Epstein Secrets

DATE TO FROM DESCRIPTION OBJECTION 15454-15475 09/15/2009 Adam Horowitz Jacquie Johnson Critton's notice of depo;Epstein notice of hearing,Mark Epstein notice of depo Joint W/P Priv. 01465 07/13/2009 Katherine Ezell Bradley Edwards Epstein Joint W/P Priv. 15485-15492 09/17/2009 Jacquie John

e; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05312.05313 07/22/2009 Nora Batian Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissi

494.02515 09/20/2009 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; protected by privacy rights 02260-02261 07/22/2009 Nora Batian Bradley J. Edwards Epstein — coordinating meetings Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead

DATE TO FROM DESCRIPTION OBJECTION 15454-15475 09/15/2009 Adam Horowitz Jacquie Johnson Critton's notice of depo;Epstein notice of hearing,Mark Epstein notice of depo Joint W/P Priv. 01465 07/13/2009 Katherine Ezell Bradley Edwards Epstein Joint W/P Priv. 15485-15492 09/17/2009 Jacquie John

e; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05312-05313 07/22/2009 Nora Batian Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissi

494-02515 09/20/2009 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; protected by privacy rights 02260-02261 07/22/2009 Nora Batian Bradley J. Edwards Epstein — coordinating meetings Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead