Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23 Bates Range Description Privilege(s) Asserted Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney (Villafafia) handwritten notes of interview Work product Investigative privilege Box #1 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena 6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-004717 Thru P-004722 File folder entitled "IGOR ZINOVIEV" containing attorney research regarding witness Work product Investigative privilege Box #1 P-004723 Thru P-004725 File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient Work Product Investigative privilege Box #1 P-004726 Thru P-004819 File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business litigative practices Work Product Investigative privilege Box #1 P-004820 Thru P-004959 Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships Work Product Investigative privilege Box #1 P-004960 Thru P-005059 File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005060 Thru P-005081 File folder bearing name of victim/witness containing correspondence with counsel for victim/witness, attorney witness outline with attorney handwritten notes, attorney handwritten notes regarding witness reports and case preparation Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Investigative privilege Page 7 of 23 EFTA00795271