materials 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 Jane Doe Us 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 Attorneys at RRA Ken Jenne RE Epstein Meeting W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Privilege Log Dated I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM 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 MikeFisten 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 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 RE Epstein-Maxwell Subpoena W/P Attorney Cllent 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 W/P 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 Weissine Edwards Fistos Lehrman BATES DATE TO fBQ.M 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 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 William Berger Alessi Depa 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 lnelevant 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 I I I I Farmer Jaffe Weissine 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 W/P 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 KenJenne 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 I I I Farmer Jaffe Weissimz Edwards Fistos Lehrman BATES Q8.Il IQ EB.QM DESCRIPTION JECTION 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 267protected 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 I I I I Farmer Jaffe Weissini Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTIOM 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 ME 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 I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJEglON 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 Tria I 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 Mikefisten 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 I I I Farmer Jaffe Weissint.t Edwards Fistos Lehrman BATES Mn 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 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 I I I Farmer Jaffe Weissinj Edwards Fistos Lehrman BATES DATE TO ffiQM DESCRIPTION OBJECTION Mike Fisten Pat Diaz Bill Riley 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 Depa 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 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 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 KenJenne 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 I Farmer Jaffe Weissim Edwards Fistos Lehrman QATES DATE TO FROM DESCRIPTION OBJEglQN 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 William 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 Farmer Jaffe Weissimt Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence protected by privacy rights William Berger Bradley Edwards Depa 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 Mike Fisten 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 Attorneys at RRA Bradley Edwards Legal privacy rights 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 Bradley Edwards Susan Stirling privacy rights Filed Motions W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights KenJenne Bradley Edwards Epstein Probation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by e?d?j yQ?l qE Aϗ?FEQ5?4ER t?maUqʉ U?e?-?vp?X _F W?-L 1s;QI o??Cx HB??k5 g??v8mΒ ʍ2l2_oQ ô??"te?b M4Ԋa_d KK?JI??V G?t h??h??sY Ǘ?Y ZG?,na?ߦ?1?/edʣbm dL K/hA?a 븘?zч вg s?e??U K?Kt A x?ȝr x1 I j?X i??O bѹ?Mq Eh ίL Z??ڨ LF?q G4 ROd g?u 2C BGRŵ AJ Iny gu r??FK AEx?Z??b lp mqv pl mg6 xbK?u g??n?Ti JcҎ ċ?n kq Wpo jY??E 3?n?Et?JfI?AW?_ Pn _Q r?y y?bC IE?甃 mĝ q?l GPB SVm I??r 3h ne??oi 8?Udtv U?P r?c fm?S t??ñ u??x o"?o d?uX M?M G?4Gݚv?_ Y??t ck6 do?y?y u?Ð I2 n3 Oɬ s:?f J?l L?,H t?p aC KH?f Vڰ?J a zF,"?댎 HC HjX cw Bb6?Y Fl p?gq/?2sz4є m??m?o ݮ?߄I r?눠?h?q TD 5T n?L RD!_ tF??o?s?h FN?M?F?2P I Z?T t??㘙C Jy Ei??ɢZ B1IÍ?r2 Privilege Log Dated I I Farmer Jaffe Weissine Edwards Fistos Lehrman B_ATES 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 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 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 Depo 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 Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Mike Fisten Copperfield 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 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 Dersnowitz 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 Depo 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 admissible evidence protected by privacy rights Pat Roberts Ronald Wise Visoski 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 W/P 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 I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES QA TO FROM DESCRIPTION OBJEg!QN 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 Depa 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 Depa 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 lnvestigatio 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 Attorneys at RRA Maribel Matiska privacy rights 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 QBJECTION discovery of admissible evidence protected by privacy rights Russell Adler Bradley Edwards Dershowitz Involvement W/P 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 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 Staff Bradley Edwards privacy rights Epstein Depa 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 WeissinR Edwards Fistos Lehrman BATES DATE TO 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 privacy rights KenJenne 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 Prlvilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Jacquie Johnson Bradley Edwards Epstein Depo 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 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 Weissinf 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 Attorney Client Privilege Irrelevant and Privilege Log Dated I I I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE IQ E!l.QM 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 KenJenne Bradley Edwards Investigation into Epstein planes 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 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 Privile 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 Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the Privilege Log Dated I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES TO FROM DESCRIPTION OBJECTION 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 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 MarcNurik 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 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 Meeting on Epstein W/P Attorney Client Privilege Irrelevant and not reasonably calculated to ead to the discovery of admissible evidence protected by privacy rights Marc Nurik Bradley Edwards NewVictim 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 discovery of admissible evidence protected by Privilege Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman 247ATES DATE TO FROM DESCRIPTION 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 privacy 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 discoverv of admissible evidence protected by privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES Qfil TO FROM DESCRIPTION OBJECTION Roben 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 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 DOJ W/P Attorney Client Privilege Irrelevant and Privilege Log Dated I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman Mm DATE TO FROM DESCRIPTION OBJECflON not reasonably calculated to lead to the discoveiy 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 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 case Numbers W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discoveiy 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 discoveiy of admissible evidence protected by privacy rights Mike Fisten 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 W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discoveiy 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 discoveiy 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 I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION 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 I I Farmer Jaffe Weissimz Edwards Fistos Lehrman BATES DATE 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 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 Wayne Black Epstein Victims W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights 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 I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE IQ fRQM 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 Stearns 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 KenJenne 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 Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO fHQM 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 Bradley Edwards Seth Lehman Litigation Strategy W/P Attorney Client Privilege Irrelevant and Privilege Log Dated I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE 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 Weissimt Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJErTION 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 Bradley Edwards Paul Cassell Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence jprotected 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 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 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 Wayne Black Bradley Edwards privacy rights Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by i L?ƚ5 o??j B??G?C A zHd A?D?3ky?c F?ͻ T?x?HT i?N?Ws??wE Nw anΏ/1?v?c x?V o?ցv?g7G HGU4 7ff??E Vgq f?C Q?N zP8:aR 䏍fӾ?;8N z?g??圝 0p n?L2f?d?UxS _ݩamG?Gӆ ar by 8hu s??n w?Z??q?R 2n zzb?Ur Ue X!!wK P4 x??p T?W X?qT??W mE J!j cn RȐ?qյ?r3 A n?w U?o?j Yc??y??n Oeހ:??m bT??b A 悲?7h Ѳ9?2Am h7 z??A e??Em dVv?G 7eB hDuߵ cٶ vm Ө?XmN,??M Lۇ?J U??T?D i S?p 6HYc QD IsV??G ňa һ??ÜG Qje Z?:?qy ﺐ?k j?s?L bi NpI qdz?y_ B?H Fy ZcX??Qo?E58 U??EdU 4E XqF Nа Ag pN Z??f CC Xt d?r z?tw ѧ??Z ܯN?;p i 2??PKV3P A M??v l?jݯ Kw Тp S2 0Ƕ jML?N ws)y ov)s b?xW??K RN lE_??t G??ߊ gu?BH j?G Y7 Bf C?A ɕ?e d??bg d?e ݎq no džWt OŻ)i?Z e_ 2T q?l??u??GeJͽ Kd ȸ?u ĝ?O dH y?U x?T?a I 4Ŀ?H l?N r?kb ъL l??G?pŋ?h V??mV E?t?Ra??P?s ʨb DZ5 vn JH _??V?qY?nU i SD cNQ??X t?oT?J٧ ljjt9 I?SDg nڷZ?Hޕ A Qn ud b5?䁤?D ϣ?ZڮN i?o wgB ݗl k?C?J 1e8Up nkT at 3?W?dj yE)ȭ I BS?Q i Sw A a I UT S;aZ?n Jw Ir??ǫ E1 i??5m?Rj T??U?V dkqk b?g4 ˑ?"CQ?b i ޓG??a 4yr Ժ_?JdZ vs?C?a F?5?dnڄ;T b?Mr A h?W 8bdn o?FK Κ??bZV hj??L?Pzok?L b?ok?h ꕕ?KN?l?wi?C nT?E r6??MK?n W??ULck W9D7 ri??rV FiHB i?i?F?q??k F?gc i 4Eݡ 1xH S??l S??lL h??T 8D Ť?2?Cw ÿi q??bN ߴVP mp?m?VK?ljܘ?K??"W_ dD?!r Q?M C?W?G TP U??v yҌ1P 8Ҙ3A L?j??HHc y??YM 㢨g?9 J?ŵ W??GT?i8 Mx Wk Hǂ c?D I?iVW?R V)?Dǯ?y?o?k Z9n?B IK j?q?a m-?ʑ B?u ՀT x0tn ᖭ?l a ui K??lI I-??ݐ?ȬF-?A?dt?Rcg?2 muG a?cY xV Ts?6 Kd 5L O?u 峍n i?5T InCʑ Y?R eHk t?a R?K Sk?g?3 לV Akꨂ r3T?k Ǡu Ѓs5:z 庴L VQە N?v Ut yK?JbU f??x jNxe JO W?z?Q DT åf q?f Ԍ?4V w??M gT Q??