Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 03550-03574 09/09/2009 Attorneys at RRA Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03575-03588 10/19/2009 Kendall Coffey Bradley Edwards Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03589-03604 04/11/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03605-03606 10/16/2009 Attorneys at RRA Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03607-03610 10/16/2009 William Berger Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03611-03612 10/16/2009 Attorneys at RRA Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03613-03615 10/29/2009 Bradley Edwards Cara Holmes Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03616-03618 10/01/2009 Pat Diaz Bradley Edwards Providing New Witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03628-03637 09/15/2009 Jacquie Johnson Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and 100 EFTA00310147
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman MTES DATE TO FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03638-03641 09/08/2009 Bradley Edwards Paul Cassell Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08454 10/23/2010 Attorneys at RRA Mark Fistos Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08118-08123 10/23/2009 Attorneys at RRA Russell Adler Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08124-08156 10/23/2009 Attorneys at RRA Steven Jaffe Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01913-01914 06/15/2009 Susan K. Stirling Bradley J. Edwards Activity in case 9:08-cv-80893- Doe v. Epstein Motion to Dismiss — Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01918- 01919 04/15/2009 Attorneys at RRA Bradley J. Edwards Activity in case 9:08-cv-80893- Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights OS Doe v. Epstein Motion to Compel 01920-01924 05/20/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80994- KAM Jane Doe No. 6 v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 101 EFTA00310148
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Motion to Strike to the discovery of the admissible evidence; protected by privacy rights 01925 08/26/2009 Jacquie Johnson Bradley J. Edwards Adriana Surveillance/Interview Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01928-01929 08/03/2009 Jacquie Johnson Bradley J. Edwards Alfredo Rodriguez address work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01930 09/05/2009 Bradley J. Edwards William J. Berger Client info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01940 09/10/2009 Russell Adler Bradley J. Edwards Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01944-01952 04/10/2009 Russell Adler Bradley J. Edwards Epstein assets Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01969 05/04/2009 Susan K. Stirling Bradley J. Edwards Call from sources of information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01971-01972 05/13/2009 Attorneys at RRA Bradley J. Edwards Cassell Draft Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01973-01974 07/23/2009 Mike Fisten Bradley J. Edwards CMA vs. Epstein — new investigator info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 102 EFTA00310149
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman RATES DATE 12 FROM DESCRIPTION OBJECTION protected by privacy rights 01975 08/10/2009 Jacquie Johnson Bradley J. Edwards Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01976-01978 07/06/2009 Bradley J. Edwards Paul Cassell Conference Call Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01981-01982 04/01/2009 Bradley J. Edwards Russell Adler Conflict check for Brad Edwards files Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01990 05/14/2009 Bradley J. Edwards Paul Cassell Consolidation order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02000 09/03/2009 Jacquie Johnson Bradley J. Edwards Dates for Subpoena — Epstein's housekeepers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02001-02003 10/09/2009 Jacquie Johnson Bradley J. Edwards David Copperfield Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02009-2010 09/09/2009 Pasquale Diaz Bradley J. Edwards Deposition of Bill Riley Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02017-02018 05/18/2009 William J. Berger Bradley J. Edwards Doe v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 103 EFTA00310150
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE y_Q FROM DESCRIPTION OBJECTION 02023 05/14/2009 Attorneys at RRA Bradley J. Edwards Sid's deposition of Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02045.02046 09/04/2009 Attorneys at RRA Bradley J. Edwards E.W., L.M. Doe v. Epstein — Letter from Bob Critton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02049.02053 09/04/2009 Paul Cassell Bradley J. Edwards E.W., L.M. Doe v. Epstein — Letter from Bob Critton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02063-02064 05/19/2009 William J. Berger Bradley J. Edwards Epstein — Confirming AT&T Dial in Telephone Conference for Monday , 6/8/09 at 2:00 p.m. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02089.02090 09/17/2009 Paul Cassell Bradley J. Edwards Epstein hearing Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02091-02092 06/16/2009 Attorneys at RRA Bradley J. Edwards Epstein — Monthly Call in Telephone Conference Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02106-02108 04/29/2009 Susan K. Stirling Bradley J. Edwards Epstein — Telephone Conference Work product; attorney/client privilege; 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 calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02110.02111 09/15/2009 Bradley J. Jacquie Johnson Epstein - Cancelling depositions Work product; attorney/client privilege; 104 EFTA00310151
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman DATES DATE 12 FROM DESCRIPTION OBJECTION Edwards in New York for the following week irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02112.02116 09/10/2009 Bradley J. Edwards Jacquie Johnson Epstein — Yearbook picture of Epstein rape victims Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02117-02118 10/23/2009 Jacquie Johnson Bradley J. Edwards Epstein (AUSA) Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02119-02121 09/08/2009 Beth S. Williamson Bradley J. Edwards 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 02130-02137 05/26/2009 Susan K. Stirling Bradley J. Edwards Epstein cases- depositions in federal cases Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02138-02139 08/04/2009 Jacquie Johnson Bradley J. Edwards Epstein depo — New York Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02143-02146 09/28/2009 Jacquie Johnson Bradley J. Edwards Epstein Depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02229 05/05/2009 Paul Cassell Bradley J. Edwards Epstein Depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02236-02337 05/20/2009 Attorneys at RRA Bradley J. Edwards Epstein info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 105 EFTA00310152
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 02256-02257 07/22/2009 Jacquie Johnson Bradley J. Edwards 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 to the discovery of the admissible evidence; protected by privacy rights 02263-02265 07/23/2009 Attorneys at RRA Nora Batian 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 02266 07/30/2009 Jacquie Johnson Bradley J. Edwards Epstein — Video Deposition of S.K. in NY Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02273.02276 09/18/2009 Jacquie Johnson Bradley J. Edwards 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 02278-02279 07/23/2009 Priscila A. Nascimento Nora Batian 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 02284-02855 05/11/2009 Susan K. Stirling Bradley J. Edwards 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 01769 10/30/2009 Mike Fisten Bradley J. Edwards Barbara Berg info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 106 EFTA00310153
