Epstein Secrets

signed Assistant United States Attorney, hereby gives notice of its filing of its Second Supplemental Privilege Log. The index has been marked with Bates Numbers P-013970' thru P-014923. The documents referenced in the Second Supplemental Privilege Log will be delivered today to the Chambers of U.S.

l Privilege Log, the undersigned discovered an error on the Supplemental Privilege Log, that is, the last entry states that the last document bears Bates Numbers P-013956 thru P-013846. The correct Bates range for that document is P-013956 thru P-013969 [14 pages]. 1 EFTA00185428 Case 9:08-cv-8073

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Or

fficult since the items do not appear to be in date order or bates number order. 2. Each page of the Log contains six columns which consist of the Bates number, the date of the item, the sender, the recipient, the so-called "description" of the item, and the nature of the objection. The Log does not

iness on Tuesday, March 1, 2011 to supplement these objections, if necessary. The request is being made because we were not able to begin reviewing the Privilege Log for these objections until late Thursday afternoon, on February 24, 2011, because the arrival of the Privilege Log and documents was not communicate

face of Edwards' privilege log, Epstein has no way to determine whether the work product privileges claimed are fact or opinion work product. (See Bates . (Ex. F). It is essential that sufficient information be provided by Edwards to distinguish between fact and opinion work product because Epstein

rior to that time, although Epstein does not hereby waive the right to an in camera review with respect to any of the other materials referenced in the Privilege Log. Finally, the actual prejudice to and impact on Epstein by Edwards' willful and continued non-compliance is palpable. Epstein has been prejudiced