ўy TɅ?U?H ȴ5??wa ݑ??Zo-e Ԛs?p s?FZ?nK?X??g0 H?Z?t?E?jh?u?o GYt UU?xB l7F?JJ hqs il??W z)f?y?Rd 3A v?V9 qw??m j??e Ty Z2T v?R U?BcR r2?ƭгy?ľ0 F?PŸ d?D?L d?P LA x?NT?U g?a0 c?C 1sO?s??o j?UǾF99 n?ŕ ưA?º?hhj?kM?w Nɥ?0 Ye xS;?Fbq HzĄ Z?C L??ZF LL??x?e??kz W?BH R?f??O y?O??خ f?Fʑ xG??q?k u-??Ɋ?Ig 楀me?n?ziP 7h b3??ce Ý?N 5q bu ѦX;3?M??BQ W.?nj p?ͿPa DC?8?Ѫ W??Kjw N۹ SDg M_f 9y ZWX mS?l G?;h SNQ ԥL 7o iS ΈSı i cW?V?T A??9?Sjh?UI c?j??f 8w?B?P w?T X?ɋ??KJ?3H?Ǎ?tbL?K?/w rG Privilege log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO ffiQM 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 W/P 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 W/P 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 W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence JProtected 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 I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES QA1 TO fBQ.M DESCRIPTION OBJECTI 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 W/P Attorney Client Privilege Irrelevant and __ Privilege Log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE 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 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 Mikefisten 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 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 Privilege Log Dated I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN discovery of admissible evidence protected by privacy rights Bradley Edwards Paul Cassell Other Rape Victims 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 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 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 Prlvilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by Susan Stirling Bradley Edwards privacy rights 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 Farmer Jaffe Weissin Edwards Fistos Lehrman BATES Qfil TO FROM DESCRIPTION QBJECTION 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 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 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 Paul Cassell Bradley Edwards privacy rights 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 I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEglON 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 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 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 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 EÐI M1 BfȮ?V 2bc?K y?C Em?uSP?6pB?E NvO Dv WA gc?8 rSV1 Sgo n/(??qVn b,q BB zUT?5dl n?Ѕ?doV?pc??tߛ E?E F?,y 8N ªᤄ Vh LV X??SXV?s??N mJ ϥq g?b?P M6 G?f Cg?N r?GV??i WE cKN?R??Xo ji?b,m?wHn ĉ?L Mӱ og V?A T?PhPt Y1ca4GZD bb?l P2 co DWAr Jռ?ӨK tkZ wj?Gi pgj;;B So 69Hٶ g?rm W??H v??y Wj?Q θi ۹W m?mB?u?u 2?IFt?Ks5X?:m E?ۦ ƈ??vEΒ??I V??dW Շ??5QC KoHB?I TzO Οa XA?Si N??z s?8I??c?x?k?S?zc?pQ8 ʏ0 c?Q U?mu I i I??0pm?e y?X?n?A G?!y 0AE?9t N?js/Pe n.Tt?Kv T?zڢ dkl qWdu h?db Ij Ih?e?3 A l6 s?!fF?f?B dDŽ?k7?b 1?Jy Oe Ta A?eI XGق GH I Zw O?ꅴ?y h6 R?v s_ Ey C?IJߊ J?i bZd XCO 2?ٶu ˊV??L?QV?kCv f_ Bߤ Uhu??fV(1ƴO I M??ݧ J??W K?l?y Nj??u W,?X?I AC Pv n?b eo ҦC?F o?nXP դ?h?dJ I U?:d??MO ݿP Igm oK ǯΛ z5?QK?ވ?u e?JFp.?op a?l e?Dꈀ EF M??Z 5A ɢR C?b2 a?Px YǶ?b f??Y?lL m2?w 힠?h?XE F5 Ӡ?M w?nğ sNק I?L Ȕ??T _u?JF MN Սğ V-sd ϤW8 V?a?s NO??ٺQ?zv P?ߥ4 Q??Y K8 D?H?k j,R?O 3Ͼ?w O?z?Ͳ ӣ?i 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o?n??(kb З??Ä p?b?y T?Wt DLmEj?㐪B R?qK?i f-qQ u?X?M Zu6 Lż 2d?D?yB mWZ)P s?b M?Q Y?Z A N?P t??F Q?G.D cl Q?x A aD?1ɒ 6u?ڞ ݫY W?ӂ l?yQ??yR wkR?Ė??G?ƲK O?㣠?W?A GI P?n i??I?T X5р p7l Z?G x?A F?a?U ڔ?Mlu??ez?Wn??趠??m?az io L,Ȍ W?Ń OI??e??z,?cZ?T??zl ļ?P?S Wq?H DG?6?i IЮ g?n??w i kx r?q?o BG x??u?Ы βG?N)??O Hql J,m PE Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES OATE 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 dient 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 Wilamson 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 Weissine Edwards Fistos Lehrman BATES DATE 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 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 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 Farmer Jaffe Weissine Edwards Fistos Lehrman BAilS DATE TO 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 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 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 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 privacy rights Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Attorneys at RRA Paul Cassell Litigation Strategy W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights 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 to 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 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 Jacquie Johnson Bradley Edwards Litigation Strategy W/P Attorney Client Privilege Irrelevant and Privilege Log Dated I I Farmer Jaffe WeissinJ 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 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 Privilege Log Dated I I Farmer Jaffe Weissin1 Edwards Fistos Lehrman BATES DATE TO ERQM DESCRIPTION OBJECTION Motion to Strike to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Adriana Surveillance/lnteiview 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 Alfredo Rodriguez address 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 William Berger Client 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 Russell Adler Bradley Witness 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 Russell Adler Bradley Epstein assets 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 Call from sources of 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 Attorneys at RRA Bradley Cassell Draft Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Mike Fisten Bradley CMA vs protected by privacy rights Epstein new Work product attorney/client privilege Edwards investigator info 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 BATES DATE IQ FROM DESCRIPTION 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/ciient privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Jacquie Johnson Bradley Oates 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 Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE IQ FROM DESCRIPTION QBJECTION 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 cau 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 I I I Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES Rfil IQ FROM DESCRIPTION JECTION 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 Depa 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 I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION 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 Susan Stirling Bradley Epstein info protected by privacy rights Work product attorney client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Mike Fisten Bradley protected by privacy rights 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 I I I Farmer Jaffe Weissine Edwards Fistos Lehrman 247ATES DATE TO ffiQM DESCRIPTION QBJECTION 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 Paul Cassell Bradley Activity in protected by privacy rights 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 I I I I Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTIQN 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 privacy 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 Privilege Log Dated I I I Farmer Jaffe Weissim Edwards Fistos Lehrman DATE IQ FROM DESCRIPTION OBJEglON Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Paul Cassell Epstein complaint 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 Epstein fraudulent transfer 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 Revisited sexual history memo Work product attorney client privilege Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evid_ence protected by privacy rights Bradley Paul Cassell Reply memo on asset transfers 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 Cara Holmes Rodriguez Deposition 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 William Berger Strategy 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 Mike Fisten Subpoena 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 Bradley Mike Fisten Synopsis Work product attorney/client privilege Edwards irrelevant and not reasonably calculated to lead Privilege Log Dated I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE 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 privllege 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 Zinoview depo 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 QAll 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 die nt privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Or 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 Fo rensics/lnvestigatio ns 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 I I Farmer Jaffe Weissine Edwards Fistos Lehrman ftP.TES Mn IQ ffi.QM 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 Farmer Jaffe Weissini Edwards Fistos Lehrman ATES 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 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 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 privllege 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 Weissim Edwards Fistos Lehrman BATES DATE TO FROM DESCBIPTION OBJECTION 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 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 tog Dated I I I I Farmer Jaffe Weissine 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 Farmer Jaffe Weissin Edwards Fistos Lehrman TES DATE TO f.l!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 admissible 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 I Farmer Jaffe WeissinJ 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 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 die nt privilege irrelevant and not reasonably calculated to lead Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman SATES DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence protected by privacy rights Carla Martinez Bradley Edwards Vanity Fair Work product attorney I cl lent 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 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 Ken Jenne 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 Ken Jenne 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 SATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights Jacquie Johnson Cara Holmes Subpoenas for Epstefns 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 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 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 by 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 I I I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES DATE IQ FROM DfStRIPTION 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 Visoski 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 privilege 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 I Farmer Jaffe Weissing 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 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 Carolyn Edwards Bradley Edwards Litigation Strategy protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated I I I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES M!E TO FROM DESCRIPTION OBJEglON to the discovery of the admissible evidence protected by privacy rights Bradley Edwards William Berger 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 Paul Cassell 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 Conference Call 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 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 Paul Cassell Bradley Edwards Accounts Motion for IME 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 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 Susan Stirling 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 Pat Diaz Mark Epstein Info 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 Farmer Jaffe Weissim Edwards Fistos Lehrman 1ATE5 QAis 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 Seth 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 Weissine Edwards Fistos Lehrman ATES Rm IQ FROM DESCRIPTION OBJECTION Jacquie Johnson MikeFisten 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 dlent 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 Complaint 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 I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE 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 privllege 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 I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE fBQM DESCRIPTION OBJECTION 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 die nt 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 nd depo 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 WeissinR Edwards Fistos Lehrman BATES DATE IQ FROM 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 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 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 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 privacy 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 I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE IQ 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 L.M.s Sons 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 8-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 Evidence of Asset transfers Work product attorney/client privilege Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman SATES TO FROM 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 LM and E.W Epstein Im on Work product attorney/dient privilege it irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Beth Williamson 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 Fisten Bradley Edwards Interesting Web Site Work product attorney/client privilege Privilege Log-Dated I I I Farmer Jaffe Weissin Edwards Fistos Lehrman SATES DATE TO FROM DESCRIPTION OBJECTION 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 Bradley Edwards Jacquie Johnson IMEs 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 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 Paul Cassell Bradley Edwards Depa of Jeffrey Epstein protected by privacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Bradley Edwards Paul Cassell Asset Protection Issue 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 Bradley Edwards Mike Fisten Igor Zlnoview 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 I I I Farmer Jaffe Weissinf Edwards Fistos Lehrman ATES DATE IQ FROM DESCRIPTION QBJEglON 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 I I I Farmer Jaffe Weissinl Edwards Fistos Lehrman BATES DATE IQ EB.QM 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 Visoski 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 Weissimz Edwards Fistos Lehrman SATES Mm TO FROM DESCRIPTION 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/dient 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 I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES QAis IQ 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 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 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 Ryan Hall Psychiatrist 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 Bradley Edwards Clients Cell Phone Number 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 AmySwan Clients Cell Phone Number 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 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 William Berger 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 ȁ?a??W?N kO_c m??j?K B?Wk F?vo ÃO?iMK Jk?f?p ߨ?t heb?Y?4??G ҧE?C f??j?c?wrfܨX Eծ P?t t?f Ш?i?l0nd bqC?5W k?b?V sW Ez ت??e n6xh?u rb?e ZA?C Ҵ.v C?v k?b?J"U bA LS t8 m?ߠ i??Q 3dөѠbs??s m?y?:X HS ӡo?a?L?U??C eo A _gTG i kD t?Mf?T YVV?ǠH 4U?z?p?i x?P??s9W R4 I 靸?y?H 䝅?Tc VP?z?Y Ij B?b U??N Privilege Log Dated I I I Farmer Jaffe Weissine Edwards Fistos Lehrman ATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Amy Swan litigation Strategy Work product attorney/client privilege irrelevant and not reasonably calcuf ated 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 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 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 Matiska Litigation strategy Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege Log Dated I Farmer Jaffe Weissin2 Edwards Fistos Lehrman SATES Mn IQ FROM DESCRIPTION OBJEglON to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Ken Jenne 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 MarcNurik 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 I I I Farmer Jaffe Weissim Edwards Fistos Lehrman DATE TO ERQ.M 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 dient privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Attorneys at RRA 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/clien1t 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 Susan Stirling Bradley Edwards Request for Copies 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 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 I Farmer Jaffe Weissin Edwards Fistos Lehrman 247ATES DATE IQ FROM DESCRIPTION QBJECTION MarcNurik 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 Fisten 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/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 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 Privilege Log Dated I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEg:ION 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 Marc Nurik 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 privilege 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 I I I I Farmer Jaffe Weissin Edwards Fistos Lehrman ATES DATE IQ FROM DESCRIPTION OBJECTION 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 I I I I Farmer Jaffe Weissin Edwards Flstos Lehrman 247ATES DATE IQ fRQM 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 privllege accountant irrelevant and not reasonably calculated to lead Privilege Log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman I ATES Qfil 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 nQt 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 I I I I Farmer Jaffe Weissini Edwards Fistos Lehrman JIATES ME TO FROM DESCRIPTION QBJECTIQN 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/clienI 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 I I I Farmer Jaffe Weissim Edwards Fistos Lehrman rurr DATE TO EB.QM 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 I Farmer Jaffe Weissin Edwards Fistos Lehrman BATES MJ TO FROM SCRIPTION 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 privacy rights Bradley Edwards Paul Cassell Taking the th 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 I I I I Farmer Jaffe Weissim Edwards Fistos Lehrman BATES DATE TO ffiQM OESCRIPTIQN JECTION 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 rightsO Privilege Log Dated I Farmer Jaffe Weissing Edwards Fistos Lehrman BATES DATE TO fRQM DESCRIPTION OBJECTION Pat Diaz Bradley Edwards New Epstein victim 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 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 I I Farmer Jaffe Weissin 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 dient 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 Farmer Jaffe Weissinf Edwards Fistos Lehrman BATES Qfil IQ 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 privacy 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 evidence 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 Witness list Work product attorney/client privilege Privilege Log Dated Farmer Jaffe Weissinl Edwards Fistos Lehrman i,iATES Qfil 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 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 I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman SATES DATE IQ 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 Gilbert 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 Bradley Edwards Paul Cassell Epstein affidavit to the protected by privacy rights reply Work product attorney/client privilege memo irrelevant and not reasonably calculated to lead Privilege Log Dated I I Farmer Jaffe Weissinf Edwards Fistos Lehrman ATES gfil IQ FROM DESCRIPTION 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 Flsten 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 Oershowitz 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 KenJenne 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 I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OB!ECTIQN 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 Fisten 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 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 List of witness Work product attorney/client privilege irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence Attorneys at RRA Bradley Edwards Serving Dershowitz 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 Weissine Edwards Fistos Lehrman BATES MI TO FROM DESCRIPTION OBJECTION Attorneys at RRA Bradley Edwards Proof of him being out of FL Work product attorney/client 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 Mikefisten 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 I Farmer Jaffe Weissinf Edwards Fistos Lehrman 247ATES 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 I I Farmer Jaffe Weissing Edwards Fistos Lehrman QATES DATE TO 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 ta Jay irrelevant and not reasonably calculated to lead Howell Ca 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 Weissin2 Edwards Fistos Lehrman BATES QAll TO fBQM 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 Ken Jenne 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 Farmer Jaffe Weissini Edwards Fistos Lehrman ATES DATE FROM DESCRIPTION OBJECTION 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 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 Fisten 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 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 I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 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 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 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 EXHIBIT I EXHIBIT I DOCUMENTS PRODUCED BY EDWARDS IN MAY THAT ARE ON HIS FEBRUARY PRIVILEGE LOG AND IDENTIFIED ON EPSTEINS NOVEMBER EXHIBIT LIST EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Susan Spencer p.m Wendel FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Susan Spencer Wendell to Bradley p.m Edwards FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Timothy Malloy to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Susan Spencer Wendell to Bradley p.m Edwards FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to William Berger p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Other Rape W/P Priv not reasonably Source Edwards Victims calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Eric Glasser pp p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Providing New W/P Priv not reasonably Source Edwards Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Course Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Secret Plea Deal W/P Priv not reasonably Source Edwards for Epstein calculated to lead to Providing New discovery of admissible Witnesses evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Secret Plea Deal of W/P Priv not reasonably Source Edwards Epstein providing calculated to lead to new witnesses discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Secret Plea Deal W/P Priv not reasonably Source Edwards for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Secret Plea Deal W/P Priv not reasonably Source Edwards for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to William Berger pp p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Susan Spencer a.m Wendel FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Additional W/P Priv not reasonably Source Edwards Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Susan Spencer Wendel to Bradley a.m Edwards FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Providing New W/P Priv not reasonably Source Edwards Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Additional W/P Priv not reasonably Source Edwards Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michele Dargan to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michael lsikoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michael lsikoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michael lsikoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michael lsikoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Jacquie Johnson a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Other Rape W/P Priv not reasonably Source Edwards Victims calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Other Rape W/P Priv not reasonably Source Edwards Victims calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Providing New W/P Priv not reasonably Source Edwards Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing New W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Susan Spencer p.m Wendel FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michele Dargan p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Providing W/P Priv not reasonably Edwards Source Witnesses calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Litigation Strategy W/P Priv not reasonably Source Edwards calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards cc a.m Renee/Carlos Morrison FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Mike Fisten to Conchita Sarnoff p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Confidential Bradley Additional W/P Priv not reasonably Source Edwards Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Mike Fisten p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Michael lsikoff cc p.m Jacquie Johnson FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Michael lsikoff to Bradley Edwards cc p.m Jacquie Johnson FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Litigation Strategy W/P Priv not reasonably Edwards Source calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Richard Johnson p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Secret Plea Deal W/P Priv not reasonably Edwards Source for Epstein calculated to lead to discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Bradley Edwards to Conchita Sarnoff a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information re calculated to lead to Epstein Strategies discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from Conchita Sarnoff to Bradley Edwards a.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information Re calculated to lead to Epstein Strategies discovery of admissible evidence EPSTEINS NOVEMBER EXHIBIT LIST No Date Document Privilege Log E-mail from George Rush to Bradley Edwards p.m FARMER JAFFES FEBRUARY PRIVILEGE LOG Bates Date To From Description Objection Bradley Confidential Additional W/P Priv not reasonably Edwards Source Information Re calculated to lead to Epstein discovery of admissible Molestations evidence EXHIBIT IU THE CIRCUIT COURT OF THE FfFrtENTH JU.DfC:I.AL CIRCUIT _TN AND FOR PALM BEACH COUNTY FLORIDA case No 9,CAO so 0XMB JEFFREY EPSTEIN Piaintiff coun:ter-,Defendant SCOTT ROIHS_TEJN in,diviciua,lly BRADLEY EDWARDS ind:ividually Qe:Eendants/Counter-Plaintiffs I TRANSCRIPT OF PROCEEDINGS DATE TAKEN TIME 267.PLACE BEFORE _TfiursdaJ-1f March 18th Dixie Highwayi Room West Palm Beach Florida 267oonald Ha._fele Pres:Lciing Judge This cause Came on to_ be heard at the time and v1ac aforesaid when and where the following proceedings were reported by Elaine Williams Palm Beach ep9rting rvice Inc Palm Beach Lakes Boulevard 9uite iodi West J?alm Beach FL 267Palm Beach Reporting service Inc I APPEARANCES For Plaintiff/Qounter,-Defendant ttNK ROCKENBACH A Palm Beach Lakes Boulevard Suite West Palm Beach FL By KA.RA BERARD R,OCKEtU3A.CH ESQQIRE By SCOTT LINK ESQUIRE For Defendarit/Cc:iunter-Plaintiff SEA!lCY DENNEY SCAROLA BARNHART SHIPLEY P.A Palm Be dh kes Boulevard West Palm Beach FI By JACK SCAROLA ESQUIRE By DAVID VITALE JR ESQUIRE By KAREN TERRY ESQUIRE For Non-Parties L.M E.W Jahe Doe HATCH JAMES DODGE West Broadway Suite Salt Lake City UT By PAUL 267CASSELL ESQUIRE _For Je:ftrey Epstein ATTERBURY GOLDBERGER WEISS P.A Austral:i.an,Ayi3 Soui:h Suite West Palm Beach FL By JACK A GQLDBERGER ESQUIRE Palm Beach Reporting Servic:e Inc MR SCl ROLl That is correct The Conrad cherer firm was involved in that litigation a.hd the Conrad Scherer firrn wa.s also interested ln getting to t:ake a at whatever rel vant e-:-mai1s might have been in the hands of tlJ.e bankruptcy trustee and then got turned over to us Well ther were direct negotiations in which I was a personal participant with the lawyers for Conrad Scherer a.rid ari agreement was reached with the lawyers for CO:nra.d Scherer because as We haye told every judge before whom we have appearecl 1th regard to these matters re not attempting to h:Lde anything You want to conduct an in:-carner Clii 247pection we want you to conduct an iri-carner Ciri 247.Rection because it will confirm tha.t were notj attem12tin to hide anything We will turn ayer anythir1g tpat you consider af propria.te for us to turn over _But we have no ability to waivE our clients attorney-client privilege your Honor and some of these e".:fuails clearly 225,contain inforrna.tioh that originated with clients And we a.re L-n the midst at this point still-peric:i.ing iitiga.:tion and it Ls important for us to 267protect our work product privilE!ge as well Some of t:hat 1.itigatio is stilL ongoing right now Palm Beach Reporting Service Inc i 2i i _that was not in the hands of Mr pstein lawyers since whenever this all came to fruition then I would say wed have to take a different approach But the very nature bf the documents that were talking about again right:Iy or wrongiy held were in fact 1eld by Fowler White Epstein:i c9,unseJ at an Jncredib:Le crucial time in this px-oce_ss and that being in and around when the Rothstein firm imploded wheri 267these e-mails were apparently confiscated when sorri.ebpdy inade the decision that instead of Farmer paying for the copy costs they be handed over to Fowler Whi;te i.nd if I have a btt of an incredulous tone to that statern,er1t its probably purposeful But the fact remains Mr Lirik that these materials were in the hands of Epstein.is attorneys from the inception of the Ls sue itself And to now come to the Court with not fiye pages of doc.urnents to look at b_ut or wh_atever that number is it scapes me eca,use of its shear 225mass is impossible and is not going to be cburitenariced here And understand what you re to tell me because Ive gotten flayor for some of these documeht that have been provi:a Palm Beach Reporting Service Ind 1a i4 is MR LINK sir lJIE COURT Aoo tfiat is tfiat tliey are detrimental to the position taken by_Jg Edward and tnat tliey are helpful to the position taken l5y The issue though is one of wh ther 267the protocol and the orderly _administration of justice is going to be forsaken notwithstanding also the aspect of privilege and the sanctity of priv:i..leged communications whether all of those considerations are g6irig to be thrown out whenpalanced against material that has be in the hands of Mr Epstein lawyers fr.om day one And I for one a,m not going to sacrifice protocol over what may or may not be nuinber ohe privileged and if nOt privileged certainly late disclosed d6cumehtati6h of a mass:i.ve nature i Should the amount qf documentation be a determinative ct:or i.ri a courts analysis in this context a.sed upon years of compound experience bench and bar and a little bit more now 267than half on the bench I do not believe that the order;Ly administratfon _of justice should be colinten 267anced and should be disrupt:,i ve Should be disruptive Palm Beath Reporting Service Inc EXHIBIT INRE Case Doc Filed Page of UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor I MOTION FOR ISSUANCE OF AN ORDER TO SHOW CAUSE WHY FOWLER WHITE AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT TO PERMIT DISCOVERY TO ASSESS SANCTIONS AND COSTS AND FOR OTHER APPROPRIATE RELIEF Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Farmer Jaffe through counsel hereby moves this honorable Court for an Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court to Permit Discovery to Assess Sanctions and Costs and for Other Appropriate Relief and as grounds therefore states as follows INTRODUCTION As the Court will recall from previous litigation in this matter Jeffrey Epstein is a convicted sex offender who has been sued by dozens of victims