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES AT m FROM DESCRIPTION OBJECTION protected by privacy rights 01780 09/14/2009 Bradley J. Edwards William J. Berger Discussion of belief that Epstein is transferring assets to avoid judgments Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01787.01788 09/04/2009 Ken Jenne Bradley J. Edwards 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01799.01801 10/14/2009 Bradley J. Edwards Paul Cassell Activity in case 9:08-cv-80119- Moe v. Epstein Notification of ninety days expiring Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01804-01805 09/04/2009 Beth S. Williamson Bradley J. Edwards Activity in case 9:08-cv-80119- Doe v. Epstein — Order on motion for Medical Exam Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01806-01807 09/09/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- oe v. Epstein — Motion for protective order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01808-01809 09/10/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- Doe v. Epstein - Order on otion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01810-01816 09/09/2009 Attorneys at RRA Bradley J. Edwards Activity in case 9:08-cv-80119- Doe v. Epstein — Response to Motion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01817.01818 06/11/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- ■ Doe v. Epstein — Response to motion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 107 EFTA00310154
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE N FROM DESCRIPTION OBJECTION 01840-01841 07/16/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Order on Motion to Stay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01867-01868 09/28/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- KAM Doe v. Epstein — Notice (Other) Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03662-03663 08/10/2009 Attorneys at RRA Bradley J. Edwards Meeting with clients Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03664.03668 09/18/2009 Paul Cassell Bradley J. Edwards Litigation strategy and preparation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08166.08168 10/28/2009 Paul Cassell Bradley J. Edwards Weds filing Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08169-08170 08/06/2009 Bradley J. Edwards Jacquie Johnson Wexner deposition for 14th Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08190-08196 04/07/2009 Bradley J. Edwards Paul Cassell Motion to unseal/Motion to stay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08265-08300 09/04/2009 Attorneys at RRA Bradley J. Edwards Witness Information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08377-08378 10/02/2009 Bradley J. Paul Cassell Zorro Trust research info. Work product; attorney/client privilege; 108 EFTA00310155
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION L Edwards irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08381-08383 09/06/2009 Bradley J. Edwards Paul Cassell Epstein — complaint Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08384.08388 04/13/2009 Bradley J. Edwards Paul Cassell Epstein fraudulent transfer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08389-08397 05/14/2009 Bradley J. Edwards Paul Cassell Revisited sexual history memo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08401 07/22/2009 Bradley J. Edwards Paul Cassell Reply memo on asset transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08409-08410 08/01/2009 Bradley J. Edwards Cara L. Holmes Rodriguez Deposition Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08421 06/02/2009 Bradley J. Edwards William J. Berger Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08423-08425 10/09/2009 Bradley J. Edwards Mike Fisten Subpoena info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08426 08/10/2009 Bradley J. Edwards Mike Fisten Synopsis Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 109 EFTA00310156
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPagli OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08441-08446 10/05/2009 Attorneys at RRA William J. Berger Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03706-03718 08/05/2009 Bradley Edwards Paul Cassell Cf. Response to Motion to File Epstein Affidavit Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03737 08/25/2009 Bradley Edwards Cara Holmes Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03746.03753 08/02/2009 Bradley Edwards William Berger Computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02335-02338 05/08/2009 William Berger Bradley Edwards Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02360-02361 06/09/2009 Susan Stirling Bradley Edwards Hearing to Un-seal- Criminal Plea Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02368-02373 10/14/2009 Bradley Edwards Jacquie Johnson Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 110 EFTA00310157
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 02376.02392 10/14/2009 Mike Fisten Bradley Edwards Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02401.02410 05/08/2009 William Berger Bradley Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02414-02419 05/12/2009 Attorneys at RRA Bradley Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03669-03670 10/08/2009 Carolyn Edwards Bradley Edwards Epstein house arrest monitor Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02288.02289 05/26/2009 Susan Stirling Bradley Edwards Motion date Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02292-02293 05/19/2009 Dr. Lee (Expert) Bradley Edwards Pimp and His Game Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02304-02308 09/17/2009 Bradley Edwards Jacquie Johnson Forensics/Investigations Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02313-02316 07/01/2009 Bradley Edwards William Berger Confidential Agreement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 111 EFTA00310158
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Susan Stirling Bradley Edwards Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02173 09/04/2009 Attorneys at RRA Mike Fisten Epstein Juan Alessi Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02187 07/26/2009 Bradley Edwards Wayne Black Epstein matter Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02195.02197 09/17/2009 Jacquie Johnson Bradley Edwards Epstein Order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02199-02203 09/18/2009 Jacquie Johnson Bradley Edwards Epstein Order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02211-02214 07/01/2009 Paul Cassell Bradley Edwards Epstein v. State of Florida- Emergency Petition for Writ of Certiorari Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02224 07/28/2009 Jacquie Johnson Bradley Edwards Witness of Epstein rapes from Switzerland Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10787-10799 10/19/2009 Bradley Edwards Jacquie Johnson Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10901-10902 05/11/2009 Bradley Edwards William Berger RICO Enterprise Work product attorney/client privilege; 112 EFTA00310159
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10904.10905 05/11/2009 Attorneys at RRA Bradley Edwards RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10908-10909 05/11/2009 Attorneys at RRA Bradley Edwards RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10912-10913 05/11/2009 Attorneys at RRA Bradley Edwards RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10955-10963 06/01/2009 Bradley Edwards William Berger Plaintiffs Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10979-10981 06/03/2009 Bradley Edwards Wayne Black Serve Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11022.11025 06/26/2009 Bradley Edwards Wayne Black Info on 2 MC2 Workers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11036.11037 07/21/2009 Bradley Edwards Wayne Black Serve Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11039-11071 07/21/2009 Bradley Edwards Wayne Black Retainer from the Firm Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 113 EFTA00310160
