Epstein Secrets

Objections Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty;

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafia) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

litigation Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also c

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00211393 Case 9:08-cv-80736-KAM Document

LY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (Villafafia) handwritten notes 6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of

litigation Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney (Villafafia) notes, target letters, correspondence re grand jury subpoena Work product 6(e) Contains information subject to investigative privilege. Also c

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00191371 Bates Range Description Privi

withheld as privileged — copy provided to opposing counsel] Box #2 P-009104 Thru P-009111 File folder entitled "Meeting Timeline" containing Villafafia typed notes summarizing meetings with opposing counsel prepared at Work product Deliberative process request of with handwritten correction and

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00065071 Case 9:08-cv-80736-KAM Document

to this litigation Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney (Villafafia) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) Contains information subject to investigative privilege. A

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00191220 Bates Range Description Privi

hru summary chart, witness/victim names and Contains information and Anticipation of Litigation; Improper P-002386 contact list, attorney (Villafafia) documents subject to Invocation; Overriding Need; Claims Against handwritten notes, 302s, portions of state investigative privilege. Public Pro

Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty;