Epstein Secrets

ding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P-013860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] N/A Suppl. Box 3 P-013861 Thru

Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Du

with handwritten correction and t d uideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to A. Marie Villafafia and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will b

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Page 8 of 23 EFTA00211394 Case 9:08-cv-80736-KAM Doc

ith handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposi

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Page 8 of 23 EFTA00223834 Case 9:08-cv-80736-KAM Doc

ion Privilege(s) Asserted Box #4 P-013970 thru P- 1 5/18/2007 email from Marie Villafafia to Matt Menchel informing him of intent to subpoena Roy Black's private investigator and steps taken to obtain DOJ authorization Work Product 6(e) Deliberative Process Investigative Privilege 2 5/21/2007 em

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Page 8 of 23 EFTA00191221 Bates Range Description

riding Need; Attorney Conduct at Issue Suppl. Box 3 P-013859 Through P413860 Email, Gerald Lefcourt to Marie Villafana, Lilly Ann Sanchez, Roy Black, re: Jeffrey Epstein [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) N/A Suppl. Box 3 P-013861 Thru

Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Inadequate Log; No Factual Underpinnings; Fiduciary Du

ith handwritten correction and typed guideline estimate Work product Deliberative process Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to A. Marie Villafafia and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged — will b

and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Investigative privilege Page 8 of 23 EFTA00191372 Bates Range Description