Privilege bag— Dated 2-23-2011 Farmer, Jaffe, Weissine, Edwards. Fistos & Lehrman BATES DATE m FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 11083-11084 09/04/2009 Attorneys at RRA Bradley Edwards Witness info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11105-11110 09/09/2009 Jacquie Johnson Bradley Edwards Disseminate letter from Wexner attorney Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11137-11139 10/03/2009 Paul Cassell Bradley Edwards Zorro Trust research info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11143-11146 10/04/2009 William Berger Bradley Edwards 11/28 Discovery Cutoff Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11155-11156 10/18/2009 Attorneys at RRA Bradley Edwards New Property Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11175-11183 04/27/2009 Marc Nurik Bradley Edwards Epstein Case info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11196-11197 05/28/2009 Susan Stirling Bradley Edwards Jail Visitors Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11205.11207 05/28/2009 Paul Cassell Bradley Edwards Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 114 EFTA00310161
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 11215 06/01/2009 William Berger Bradley Edwards Activity in Case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11238-11239 06/03/2009 Wayne Black Bradley Edwards Depo Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11246-11247 06/22/2009 Wayne Black Bradley Edwards Epstein Article Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11251-11254 06/23/2009 Wayne Black Bradley Edwards Info on 2 MC2 workers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11267-11268 06/30/2009 William Berger Bradley Edwards Witness List revised Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11282.11315 07/18/2009 Wayne Black Bradley Edwards Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11326-11331 08/03/2009 Jacquie Johnson Bradley Edwards Donald Trump depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11337-11339 08/04/2009 Mike Fisten Bradley Edwards Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 115 EFTA00310162
Privilege Log - Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 11359-11362 08/10/2009 Jacquie Johnson Bradley Edwards Epstein depos Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11366.11371 08/11/2009 Jacquie Johnson Bradley Edwards Trump depo info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11377-11379 08/12/2009 Jacquie Johnson Bradley Edwards Issuing Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11390-11395 08/17/2009 Jacquie Johnson Bradley Edwards Witness depos Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11400-11415 08/18/2009 Jacquie Johnson Bradley Edwards Subpoenas for pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11420-11426 08/24/2009 Attorneys at RRA Bradley Edwards Serving Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11428-11429 08/26/2009 Attorneys at RRA Bradley Edwards Witness info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11568 10/07/2009 Paul Cassell Bradley Edwards Meeting with Leslie Wexner Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11587 10/23/2009 Paul Cassell Bradley Edwards Visoski Depo Work product; attorney/client privilege; 116 EFTA00310163
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11861.11865 10/23/2009 Attorneys at RRA Bradley Edwards Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11870-11871 08/24/2009 Attorneys at RRA Bradley Edwards 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 11874 08/24/2009 Jacquie Johnson Bradley Edwards Confidential info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11876 08/24/2009 Attorneys at RRA Ken Jenne Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11967.11972 10/29/2009 Cara Holmes Jacquie Johnson Subpoenas for Epstein's Attorneys Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08072-08075 07/22/2009 Paul Cassell Bradley Edwards Total counts fo= Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08090-08091 10/05/2009 William Berger Bradley Edwards Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08114.08117 08/18/2009 Pat Diaz Bradley Edwards Updated Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 117 EFTA00310164
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08157-08159 06/03/2009 Carla Martinez Bradley Edwards Vanity Fair Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08499-08501 08/24/2009 Attorneys at RRA Bradley Edwards Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10063-10068 08/03/2009 Bradley Edwards Mike Fisten Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10090-10091 08/31/2009 Attorneys at RRA Jacquie Johnson Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10103-10104 08/27/2009 Attorneys at RRA Ken Jenne Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10106-10137 08/24/2009 Attorneys at RRA Ken Jenne Meetings/ Confidential Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 12569 07/30/2009 Carl Linder Bradley Edwards Epstein Sex Abuse Litigation Forum Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15827-15837 07/22/2009 Jacquie Johnson Bradley Edwards Retainer for Investigator Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 118 EFTA00310165
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 15820-15822 10/29/2009 Jacquie Johnson Cara Holmes Subpoenas for Epstein's Attorneys Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15401-15412 09/09/2009 Jacquie Johnson Bradley Edwards Disseminate the letter from wexner any Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15356-15359 08/26/2009 Attorneys at RRA Bradley Edwards Witness info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 14934-14950 07/22/2009 Jacquie Johnson Bradley Edwards Investigator Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 13413.13414 08/06/2009 Denis Kleinfeld Bradley Edwards Epstein information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 13908-13911 08/24/2009 Attorneys at RRA Mike Fisten Meeting info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10595-10597 09/29/2009 Bradley Edwards Jacquie Johnson Subpoena for Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10621-10624 10/02/2009 Bradley Edwards Jacquie Johnson Meeting with Wexner atty Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 119 EFTA00310166
Privilege Log- Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 10633-10638 10/05/2009 Bradley Edwards William Berger Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10681-10692 10/07/2009 Jacquie Johnson Mike Fisten Depositions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10777-10786 10/16/2009 Bradley Edwards Paul Cassell New Evidence of Epstein Fraudulent Transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04094.04100 04/07/2009 Bradley Edwards Paul Cassell Draft Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02915 10/03/2009 Attorneys at RRA Mike Fisten Finances Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02971 10/14/2009 Jacquie Johnson Bradley Edwards Larry Visoski depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02976 09/09/2009 Jacquie Johnson Bradley Edwards Disseminate the letter from wexner Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02995 06/24/2009 Bradley Edwards Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10172-10178 08/12/2009 Bradley Edwards Jacquie Johnson Trump Depo Work product; attorney/client privilege; 120 EFTA00310167
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10193 08/11/2009 Bradley Edwards Jacquie Johnson Trump Depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10255 09/09/2009 Bradley Edwards William Berger Depo of Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10259-10263 09/09/2009 Attorneys of RRA Jacquie Johnson Cooperfield Service Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03876-03877 10/26/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03879.03884 07/13/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03886.03891 07/13/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy ri hts 03905.03920 09/08/2009 William Berger Bradley Edwards Doe v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03937 08/17/2009 Carolyn Edwards Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 121 EFTA00310168
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 04005-04011 05/13/2009 Bradley Edwards William Berger Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04070-04093 04/07/2009 Bradley Edwards Paul Cassell Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03754 07/08/2009 Paul Cassell Bradley Edwards Conference Call Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03848-03858 09/09/2009 Bradley Edwards Jacquie Johnson Cooperfield Service Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03642-03643 09/04/2009 Paul Cassell Bradley Edwards 1. Accounts/ 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03657-03661 09/04/2009 Attorneys at RRA Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02475 06/15/2009 Susan Stirling Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02494-02515 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; 122 EFTA00310169
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE m FROM DESCRIPTION OBJECTION protected by privacy rights 02520-02543 06/06/2009 Bradley Edwards Paul Cassell Memo of Assest Transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02560-02565 07/31/2009 Bradley Edwards Jacquie Johnson Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02568-02570 10/13/2009 Jacquie Johnson Bradley Edwards New Times Article Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02578-02583 05/28/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02619-02622 09/09/2009 Jacquie Johnson Bradley Edwards New client Retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02633-02646 05/01/2009 Paul Cassell Bradley Edwards Response to Motion to Consolidate + Cassell strategy Memo for Jay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07959.07964 09/24/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 123 EFTA00310170
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 07967.07975 09/22/2009 Jacquie Johnson Mike Fisten Subpoena on Epstein case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07979-08000 08/18/2009 Bradley Edwards Jacquie Johnson Subpoenas for Pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07735.07736 07/24/2009 Bradley Edwards Jacquie Johnson Releases for therapist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07643-07645 09/09/2009 Bradley Edwards Jacquie Johnson New client Retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07698-07706 09/06/2009 Paul Cassell Bradley Edwards Answer to the Complaint Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07620-07632 08/14/2009 Jacquie Johnson Bradley Edwards Review of "Notice of Taking Depo — RC — Bear Sterns" Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07635-07636 10/15/2009 Mike Fisten Bradley Edwards Questions from forensic accountant detecting Epstein fraudulent transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07617-07618 07/13/2009 Paul Cassell Bradley Edwards Epstein strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07550-07589 10/30/2009 Bradley Edwards Paul Cassell Motion to Supplement with the Work product; attorney/client privilege; 124 EFTA00310171
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07616 07/22/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07530-07549 06/11/2009 Bradley Edwards Susan Stirling Overtime Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07470-07507 07/09/2009 Paul Cassell Bradley Edwards Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07447.07469 10/13/2009 Attorneys at RRA Russell Adler New Times Article on epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07444-07446 05/01/2009 Bradley Edwards Paul Cassell Response to Motion to Consolidate + Cassell Strategy Memo for Jay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07440 10/18/2009 Attorneys at RRA Bradley Edwards New Trump Property Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07436 04/11/2009 Russell Adler Bradley Edwards New cases Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 125 EFTA00310172
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman DATES DATE 12 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 07424-07431 09/26/2009 Bradley Edwards Paul Cassell Need Depo Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07412-07423 04/08/2009 Bradley Edwards Paul Cassell Draft Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07403-07411 04/08/2009 Paul Cassell Bradley Edwards Draft Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07394.07402 07/10/2009 Bradley Edwards Paul Cassell Multiple 2255 Counts Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07386-07392 05/28/2009 William Berger Bradley Edwards Motion to Unseal Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07378-07385 04/07/2009 Bradley Edwards Paul Cassell Motion to Unseal Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07370-07377 04/07/2009 Paul Cassell Bradley Edwards Motion to Unseal Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07354-07369 10/28/2009 Beth Williamson Bradley Edwards Motion to Protect e d depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 126 EFTA00310173
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE 12 FROM DESCRIPTION OBJECTION protected by privacy rights 07346 10/28/2009 Beth Williamson Bradley Edwards Motion to protect 2nd depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07337 10/28/2009 Bradley Edwards Jacquie Johnson Motion to protect 2nd depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07328 10/28/2009 Bradley Edwards Beth Williamson Motion to protect e d depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07319 10/28/2009 Bradley Edwards Jacquie Johnson Motion to protect r d depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07313-07318 04/10/2009 Paul Cassell Bradley Edwards Motion to Compel — Photograph Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07287.07301 07/08/2009 Bradley Edwards Paul Cassell Motion to Compel — File this week? Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07252-07278 09/08/2009 Bradley Edwards Paul Cassell Motion for IME + Accountant Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07247-07251 09/08/2009 Paul Cassell Bradley Edwards Motion for IME + Accountant Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 127 EFTA00310174
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PATES DATE 1.Q FROM DESCRIPTION OBJECTION 07230.07233 06/08/2009 Paul Cassell Bradley Edwards Memo on Asset Transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07157-07158 09/29/2009 Russell Adler Bradley Edwards RE: Mark Schwartz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07128-07141 07/08/2009 Paul Cassell Bradley Edwards Motion for bond asset transfer and memo final Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07094-07098 09/14/2009 Paul Cassell Bradley Edwards Letter to Critton RE: Motions to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07025.07027 10/29/2009 Bradley Edwards Paul Cassell v. Epstein — Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07099-07106 09/14/2009 Bradley Edwards Paul Cassell Letter to Critton RE: Motions to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07071-07078 07/23/2009 Paul Cassell Bradley Edwards Ills Son's B-day Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07066-07070 07/23/2009 Bradley Edwards Paul Cassell L.M.'s Son's B-day Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07015.07016 10/13/2009 Bradley Edwards Paul Cassell Evidence of Asset transfers Work product; attorney/client privilege; 128 EFTA00310175
