Epstein Secrets

Lopez • EFTA00040232 Page 3 • • Pat McHugh • • • Jennifer Naso • • a • • David Rodgers • Alfredo Rodriguez • Dr. Lisa Rocchio • Lawrence Visoski • Les Wexner • II. List of Places The following is a list of places that may be discussed at trial: • 358 El Brillo Way, Palm Beach, Florida •

fredo Rodriguez • Dr. Lisa Rocchio • Lawrence Visoski • Les Wexner • II. List of Places The follo

A00040231 Page 2 • • Tracy Chappell • • Dr. Park Dietz • Eva Anderson Dubin • Glen Dubin • • Bennett Gershman • Lesley Groff • Dr. Ryan Hall • • • • Jordana Feldman • • Stephen Flatley • • Robert Hanson • • • Paul Kane • Robert Kelso • • • Gerald LaPorte • • Dr. Eli

orida Department of Law Enforcement related to Jeffrey Epstein 39. All statements made by Jeffrey Epstein 40. List of properties and vehicles in Larry Visoski's name 41 All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and case

in 40. List of properties and vehicles in Larry Visoski's name 41 All of Jeffrey Epstein's Responses to

in preparation for this litigation by any party to this cause 131. Curriculum vitaes of any and all listed experts 132. Curriculum vitae of Dr. Ryan Hall 133. Any articles or publications of Dr. Ryan Hall 134. Any articles or publications of Dr. Richard Hall 135. Any articles or publications of D

n. 40. List of properties and vehicles in Larry Visoski's name. This is so overbroad that Epstein cannot

y make a determination as to whether or not he seeks to exclude anything under this exhibit identification. 40. List of properties and vehicles in Larry Visoski's name. This is so overbroad that Epstein cannot possibly make a determination as to whether or not he seeks to exclude anything under this exhibit i

ot possibly make a determination as to whether or not he seeks to exclude anything under this exhibit identification. 131. Curriculum vitae of Dr. Ryan Hall. 132. Any articles or publications of Dr. Ryan Hall. 133. Any articles or publications of Dr. Richard Hall. 134. Any articles or publications of D

y calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02971 10/14/2009 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; pr

4 EFTA00310171 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 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 evide

y calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02971 10/14/2009 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; pr

24 EFTA00602958 Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissine. Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 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 evide