1417.pdf

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Filing# 80632955 E-Filed 11/09/2018 04:12:00 PM 
JEFFREY EPSTEIN, 
Plaintiff/Counter-Defendant, 
V. 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, individually, 
Defendants/Counter-Plaintiff. 
_________________ 
./ 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH filDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
Case No. 50-2009CA040800XXXXMBAG 
COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION 
FOR AN IN CAMERA INSPECTION OF 30 E-MAILS 
Counter-Defendant, Jeffrey Epstein ("Epstein"), moves 1 this Court for an in camera 
inspection of 302 e-mails identified on Epstein's March 2, 2018 Clerk's Trial Exhibit List and to 
find that no privilege applies to them. These e-mails directly contradict Edwards' sworn testimony 
and repeated misrepresentations before this Court. Edwards, an officer of this Court, previously 
disclosed all of these e-mails to another adversary, thereby eliminating any privilege or work 
product protection that ever could have been applicable to them, and then improperly withheld them 
from discovery by Epstein and what appears to be a deliberate concealment of them in a non-
compliant privilege log, previously ruled by the Court to be legally deficient, based on false claims 
1The original Motion was filed on March 5, 2018, but not ruled on before the March 9, 2018, 
appellate court stay. The parties further agreed to stay hearings on pending motions until mediation was 
completed. Additionally, The Honorable Donald W. Hafele's stated interest in first allowing the Show 
Cause proceedings before The Honorable Raymond B. Ray, United States Bankruptcy Court for the 
Southern District of Florida, to occur before this Court proceeded with this review. With trial 
approaching on December 4, 2018, this Court instructed Epstein to file this Motion and deliver the 
accompanying sealed Memorandum by November 9, 2018. Edwards was instructed to deliver a 
response sealed Memorandum by November 16, 2018. 
2Epstein has reduced the origi...

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of irrelevancy and attorney-client privilege and claims of work product that could no longer 
possibly be applicable under Florida law. 3 Following this Court's in camera review, Epstein seeks 
a ruling from this Court that these 30 e-mails must be unsealed and properly included on Epstein's 
Exhibit List. 
PREFACE 
The Bankruptcy Court, The Honorable Raymond B. Ray, entered an Order on October 29, 
2018 (Exhibit 1), discharging the Order to Show Cause against Epstein in relation to the "disc" on 
which the e-mails were discovered. As of the time of this submission, Judge Ray has not yet 
determined whether Fowler White, Epstein's counsel at the time of the November 2010 Agreed 
Order (and from whom Link & Rockenbach, PA received the disc4), violated the Agreed Order. 
Edwards is hoping that this Court will refuse to conduct an in camera inspection because of a 
possible finding by Judge Ray that Fowler White negligently or inadvertently held the disc in its 
storage facility for some number of years. Even if Judge Ray makes such a determination, this 
Court should not excuse Edwards' (and Farmer Jaffe's) failure to produce all of these e-mails as 
they were required to do and represented they would in 2011. 
Importantly, this Court has found that Link & Rockenbach, PA did nothing wrong relating 
to its discovery and use of the disc: 
3Farmer Jaffe agreed to produce all work-product related to closed cases to Epstein's attorneys. 
4At the bankruptcy hearing and for the first time, Epstein's counsel learned from Lilly Sanchez's 
testimony that Fowler White was given two discs from the Farmer Jaffe firm to create two sets of hard 
copy documents that were bate stamped. This uncontroverted testimony demonstrated that the "disc" 
was created for Special Master Camey and not for Fowler White or Epstein. The disc was made because, 
according to Lilly Sanchez, Special Master Camey did not want 27,542 bate stamped pages of 
documents. Rather, Special Ma...

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• 
"I'm not finding fault with anything you or Miss Rockenbach or 
Miss Campbell did. That's not the issue. You've done your job." 
(March 8, 2018, Aft. Tr. 59:1-4.)5 
• 
"So I again want to make clear that I'm finding absolutely no fault 
with Mr. Link, Miss Rockenbach, Miss Campbell or anyone else 
from the Link and Rockenbach firm in terms of what they did, albeit 
in the manner in which they had to do it and the timing, 
unfortunately, of the matter from their perspective in having to do it 
" (March 8, 2018, Aft. Tr. 61:15-21.) 
IN CAMERA REVIEW 
Epstein requests that the 30 e-mails remain unsealed for the duration of the in camera 
inspection and counsel for both parties be allowed to review and present argument as to each e-
mail. This is the same protocol agreed to by Farmer Jaffe in 2011 when the Special Master was 
contemplating this same review. That is, Farmer Jaffe agreed to turn over work product materials 
except for materials related to new or ongoing cases conditioned on a "For Attorneys' Eyes Only" 
basis until such time as the Court overruled any privilege claim upon the Special Master's ( or 
Court's) review with counsel present. (See Exhibit 3.) 
During its in camera review, this Court must consider and determine: 
1. 
The e-mails are directly relevant to the issues for trial and no Binger6 
"surprise in fact" exists regarding them; 
2. 
If any work product protection existed, it was waived or excepted 
based on: 
a. Farmer Jaffe's express agreement to turn over all work product 
to Epstein's attorneys; 
b. Edwards' production to Razorback victims/adversaries; 
c. Edwards' issue injection; and 
d. Crime fraud exception; 
3. 
The e-mails do not constitute attorney-client communications. 
5Excerpts of the March 8, 2018, afternoon hearing transcript are attached s Exhibit 2. 
6Bingerv. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 
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BACKGROUND 
A. 
Discovery of Deliberately Concealed E-Mails 
As this Court is well aware, in February 2018, Link & Rockenbach, PA discovered 
documents that were voluntarily produced years ago by Edwards to his potential adversaries at the 
time - the Razorback plaintiffs. These e-mails directly contradict Edwards' sworn testimony and 
positions taken by Edwards in this action. Importantly, the e-mails eviscerate Edwards' claim for 
emotional distress damages, and worse - they illustrate that Edwards provided suspect testimony 
in this action about his anxiety over being sued by Epstein. They also directly contradict Edwards' 
sworn testimony regarding interaction with Ponzi-schemer Scott Rothstein ("Rothstein") and the 
strength/weakness of Edwards' clients' damage claims against Epstein, both which have become 
critical factual issues in this case. 
First and foremost, the e-mails have become highly relevant in light of Edwards' sworn 
testimony that Epstein's lawsuit has caused him daily anxiety (emotional damages and credibility). 
Next, the e-mails are direct evidence controverting factual claims made by Edwards that he argues 
disproves probable cause, such as his interaction with Rothstein on the Epstein cases and the known 
"weakness" of the tort claimants' damages. While the e-mails only became known to Epstein's 
current counsel earlier this year, Edwards has known of them from the time of their existence! 
Moreover, the e-mails were produced by Edwards approximately eight years ago to counsel for 
Razorback, Edwards' adversary at the time. Edwards, knowing how potentially damaging thee-
mails are to him professionally, let alone their terminating effect on this lawsuit, has desperately 
taken multiple positions that Epstein's current counsel improperly obtained the e-mails (proven to 
be untrue), that none of the e-mails were ever produced (incorrect), and that they are all protected 
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subject to attorney-client privilege (false) and/or the work product doctrine (waived or broken by 
exceptions if ever applicable). 
B. 
Edwards' Deceptively Concealed the E-Mails and Clearly Violated Rule l.280{b)(6) as 
Previously Determined by the Court 
Edwards is responsible for improperly withholding these undeniably relevant e-mails from 
Epstein for more than eight years after specifically agreeing to tum over all work product to 
Epstein's lawyers. Specifically, Farmer Jaffe agreed: 
[February 2, 2011] All work product materials will be turned over 
to Plaintiff except for materials related to new or ongoing cases, 
AND on the condition that they be produced "For Attorneys' Eyes 
Only. (Exhibit 3.) 
Unfortunately, this promise to produce all work product was hollow. Although Farmer Jaffe 
did in fact tum over purported work product specifically relating to Edwards' three clients' cases 
against Epstein, which had then been settled in July 2010, it did not tum over the e-mails in question 
relating to those same cases. Further, in order to ensure that the e-mails would never see the light 
of the courtroom, Edwards concealed their existence by hiding them within a deceptively worded 
1,607-entry, 159-page privilege log that this Court's predecessor, The Honorable David Crow, 
found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil 
Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). 
Edwards has claimed that none of the documents on the disc that were listed on his privilege 
log had ever been produced. However, this is demonstrably inaccurate. Specifically, on May 7, 
2012, Edwards produced 163 pages representing 89 documents identified on his 159-page privilege 
log. In addition, Edwards' counsel suggested that Link & Rockenbach received the evidence from 
7Florida Rule of Civil Procedure 1.280 has been amended since the Court's Order and privilege 
cla...

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attorney William Scherer (Razorback's counsel). Although that is inaccurate, it demonstrates that 
any potential work-product protection has been waived by virtue of production to at least one other 
potentially adverse party in separate litigation. 
C. 
The Truth and this Court's Process-Driven "Level Playing Field" 
This Court has repeatedly expressed its intention to preserve the integrity of the judicial 
process and maintain a level playing field between the parties in order to ensure a fair trial. Now 
is the time for process and this balance to yield the truth. 
Consistent with this Court's efforts to level the playing field by allowing Edwards to 
introduce certain evidence bearing on Epstein's criminal history, his non-prosecution agreement 
with the government, settlements with Edwards' three clients and the existence and settlement of 
other civil claims against Epstein, this Court must allow the jury to review these 30 e-mails which 
would allow a full evaluation of Edwards' absurdly false anxiety damages claim, his conduct and 
the true value of his clients' cases as known by Edwards. The e-mails reveal as a sham Edwards' 
efforts to disprove Epstein's probable cause for believing Edwards' unusual litigation tactics were 
designed for an improper purpose, and leave undisputed and intact the extrinsic evidence on which 
Epstein reasonably relied as probable cause for the original action. 
ARGUMENT 
A. 
The 30 E-mails are Relevant and Directly Controvert Edwards' Sworn Testimony and 
Repeated Misrepresentations to this Court 
The 30 e-mails are all undeniably relevant to this case. They eviscerate Edwards' damages 
claim and directly controvert Edwards' denials under oath and repeated representations before this 
Court regarding the weakness of Edwards' clients' damages claims against Epstein, Edwards' 
association and interaction with Rothstein and the litigation tactics in which Edwards improperly 
engaged, and they destroy the over...

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mails are not only relevant and material, but make it impossible for Edwards to establish any 
damages at all or to satisfy his heavy burden to prove the absence of probable cause for Epstein to 
have filed suit against him. 
Edwards claims that he has suffered and continues to suffer damages arising out of his 
"anxiety" from Epstein's Complaint that was filed more than eight years ago and dismissed six 
years ago because it: (a) falsely characterized Edwards' cases as "weak"; (b) indicated that Edwards 
knew or should have known ofRothstein's Ponzi scheme; and (c) alleged that Edwards engaged in 
litigation conduct to support the Ponzi scheme. As support for this assertion, Edwards sets up as the 
central issues (and issue injection) in the trial of his Counterclaim against Epstein: (a) the strength 
of his clients' cases against Epstein; (b) the lack of any association between Rothstein and either 
Edwards or Edwards' clients' cases against Epstein; and ( c) the legitimacy of Edwards' litigation 
conduct in his clients' cases against Epstein. 
Epstein is entitled to have the Court and jury consider these e-mails as the jury determines 
whether Epstein exceeded the wide latitude which the law confers on all plaintiffs "to use their best 
judgment in prosecuting ... a lawsuit without fear of having to defend their actions in a subsequent 
civil action for misconduct." Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 
2d 380, 384 (Fla. 2007). It is also crucial that these e-mails be available to the jury as they evaluate 
the factual issues that Edwards claims determine whether it was objectively reasonable or 
unreasonable to rely on the extrinsic evidence that Epstein proffers as probable cause. 
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B. 
No Binger "Surprise in Fact" and Truth and Justice Requires the Courtroom's Light 
There is no Binger prejudice and truth and justice require admissibility of these 30 highly 
relevant, case-ending e-mails either authored or received by Edwards, and undeniably within 
Edwards' possession since 2009. Based on this, Edwards - an officer of the court, who took an 
oath to "never seek to mislead the judge or jury by any artifice or false statement of fact" - cannot 
claim "surprise."8 
The decision before this Court is one of right and wrong, and as this Court has acknowledged 
its task - "What is the right thing to do" which allows the Court to "look in the mirror at the end of 
the day," and respond to one question: "Did I do the right thing by those who came before me ... " 
- regardless of economic status or popularity of either party or his counsel. (11/2/18 Hearing 
Transcript, 88-89.) Edwards wrongly placed, and Edwards has advanced, an "attorney-client" label 
on the 30 e-mails with the intent that Epstein should never discover the existence of these 
devastatingly harmful documents, while at the same time allowing other adversaries access to these 
so called "privileged" e-mails. 
Importantly, the attorney-client label is false because none of the 30 e-mails were to or from 
clients and none of the e-mails contain confidential information provided by Edwards' three clients. 
Further, any information about Edwards' clients' past was all publicly available (and generally 
known) and even testified about by those very clients. Edwards also knows that Farmer Jaffe agreed 
to produce work-product e-mails in 2011 and, in fact, did so, including asserted work-product e-
mails relating to Edwards' three clients' cases. Edwards' hollow attorney-client privilege and work 
product assertions are now squarely challenged and must be rejected in favor of the truth. See 
Loureiro v. State, 133 So. 3d 948, 956 (Fla. 4th DCA 2013)("A trial must be a sea...

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Katzman v. Rediron Fabrication, Inc., 76 So. 3d 1060, 1063 (Fla. 4th DCA 2011)(" ... jury can the 
search for truth and justice be accomplished"). 
Not only are the e-mails highly relevant and constitute no Binger "surprise in fact" to 
Edwards, as this Court has already glimpsed upon cursory review of the e-mails in March 2018, not 
a single one of the 30 e-mails are attorney-client privileged. Further, if any work product existed, 
it was either waived or is subject to a clear exception to such protection under the law. If this Court 
follows Edwards' lead, a ruling shielding the jury from case-eviscerating e-mails would result in 
reversible error and lead to a second trial. 
Because these e-mails are case-ending or worse for Edwards, Edwards has attacked 
Epstein's counsel and derided the truth of these e-mails in an attempt to hide them from the light of 
the courtroom, but in the end, there it is: truth. 
C. 
Edwards Expressly Waived Work Product Protection in 2011 and His Deceptive 
Concealment of the 30 E-Mails on a Legally Deficient Privilege Log Violated Florida 
Law and Court Orders 
Edwards expressly, and on multiple occas10ns, waived work-product protections. In 
negotiating the preparation of the privilege log, on February 2, 2011, Farmer Jaffe informed 
Epstein's counsel and the Special Master that it would omit from the log any work product 
objections that related to closed cases: 
All work product materials will be turned over to Plaintiff except for 
materials related to new or ongoing cases, AND on the condition that they 
be produced "For Attorneys' Eyes Only. (Exhibit 3.) 
Gary Farmer, Jr. told the Special Master he would then only list on the new privilege log 
work product materials for existing cases and attorney-client privilege materials. Id. Farmer 
confirmed this agreement more than once: 
[February 9, 2011] "We also have 2 more boxes that contain work product 
materials what we will tum over subject to the agreement...

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not assert any privilege has been waived by turning them over now, and 
further subject to the agreement that they be produced 'For Attorneys' Eyes 
Only."' (Exhibit 4.) 
[February 16, 2011] Farmer: "Do you still want to do the attorney's eyes 
only? Do you want to speed it up or not? You'll get work-product stuff 
if you agree to the attorney's-eyes only." Epstein's counsel confirmed their 
agreement. (Exhibit 5.) 
This representation was significant. At the time Farmer made this representation to Epstein 
in 2011, the three cases Edwards had been litigating against Epstein while he was Rothstein's 
partner at Rothstein Rosenfeldt & Adler ("RRA") were closed and had long been settled (in July 
2010). Thus, based on Farmer's representation, Edwards was obligated, as an officer of the Court, 
to have produced all e-mails reflecting work product pertaining to the three closed Epstein cases 
because they did not pertain to "new or ongoing cases." While at the time of the production 
Edwards had other clients who had claims against Epstein, those, too, have now long been settled9, 
and none of those claims remain pending against Epstein. 
In fact, Edwards did produce more than 5,000 pages as "attorneys' eyes only" in February 
2011 (including asserted work product relating to the cases of his three clients that Edwards intends 
to feature in the prosecution of his malicious prosecution claim against Epstein). Epstein has now 
discovered that Edwards did not produce select items, and specifically withheld inculpatory e-mails 
pertaining to his closed cases against Epstein, despite his partner's representation to counsel and 
the Court (Special Master). 10 To the extent that the 30 e-mails identified for this Court relate to 
9Edwards settled his last clients' claims against Epstein in August 2011. 
10In anticipation of Edwards' response that some work-product documents relating to L.M. and 
E.W. were not produced because of some tangential privilege ...

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actual cases Edwards litigated against Epstein, they were closed cases. If work-product protection 
ever even arguably applied to them, the e-mails should have been turned over for review by 
Epstein's counsel pursuant to Farmer Jaffe's agreement. Moreover, because all of Edwards' clients' 
claims against Epstein have now settled, in reliance on Edwards' previous waiver and agreement 
to produce the same, there is simply no basis for them not to be subject to review by this Court and 
a determination that any work-product protection that may at one time have been available is no 
longer applicable as a result of Edwards' clear and irrefutable waiver. See Jane Doe No. 1 v. United 
States, 749 F.3d 999 (11th Cir. 2014)(held that Epstein's former counsel had waived the work-
product privilege with respect to documents sought by Edwards' clients, after having voluntarily 
sent allegedly privileged correspondence to the United States during plea negotiations). 
Moreover, this Court's conclusion that Edwards' waiver of any protection is further 
mandated by his subsequent deliberate concealment of the e-mails in question on a 159-page 
privilege log that was determined by the Court on May 7, 2012, to be legally deficient on its face 
and to have utterly failed to comply with the legal requirements of Florida Rule of Civil Procedure 
1.280(b)(5) and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). (Exhibit 7.) It 
was through this device that Edwards prevented the e-mails from ever seeing the light of day despite 
Edwards' misrepresentations to Epstein's counsel that all e-mails qualifying as work product in 
closed cases against Epstein had been produced. While the e-mails remained concealed through 
Edwards' improper device, Edwards continued to prosecute his Counterclaim against Epstein based 
on the very issues directly refuted by e-mails Edwards concealed from existence. Edwards, who is 
was in September 2010 after the court administ...

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both an officer of the court, a plaintiff and counsel of record for himself in this action, should not 
be rewarded for such unethical gamesmanship and violation of court rules. 
On August 17, 2012, the Court vacated the May 7, 2012, Order, but did not relieve Edwards 
of the requirement to provide a new fully compliant privilege log. In fact, the Court's August 17, 
2012, Order provides, in pertinent part: 
EDWARDS shall file a written response specifically addressing the 
production sought in Paragraph 13 of EPSTEIN's Motion to Compel and 
Amend Protective Order of March 9, 2012 as Ordered in this Court's April 
10, 2012 Order. The response shall identify non-privileged responsive 
documents previously produced, shall be accompanied by all non-
privileged responsive documents not previously produced, if any and shall 
identify, in a proper privilege log as referenced in this Court's May 7, 
2012 Order, responsive documents withheld from production on the basis 
of any assertion of privilege. This response shall be filed within 10 days 
from the date of this Order. 
(August 17, 2012, Order) (emphasis added) (Exhibit 8). Edwards failed to comply with the Court's 
Order and provide an accurate privilege log. His February 23, 2011 privilege log (Exhibit 9) is 
clearly invalid and the protections asserted thereunder must be deemed waived for any number of 
reasons, including Edwards' failure to comply with the Court's Order. 
Because Edwards blatantly disregarded the Court's Order, as well as the requirements of 
Florida's Rules of Civil Procedure and the TIG case, the February 23, 2011 privilege log remains 
wholly deficient and worse - deliberately misleading. The privilege log misstates objections, 
improperly identifies or altogether excludes the required identities of the document authors and 
recipients, and its document descriptions are deceptively vague and misrepresent the true nature of 
the documents listed on the privilege log. Had Edwa...

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In light of Edwards' promise to tum "work-product" e-mails over coupled with his 
deliberately misleading and non-compliant privilege log and multiple instances of waiver regarding 
work product from closed cases, the Court need not make any further determinations other than to 
unseal the 30 e-mails and allow Epstein to use them at trial. Edwards' deceptive privilege log and 
subsequent disregard for the Court's Order mandating ("shall") a proper privilege log should not 
be rewarded by this Court, and requires a finding that Edwards has waived any claim of protection, 
particularly protection he has already waived or lost for a variety of other reasons discussed herein. 
D. 
Edwards Waived Any Attorney-Client and Work-Product Protection by Voluntary 
Disclosure to a Clear Adversary in the Razorback Litigation 
Additionally, Edwards' counsel conceded on March 8, 2018, that the e-mails were shared 
with the Conrad, Scherer law firm-- counsel for Razorback. (Exhibit 2, 15: 1-16; 18: 18-19:3). (Also 
see April 2011 communication between Edwards' counsel and Razorback's counsel, Composite 
Exhibit 10.) Clearly, Razorback sought their production to prove its allegations in the Razorback 
lawsuit that Rothstein used the three cases against Epstein, in part, to lure investors into the Ponzi 
scheme. Once Edwards provided the documents that he claims are privileged in this case (both 
attorney-client and work product) to Conrad, Scherer, an adversarial party's counsel, Edwards 
waived those privileges. See§ 90.507, Fla. Stat.; Delap v. State, 440 So. 2d 1242, 1247 (1983). See 
also Tucker v. State, 484 So. 2d 1299, 1301 (Fla. 4th DCA 1986) ("The law is clear that once 
communications protected by the attorney-client privilege are voluntarily disclosed, the privilege 
is waived and cannot be reclaimed.") (emphasis added). 
Recognizing his voluntary disclosure to Razorback, Edwards has defended against Epstein's 
claim of waiver by arguing "selective wai...

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Rothstein without waiving privilege as to their communications or documents shared." Edwards' 
Supp. Resp. to Epstein's Mot. to Declare Relevance, July 26, 2018, at 14. This is a claim of 
"selective waiver"-that Edwards may waive privilege as to one recipient while maintaining it as 
to others. However, every court that has recently addressed the logic and viability of "selective 
waiver" has concluded that it fails as inconsistent with the purpose of the attorney-client privilege. 
Permian Corp. v. US., 665 F.2d 1214, 1221 (D.C. Cir. 1981). In addition, "[o]nce a party has 
disclosed work product to an adversary, it waives the work product doctrine as to all other 
adversaries." McMorgan & Co. v. First Cal. Mortg. Co., 931 F. Supp. 703 (N.D. Cal. 1996). 
Case law from across the country demonstrates that the confidentiality agreement is of no 
merit because a litigant who chooses to disclose information claimed as confidential cannot have 
his cake and eat it too. Simply put, actions speak louder than words. 
The general rule applies here. On March 8, 2018, Edwards' counsel, Jack Scarola, implied 
(incorrectly) that the e-mails were shared with Epstein's counsel by Mr. Scherer, counsel for 
Razorback. Thus, Edwards admits that he voluntarily furnished the e-mails to Mr. Scherer. 
Razorback sought these allegedly privileged communications to prove its allegations in the 
Razorback litigation that Rothstein used Edwards' three cases against Epstein to lure investors into 
Rothstein 's Ponzi scheme. When Edwards produced these documents to Mr. Scherer, who was 
prosecuting an action against Rothstein and the firm, Edwards waived his claim to attorney-client 
privilege and work-product protection as to the whole world. 11 See infra. 
Likewise, no "common interest" protection exists because the Razorback victims were 
outspokenly not aligned with Edwards. This is perhaps best illustrated in the hearing transcript 
before the United States Bankruptc...

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RBR, in In re Rothstein Rosenfeldt Adler, P.A., in which the following were statements made by 
William Scherer, Razorback's counsel: 
• 
"[I]n November we filed a lawsuit in State Court and we alleged that as part 
of Mr. Rothstein and the firm, and the firm's employees, and maybe some 
of the firm's attorneys, conspired to use the Epstein/LM litigation in order 
to lure $13.5 million worth of my victims, my clients, into making 
investments in these phoney [sic] settlements." (17:7-14.) 
• 
"In addition, as we have alleged, that Mr. Edwards and the firm put 
sensational allegations in the LM case that they knew were not true, in order 
to entice my clients into believing that Bill Clinton was on the airplane with 
Mr. Epstein and these young woman ... " (18:24-19:4.) 
• 
"I can't conceive that Mr. Edwards and the predecessor law firm would have 
any standing to prepare privilege logs or anything else, given what I just 
told the Court. That would be like having the fox guard the hen house." 
(20:5-9.) 
• 
"[The Complaint] names Rothstein. It does not name Mr. Edwards. It just 
names Rothstein, not the firm, and lays out the facts and says other people 
in the firm. We did not name them because we want to see the documents 
and see whether they had involvement." (22:3-8.) 
• 
"I support the same position that [Epstein] has asked the Court, and that is 
to have the trustee deal with this, get these documents and deal with it with 
you, rather than allow the successor law firm (i.e., Edwards' law firm) to 
have them." (22: 19-24.) 
(8/4/10 Hearing Transcript, Exhibit 11.) 
It really is that simple. Edwards' decision years ago (for whatever expedient or economic 
reason) to voluntarily give away the allegedly attorney-client privileged and work product e-mails 
to Conrad Scherer in the Razorback litigation triggered section 90.507. After taking steps 
inconsistent with the maintenance of privileges in confidential information, the privileges canno...

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E. 
Work-Product Protection Was Waived by Edwards' Issue Injection 
Edwards has also waived attorney-client and work-product protections in the 30 e-mails 
under Florida's "at issue" doctrine (also known as "issue injection"). Related to the "at issue" 
doctrine is the "implied waiver" doctrine. 
The "at issue" doctrine requires that a court find a waiver of attorney-client privilege. 
Genovese v. Provident Life & Acc. Ins. Co., 74 So. 3d 1064 (Fla. 2011) (noting that privilege is 
waived where, for example, advice of counsel is raised as a defense and privileged communication 
is necessary to establish the defense). Under the "at issue" doctrine, "[A] party cannot hide 
behind the shield of privilege to prevent an opponent from effectively challenging pertinent 
evidence." Carles Const. Inc. v. Travelers Cas. & Sur. Co. of Am., 56 F. Supp. 3d 1259, 1273 n.40 
(S.D. Fla. 2014) (emphasis added). 
Here, the e-mails are vital and necessary to defend against one or more elements of 
Edwards' malicious prosecution claim. Among other things, the e-mails directly relate to the 
credibility of Edwards' claim for damages based on "anxiety" he has allegedly suffered every single 
day of his life since December 2009 when Epstein's lawsuit was filed, and continues to suffer 
through today. (Edwards, 11/10/17, 11:21-12:16; 21:14-22:8; 23:5-16.) 12 In addition, the e-mails 
directly debunk Edwards' assertion that he had no involvement with Rothstein, that he acted 
properly in the litigation and that there is nothing to demonstrate any weakness in Edwards' now-
settled three clients' cases against Epstein. Repeatedly, through his own sworn testimony and 
repeated misrepresentations before the Court, Edwards has made these central issues in his 
malicious prosecution Counterclaim against Epstein. Edwards' own statements in the e-mails are 
directly relevant and go to the heart of Epstein's ability to demonstrate that Edwards had no 
12Excerpts of Edwards' Nove...

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damages, that any damages from anxiety as claimed by Edwards cannot be blamed on the 
allegations in the Complaint, but are attributable to Edwards' voluntary association with Rothstein 
and his own litigation activities in the Epstein cases, and that in the end, Edwards' claimed reasons 
that Epstein could not have had probable cause and acted with malice are plainly false. Therefore, 
they are critical to Epstein's defenses to Edwards' malicious prosecution claim and any work-
product that may have applied to them must be deemed to have been waived. 
F. 
The Crime-Fraud Exception Applies to Some E-mails 
Under Florida law, there is no attorney-client privilege when the services of a lawyer are 
sought to enable or aid anyone to commit or plan to commit what the client knew was a crime or 
fraud. § 90.502(4)(a), Fla. Stat.; see also Fla. R. Profl Conduct 4-1.6 ("A lawyer must reveal 
confidential information to the extent the lawyer reasonably believes necessary ... to prevent a 
client from committing a crime."). Following earlier precedent in Parrott v. Wilson, 707 F.2d 1262, 
1271 (11th Cir. 1983), the Eleventh Circuit affirmed the part of the district court's order determining 
that the crime-fraud exception may be applied because an attorney's illegal or fraudulent conduct 
may, alone, overcome attorney work-product protection. See Drummond Co., Inc. v. Conrad 
Scherer, LLP, No. 2:11-cv-03695-RDP-TMP (11th Cir. March 23, 2018), at 23-24. (Exhibit 13.) 
As further support for this crime-fraud argument and Rothstein' s and Edwards' working 
together as alleged in Epstein's Complaint, Epstein directs the Court to his Memorandum filed 
under seal and the illustrative sampling of exhibits. This is more specifically explained in Epstein's 
Confidential Memorandum. 
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G. 
No Attorney-Client Privilege Exists 
Farmer Jaffe, and now Edwards, misleadingly and repeatedly have advanced the "attorney-
client privilege" label again and again in the hope that this Court will turn away and preclude the 
documents from jury consideration. Of the 1,607 claimed privilege items on Farmer Jaffe's 
privilege log, 938 entries were labeled as "irrelevant and not reasonably calculated to lead to the 
discovery of admissible evidence," while 994 entries were labeled as "work product and attorney-
client privilege" ( only 19 were communications with a client as determined by the description in 
the privilege log). 
Despite Edwards' and Paul Cassell' s ( counsel for the Intervenors) protestations to the 
contrary, this Court can plainly see that not a single one of the 30 e-mails are attorney-client 
privileged communications between Edwards ( or any other co-counsel) and Edwards' and Mr. 
Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e-
mails among attorneys and staff within RRA, with Mr. Cassell, and with media sources and do not 
qualify for that protection as codified in section 90.502 of the Florida Statutes. A quick read of the 
30 e-mails makes it easy to understand both that the e-mails do not in any way reflect attorney-
client communications and that Edwards and Mr. Cassell have very significant personal and 
professional reasons that they do not want the e-mails to see the light of the courtroom. See Buckley 
v. Am. Constitutional Law Found., Inc., 525 U.S. 182,223, 119 S. Ct. 636, 657, 142 L. Ed. 2d 599 
( 1999)("' Sunlight is said to be the best of disinfectants; electric light the most efficient policeman."' 
citing Buckley v. Valeo, supra, at 67, and n. 80, 96 S.Ct. 612 (quoting L. Brandeis, Other People's 
Money 62 (1933)). 
Under Florida's Evidence Code, "[a] client has a privilege to refuse to disclose, and to 
prevent any other person from disclosing, the conten...

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other person learned of the communications because they were made in the rendition of legal 
services to the client." § 90.502(2), Fla. Stat. (2017). A communication between lawyer and client 
is "confidential" if it is not intended to be disclosed to third persons other than: 
1. 
Those to whom disclosure is in furtherance of the rendition of legal 
services to the client. 
2. 
Those 
reasonably 
necessary 
for 
the 
transmission 
of the 
communication. 
Las Glas River House Condo. Ass'n, Inc. v. Lorh, LLC, 181 So. 3d 556, 557-58 (Fla. 4th DCA 
2015); § 90.502(1)(c), Fla. Stat. (2017); Witte v. Witte, 126 So. 3d 1076 (Fla. 4th DCA 
2012)(second exception applies to agents of the client such as a family member on behalf of an 
incapacitated relative). Not one of the 30 e-mails provides any basis to conclude that the documents 
constitute or reflect attorney-client communications in the rendition of legal services to a client. 
This Court's in camera review of the 30 e-mails will easily confirm that no attorney-client privilege 
applies. 
CONCLUSION 
Edwards, an officer of the court, the plaintiff in this case and counsel of record for himself, 
can claim no surprise for e-mails he authored, received or possessed since 2009 and deliberately 
and improperly concealed from disclosure to Epstein since February 2011. The 30 e-mails are 
relevant, directly controverting Edwards' sworn testimony and repeated misrepresentations before 
this Court, and clearly none of them are attorney-client communications. Additionally, Edwards 
has waived the right to assert attorney-client privilege and work-product doctrine with respect to 
the 30 e-mails for all reasons set forth above. This Court is equipped with the controlling law and 
equitable principles to perform the now substantially narrowed request for an in camera review of 
the sealed 30 e-mails, and to confirm the critically relevant nature and admissibility of these e-mails 
based on the absence or wa...

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camera review will confirm that Edwards expressly waived all privilege in February 2011 and such 
documents should be deemed to have been produced by him. As directed by this Court, a 
memorandum outlining Epstein's positions with respect to the specific e-mails that are the subject 
of this Motion is being provided to this Court separately under seal for its consideration. 
WHEREFORE, Counter-Defendant, Jeffrey Epstein, moves for this Court for an in camera 
review of the 30 e-mails, with counsel present to be heard, and for a ruling that no privilege exists, 
or that waiver or other reasons preclude any potential protection and the 30 e-mails may be 
identified by Epstein on his Exhibit List and introduced at trial. 
CERTIFICATE OF SERVICE 
I certify that the foregoing document has been furnished to the attorneys listed on the Service 
List below on November 9, 2018, through the Court's e-filing portal pursuant to Florida Rule of 
Judicial Administration 2.5 l 6(b )(1 ). 
LINK & ROCKENBACH, PA 
1555 Palm Beach Lakes Boulevard, Suite 930 
West Palm Beach, Florida 33401 
(561) 847-4408; (561) 855-2891 [fax] 
By: Isl Scott J Link 
Scott J. Link (FBN 602991) 
Kara Berard Rockenbach (FBN 44903) 
Primary: Scott@linkrocklaw.com 
Primary: Kara@linkrocklaw.com 
Secondary: Tina@linkrocklaw.com 
Secondary: Troy@linkrocklaw.com 
Counsel for Counter-Defendant Jeffrey Epstein 
20 

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SERVICE LIST 
Jack Scarola 
Karen E. Terry 
David P. Vitale, Jr. 
Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, FL 33409 
mep@searcylaw.com 
jsx@searcylaw.com 
dvitale@searcylaw.com 
scarolateam@searcylaw.com 
terryteam@searcylaw.com 
Co-Counsel for Defendant/Counter-Plaintiff 
Bradley J. Edwards 
Bradley J. Edwards 
Edwards Pottinger LLC 
425 N. Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301-3268 
brad@epllc.com 
Co-Counsel for Defendant/Counter-Plaintiff 
Bradley J. Edwards 
Jack A. Goldberger 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue S., Suite 1400 
West Palm Beach, FL 33401 
j goldberger@agwpa.com 
smahoney@agwpa.com 
Co-Counsel for Plaintiff/Counter-Defendant 
Jeffrey Epstein 
21 
Philip M. Burlington 
Nichole J. Segal 
Burlington & Rockenbach, P.A. 
Courthouse Commons, Suite 350 
444 West Railroad A venue 
West Palm Beach, FL 33401 
pmb@FLAppellateLaw.com 
njs@FLAppellateLaw.com 
kbt@FLAppellateLaw.com 
Co-Counsel for Defendant/Counter-Plaintiff 
Bradley J. Edwards 
Marc S. Nurik 
Law Offices of Marc S. Nurik 
1075 Broken Sound Parkway N.W., Suite 102 
Boca Raton, FL 33487-3541 
marc@nuriklaw.com 
Counsel for Defendant Scott Rothstein 
Paul Cassell 
383 S. University 
Salt Lake City, UT 84112-0730 
cassellp@law. utah. edu 
Limited Intervenor Co-Counsel for L.M, E. W 
and Jane Doe 
Jay Howell 
Jay Howell & Associates 
644 Cesery Blvd., Suite 250 
Jacksonville, FL 32211 
jay@jayhowell.com 
Limited Intervenor Co-Counsel for L.M, E. W 
and Jane Doe 

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EXHIBITS 
Ex. 
Date 
Description 
1 
10/29/18 In re Rothstein Rosenfeldt Adler, P.A., U.S. Bankruptcy 
Court, Southern District of Florida, Case No. 09-34791, 
Order Discharging Order to Show Cause Against Jeffrey 
Epstein (D.E. 6508) 
2 
03/08/18 
Afternoon Hearing Transcript Excerpt, pp. 15, 18, 19, 59, 61 
3 
02/02/11 
E-mail from Gary Fanner to Robert Camey, Jack Scarola, 
Seth Lehrman, Lilly Sanchez, Joseph Ackerman and Brad 
Edwards 
4 
02/09/11 
E-mail from Gary Fanner to Robert Camey, Joseph 
Ackerman, Lilly Sanchez, Jack Scarola, Christopher Knight, 
Seth Lehrman and Brad Edwards 
5 
02/16/11 
Hearing Transcript Excerpt, p. 41 
6 
NIA 
Jane Doe v. United States, U.S. District Court, Southern 
District of Florida, Case No. 9:08-cv-80736, Excerpt of 
Docket 
7 
05/07/12 
Order on Jeffrey Epstein's Motion to Compel Production of 
Documents from Edwards and for Sanctions 
8 
08/17/12 
Order on Outstanding Discovery Motions 
9 
02/23/11 
Farmer Jaffe's Privilege Log 
10 
04/08/11 
Communications between Conrad Scherer and Jack Scarola re 
04/10/11 
production of documents 
11 
08/04/10 In re Rothstein Rosenfeldt Adler, P.A., U.S. Bankruptcy 
Court, Southern District of Florida, Case No. 09-34791, 
Hearing Transcript 
12 
11/10/17 
Bradley J. Edwards Deposition Transcript Excerpts, pp. 11-
12, 21-23 
13 
03/23/18 
Drummond Company, Inc. v. Conrad & Scherer, LLP, United 
States Court of Appeal, Case No. 16-11090, 15-90031, 
Opinion 

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EXHIBIT 1 

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Case 09-34791-RBR 
Doc 6508 
Filed 10/30/18 
Page 1 of 2 
ORDERED in the Southern District of Florida on October 29, 2018. 
INRE: 
~~ 
United States Bankruptcy Court 
UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
www.flsb.uscourts.gov 
ROTHSTEIN ROSENFELDT ADLER, P.A., 
Debtor. 
CASE NO. 09-34791-RBR 
CHAPTER 11 
I 
----------------
ORDER DISCHARGING ORDER TO SHOW CAUSE AGAINST JEFFREY EPSTEIN 
On April 20, 2018, the Court entered its Order To Show Cause Why Fowler White And 
Jeffrey Epstein Should Not Be Held In Contempt And Scheduling Evidentiary Show Cause 
Hearing (ECF No. 6366) ("Order to Show Cause"). On October 25, 2018, the Petitioners, Farmer 
Jaffe Weissing Edwards Fistos & Lehrman, Bradley J. Edwards, and Intervenor L.M., filed their 
Notice of Joint Voluntary Dismissal of Jeffrey Epstein (ECF No. 6496). Based upon the above, 
the Court hereby discharges the Order to Show Cause against Jeffrey Epstein. 
### 

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Case 09-34791-RBR 
Doc 6508 
Filed 10/30/18 
Page 2 of 2 
Submitted by: 
Chad P. Pugatch, Esq. 
Rice Pugatch Robinson Storfer & Cohen, PLLC 
101 N.E. Third Avenue, Suite 1800 
Ft. Lauderdale, FL 33301 
Telephone: (954) 462-8000 
Telefax: (954) 462-4300 
cpugatch@rprslaw.com 
Attorney Chad P. Pugatch, Esq., is directed to serve copies of this Order on all interested parties 
and file a certificate of service. 
2 

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EXHIBIT 2 

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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, FLORIDA 
Case No. 502009CA040800XXXXMB 
JEFFREY EPSTEIN, 
Plaintiff/Counter-Defendant, 
vs. 
SCOTT ROTHSTEIN, individually; 
BRADLEY EDWARDS, individually, 
Defendants/Counter-Plaintiffs. 
I 
------------------
TRANSCRIPT OF PROCEEDINGS 
DATE TAKEN: 
TIME: 
PLACE 
BEFORE: 
Thursday, March 8th, 2018 
1:30 p.m. -
4:50 p.m. 
205 N. Dixie Highway, Room l0D 
West Palm Beach, Florida 
Donald Hafele, Presiding Judge 
This cause came on to be heard at the time and 
place aforesaid, when and where the following 
proceedings were reported by: 
Elaine V. Williams 
Palm Beach Reporting Service, Inc. 
1665 Palm Beach Lakes Boulevard, Suite 1001 
West Palm Beach, FL 33401 
(561) 471-2995 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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MR. SCAROLA: 
That is correct. 
The Conrad 
Scherer firm was involved in that litigation, and 
the Conrad Scherer firm was also interested in 
getting to take a look at whatever relevant e-mails 
might have been in the hands of the bankruptcy 
trustee, and then got turned over to us. 
Well, there were direct negotiations in which 
I was a personal participant with the lawyers for 
Conrad Scherer, and an agreement was reached with 
the lawyers for Conrad Scherer because, as we have 
told every judge before whom we have appeared with 
regard to these matters, we're not attempting to 
hide anything. 
You want to conduct an in-camera 
inspection, we want you to conduct an in-camera 
inspection because it will confirm that we're not 
attempting to hide anything. 
We will turn over anything that you consider 
appropriate for us to turn over. 
But we have no 
ability to waive our client's attorney-client 
privilege, your Honor, and some of these e-mails 
clearly contain information that originated with 
clients. 
And we are in the midst at this point of 
still-pending litigation, and it is important for 
us to protect our work product privilege as well. 
Some of that litigation is still ongoing right now. 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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the Bates numbers of these documents on that 
privilege log, you have an obligation, an ethical 
obligation, to turn them over to us, to turn them 
over now, and to make no use of those documents 
unless and until you have a court order that says 
otherwise. 
You need to tell us where did you get 
them, when did you get them, how did you get them, 
to whom have you distributed them? 
And those are 
questions that we still don't have answered. 
What we get from the other side is, "Well, 
they could have come from here, they could have 
come from there, maybe they came from someplace 
else, we don't know." 
And if they don't know where 
they came from and that source is clearly a proper 
source, they have the burden in overcoming this 
privilege assertion to prove a waiver if they 
contend any waiver existed. 
It wasn't with regard to Conrad Scherer 
because when those documents were turned over to 
Conrad Scherer -- and we have the letters that 
confirm the written agreement with every detail of 
that agreement in place -- those were turned over 
as part of a common interest privilege with an 
express representation it was attorneys' eyes only, 
with an express representation they would be turned 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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over to no one. 
Indeed, when they got turned over 
to Conrad Scherer, they were originally turned over 
with a confidentiality watermark on every document. 
And then they contacted us back again and 
said, "We're trying to OCR all of these documents 
so that they are searchable, and we can't do that 
with the watermark on them. 
Can you please provide 
us with another copy without a watermark?" 
And we 
did that; again, trusting these officers of the 
court to abide by their agreement. 
And we have 
every reason to believe that Conrad Scherer did. 
They were not the source. 
The obvious source, based now upon what we 
have been able to piece together, is very clearly 
Fowler White's improper retention of this material 
after they had been expressly ordered by the 
federal court not to retain any of it. 
Now, every representation I have made to the 
Court, everything that is included on this timeline 
can be established through documents that pinpoint 
the dates and the identity of the individuals 
involved and the character of every disclosure that 
was made and every disclosure that was withheld. 
It has taken a substantial effort to put all of 
this together again. 
We have been working on this 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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file. 
How that could be the case, who knows? 
But 
I'm not finding fault with anything you or 
Miss Rockenbach or Miss Campbell did. 
That's not 
the issue. 
You've done your job. 
MR. LINK: 
I understand. 
Your Honor, may I 
have one minute to confer with appellate counsel to 
make sure there's nothing I need to do to preserve 
this? 
THE COURT: 
Absolutely. 
Let's just take a 
brief recess. 
(Thereupon, a short recess was taken.) 
THE COURT: 
All right. 
Thank you again. 
Please have a seat. 
Welcome back. 
MR. SCAROLA: 
Your Honor, I want to hopefully 
tie up a few loose ends on the matter that has just 
been ruled on. 
Am I correct in understanding that the 
defendant is prohibited from making any use of the 
724 late-disclosed exhibits? 
THE COURT: 
Yes. 
MR. SCAROLA: 
Next, sir, we would request the 
defendant be required to relinquish possession of 
all copies of the privileged documents to the Court 
under seal. 
They have expressed some concern 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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ability to weigh in somehow as to these critical 
issues. 
Perhaps I'm being a bit naive when I say that 
having served Mr. Epstein in their capacity as 
counsel, it's my respectful belief that they owed 
an obligation to Mr. Epstein, if not this Court, to 
explain how and why they had access and kept these 
records in their possession in light of that court 
order and in light of this ongoing litigation. 
And 
as a matter of respect to Mr. Epstein and his 
ongoing legal team, to have made some type of 
affirmative steps to have dealt with this issue 
head on because of the apparent implications of 
same. 
So I again want to make clear that I'm finding 
absolutely no fault with Mr. Link, Miss Rockenbach, 
Miss Campbell or anyone else from the Link and 
Rockenbach firm in terms of what they did, albeit 
in the manner in which they had to do it and the 
timing, unfortunately, of the matter from their 
perspective in having to do it, but that takes 
nothing away from what the Court has already 
remarked upon concerning the fact that now Fowler 
White in the representation of Mr. Epstein had 
these records from the inception is one of the 
Palm Beach Reporting Service, Inc. 
561-471-2995 
61 

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EXHIBIT 3 

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., ,., 
1 
.--Joseph L. Ackerman, Jr. 
From: 
Sent: 
To: 
Subject: 
Gary Farmer <gary@pathtojustice.com> 
Wednesday, February 02, 20111:49 PM 
ROBERT CARNEY; Jack Scarola; Seth Lehrman; lilly Ann Sanchez; Joseph L. Ackerman, Jr.; 
Brad Edwards 
RE: It's time to meet 
Judge, I apologize for the delay in replying, I was out of the office most of the day yesterday, and could not get 
with my partners and our clients to discuss all issues. We have now done so. We are certainly happy to meet, 
but maybe a conference call can accomplish the same thing. But even before that, let me lay out a proposal 
that I think should be acceptable to all parties. Here is what we propose ... and it essentially includes the "aye, 
aye
11 you requested, with some additiona·I provisions. 
We will agree to prepare a revised log in which we add dates for the emails and a description ofthe subject 
matter & parties. But we will also omit from the log any work product privilege objections, subject to the 
following agreement. All work product materials will be turned over to Plaintiff except for materials related to 
new or ongoing cases, AND on the condition that they be produced "For Attorneys' Eyes Only" such that no 
copies or images will be made of them, and Epstein will not see these documents, unless and until such time 
as Judge Crow and/or Judge Ray has overruled any privilege claim (following your recommended report, or 
course). If the objections are sustained, the documents will be returned to us and no copies retained by 
)Plaintiff's attorneys; if the objections are overruled and the documents otherwise deemed discoverable, 
Plaintiff gets them. The Plaintiff and his attorneys will also agree that by entering into this agreement and 
producing these documents as described, Plaintiff will not take the position that we have waived any 
privilege. Thus, the only items Your Honor will have to review and make privilege determinations would be as 
to work product m...

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' ., 
Carney can begin his review of the privileged docum~nts; We will then produce the revised log and the 
()Plaintiff's counsel can then raise any objections they have, and w~ can have one hearing before Judge Carney 
• 
on all issues before.he enters his recommended order to Judge Ray. 
finally, with regard to your review Judge, we think that itwill be an extreme Inconvenience to our firm to have 
to sit with you for a week o{ even a few.days while you conduct the in camera inspection. Instead, we 
propose that we submit a list to you ih which we idehtify as niany people as possible Whose identities or 
connection to the privilege claims may not be apparent; to aid you in your review. We can make ourselves 
available by phone if someone else corrtes.up, or for other questions. Alternatively, you could. put questio11ed 
items in a pile and then call both sides.in for any qt1estions you h_ave about that pile. This would greatly 
reduce the amount oftime the attorneys have to spend sitting around while Your Honor conducts.the 
review; While Plaintiffs counsel is being paid by the hour in this case, we are not and we. can put the time 
spentsitting while Your Honor reviews to much more productive use. Moreover, if Plaintiff agrees to the 
prnposal above for work product, the universe of documents in which Your Honor needs guidance should be· 
significantly reduced. 
I truly believe this to be a fair compromise that allows the process to proceed while we revise the log, and 
preserves all arguments for both sides. Please advise if this is acceptable. Thank you; 
Gary M. Farmer1 Jr., Esq. 
Civil Justice Attorney 
('Farmer, Jaffe, Weissing, 
-JEdwards, Fistos ft Lehrman, P.L. 
425 North Andrews Avenue; Suite 2 
• Fort Lauderdale, Florida 33301 
(954) 524-2820 
(954) 524-2822 fax 
(954) 648-3903 cell 
bathtojustice.corn 
Save a Tree I~ Please consider the envirorimenthefore prinUn_g this e-mail. 
NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSIO...

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present when] make my inspection because Iafu going to have to have input on vyho is.who. Because the log 
()canrtotfirstbe culled by the Plaintiff in i!s pr~sent form, this is g?ingt9 be a laborio~s and ve3rtime consum!ng 
;process, so we need to block off appropnat~ time now'.! don't thmk that a full week1s out oflme •. Judge Ray s 
Ordergives this.phase one month. • 
J seethls playing out as follows: 
L 1.Review of documents where privilege isclaimedto sedfthereis ~yfaciat'reasori.forthat claim. This means 
both sides being'ptesent as I go thru all 17,000 documents. Many d6cimierits are sentto third parties. Whether 
this waives the privilege depends on wllo the third partyis and how he or she fits into the case. Where there is. 
n9 privilege,,the documents would ,be ·eru.madced for. release to the'Plaintiff. The Plaintiff, as recently as one of 
Joe'slastemails, continuessrmder the belief that I am assistingthe Defendant in preparingthe log. lam.not. Iain 
,the neutral Master ruling on log. As such, Lam not going to work withthe Defe11dant on this. Both sides ate 
present or neither side is present duringthe review; 
• 
• • 
2. 2.After that process, for those documents where there legitiniatelyis a privilege, an evidentiaryhearingwm.ildbe 
conductedto see if the privilege has beeri abrogated in any way: 
• 
.,. 
. 
3. 3iPreparation of a Special Master'l.leport to'JudgeR.ay outlining my findings. 
Hadthe Defendantpreparedalog in compliancewith Tig, we might have been abieto shorten this process. 
Whethedhere has been an appropriate privilege log and·what sanction, if any; should be imposed if there-has 
not, can be addressed as we proceed, but we are urider a.one month time limitation as of now .. We need to meet 
(-)or conference not 1atfathail Wednesday as lindica.ted in my last email.Jf anyone has a better idea on how to 
_.1proceed, I run all ears, but I am not lookingto extend the Orcler. We liaveone inonth, and in the absence of 
comple...

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EXHIBIT 4 

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I , , 
Joseph L. Ackerman, Jr. 
_--...,prom: 
Sent: 
To: 
Subject: 
Gary Farmer <gary@pathtojustice.com> 
Wednesday, February 09, 2011 4:27 PM 
ROBERT CARNEY; Joseph L. Ackerman, Jr.; Lilly Ann Sanchez; Jack Scarola; CHRISTOPHER 
E. KNIGHT; Seth Lehrman; Brad Edwards 
RE: Suggestion 
Hello all. I wanted to provide and update, and get written confirmation from the Plaintiffs counsel of the deal that was 
verbally agreed to on Friday and put into an email by me on Monday. I have not received any reply to my Monday 
email. I will resend it after this. 
But by way of update I can tell you that we have four (4) boxes of documents that are ready to be turned over now (or 
when we get them back from a copy center that is scanning them) under the ag~eement. To be specific, we have 2 
boxes of documents that contain materials that we believe to be irrelevant but that implicate privacy rights of the 
parties or non-parties (mostly staff at the old RRA). These will be turned over subject to a confidentiality order (and that 
needs to be drafted, BTW), s.uch that Plaintiff & his counsel can immediately begin reviewing same. We also have 2 
more boxes that contain_ work product materials that we will turn over subject to the agreement that Plaintiff will not 
assert that any privilege has been waived by turning them over now, and further subject to the agreement that they be 
produced "For Attorneys' Eyes Only." Should Plaintiff or his attorneys believe that a document is not confidential or 
privileged, that objection will be brought before Judge Carney and he will issue a recommended order to both Judges 
Crow and Ray. 
_ We have also completed what I would estimate to be 1/5 of the revised privilege log, and are prepared to make those 
" 
pocuments available immediately for Judge Carney to begin reviewing, and we will produce that portion of the privilege 
- log to Plaintiff as well. We estimate that the privilege log will be completed by Tuesday, perhaps...

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pathtojustice.com 
Save a Tree! ~ 
Please consider the environment before priti.ting this e-mail. 
l ••• )NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED 
ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED 
RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY 
PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE COLLECT 
AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. 
From: ROBERT CARNEY [mailto:rbcarney3@gmail.com] 
Sent: Friday, February 04, 20114:31 PM 
To: Joseph L. Ackerman Jr.; Lilly Ann Sanchez; Jack Scarola; CHRISTOPHER E. KNIGHT; Gary Farmer; Seth Lehrman; 
Brad Edwards 
Subject: Suggestion 
I have another suggestion for you all to ponder over the weekend. I am assuming by now that all have read 
Judge Crow's Order. Translated into plain English, he is saying 'I don't care what you all do in bankruptcy 
court. i am only bound by it ifI agree with it.' This puts everyone in a precarious position. Epstein's rights only 
come from his state court subpoena, and what he puts in evidence in state court is controlled by Judge Crow, not 
by Judge Ray. Remember, Judge Ray has no interest in the outcome of the state court litigation, no interest in 
what gets put into evidence in state court, and no interest in whether Epstein gets to look at the documents. He 
is only looking to protect the trustee. 
( )We can be wasting a huge amount of time and mo.ney if the state court does not like what Judge Ray does. And 
• the Plaintiff is not really going to be able to circumvent an adverse order by Judge Crow by waiving Judge 
Ray's Order at him. 
So here is my suggestion. I have made this before and will do it again. Both sides request a stay from Judge Ray 
with a request to let Judge Crow rule on this. It is, after ...

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EXHIBIT 5 

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MEETING HELD BEFORE SPECIAL MASTER ROBERT CARNEY 
IN RE: 
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
Complex Litigation, Fla. R. Civ. Pro.1201 
CASE NO. 50 2009CA040800XXXXMB AG 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, individually, 
and L.M., individually, 
Defendants. 
I 
-'-------------------
DATE TAKEN: 
Wednesday, February 16, 2011 
10:05 AM -
11:15 AM 
TIME: 
PLACE: 
SEARCY DENNEY SCAROLA BARNHART & SHIPLEY 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Lee Lynott, Registered Merit Reporter 
Registered Professional Reporter 
Certified Shorthand Reporter 
Hi-Tech/United Reporting, Inc. 
1218 SE 3rd Avenue 
Fort Lauderdale, FL 33316 
United Reporting, Inc. 
954-525-2221 
1 

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191 
201 
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41 
to 
Let me see if we can cut quickly to the chase 
here. 
I 
The confidentiality, can we get the confidentiality 
I 
1 
worked out so that we get something in writing so 
everyone is happy, in writing by next Friday at the 
latest? 
MR. ACKERMAN: 
That will be fine. 
MR. FARMER: 
How about this Friday? 
MRS. SANCHEZ: 
The documents are ready to go. 
Write 
up whatever you want and we'll -- we don't have a· 
problem with that. 
MR. FARMER: 
You guys have to have 19,000 
confidentiality orders done in other cases and you get 
paid by the hour to do this. 
MRS. SANCHEZ: 
I don't have a problem, but we will 
get an order to you by tomorrow and you can get the 
documents to us by Friday, and that's done. 
MR. FARMER: 
Do you still want to do the 
attorney's-eyes only? 
Do you want to speed it up or 
not? 
You'll get work-product stuff if you agree to the 
attorney's-eyes only. 
MRS. SANCHEZ: 
Yes. 
MR. KNIGHT: 
We need to get the ball rolling. 
MR. ACKERMAN: 
Let's do that. 
MRS. SANCHEZ: 
Yes. 
United Reporting, Inc. 
954-525-2221 
• I 

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EXHIBIT 6 

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CM/ECF - Live Database - flsd 
Page 1 of 47 
REF_ SETTLEMENT,WM 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE#: 9:08-cv-80736-KAM 
Doe v. United States of America 
Assigned to: Judge Kenneth A. Marra 
Referred to: Magistrate Judge Dave Lee Brannon 
(Settlement) 
Case in other court: USCA, 13-12923-C 
USCA, 13-12926-C 
USCA, 13-12928-C 
Cause: no cause specified 
Petitioner 
Date Filed: 07/07/2008 
Jury Demand: None 
Nature of Suit: 440 Civil Rights: Other 
Jurisdiction: U.S. Government 
Defendant 
Jane Doe 
represented by Bradley James Edwards 
V. 
Respondent 
United States of America 
represented by 
Farmer Jaffe Weissing Edwards Fistos 
&Lehrman PL 
425 N Andrews Avenue 
Suite 2 
Fort Lauderdale, FL 33301 
954-524-2820 
Fax: 954-524-2822 
Email: brad@pathtojustice.com 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jay C. Howell 
Jay Howell & Associates PA 
644 Cesery Boulevard 
Suite 250 
Jacksonville, FL 32211 
Email: jay@jayhowell.com 
PROHAC VICE 
ATTORNEY TO BE NOTICED 
Paul G. Cassell 
Email: cassellp@law.utah.edu 
PROHACVICE 
ATTORNEY TO BE NOTICED 
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?96 l 881247922712-L _ l _ 0-1 
10/23/2017 

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CM/ECF - Live Database - flsd 
Page 8 of 47 
Clerks Notice of Docket Correction and Instruction to Filer re 30 
Response/Reply (Other), Response/Reply (Other) filed by Jane Doe. Error -
Wrong Event Selected; Correction - Redocketed by Clerk as Reply to 
Response to Motion. Instruction to Filer - In the future, please select the proper 
event. It is not necessary to refile this document. (ls) (Entered: 10/17/2008) 
12/05/2008 
33 
Sealed Document. (rb) (Entered: 12/05/2008) 
12/05/2008 
SYSTEM ENTRY - Docket Entry 32 restricted/sealed until further notice. ( dj) 
(Entered: 11/03/2010) 
12/09/2008 
34 Clerks Notice of Docket Correction re 33 Sealed Document. Error(s): Sealed 
Document Filed in Wrong Case; Correction - Original document restricted and 
refiled in correct case. (rb) (Entered: 12/09/2008) 
12/22/2008 
35 AFFIDAVIT signed by : A. Marie Villafana. re 14 Affidavit, .U 
Response/Reply (Other) Supplemental Declaration by United States of 
America. (Attachments: # l Certification Certificate of Service )(Villafana, Ann 
Marie) (Entered: 12/22/2008) 
02/12/2009 
36 ORDER denying 28 Motion to Unseal Document. Signed by Judge Kenneth A. 
Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 
04/09/2009 
37 NOTICE by Jane Doe of Change of Firm Affiliation (Edwards, Bradley) 
(Entered: 04/09/2009) 
09/08/2010 
38 Administrative Order Closing Case. Signed by Judge Kenneth A. Marra on 
9/8/2010. (tb) (Entered: 09/09/2010) 
09/13/2010 
39 NOTICE by Jane Doe re 38 Administrative Order In Response to 
Administrative Order Closing Case (Edwards, Bradley) (Entered: 09/13/2010) 
10/12/2010 
40 ORDER TO SHOW CAUSE for lack of prosecution. Show Cause Response 
due by 10/27/2010. Signed by Judge Kenneth A. Marra on 10/8/2010. (ir) 
(Entered: 10/12/2010) 
10/27/2010 
41 
STATUS REPORT by Jane Doe (Edwards, Bradley) Modified to add missing 
event 42 Response to Order to Show Cause on 10/28/2010 (ls). (Entered: 
10/27/2010) 
10/27/2010 
42 RESPONSE TO ORDER TO SHOW...