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DAT€ TO FROM DESC • IPTION OBJECTION and/or liquidations irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07019-07024 10/29/2009 Bradley Edwards Paul Cassell v. Epstein — I'm on it Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06837-06839 04/08/2009 Beth Williamson Bradley Edwards Jane Doe change of address Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06826-06836 04/08/2009 Bradley Edwards Beth Williamson Jane Doe change of address Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06823-06825 04/08/2009 Bradley Edwards Beth Williamson Jane Doe change of address Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06813-06816 07/02/2009 Paul Cassell Bradley Edwards Doe v. Epstein Motion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06808-06810 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi schemer' Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06804-06805 09/13/2009 Paul Cassell Bradley Edwards "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi schemer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06794 10/23/2009 Mike Fisten Bradley Edwards Interesting Web Site Work product; attorney/client privilege; 129 EFTA00310176
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman DATES DATE 12 FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06800-06803 09/06/2009 Paul Cassell Bradley Edwards RE: 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06761-06762 08/19/2009 Attorneys at RRA Paul Cassell IME Rules Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06767-06769 09/10/2009 Bradley Edwards Jacquie Johnson IME's Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06782.06787 04/10/2009 Paul Cassell Bradley Edwards Confidential Detailed Strategy Memo on Asset Protection Issues Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06744-06747 05/01/2009 Paul Cassell Bradley Edwards Depo of Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06736-06739 05/01/2009 Bradley Edwards Paul Cassell Asset Protection Issue Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06709-06710 10/14/2009 Bradley Edwards Mike Fisten Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 130 EFTA00310177
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman DATES DATE 12 FROM DESCRIPTION OBJECTION 06691-06696 07/09/2009 Bradley Edwards Paul Cassell How many 2255 claims? Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06683.06686 07/08/2009 Paul Cassell Bradley Edwards Hiding Assets Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06654 07/24/2009 Paul Cassell Bradley Edwards Secretary Contact info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06599.06600 07/08/2009 Bradley Edwards Paul Cassell Hiding Assets Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06574-06590 04/07/2009 Paul Cassell Bradley Edwards Motion to Unseal Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06567.06570 07/09/2009 Bradley Edwards Paul Cassell Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06558-06561 07/09/2009 Paul Cassell Bradley Edwards Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 131 EFTA00310178
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissine, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 06554-06557 05/14/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06549.06553 05/14/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06540-06541 09/21/2009 Bradley Edwards Mike Fisten Info on Maxwell Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06537 10/23/2009 Bradley Edwards Paul Cassell Doe v. Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06529-06530 10/23/2009 Paul Cassell Bradley Edwards Doe v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06496.06505 10/20/2009 Bradley Edwards Paul Cassell Visoski depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06177-06181 09/25/2009 William Berger Bradley Edwards Financial discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06149-06153 07/10/2009 Paul Cassell Bradley Edwards Federal First Amendment Complaint Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 132 EFTA00310179
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing. Edwards, Fistos & Lehrman BATES DATE LQ FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Macys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06113-06117 07/14/2009 Bradley Edwards Richard Wolfe Facebook/Myspace Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06106-06112 05/19/2009 Amy Swan William Berger Expert Witness Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06091 08/04/2009 William Berger Paul Cassell EW and LM v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06001-06011 07/18/2009 Paul Cassell Bradley Edwards Epstein's Address and Position of Critton on Motion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05996 04/08/2009 Bradley Edwards Beth Williamson Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05998-06000 09/17/2009 Jacquie Johnson Bradley Edwards Epstein: Forensics/Investigations INVOICE Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05992 04/19/2009 Bradley Edwards Marc Nurik Litigation Strategy Work product; attorney/client privilege; 133 EFTA00310180
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05968 10/17/2009 Bradley Edwards William Berger Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05944-05947 05/01/2009 William Berger Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05931-05932 07/27/2009 Amy Swan Bradley Edwards Client's Cell Phone Number Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05919-05920 07/28/2009 Bradley Edwards Amy Swan Client's Cell Phone Number Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05915 04/22/2009 Bradley Edwards Marc Nurik Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05911 05/28/2009 Bradley Edwards William Berger Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 134 EFTA00310181
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES MIL TO FROM DESCRIPTION OBJECTION 05890 07/27/2009 Bradley Edwards Amy Swan Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05893-05894 07/27/2009 Bradley Edwards Amy Swan Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05898-05899 07/28/2009 Bradley Edwards Amy Swan Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05885 09/15/2009 Bradley Edwards Jacquie Johnson Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05874.05879 07/23/2009 Bradley Edwards Jacquie Johnson Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05868 08/03/2009 Bradley Edwards Ken Jenne Epstein Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05865 09/10/2009 Bradley Edwards Jacquie Johnson Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05860-05861 09/10/2009 Bradley Edwards Maribel Matiska Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 135 EFTA00310182
Privilege Log — Dated 2-23-2011 Farmer. Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE 12 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05845 07/24/2009 Bradley Edwards Ken Jenne Plane Tail Numbers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05811 06/09/2009 Bradley Edwards Susan Stirling Witness Numbers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05813 08/15/2009 Bradley Edwards Ken Jenne Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05748.05749 08/11/2009 Bradley Edwards Jacquie Johnson Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05711 05/11/2009 Attorneys at RRA Bradley Edwards Subpoena Clinton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05701.05704 04/20/2009 Bradley Edwards Russell Adler Epstein strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05687 08/21/2009 Bradley Edwards Marc Nurik Alfredo Rodriguez Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05690-05691 05/11/2009 Bradley Edwards Susan Stirling Motion to Unseal Work product; attorney/client privilege; 136 EFTA00310183
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05680-05682 05/11/2009 Bradley Edwards William Berger Subpoena Clinton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05676 08/24/2009 Attorneys at RRA Mike Fisten Topics for Meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05648 07/23/2009 Attorneys at RRA Gary Farmer Assemble Epstein Litigation meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05629 08/03/2009 Bradley Edwards Mike Fisten Law Enforcement cannot release juvenile reports Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05621-05622 09/18/2009 Amy Swan Bradley Edwards Preparing Motion to take an IME of Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05610-05612 04/27/2009 Susan Stirling Bradley Edwards Request for Copies Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05588-05590 08/24/2009 Attorneys at RRA Bradley Edwards Travel restrictions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 137 EFTA00310184
Privilege Log — Dated 2-23-2011 Farmer. Jaffe, Weissing, Edwards, Fistos & Lehrman BATES QAI1 IQ FROM DESCRIPTION OBJECTION 05575-05576 08/21/2009 Marc Nurik Bradley Edwards Alfredo Rodriguez Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05582 09/11/2009 Bradley Edwards Mike Fisten Epstein strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05569-05570 08/17/2009 Marc Nurik Bradley Edwards Legal Opinion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05556-05558 08/14/2009 Attorneys at RRA Bradley Edwards Communication with legal expert Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05537 07/30/2009 Jacquie Johnson Bradley Edwards No objections from defense counsel regarding depo for Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05534 07/24/2009 Ken Jenne Bradley Edwards Flight logs for Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05518 07/22/2009 Attorneys at RRA Bradley Edwards Assemble Epstein Litigation meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05512-05513 07/23/2009 Priscila Nascimento Nora Batian Assemble Epstein Litigation meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 138 EFTA00310185
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman DATES DATE lig FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05502-05507 07/22/2009 Jacquie Johnson Bradley Edwards Wayne Black's email Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05475 04/21/2009 Marc Nurik Bradley Edwards Call with Chris Hanson from dateline Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05471-05472 08/14/2009 Marc Nurik William Berger Legal expert regarding legal issue Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05447 08/14/2009 Marc Nurik William Berger Communication with legal expert Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05420-05423 05/20/2009 William Berger Bradley Edwards Research on cases saying a judge can postpone one party's depo until the other is completed Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05409-05412 08/17/2009 Bradley Edwards Marc Nurik Legal opinion regarding discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 139 EFTA00310186
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM PESCRIPTION OBJECTION 05399 10/17/2009 William Berger Bradley Edwards Proposal for settlement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05399 10/17/2009 William Berger Bradley Edwards Proposal for settlement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05271-05272 07/22/2009 Bradley Edwards Jacquie Johnson Depo Dates to take SR, LM, and CW Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05259-05260 07/22/2009 Bradley Edwards Jacquie Johnson Investigator retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05238 07/14/2009 Bradley Edwards William Berger File a request to produce Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05240-05241 08/24/2009 Attorneys at RRA Ken Jenne Judge's order on the Epstein probation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05197-05199 08/24/2009 Attorneys at RRA Ken Jenne Michael Reiter info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 140 EFTA00310187
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 05155-05156 04/20/2009 Russell Adler Bradley Edwards Set Epstein's depo duces tecum Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05159-05160 05/28/2009 William Berger Bradley Edwards Right to move to reconsider all rulings Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05149-05150 05/27/2009 Susan Stirling Bradley Edwards Epstein filed a motion to continue the trial Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05153 08/24/2009 Bradley Edwards Mike Fisten Epstein traveling Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05146-05147 05/26/2009 Paul Cassell Bradley Edwards The response to the motion to continue is due 6/8 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05137-05144 05/20/2009 Attorneys at RRA Russell Adler Epstein litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05133-05136 05/11/2009 William Berger Bradley Edwards Subpoena Clinton and others on Sid Garcia's witness list Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01749.01751 10/28/2009 Bradley Edwards Phaedra Xanthos Final affidavit from forensic accountant Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 141 EFTA00310188
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PATES DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05125-05132 05/05/2009 William Berger Bradley Edwards Response to motion to compel all the sex information of his clients Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05115-05117 04/27/2009 Bradley Edwards Susan Stirling Epstein depos Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01699 09/15/2009 Jacquie Johnson Bradley Edwards depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05120-05121 05/04/2009 William Berger Bradley Edwards Reporter asking how the depo of Epstein went Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05095.05098 07/01/2009 Bradley Edwards Paul Cassell Epstein v. State of Florida — Emergency Petition for Writ of Certiorari; Emergency Motion to Review Denial of Stay Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01694 10/17/2009 Jacquie Johnson Bradley Edwards PFS Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05066-05067 05/06/2009 Marc Nurik William Berger Epstein sealed records and TV Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 142 EFTA00310189
Privilege Log — Dated 2-23-2011 Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman BATES DATE m FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05054-05065 08/18/2009 Attorneys at RRA Mike Fisten Epstein Potential witnesses Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05049-05053 08/18/2009 Mike Fisten Bradley Edwards Subpoenas for potential witnesses Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04957-04964 09/04/2009 Bradley Edwards Scott Goldstein Juan Alessi statement and burglary report Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04952-04953 10/28/2009 Attorneys at RRA Paul Cassell Epstein injunction filing — accountant affidavit will be sent Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04955-04956 09/03/2009 Attorneys at RRA Bradley Edwards Epstein Invoice Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04916-04920 09/11/2009 Elizabeth Villar Bradley Edwards Updates on # of victims, billing amounts, etc. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04899 09/10/2009 Bradley Edwards Jacquie Johnson Epstein Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 143 EFTA00310190
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 04893-04896 09/10/2009 Jacquie Johnson Bradley Edwards Epstein Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04890 09/10/2009 Jacquie Johnson Bradley Edwards Epstein Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04884-04885 09/10/2009 Bradley Edwards Jacquie Johnson Epstein Discovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01469 07/17/2009 Ken Jenne Bradley Edwards Discussions about the Epstein case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04745.04747 08/04/2009 Bradley Edwards Jacquie Johnson Epstein depo in New York Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04738.04744 08/25/2009 Bradley Edwards Paul Cassell Hearing regarding the Epstein computers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04660 10/22/2009 Bradley Edwards Marc Nurik Epstein AUSA — Attorneys Fees Work product; attorney/client privilege; irrelevant and not reasonably cakulated to lead to the discovery of the admissible evidence; protected by privacy rights 04642.04646 09/11/2009 Bradley Edwards Beth Williamson Discussions about Brad's recovery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 144 EFTA00310191