for sexual abuse of children In the course of the above-captioned bankruptcy proceedings in Epstein served a broad subpoena attempting to secure thousands of attorney communications by Farmer Jaffe attorney Bradley Edwards Esq who while previously employed as an attorney at Rothstein Rosenfeldt Adler RRA had represented a number of Epsteins victims in their civil suits against Epstein Farmer Jaffe sought to have Epstein bear the costs of copying and Bates stamping these thousands of documents DE ultimately resulting in an order from this Court that Epsteins counsel attorneys at the law firm of Fowler White Burnett P.A Fowler White would make a copy of the materials and return them to Farmer Jaffe Because of Farmer Jaffes obvious concern that Case Doc Filed Page of Epstein or his legal counsel might misappropriate these documents while in their physical possession for the limited purpose of copying and Bates numbering them this Court specifically ordered that Fowler White will not retain any copies of the documents contained on the discs provided to it nor shall any images or copies of said documents be retained in the memory of Fowler Whites copiers DE To ensure compliance with its order involving the transmission of highly sensitive materials this Court specifically added an enforcement provision Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its computer or otherwise the Court retains jurisdiction to award sanctions in favor of Farmer Brad Edwards or his client DE Remarkably in clear and intentional defiance of this Courts order Farmer Jaffe recently discovered that Fowler White indeed retained a copy of the confidential materials at issue-and those materials have now been passed along to Epsteins current set of lawyers as well as to Epstein personally Not to put too fine a point on it Epstein and his lawyers at Fowler White appear to have misappropriated a set of confidential documents which include sensitive and attorney-client protected communications about Epsteins sex abuse victims and those documents to this day remain in the possession of the victims sexual abuser Epstein Farmer Jaffe asks this Court to enter an order to show cause to allow appropriate discovery into the apparent misconduct and to ultimately enter sanctions and costs as may be appropriate HISTORICAL BACKGROUND While information surrounding the apparent misappropriation of privileged documents is continuing to be revealed it appears that the following facts cannot be reasonably contested by Fowler White or Epstein and should any of them be contested Farmer Jaffe requests an evidentiary hearing to prove them Case Doc Filed Page of From the through the billionaire Jeffrey Epstein sexually abused dozens of then-minor girls in his Palm Beach mansion in the Southern District of Florida and elsewhere Several of these victims including L.M E.W and Jane Doe were represented by Farmer Jaffe attorney Bradley Edwards in their civil suits against Epstein DE Edwards filed the three sexual abuse lawsuits against Epstein in while a sole practitioner before taking the cases with him while Edwards was employed at RRA from April through the firms implosion in November In late Epstein sued Edwards for purportedly improperly representing his clients who were Epsteins sex abuse victims Jeffrey Epstein Scott Rothstein Bradley Edwards and L.M Fifteenth Judicial Circuit in and for Palm Beach County Florida Case No CA MB AG hereinafter the Epstein lawsuit On April Epstein served a subpoena in the Epstein lawsuit upon Rothstein Rosenfeldt Adler PA RRA Bankruptcy Trustee Howard Stettin seeking to obtain documents from the Trustee which included documents from attorney Edwards related to Edwards representation of the sex abuse victims while at RRA DE On May this Court entered an Order approving a proposed Document Production Protocol delineating the process that the RRA Bankruptcy Trustee would use to identify documents responsive to among other requests Epsteins subpoena DE The Order provided this Court with jurisdiction over all discovery sought from the RRA Trustee On August this Court appointed former Broward County Circuit Judge Robert Camey as Special Master who was directed to work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by Jeffrey Epstein Specifically the Special Master was to i review all electronically stored information ESI and other Case Doc Filed Page of documents in the Trustees possession including Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M and Brad Edwards and other current or former clients of Farmer Jaffe ii segregate any such privileged documents and i prepare a privilege log in accordance with standard practice and law DE On September Special Master Camey moved for clarification of this Courts order suggesting that Farmer Jaffe be permitted the opportunity to review the documents themselves in order to determine the applicability of privileges DE On October this Court amended DE to require the RRA Trustee to provide the emails at issue to Farmer Jaffe and requesting that Farmer Jaffe prepare the privilege log On November L.M and Edwards filed a Motion requesting that Epstein the party seeking the discovery bear the printing expense and other reasonable costs and attorneys fees associated with his discovery request DE On November this Court entered an Agreed Order directing the law firm of Fowler White Burnett P.A to print a hard copy of all of the documents contained on the discs with Bates numbers added and provide a set of copied stamped documents to the Special Master and an identical set to Farmer Jaffe Weissing Edwards Fistos Lehrman Farmer Jaffe The Farmer Jaffe attorneys were to then use their set to create its privilege log DE The Court recognizing the trust Farmer Jaffe was being forced to place in the adversary lawyers to perform the copying and Bates numbering without stealing the materials specifically ordered Fowler White will not retain any copies of the documents contained on Qtask was an internal firm electronic communication platform Case Doc Filed Page of the discs provided to it nor shall any images or copies of said documents be retained in the memory of Fowler Whites copiers Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its computer or otherwise the Court retains jurisdiction to award sanctions in favor of Farmer Brad Edwards or his client DE On December bates stamped documents were provided to Farmer Jaffe On January Farmer Jaffe provided Epstein with pages of non privileged emails On January Farmer Jaffe served Epstein with a privilege log governing the remainder of the documents On February Epstein challenged the privilege log as insufficient before this Court DE On February Farmer Jaffe provided Epstein with an additional pages of emails and an Amended Privilege Log containing pages identifying the remaining pages of emails containing privileged information that were not being produced On March Special Master Camey filed his Interim Report before this Court confirming that of the more than pages of emails all documents had been released to Epstein subject to confidentiality provisions with the exception of the documents identified on The pages of documents were 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 totaling pages Two 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 totaling pages Case Doc Filed Page of Farmer Jaffes 159-page privilege log of February which documents were not subject to discovery DE In additional litigation ensued regarding some of the documents in state court in the Epstein lawsuit against Edwards To date pages of emails have been permissibly and lawfully provided to Epstein Consequently pages of emails have never been provided to be retained by Epstein and his lawyers as they are protected by various privileges including attorney client privilege and work product privilege and remain on the privilege log RECENT EVENTS On November the law firm of Link Rockenbach P.A entered a Notice of Appearance in the Epstein lawsuit pending before Judge Donald Hafele the successor to Judge Crow As it has evolved Epsteins lawsuit against Edwards was dismissed and the lawsuit now Specifically on April Judge David Crow presiding over the Epstein lawsuit entered an Order requiring Edwards to produce any non-privileged documents identified in paragraph of Epsteins Motion to Compel and Amend Protective Order which specifically only included emails relating to news reporters or the media On May Judge Crow entered an Order on Plaintiff Jeffrey Epsteins Motion to Compel Production of Documents from Defendant Bradley Edwards and for Sanctions stating Bradley Edwards shall within days of the date of this order file a more complete privilege log The Court finds the privilege log is insufficient on its face and does not comply with the requirements ofF.R.C.P and Ins Corp Johnson So 2d Fla 4th DCA In all other respects the Motion is denied at this time On May Edwards provided Epstein with pages of emails pursuant to Judge Crows April IO Order On May Edwards filed a Motion for Clarification of Recent Discovery Orders before Judge Crow On August Judge Crow granted Edwardss Motion for Clarification and vacated its Order of May without prejudice upholding Edwardss February Privilege Log and requiring Edwards only to file written response specifically addressing the production sought in Paragraph of Epsteins Motion to Compel and Amend Protective Order of March as Ordered in this Courts April Order Ultimately following a summary judgment motion by Edwards Epstein dropped his lawsuit currently pending before Judge Crows successor Judge Hafele is a follow-on action Edwards Epstein for malicious prosecution by Epstein in filing his lawsuit in the first place Case Doc Filed Page of involves a malicious prosecution claim brought by Bradley Edwards against Jeffrey Epstein Edwards alleges that Epstein sued him with malice and without probable cause for representing then-minor girls sexually abused by Epstein including L.M On March Epstein through counsel Scott Link and Kara Rockenbach Epstein filed Plaintiff/Counter-Defendant Jeffrey Epsteins Notice of Filing of Redacted Appendix in Support of Response in Opposition to Defendant/Counter-Plaintiff Bradley Edwards Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence Included in Epsteins 353-page filing were at least privileged emails spanning over pages that are subject to various privileges pursuant to the privilege log and that were never lawfully permitted to be provided to Epstein or retained by his lawyers Epstein attached not only actual copies of various emails but also provided a purported summary of the emails which included specific quotations from communications over which attorney-client privilege and other protections had been repeatedly asserted by Farmer Jaffe Edwards and L.M Epstein also provided a wholly out-of context and substantially misleading summary of what he believed the emails demonstrated In subsequent filings in court proceedings he has continued to reference the content of privileged documents and mischaracterize their significance in the pending state court malicious prosecution case On March Edwards filed his Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Farmer Jaffes Privilege Log On March L.M and two other minor girls Epstein had sexually abused E.W and Jane Doe filed an emergency motion to intervene and an emergency motion to join Case Doc Filed Page of Edwards motion to strike The three victims alleged that Epsteins recent filing disclosed their protected attorney-client communications On March counsel for Epstein delivered a flash drive to counsel for Edwards which duplicates the disc we located in Fowler Whites files Letter of transmittal attached hereto as Exhibit A The subject flash drive contained three separate PDF files respectively titled Bradley Edwards.pdf containing pages of emails Epstein Searches.pdf containing pages of emails and Scott Rothstein.pdf containing pages of emails subject documents Notably the flash drive indicated that the three PDF files had been last modified on December a mere nine days after this Court ordered Fowler White to take very limited possession of the subject documents to print and Bates stamp them and then not to retain any copies This was also a short five days before the Bates stamped documents were delivered to Farmer Jaffe on December On March counsel for Epstein also provided a sworn affidavit from certified paralegal Tina Campbell that she had obtained these materials from Fowler Whites files Specifically Ms Campbell attested under oath that on January she had reviewed approximately boxes of Fowler Whites Epstein files at Fowler Whites Miami Florida offices During that review electronic discs found in the Fowler White files were marked for review but the contents were not reviewed Affidavit attached hereto as Exhibit On February Link Rockenbach P.A received three boxes from the Fowler White firm containing copies of the items that had been marked for reproduction including a disc labeled Epstein Bate Stamp handwritten in black sharpie The disc marked Epstein Bate Stamp was not reviewed until February Case Doc Filed Page of It is thus undisputed that a disk containing the privileged emails in question was in the possession of Fowler White in early January disc showing that it had last been modified on December On March Judge Hafele held a hearing regarding the privileged communications Counsel for Epstein Edwards and the three victims at issue L.M E.W and Jane Doe all appeared Counsel for Edwards began the hearing by explaining the relevant background as well as how Fowler White had made and retained a copy of the privileged communications in violation of this Courts order Counsel for Epstein then responded arguing that they i.e Link Rockenbach had not improperly taken any documents from Fowler White This argument led Judge Hafele to ask the critical question though is why did Fowler White have these documents why were they continued to be held and was it in violation either expressly or constructively as it relates to Judge Rays order Hearing Trans at all portions of the March hearing transcript cited herein are attached hereto as Exhibit Without offering any real explanation in response to the Courts inquiry counsel for Epstein simply stated so lets talk about Fowler White because it is as clear as mud Hearing Trans at Counsel for Epstein further explained that hen these issues came up we asked Fowler White to please give us the original boxes We got the original boxes and found the disc in a folder that says Camey printing on it Thats it Thats all thats on this folder Hearing Trans at Epsteins counsel then conjectured certain speculative scenarios but Epsteins current legal counsel speculated that after a copy of the materials were provided to the Special Master Judge Camey that Judge Camey somehow turned around contacted Fowler White and gave the disk to them Judge Hafele however summarily rejected this speculation explaining that this would require believing that Judge Camey a respected jurist was somehow engaged in some type of ex parte communications with Fowler White Hearing Trans at Case Doc Filed Page of ultimately admitted I wasnt there I cant tell you what Fowler White did Hearing Trans at During the hearing counsel for Epstein revealed that Epstein personally had retained copies of the confidential materials in contravention of the November Order Hearing Trans at counsel for Epstein admits that copies of the documents have been provided within my law firm and my client When further asked Has Mr Epstein been provided with copies of the documents or the contents of these privileged documents counsel for Epstein replied I just said my client My law firm and my client And I can say legal counsel Mr Goldberger So thats it Hearing Trans During the hearing counsel for Epstein Link and Rockenbach also revealed that Fowler White was disclaiming any memory of the circumstances surrounding the creation and retention of the disc We have reached out to lawyers for Fowler White They have no memory of it Hearing Trans at Epsteins claim that Fowler White had no memory of the surrounding circumstances led counsel for Edwards to respond that it was difficult to believe Fowler White had no records regarding the disc Your Honor knows very well that Fowler White is a very large law firm that keeps meticulous time records with regard to the services they render And the concept that it is impossible to reconstruct through those time records what was received when it was received when it was reviewed what happened with it who was informed of what was happening with it quite frankly is inconceivable to me Hearing Trans at Judge Hafele responded in agreement by noting his surprise that Fowler White was not explaining what had happened And thats a good point What I was going to point out earlier is that I would have expected certainly in deference to the fact that Mr Epstein was a client of Case Doc Filed Page of Fowler White that someone from Fowler White would have had the ability to weigh in somehow as to these critical issues Perhaps Im being a bit naive when I say that having served Mr Epstein in their capacity as counsel its my respectful belief that they owed an obligation to Mr Epstein if not this Court to explain how and why they had access and kept these records in their possession in light of that bankruptcy court order and in light of this ongoing litigation And as a matter of respect to Mr Epstein and his ongoing legal team to have made some type of affirmative steps to have dealt with this issue head on because of the apparent implications of same Hearing Trans at Counsel for victims L.M E.W and Jane Doe also asked Judge Hafele to order Fowler White to explain who they had distributed the confidential materials to Judge Hafele indicated that in light of Fowler Whites withdrawal from the case in front of him he did not have that ability to enter such an order directed against them Hearing Trans at Based on the foregoing facts over the past seven years Fowler White has been in possession of a disc containing over pages of documents-6,741 pages of which were privileged materials never lawfully received by them-that they were specifically ordered not to retain in any format The retained disc in question had the exact number of documents copied to it that Fowler White copied at the direction of this Court on November And the subject disc was last modified a mere nine days after this Court ordered Fowler White to copy Bates stamp tum over and permanently destroy the materials from their internal system This was also a short five days before the final Bates stamped documents were delivered in hard copy to Farmer Jaffe by Fowler White on December date after which Fowler White had no lawful reason to retain the subject documents in any format whatsoever Case Doc Filed Page of MEMORANDUM OF LAW Based on the egregious conduct of Epstein and his attorneys the exact fear contemplated by the parties the Special Master and this Court when the November order was entered has alarmingly come to fruition Despite obligations as officers of this Court to follow a specifically delineated procedure designed to protect highly confidential and privileged materials Fowler White has apparently deliberately copied and retained highly sensitive confidential and privileged materials for over seven years Recently these materials have been disclosed to additional counsel for Epstein and these materials remain in the possession of Epstein personally The misappropriation of this information has caused irreparable harm Epsteins current counsel Link Rockenbach have also now filed privileged information in the public court file in the Edwards Epstein matter although that filing has since been placed under seal and have repeatedly referenced the privileged content of the misappropriated documents in other filings Specifically foreseeing the need to ensure that its earlier order was complied with in full this Court expressly retained jurisdiction to award sanctions in the event of any breach This Court should take steps to ensure that its order is complied with in the future and to punish and remedy violations in the past Farmer Jaffe believes that the true extent of its damages can only be determined through a thorough inquiry into the entire chain of custody detailing the whereabouts of the subject documents since inception and including any person who has seen or been informed of the content of said documents To that extent an evidentiary hearing and corresponding discovery are essential as complete determination of the breadth and degree of complicity by Fowler White and Jeffrey Epstein both jointly and severally is imperative to the formulation of the appropriate sanctions in this matter Farmer Jaffe has the right to inquire as to whether the subject documents Case Doc Filed Page of were downloaded into the Fowler White system whether they were disseminated to third parties and ultimately when and how they ended up in the hands of Jeffrey Epstein Stated more succinctly the sanctions here must be commensurate with the misconduct Specific Relief Sought This Court previously entered an order directing that both Fowler White and Epstein were not to retain images or copies of the subject documents on their computers or otherwise DE In light of the clear violation of that order Farmer Jaffe now asks this Court to enter an additional order as follows Fowler White and Epstein are directed within seven days of the entry of this order to show cause as to why they should not be held in contempt of the Courts order DE Fowler White and Epstein including all of Epsteins past and present legal counsel are directed within seven days of the entry of this order to provide to counsel for Farmer Jaffe all physical electronic and other