A privilege log exhibit from the Giuffre v. Maxwell civil lawsuit documenting approximately 57 withheld communications between Virginia Giuffre's legal team and law enforcement regarding an ongoing criminal investigation of Jeffrey Epstein.
This is a privilege log entry submitted as Exhibit P in the Giuffre v. Maxwell defamation case (Case No. 1:15-cv-07433). It documents communications between Giuffre's attorneys—David Boies, Stan Pottinger, Sigrid McCawley, Paul Cassell, and Bradley Edwards—and an unnamed law enforcement entity concerning an active criminal investigation of Epstein. The plaintiff invoked 'public interest privilege' under Local Civil Rule 26.2(c) to withhold approximately 57 documents, arguing that disclosing details of ongoing criminal investigations would be overly burdensome and not proportional to the needs of the civil case.

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EXHIBIT P EFTA00028927
Log ID Email Sent Date Email From Email To CC Address It Subject Matter Type of Privilege Privilee Action Page Count Doc Type 153 Email and letter communications re law enforcement investigation The law enforcement entity. David Boles, Stan Pottinger, Sigrid McCawley, Paul Cassell, Brad Edwards The law enforcement entity, S David Boles, Stan Pottmger, Sigrid McCawley, Paul Cassell, Brad Edwards Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil Rule 26.2(c). This categorical entry is regarding correspondence re the currently ongoing criminal investigation of Defendant and others. Public Interest Withheld approx. 57 documents EFTA00028928