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 04607-04617 09/11/2009 Jacquie Johnson Bradley Edwards Holding Fed Subs until we get response on form Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04526-04535 10/17/2009 Bradley Edwards Paul Cassell Two ideas regarding strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04488-04490 07/18/2009 Bradley Edwards Paul Cassell Taking the 5th Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01362 09/11/2009 Elizabeth Villar Bradley Edwards Getting the forensic aspect off the ground —epstein's asset transfers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04481-04487 08/18/2009 Paul Cassell Bradley Edwards Epstein Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05465-05467 06/26/2009 Wayne Black Bradley Edwards Subpoenas for trial Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05470 07/11/2009 Bradley Edwards Wayne Black Flight Logs Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05496-05497 08/10/2009 Bradley Edwards Alfredo Phone Numbers Work product; attorney/client privilege; 145 EFTA00310192
Privilege Log — Dated 2-23-2011 Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman !SATES DATE 12 FROM DESCRIPTION OBJECTION Rodriguez irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05501 07/21/2009 Wayne Black Bradley Edwards Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05524-05533 07/23/2009 Wayne Black Bradley Edwards Addresses for people involved in the case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2O09 Carolyn Edwards Bradley Edwards All depos in jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05635 10/22/2009 Pat Diaz Bradley Edwards New developments that require your expertise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights') 146 EFTA00310193
Privilege Log — Dated 2-23-2011 Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman BATES DAM TO FROM DESCRIPTION OBJECTION 05640 10/29/2009 Pat 0iaz Bradley Edwards New Epstein victim Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05652-05653 04/01/2009 Bradley Edwards Carolyn Edwards personal discussion Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05671 10/22/2009 Bradley Edwards Pat Diaz Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05696 05/11/2009 Bradley Edwards Wayne Black Phone number for one of the other girls on the list of prospective clients Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05815-05816 04/01/2009 Carolyn Edwards Bradley Edwards Taking the depos of everyone Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05820-05821 07/23/2009 Bradley Edwards Wayne Black Dates for depos of all witnesses in the case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 147 EFTA00310194
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE i2 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05824-05825 07/23/2009 Bradley Edwards Wayne Black Paula Heil Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05828-05829 07/23/2009 Bradley Edwards Wayne Black Dates for depos of all witnesses in the case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05833-05835 07/23/2009 Bradley Edwards Wayne Black FBI has original flight logs and they interviewed pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05839-05841 07/23/2009 Bradley Edwards Wayne Black Copies of the flight logs Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05869-05870 04/01/2009 Carolyn Edwards Bradley Edwards Personal convo between Brad and Mom Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05913-05914 04/01/2009 Carolyn Edwards Bradley Edwards Personal convo between Brad and Mom Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 148 EFTA00310195
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing. Edwards. Fistos & Lehrman BATES DATE Lq FROM DESCRIPTION OBJECTION 05995 04/01/2009 Bradley Edwards Carolyn Edwards Third party subpoenas for Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06513-06523 06/15/2009 Bradley Edwards Wayne Black Ghisella Maxwell info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06699-06701 06/17/2009 Wayne Black Bradley Edwards Epstein litigation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07079-07089 09/03/2009 Bradley Edwards Pat Diaz Discussion about girls involved in the case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07437-07439 10/19/2009 Paul Cassell Ronald Wise New evidence of Epstein Fraudulent transfers + Affidavit from you Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07936-07958 04/28/2009 Earleen Cote Bradley Edwards Cases against mansion nightclub Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08006-08011 06/03/2009 Bradley Edwards Wayne Black Getting addresses for people for us to serve subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11186.11187 08/19/2009 Bradley Edwards Bradley Edwards Plaintiffs Witness List Work product; attorney/client privilege; 149 EFTA00310196
Privilege Log— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DAT€ 11Q FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 26479-26481 08/19/2009 Attorneys at RRA Ken Jenne Assistance on the Epstein Case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 27155-27159 10/23/2009 Attorneys at RRA Steven Jaffe PACER entries Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 26604-26605 10/27/2009 Phaedra Xanthos Ken Jenne Political Contributions/advertisement for the rental on Little St. James Island Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 26570 08/13/2009 Scott Rothstein Marc Nurik Discussions about Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 04954 10/28/2009 Attorneys at RRA Jacquie Johnson Creation of another Doe file Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06665-06670 08/12/2009 Shawn Gilbert Bradley Edwards Epstein Costs Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06675-06676 08/26/2009 Shawn Gilbert Bradley Edwards Personal convo in regards to moving offices Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 150 EFTA00310197
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 06679-06682 08/26/2009 Bradley Edwards Shawn Gilbert Personal convo in regards to moving offices Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07590-07594 05/13/2009 Shawn Gilbert Bradley Edwards Office information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08451-08453 08/17/2009 Bradley Edwards Pat Diaz Updated Witness List Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08455-08456 06/03/2009 Carla Martinez Bradley Edwards Vanity Fair Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08466.08479 08/26/2009 Attorneys at RRA Bradley Edwards Witness info that we need to use Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01767 07/06/2009 Wayne Black Bradley Edwards Info on a guy going to victim's boyfriends house Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08379 06/06/2009 Bradley Edwards Wayne Black Info on Former FHP trooper subcontracted by Riley Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08399 07/23/2009 Bradley Edwards Paul Cassell Epstein affidavit to the reply memo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 151 EFTA00310198
