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

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01471 07/18/2009 Wayne Black Bradley Edwards Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the d

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01648 07/11/2009 Wayne Black Bradley Edwards Investigating Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery

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

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01471 07/18/2009 Wayne Black Bradley Edwards Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the di

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01648 07/11/2009 Wayne Black Bradley Edwards Investigating Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery

tein files? 14.12.1 BE testified that you Judge Stone, Bill Berger and Rob Buschell worked on cases? [BE tr. 229-232] 14.12.2, you, e.g., attended Mark Epstein's depo 14.12.3 you were to coordinate depos or be involved for all high profile people? 15. Did Adler and others ever talk about Epstein case(s).

sked to get from their investigation and surveillance? 21.8 How may time did the investigators conduct surveillance on Epstein? 21.9 Do you know Wayne Black? 21.9.1 Who is he? 21.9.2 Who hired and authorized Wayne Black to investigate Epstein? 21.9.3 Did he conduct surveillance on JEE? 21.9.4 What did

494.02515 09/20/2009 Bradley Edwards Pat Diaz Mark Epstein Info Work product; attorney/client privilege;

ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02109 05/13/2009 Wayne Black Bradley J. Edwards Epstein info — List of Plaintiff lawyers Work product; attorney/client privilege; irrelevant and not reasonably calculat

494-02515 09/20/2009 Bradley Edwards Pat Diaz Mark Epstein Info Work product; attorney/client privilege;

ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02109 05/13/2009 Wayne Black Bradley J. Edwards Epstein info — List of Plaintiff lawyers Work product; attorney/client privilege; irrelevant and not reasonably calculat