information in their possession concerning the copying retention and dissemination of the documents covered by DE and any materials disclosing the contents of those documents including but not limited to all information regarding the making retention and dissemination of these materials on and after December This information shall include but is not limited to any electronic or other information showing the date on which copies were made the authors of any such copies emails or transmission of such copies and any discussion or reference to such copies Epstein and all of his past and present legal counsel shall also provide all correspondence and billing records related to the copying retention review discussion and dissemination of the subject documents the Bates stamping of the subject This motion is filed on behalf of Farmer Jaffe It is counsels understanding that separate motions to the same effect will be filed shortly by Mr Edwards and by three victims with privileged materials at issue L.M E.W and Jane Doe Case Doc Filed Page of documents or any other activity related to the November Order from the day that the Epstein subpoena was issued on April through the present Fowler White and Epstein including all of Epsteins past and present legal counsel will provide to Farmer Jaffe within seven days of the entry of this order a listing of all persons or entities to whom the subject documents or any information derived from the contents of the subject materials have been viewed and distributed as well as a certification that they have asked for return of the subject materials Fowler White and Epstein and any other persons know to have ever possessed these materials including Epsteins current counsel shall allow neutral IT specialists appointed by this Court to search all computer servers including back-up servers and hard-drives for designated search terms especially found within these privileged materials While mandatory anyway under the circumstances Epstein and all past and current counsel as well as anyone else known or believed to have ever possessed the materials should be strictly ordered to maintain all possible platforms that may contain such privileged information to ensure there is no spoliation of the evidence of the improper retention review dissemination or other use of these materials by any person or entity Counsel for Farmer Jaffe is permitted to obtain deposition testimony of all persons reasonably believed to have knowledge of the circumstances surrounding the copying retention or dissemination of the documents at issue in DE An evidentiary show cause hearing will be held wherein Farmer Jaffe is afforded the opportunity to inquire into the facts and circumstances surrounding the wrongful retention and resulting dissemination of the subject privileged materials in order for the aggrieved parties and the Court to learn of the full scope of the wrongdoing Such inquiry should include but not be Case Doc Filed Page of limited to testimony from Special Master Robert Camey Jeffrey Epstein Fowler White Attorney Joseph Ackerman Fowler White Attorney Lilly Ann Sanchez Jack Goldberger Tina Campbell Scott Link Kara Rockenbach and the currently unidentified attorneys that Mr Link has represented are also working on this case on behalf of Epstein from the Gunster law firm Epstein will pay Farmer Jaffe reasonable attorneys fees and expenses connected with Farmer Jaffes efforts to determine the circumstances surrounding the retention and release of the materials and to remedy any damage caused to Farner Jaffe or its clients from the retention use or release of the materials Farmer Jaffe is permitted to seek further relief and sanctions after the discovery described above is completed Authority to Enter an Additional Order This Courts November Order specifically noted that the Court was retaining jurisdiction to enforce compliance Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its compute or otherwise the Court retains jurisdiction to award sanctions in favor of Farmer Brad Edwards or his client DE at emphasis added The Court clearly has power to now award sanctions and take all other steps necessary to secure compliance Of course all federal courts have the power by statute by rule and by common law to impose sanctions against recalcitrant lawyers and parties litigant Carlucci Piper Aircraft Corp F.2d 11th Cir Even absent explicit legislative enactment deeply rooted in the common law tradition is the power of any court to manage its affairs which necessarily includes the authority to impose reasonable and appropriate sanctions upon errant lawyers practicing before it Id at Federal courts have the inherent power to enforce compliance Case Doc Filed Page of with their lawful orders through civil contempt remedies Citronelle-Mobile Gathering Inc Watkins F.3d 11th Cir Courts also have the inherent power to sanction a party for misconduct Chambers Nasca U.S As the Supreme Court stated in Chambers it has long been understood that certain implied powers must necessarily result to our courts of justice from the nature of their institution powers which cannot be dispensed with in a Court because they are necessary to the exercise of all others Id Before the Court uses its inherent contempt power a petitioner must first establish by clear and convincing evidence that the alleged contemnor violated a courts earlier order Chairs Burgess F.3d 11th Cir quoting United States Roberts F.2d 11th Cir Once such a prima facie showing of civil contempt has been made the burden shifts to the contemnor to produce evidence at a show cause hearing that the underlying order was not violated or that the violation was excused by an inability to comply Chairs at violation need not be willful to support a finding of civil contempt McComb U.S Since the purpose of civil contempt is remedial it matters not with what intent the defendant did the prohibited act Even inadvertent or partial non-compliance with orders of the Court constitutes civil contempt if the party has not in good faith made all reasonable efforts to comply U.S Hayes F.2d 11th Cir However if the court finds the defendant acted willfully or maliciously in disregarding the injunction then the court may cite the defendant for criminal contempt Mercer Mitchell F.2d 11th Cir citing U.S.C stating a court of the United States shall have power to punish by fine or imprisonment or both at its discretion such contempt of its authority and none other as Misbehavior of any person in its presence or so near thereto as to obstruct the administration of justice Misbehavior of any of its officers in Case Doc Filed Page of their official transactions Disobedience or resistance to its lawful writ process order rule decree or command The fundamental purpose behind contempt sanctions are twofold sanctions can coerce the contemnor into complying in the future with the Courts orders or they can compensate the complainant for losses resulting from the contemnors past noncompliance Citronelle-Mobile F.2d at See also McComb Jacksonville Paper Co U.S EEOC Guardian Pools Inc F.2d 11th Cir Perfect Fit Industries Inc Acme Quilting Co F.2d 2d Cir cert denied S.Ct In fact the Court has wide discretion to fashion an equitable remedy for contempt that is appropriate to the circumstances Guardian Pools F.2d at Accord United States City of Miami F.3d 11th Cir Such options include a coercive daily fine a compensatory fine attorneys fees expenses to the aggrieved party and coercive incarceration Citronelle-Mobile F.2d 1297.Courts have broad power to fashion an appropriate sanction including anything from entry of monetary sanctions to entry of a final judgment on the merits against a party demonstrated to have committed a fraud upon the court See Vargas Peltz F.Supp S.D Fla Compensatory sanctions generally include a fine payable to the petitioner the amount of which is determined by the extent of the actual loss Id citing United States United Mine Workers U.S Compensatory sanctions also frequently include the payment of the complainants attorneys fees in seeking the redress Hutto Finney U.S an equity court has the unquestioned power to award attorneys fees against a See Federal Rule of Criminal Procedure requiring that notice be provided in open court in an order to show cause before indirect criminal contempt can be imposed Case Doc Filed Page of party who shows bad faith by delaying or disrupting the litigation or by hampering enforcement of a court order and course fees can also be awarded as part of a civil contempt penalty Watkins F.2d at 1301;Jaeger Massis No U.S App LEXIS 2d Cir Nov Courts within the Eleventh Circuit have not hesitated to impose severe sanctions pursuant to their inherent powers including cases where a party has acted in bad faith See e.g In re Mroz F.3d 11th Cir In light of the Courts sweeping powers to secure compliance with orders this Court should grant the relief sought by Farmer Jaffe above There can be no doubt that a prima facie showing of contempt has been made by clear and convincing evidence Fowler White and Epstein were directed not to retain copies of privileged documents The events cited above show that Fowler White apparently made-and indisputably retained-a copy of the privileged documents Sometime thereafter Epstein also obtained and retained a copy of the privileged documents and now numerous unauthorized people have these documents and knowledge of their privileged content At the hearing surrounding the confidential materials Judge Hafele indicated his respectful belief that Fowler White owed an obligation to Mr Epstein if not this Court to explain how and why they had access and kept these records in their possession in light of that bankruptcy court order and in light of this ongoing litigation Hearing Trans at Fowler White however has failed to come forward voluntarily Accordingly this Court should enter an order to show cause as to why they have not violated this Courts order In light of Epsteins possession of the materials he should be directed to show cause as well In addition it is already clear that efforts to avoid responsibility for violating the Courts order are underway Indeed Link and Rockenbach has certified that instead of gathering Case Doc Filed Page of cataloguing and filing under seal all improperly acquired and retained privileged materials it has directed their destruction thereby impeding further investigation of the origin of those materials Accordingly Fowler White and Epstein including his legal counsel past and present should be ordered to provide all relevant discovery about how the violation occurred To get to the bottom of this violation and be permitted to identify the necessary witnesses to be examined at the anticipated evidentiary hearing before this Court Farmer Jaffe also seeks to depose those persons who appear to be in the chain of custody of the improperly copied and retained materials Because it is clear that Farmer Jaffe is going to have to bear additional burdens in terms of time and effort in responding to Fowler White and Epsteins improper copying retention and distribution of privileged materials the Court should award attorneys fees and expenses Epstein and his legal counsel have caused these problems innocent third parties should not bear the financial consequences Finally because the violation of this Courts order appears to be evolving and on-going Farmer Jaffe requests leave to seek supplemental sanctions and remedies after discovery on the violation has been completed CONCLUSION WHEREFORE Farmer Jaffe respectfully requests that this Court enter an order to Fowler White and Epstein to show cause why they should not be held in contempt of court allowing discovery and an evidentiary hearing on the circumstances surrounding the improper copying retention and distribution of privileged materials and allowing Farmer Jaffe to seek such other sanctions and remedies as may be appropriate following discovery on these matters A proposed order to this effect is attached Case Doc Filed Page of I HEREBY CERTIFY that pursuant to L.R Movants counsel has contacted Fowler White in a good faith attempt to resolve the matter without a hearing before bringing this motion Fowler White has failed to respond I HERBY CERTIFY that a true and correct copy of the foregoing was served electronically to the examinee the debtor the attorney for the debtor the trustee all CMIECF subscribers and by email or U.S Mail on those parties listed on the attached service list this th day of March I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A EDWARDS POTTINGER LLC By Isl Bradley Edwards Bradley Edwards FLBN BrittanyN Henderson FLBN Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL Phone Fax Attorneys for Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Case Doc Filed Page of CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certified that the foregoing document is being served this day on all counsel of record or pro se parties identified on the on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CMIECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing Isl Bradley Edwards Bradley Edwards Case Doc Filed Page of Joseph Ackerman Jr Esq Fowler White Burnett P.A Phillips Point West South Flagler Drive West Palm Beach Florida Phone Fax 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 SERVICE LIST Jack A Goldberger Esq 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 Jack Scarola Esq Florida Bar No David Vitale Jr Esq Florida Bar No Attorney 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 Case Doc Filed Page of Phil Burlington Esq Nichole Segal Esq njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Jay Howell Esq Jay Howell Associates Florida Bar No Attorney E-Mail jay jayhowell.com Cesery Blvd Jacksonville FL Paul Cassell Esq S.J Quinney College of Law at the University of Utah University St Salt Lake City UT above for address purposes only Attorney E-Mail cassellp law.utah.edu Attorneys for L.M E.W and Jane Doe Judge Robert Camey Saratoga Ln West Palm Beach FL rbcamey3 gmail.com Special Master EXHIBIT Case Doc Filed Page of UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION a-::iri IJ.SBCSDF-FTL ii INRE ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER I JOINDER IN MOTION FOR ISSUANCE OF AN ORDER TO SHOW CA SE Bradley Edwards by and through his undersigned counsel hereby gives no ice of his joinder in the motion filed on behalf of Farmer Jaffe for issuance of an order to show use why Jeffrey Epstein and Fowler White should not be held in contempt of court Edwards adopts all arguments and requests for relief asserted in the referenced motion I HEREBY CERTIFY that a true and correct copy of the foregoing Jas served electronically to the examinee the debtor the attorney for the debtor the trustee all ME/ECF subscribers this ay of March No tto ey E-Mail jsx searcylaw.com and ccann searcylaw.com rimary 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 EXHIBIT INRE Case Doc Filed Page of UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor I L.M E.W AND JANE DOES JOINDER IN MOTION FOR ORDER TO SHOW CAUSE AND MOTION FOR DISCOVERY TO ASSESS SANCTIONS AND COSTS FOR OTHER APPROPRIATE RELIEF Sexual assault victims L.M E.W and Jane Doe hereinafter the Victims proceeding pseudonymously and through undersigned counsel having previously moved to intervene in this action now file this oinder in Farmer Jaffe Motion for Issuance of an Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court to Permit Discovery to Assess Sanctions and Costs and for Other Appropriate Relief DE In addition the Victims seek additional remedies as follows FACTUAL BACKGROUND To avoid duplicative pleadings the Victims simply adopt as if set forth in full herein the factual recitations made by Farmer Jaffes earlier motion for an order to show cause DE at The Victims would also direct the Court to their contemporaneously filed motion to intervene which establishes that they have a direct substantial and protectable interest in their attorney-client protected materials These pleadings demonstrate that Fowler While and Epstein have directly violated an order of this Court DE which prohibited them from retaining and distributing copies of attorney-client protected materials of the three victims Case Doc Filed Page of RELIEF REQUESTED The Victims join in and seek on their own behalves all of the relief previously requested by Farmer Jaffee DE at In addition the victims seek the following relief not specifically sought by Farmer Jaffe A letter written and signed by both Fowler White and Jeffrey Epstein and provided to the VZictims to the following effect To Whom It May Concern The documents listed on the attached list insert attachment were impermissibly retained by the undersigned in violation of an order from U.S Bankruptcy Judge Raymond Ray of the Bankruptcy Court for the Southern District of Florida See DE In Re Rothstein Rosenfeldt Adler P.A No If you are in possession of any of the attached documents as a consequence of a violation of the order you are requested to promptly return it to the attorney who has provided a copy of this letter to you Discovery regarding the distribution of the impermissible retained materials in the form of twenty interrogatories twenty requests for production and twenty requests for admission to be answered by Jeffrey Epstein any attorney paralegal other law firm employee or consultant or expert witness who has been involved in the representation of Epstein in the above captioned matter or in Epstein Edwards No Cir Ct of the th Jud Cir for Palm Beach County Fla Separate letters of apology for each of the three victims written by Epstein and all attorneys and staff found to have played a responsible role in the unauthorized retention and release of their privileged materials Case Doc Filed Page of A referral from this Court to appropriate disciplinary authorities including bar authorities for any attorney found to have apparently violated ethical obligations in connection with the improper retention and subsequent distribution of the materials at issue Monetary sanctions payable directly to each of the Victims by Epstein in the amount of for each of the three victims a total of After making payment Epstein is permitted to seek reimbursement from any of his attorneys who may have been responsible An evidentiary hearing on the circumstances surrounding the violation of the Victims right of confidentiality and a finding of civil or criminal contempt as may be appropriate along with such additional sanctions as the Court may then find to be appropriate Reasonable attorneys fees for the Victims for all attorney time costs and expenses incurred as a result of the improper retention and subsequent distribution of the materials at issue AUTHORITY FOR THE COURT TO AW ARD RELIEF This Courts previous order DE specifically indicated that the Court was retaining jurisdiction to impose sanctions In addition the Court has authority to award sanctions for all the reasons explained by Farmer Jaffe in its memorandum at which authority the Victims also specifically rely upon here CONCLUSION For the foregoing reasons the Court should grant the three Victims the relief requested above includingjoinder in Farmer Jaffes motion for sanctions and their own sanctions and other relief as described above I HEREBY CERTIFY that pursuant to L.R Movants counsel has contacted Farmer Jaffe and Fowler White in a good faith attempt to resolve the matter without a hearing before bringing this motion Farmer Jaffe supports the Victims motion Fowler White has been Case Doc Filed Page of contacted via email on March about the Victims motion and has thus far failed to respond I HEREY CERTIFY that a true and correct copy of the foregoing was served electronically to the examinee the debtor the attorney for the debtor the trustee all CM/ECF subscribers and by email or U.S Mail on those parties listed on the attached service list this th day of March I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A SHAPIRO LAW West Sunrise Boulevard Suite Plantation Florida Telephone By Isl Peter Shapiro Peter Shapiro Florida Bar No pshapiro shapirolawpa.com and Paul Cassell Esq S.J Quinney College of Law at the University of Utah University St Salt Lake City UT above for address purposes only Attorney E-Mail cassellp law.utah.edu Pro Hae Vice Motion Filed Contemporaneously Attorneys for Intervenors L.M E.W and Jane Doe Case Doc Filed Page of CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certified that the foregoing document is being served this day on all counsel of record or pro se parties identified on the on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing Isl Peter Shapiro Peter Shapiro Case Doc Filed Page of Bradley Edwards Brittany Henderson Edwards Pottinger LLC Andrews Avenue Suite SERVICE LIST Fort Lauderdale FL Phone Fax brad epllc.com brittany epll.com Attorneys for Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Joseph Ackerman Jr Esq Fowler White Burnett P.A Phillips Point West South Flagler Drive West Palm Beach Florida Phone Fax Scott Link Esq Link Rockenbach P.A Scott linkrocklaw.com Kara linkrocklaw.com Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Jack A Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack Scarola Esq Florida Bar No David Vitale Jr Esq Florida Bar No Case Doc Filed Page of Attorney 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 Judge Robert Camey Saratoga Ln West Palm Beach FL rbcamey3 gmail.com Special Master CARLTON FIELDS JORDEN BURT P.A Niall McLachlan Esq SE nd Street Suite Miami FL Telephone Facsimile Primary Email nmclachlan cfjblaw.com Secondary Email cguzman cfjblaw.com miaecf cfdom.net Counsel for Fowler White Burnett PA 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 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