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EXHIBIT 7 

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IN THECIRCUIT COURT OF THE 15th JUDICIAL ClllCUIT 
IN AND FORPALM BEACH:Cc:>UNTY, FLORIDA .. I 
• ' CIVIL DIVISION AG 
.CASE N0.'502009CA040800xxxxMB 
Judge David F. Crow -
JEFFREY EPSTEIN: 
Plaintiff/Cm..mter-Defend.ant, 
,. : 
:• v. 
SCOTT ROTHSTEIN, 'individually; and 
'BRADLEY J; EDWARDS, individually, 
-An4£ J7+ ~l),,-1v,-'4y?1 6:Jif. i..i'' 1.-isii-/6&d-·tM· ·dt 
c Au. .. Mz,:.L, 4Usa M-4- 0-:p?J wdu A u311,.,.,....b 
-~-
PP.~C!.,P' l.2&0(!,)(s-J.·a;1a • Tl~ Y1r.s#·Cfir~~- • , . 
:iJ rs/4,i,;rn i 799 Su·2c/ 33 CJ (Fl£... 9-tl /Jc-A ;Mo 1) .. ~ 
n 

NOT A CERTIFIED COPY
., 
Epstein v. Rothstein and Edwards 
Case No. 502009CA040800XXXXMB/Division AG 
Order· ori Epstein's Motion to Compel and for Sanctions 
Page 2 of 2 
. 
. 
. 
. • . 
.. 7h . 
aP olu, . ~ 
~ 1',. M..t,71Uk /Jde,1.,,.<f.a.--l- .if" 
· 
I 
. 
V> 
~ 
...... . 
77~. 
. 
DONE AND ORDERED in Chambers at.West Palm Beach, Palm Beacli _Cqunty, Florida. 
this ~ay of~ 2012. 
• 
fi11.7r 
~~~'in~~~~ ID.F. CROW'~ 
cf:Y 
.Copies furnished to: 
J\)sepij L. AAennJH\, JtEsq; 
~ 
!ow"JeN!ll!lie'Btlmel'r,-tl.A, 
AW 
7 ·aie 
~l 
~"1/ 
i~?L~ 
.. L::;~: Esq../& 
.. ·•·.~-·.·".~-·-·_ 
........ • 
Four Seaso11~ Tower,,'15!h Floor 
~- ~ 
~ill,?,~f}~'r
0 
A.~ 
JackScarola, Esq. 
, rr:-..·v . 
• Searcy Denney Scarola BaniliWhiple)', P.A. 
2139 Palm Beach Lakes Blvd. 
. 
. 
. 
. 
. 
.. ,,..__ ... 
we·st Palm Beach, FL 33i9Y 
_JackA,. Goldbergf ~sq, 
__ 
.. . 
• 
Atteroury; Golµberger-'& Weiss, P.A. 
• 
• 
., 
" ' \ 
, 
•. 
. 
• 
• 
250 AustrahanAvenue, South,Suite 1400 
. 
< ' ::,-. • .. V. 
•• 
• 
·.· 
• 
. ..... . 
V,,es~e]lcH, FL 33401-5012 
MW'.c s. ~unk, Esq. 
_ . . _ . 
Law Offices ofMarc·s. Nurik 
One E. Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
BradleyJ. Edwards, Esq, _ 
. 
Farmer; Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 
425,North AndrewsAvenµe, Sui~e.2· 
Fort Lauderdale; FL 33301 

NOT A CERTIFIED COPY
EXHIBIT 8 

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,, 
' 
TN.THE CIRCUIT COURT OF THE 
FIF.TEENT!I.JlJDICIAL·CIRClliT,'JNAND 
.FOR PALM BEACH COUNTY!FLORIDA • •. 
. 
"' " . 
. -
. . .. - . 
. 
. 
·-· . 
- -
. 
·-
-• . 
--~ . 
. 
- -
-
pASE NO.: 502009CA040800XXXXM8Acr 
JEJ:<FllEY;EPSTEIN, 
;~:i.,~ . ,, 
• •'>- ••• 
.,...._,j,_ ~ 
(-•~·--
s 
t{:C i½C.::~' ' 
Pfaintiff{s k 
vs: 
,::0 CO 0, • ~y -,, 
SCOTT ROTHSTEIN, ind.ivid~~lly,. 
~~~ ~ . ---.; 
BRADLEY J. EDWARDS, individually, and 
t1:?c:;igV•'....., r-, 
L.M., individually, 
• 
0~~9" ~ m.• 
... ·., 
-1S2 w j~ 
::<' 
•• 
\.,;J 
Defendant(s). 
:,_, g. ~ · 
ORDER
0
ON OUSTAND:G DISC~~~TIONS,'- ·, •• -
'THIS .CAUSE having conie to be consit~~gust 3, '2012, on oiitstanding 
discovery motions, and the Court having_A~tlfo file and being fully advised in the 
premises, it is hereby, 
~ 
~ 
. ORDERED and AD~9Z~>1'°W ARD~' Motion. fo'. Clarification i' GRANTED, 
and this Court's Order of M~O.il:2 is vacated without preJudice. EDWARDS shall file a 
mi~en response .spe .. cif\~_ daressifi~Jhe production sought in. Paragraph 13 -~f E~STEIN's 
Motion to C:omP.':'1~and ~end Protective Order of March 9, .2012 as Ordered m this· Court's 
A~ri'. I~, ~~-r; Th· response. ~h•n identify non°~riyileged res~onsive documents 
prev1ou§!Y~prodfced, shall 'be .accompanied ·by -all non:-pnvileged responsive .documents not 
prev~oduced, if any, and shall identify, in a proper priviiege iog as referenced iri this 
Coutt's May 7, ·2012 Qrder, r~sponsive documents withheld from production oriAhe basis of any 
assertion of privileg_e: This response shall be filed within 10 days,from th~ date of this Order. 

NOT A CERTIFIED COPY
Edwards aa.v.Epsteln. 
. . ..... . . . 
. 
Case No.: 502009CA040800XXXXMBAG. 
Order ()D Qutstand!ng _Dls~ov,ery Motions 
DONE AND ORDERED at We~tlalm Beiich,Palm BeachCounty, Florida, this 
DA 
• CROW~, 
- , '-\,, 
CIRCUIT JUDGE . } ) 
0 
C~pies have been furnished to all counsel on the attached counselllib 
''§)' 
- ~  
~~ 
• 
• ~~)7 
G~~ 
---~~-
~(;j 
2 

NOT A CERTIFIED COPY
Ed\vards adv, Epstein 
Case No;:. 502009CA040800XXXXMBAG 
Order on Outstanding Discovery Motions 
COUNSEL LIST 
Jack A. Goldberger, Esquire 
j golcltJerger@agwpa;coni; • 
. ·srnahoney@agwpa.com 
•A-tterlmry,.·Goldberger&Weiss;P.A; 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-659-8300 
Fa?C: (561)-835-8691 
Bradley :J. Ed\\'ards, Esquire· 
brad@pathtoJustice.com' 
Farmer, Jaffe, Weissing, Edwards, Fistos & 
Lehrman,EL 
425 North Andrews·Avenue, Suite 2 
ForlLaud~rdale, FL 33301. 
Ph.one: (954)~s24~2820 
Fax: (954 )-524~28i'.i 
Tonja Haddad Colemani Esquire 
to,nja@tonjahaddadpa.com 
S24. S. Andr.ew. sAv. e.11ue, Suite .2·~· 
.. g_D~ . 
F 011 Lau. de. rel.ale., F.L .3330. 1~. 
·• .. · • • •• 
Phone: (954)~467-1223• 
. :· 
.Fax:(954H37-3716 .•~·•. •• 
Lilly.Ann Sanche~irc 
·.Jsanchez@thelsfirm:com 
The L~s La~irtn 
14~1 ~iikcill?A,~enue, 15th Floor 
Miami; Eh 33131 
~rieJ39S)-503-5503 
. A~ 
(3y5)-503-6801 
~1k Scarola, Esquire 
. 
Searcy Denney Scarola Barnhart & Shipley 
M 
... •· a·r.c S .• N~n.·k 
.•. ~ Es. qu. ire . . . 
... ~· 
.•... . 
.2 
.. 139 Pa. Im B.each. La. k.e· s B.·· .oulevard 
marc@nunklaw.com 
./2- .• ·· • · · 
West Pal~ Beach, FL 33409 
On. e E Browar<iB· l·vd .• ,· Suit_e 70.0 :"..~~ 
... · • •• • 
Phone: 561. -686-630.0 
F.o·.·rt···L. au·d· e.rd. ale., FL. 33301 ·G·: 
Fax:. 
561-383-9451 
Phone: (954)-745-5849 
• 
•. 
Attorneys for Edwards 
Fax: (954}-745-3556 
• • ... 
• 
. ·.·~ 
-·~· 
-~(J 
3 

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EXHIBIT 9 

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INRE: 
UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
www.tlsb.uscourts.gov 
ROTHSTEIN ROSENFELDT ADLER, P.A., 
Debtor. 
CASE NO.: 09-34791-RBR 
CHAPTER 11 
-----------~' 
PRIVILEGE LOG 
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & 
LEHRMAN 
Dated: February 23, 2011 
Total of 159 pages 
EXHIBITQ. 