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman RATES DATE IQ FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 08406 10/30/2009 Attorneys at RRA Russell Adler Flying epstein rape survivor to St. Louis to see expert Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05697 08/19/2009 Bradley Edwards Mike Fisten Meeting with client Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20330.20334 08/24/2009 Bradley Edwards Pat Roberts Serving Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20327.20329 10/17/2009 Attorneys at RRA Mike Fisten Property purchased by Epstein in Palm Beach Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20100-20102 08/24/2009 Attorneys at RRA Bradley Edwards Epstein's arrival at his building Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20283-20326 10/14/2009 Attorneys at RRA Mike Fisten Research regarding Mr. Visoski and questions to consider during the depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20092.20099 08/24/2009 Attorneys at RRA Ken Jenne Epstein travel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 152 EFTA00310199
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATA TO FROM DESCRIPTION OBJECTION 20085-20091 10/15/2009 Bradley Edwards Mike Fisten Questions from accountant Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19996-20084 10/14/2009 Attorneys at RRA Mike Fisten Visoski Research and Questions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20217-20218 08/04/2009 Bradley Edwards Mike Fisten Info on Copperfield Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20213-20216 08/03/2009 Attorneys at RRA Ken Jenne Info on Copperfield Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20211.20212 08/03/2009 Mike Fisten Bradley Edwards Pilots depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20207-20210 08/10/2009 Jacquie Johnson Bradley Edwards List of witness Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20201-20204 08/24/2009 Attorneys at RRA Bradley Edwards Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 153 EFTA00310200
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 20193-20200 08/24/2009 Attorneys at RRA Bradley Edwards Proof of him being out of FL — Violation of the agreement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19982-19985 09/03/2009 Jacquie Johnson Mike Fisten Dave Rogers depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19988 10/07/2009 Jacquie Johnson Mike Fisten Depositions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19971-19981 08/24/2009 Attorneys at RRA Mike Fisten Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19969-19970 08/18/2009 Bradley Edwards Mike Fisten Subpoenas for Pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 19962-19968 08/03/2009 Bradley Edwards Mike Fisten Working with the FBI to get some info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20190-20192 08/24/2009 Pat Roberts Bradley Edwards Personal emails regarding Brad's surgery Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20187-20189 08/24/2009 Attorneys at RRA Ken Jenne Epstein travel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 154 EFTA00310201
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman DATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 19959-19961 07/24/2009 Attorneys at RRA Bradley Edwards Flight logs for Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 00156.00157 07/09/2009 Bradley Edwards Paul Cassell 2255 Problem Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15366-15367 09/04/2009 Attorneys at RRA Bradley Edwards Witness info that we need to use Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01003-01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01013-01014 10/29/2009 Bradley Edwards Cara Holmes Subpoenaing Epstein's attorneys for their fees and accompanying documents Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01042 07/22/2009 Marc Nurik Bradley Edwards New Info that our investigators obtained from current FBI agents Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03133-03134 06/09/2009 Josh Roberts Bradley Edwards Personal conversation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 155 EFTA00310202
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 03129-03130 06/09/2009 Josh Roberts Bradley Edwards Personal conversation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03119.03121 06/09/2009 Bradley Edwards Josh Roberts Personal conversation Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02593-02594 05/13/2009 T. Edwards (wife) Bradley Edwards Regarding personal information. Privileged document- irrelevant and not calculated to lead to discovery of admissible evidence, privacy rights of parties involved, spouse privilege 18877-18879 09/10/209 Marc Nurik Bradley Edwards Concerning the names of potential witnesses and the issuance of subpoena's for them. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18344-18347 08/24/2009 Bradley Edwards Mike Fisten Investigative information and techniques on the Epstein case are discussed. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 156 EFTA00310203
Privilege UDR— Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 18339-18340 08/24/2009 Ken Jenne Bradley Edwards Investigative information and techniques on the Epstein case are discussed. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18341-18343 08/24/2009 Mike Fisten Bradley Edwards Investigative information and techniques on the Epstein case are discussed. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18853-18854 09/10/2009 Bradley Edwards Jacquie Johnson Concerning the names of potential witnesses and the issuance of subpoena's for them. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18337-18338 08/03/2009 Bradley Edwards Mike Fisten Investigative information and techniques on the Epstein case are discussed. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18306 10/16/2009 Pat Roberts Ken Jenne List of future depo's in Epstein case and names of potential witnesses. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18307 10/17/2009 Mike Fisten Bradley Edwards Investigative Discussion re: finding of Epstein Assets. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 157 EFTA00310204
Privilege Log — Dated 2-23-2011 Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman BATES DATE 11Q FROM DESCRIPTION OBJECTION 18308.18309 10/18/2006 Mike Fisten Bradley Edwards Investigative Discussion re: finding of Epstein Assets. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18188-18189 09/04/2009 Mike Fisten Bradley Edwards Investigative Discussion re: finding of Epstein witnesses and names of potential witnesses. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18184-18185 08/26/2009 Mike Fisten Bradley Edwards Investigative Discussion re: finding of Epstein witnesses and names of potential witnesses. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18186-18187 08/31/2009 Bradley Edwards Jacquie Johnson Discussion of potential witnesses and the process of subpoena for depo's. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 18180-18183 08/24/2009 Bradley Edwards Mike Fisten Investigative Discussion re: finding of Epstein witnesses and names of potential witnesses. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05256-05257 07/21/2009 Bradley Edwards Wayne Black Investigative Discussion re: strategy of case. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 158 EFTA00310205
Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman RATES DATE TO FROM DESCRIPTION OBJECTION 05253 08/24/2009 Bradley Edwards Wayne Black Investigative Discussion re: strategy of case. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05279-05280 08/24/2009 Bradley Edwards Pat Roberts Investigative Discussion re: strategy of case. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05315-05318 07/26/2009 Bradley Edwards Wayne Black Investigative Discussion re: strategy of case. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05209-05211 06/26/2009 Bradley Edwards Wayne Black Investigative Discussion re: strategy of case. Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 159 EFTA00310206







