NOT A CERTIFIED COPY
Privilege Log - Dated 2•23·2011 
Farmer. Jaffe, Weissing. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
08076-08089 
08/04/2009 
Bradley Edwards 
Spencer Kuvin 
Transcript of Alfredo Rodriguez 
Joint W/P Priv. 
Deposition 
08311-08318 
05/26/2009 
Bradley Edwards 
Katherine Ezell 
WPB-Confidential-General-
Joint W/P Priv. 
Financial Disclosure/Discovery 
08319-08324 
10/16/2009 
Bradley Edwards 
Amy Ederi 
WPS-General-Confidential 
Joint W/P Priv. 
08398 
09/01/2009 
Bradley Edwards 
Kikka Claudio 
C.M.A. 
vs. 
Epstein, 
et Joint W/P Priv. 
al. ( File#:281849) 
08402 
09/17/2009 
Bradley Edwards 
Paul Cassell 
Report this as a parole violation 
Joint W/P Priv. 
08415 
09/16/2009 
Bradley Edwards 
Margaret Berk 
Scanned 
document 
from 
Joint W/P Priv. 
Margaret Berk 
08422 
08/11/2009 
Bradley Edwards 
Katherine Ezell 
Subpoena 
directed 
to 
the Joint W/P Priv. 
investigators 
10060 
08/03/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein-Depa-New York 
Joint W/P Priv. 
10069-10074 08/04/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Transcript 
of 
Alfredo 
Joint W/P Priv. 
Rodriguez Deposition 
10077-10079 08/06/2009 
Bradley Edwards 
Mercedes Estrada 
RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. 
& Epstein vs. Jane doe No. 102 
10099-10102 
08/27/2009 
Bradley Edwards 
Spencer Kuvin 
RE: Epstein Oepo 
Joint W/P Priv. 
10192 
08/11/2009 
Adam Horowitz 
Jacquie Johnson 
Trump Depa moved 08/18 to 
Joint W/P Priv. 
9/24 in NY 
10194-10195 
08/11/2009 
Jacquie Johnson 
Kikka Claudio 
FW: Out of state subpoenas 
Joint W/P Priv. 
10264-10266 
08/09/2009 
Adam Horowitz 
Jacquie Johnson 
RE;Epstein-Letter 
regarding Joint W/P Priv. 
Leslie Wexner 
1 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
' 
' 
I 
Farmer Jaffe Weissin2 Edwards Fistos & Lehrman 
SATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
10279-10291 08/10/2009 
Adam Horowitz 
Jacquie Johnson 
RE: Epstein-Notice of production Joint W/P Priv. 
from non parties/depo of Jane 
Doe 
10372-10373 09/17/2009 
Bradley Edwards 
Katherine Ezell 
RE: Leslie Wexner 
Joint W/P Priv. 
10490-10493 
09/21/2009 
Bradley Edwards 
Amy Ederi 
FW: Epstein Depa 
Joint W/P Priv. 
10592-10593 09/29/2009 
Bradley Edwards 
Katherine Ezell 
RE: Leslie Wexner 
Joint W/P Priv. 
10604-10620 10/01/2009 
Bradley Edwards 
Katherine Ezell 
FW:meeting w/ atty fr wexner 
Joint W/P Priv. 
10639-10643 
10/06/2009 
Bradley Edwards 
Stuart Mermelstein 
Meeting w/Leslie Wexner 
Joint W/P Priv. 
10700-10702 
10/13/2009 
Adam Horowitz 
Jacquie Johnson 
Depo 
Joint W/P Priv. 
10724-1073 
10/14/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein-de po of Alan Dershowitz 
Joint W/P Priv. 
10897 
10/29/2009 
Bradley Edwards 
Stuart Mermelstein 
Leslie Wexner 
Joint W/P Priv. 
10992-11005 06/22/2009 
Bradley Edwards 
Amy Ederi 
RE:Regular Monthly Cong. Call 
Joint W/P Priv. 
11011-11021 06/23/2009 
Bradley Edwards 
Katherine Ezell 
RE:Regular Monthly Cong. Call 
Joint W/P Priv. 
11026-11032 
07/09/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
commissioner Joint W/P Priv. 
appointees 
11072-11074 07/28/2009 
Bradley Edwards 
Katherine Ezell 
Possible 
witness 
from 
Joint W/P Priv. 
Switzerland 
11166-11169 06/23/2009 
Katherine Ezell 
Bradley Edwards 
RE:Article:Bear Stearns 
Joint W/P Priv. 
2 

NOT A CERTIFIED COPY
···-··-····:: ___ .-:, .. 
Privilege Log - Dated 2-23-2011 
' 
& 
' 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
11240-11245 06/22/2009 
Katherine Ezell 
Bradley Edwards 
Article:Bear Stearns 
Joint W/P Priv. 
11248-11250 06/22/2009 
Amy Ederi 
Bradley Edwards 
Article:Bear Stearns 
Joint W/P Priv. 
11255-11259 
06/23/2009 
Katherine Ezell 
Bradley Edwards 
USAO Chose Bradley Edwards Joint W/P Priv. 
conversation 
11269-11281 06/30/2009 
Stuart 
Bradley Edwards 
RE:Epstein 
Depo;possible 
Joint W/P Priv. 
Mermelstein 
deponents 
11316-11319 
06/28/2009 
Katherine Ezell 
Bradley Edwards 
Discussion 
about 
possible 
Joint W/P Priv. 
witness from Switzerland 
11332-11336 
08/04/2009 
Spencer Kuvin 
Bradley Edwards 
FW:Transcript 
of 
Alfrefo Joint W/P Priv. 
Rodriguez Depo and Copperfeild 
and Clinton's whereabouts 
11340-11341 
08/05/2009 
Mercedes 
Bradley Edwards 
RE:Epstein vsJane Doe No.101 & 
Joint W/P Priv. 
Estrada 
102 
11348-11358 
08/06/2009 
Adam Horowitz 
Bradley Edwards 
RE:Motion 
for 
protective Joint W/P Priv. 
order/discussion 
11430-11434 
08/27/2009 
Spencer Kuvin 
Bradley Edwards 
Discussion 
RE:Wexner 
Joint W/P Priv. 
involvement 
11443 
09/17/2009 
Katherine Ezell 
Bradley Edwards 
Wexner served subpoena OH 
Joint w/P Priv. 
11541-11542 
09/29/2009 
Katherine Ezell 
Bradley Edwards 
RE:Leslie Wexner & Bob 
Joint W/P Priv. 
11551-11559 
10/01/2009 
Spencer Kuvin 
Bradley Edwards 
RE:Meeting w.Stanely Arkin 
Joint W/P Priv. 
11585-11586 
10/14/2009 
Adam Horowitz 
Bradley Edwards 
RE:Epstein;Larry 
Visoski 
Joint W/P Priv. 
confirmed 
11675-11676 
10/29/2009 
Stuart 
Bradley Edwards 
RE:Leslie Wexner attorney info 
Joint W/P Priv. 
Mermelstein 
3 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinR: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
15981-15988 08/04/2009 
Spencer Kuvin 
Jacquie Johnson 
Attach ment:Kellen 
& 
Trump Joint W/P Priv. 
subpoena 
15999-16007 
08/05/2009 
Bert Patton 
Jacquie Johnson 
RE:Epstein Depo-New York 
Joint W/P Priv. 
16057-16065 08/06/2009 
Mercedes 
Jacquie Johnson 
Trump and Maxwell Dep dates 
Joint W/P Priv. 
Estrada 
15918-15949 08/04/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depo's 08/14,17,18 in 
Joint W/P Priv. 
NY&OH 
16066-16069 08/06/2009 
Adam Horowitz 
Jacquie Johnson 
Maxwell,Trump, Wexner convo Joint W/P Priv. 
RE:Depo dates 
16095-16098 
08/11/2009 
Adam Horowitz 
Jacquie Johnson 
Maxwell, Trumo, Wexner 
Convo 
Joint W/P Priv. 
RE:Depo dates cont.. 
15813-15814 
10/29/2009 
Stuart 
Bradley Edwards 
Wexler Lawyer's info 
Joint W/P Priv. 
Mermelstein 
15856 
08/03/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein pepo-NY;2 Attachments 
Joint W/P Prlv. 
15866-15881 
08/03/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Oepos 08/14,17,18 in 
Joint W/P Priv. 
NY&OH/PDF of Sarah 
Kellen 
Notice of Videotaped Depo 
15893-15901 
08/03/2009 
Kikka Claudio 
Jacquie Johnson 
Depo &subpoena 
notice for Joint W/P Priv. 
Trump 
15360-15363 
09/01/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Alan Dershowitz;Harvard Law Joint W/P Priv. 
Info 
15394-15397 
09/09/2009 
Jacquie Johnson 
Katherine Ezell 
RE:Epstein-Depos of Marcinkova 
Joint W/P Priv. 
& Sarah Kellen 
15413-15428 
09/10/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Esptein-Notice of Prodcution Joint W/P Priv. 
from Non Parties 
15434-15437 
09/10/2009 
Jacquie Johnson 
Katherine Ezell 
Notice Of Production from Non-
Joint W/P Priv. 
Parties discussion 
4 

NOT A CERTIFIED COPY
_____ . ___ .. :_ ..... ____ _ 
Privilege Log - Dated 2-23-2011 
I 
' 
C 
' 
Farmer Jaffe Weissimt Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
15454-15475 
09/15/2009 
Adam Horowitz 
Jacquie Johnson 
Critton's notice of depo;Epstein Joint W/P Priv. 
notice of hearing,Mark Epstein 
notice of depo 
01465 
07/13/2009 
Katherine Ezell 
Bradley Edwards 
Epstein 
Joint W/P Priv. 
15485-15492 09/17/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Epstein Depo 
Joint W/P Priv. 
15493-15500 09/18/2009 
Jacquie Johnson 
Katherine Ezell 
RE:Deposition 
of 
Jean 
Luc 
Joint W/P Priv. 
Bruhnel 
15501-15555 09/18/2009 
Jacquie Johnson 
Adam Horowitz 
RE:Epstein Depo 
Joint W/P Priv. 
15556-15564 09/22/2009 
Jacquie Johnson 
Margaret Berk 
Epstein Depos 
Joint W/P Priv. 
15565-15575 09/25/2009 
Jacqufe Johnson 
Lisa Rivera 
FW:Deposition 
of 
Jean 
Luc 
Joint W/P Priv. 
Bruhnel 
15687-15688 10/01/2009 
Jacquie Johnson 
Lisa Rivera 
Depo of David Hart Rogers 
Joint W/P Priv. 
15692-15707 
10/01/2009 
Jacquie Johnson 
Katherine Ezell 
FW:Meeting w/Sranley Arkin 
Joint W/P Priv. 
15708-15709 
10/06/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Jane Does 2-Sv. Epstein-Cross Joint W/P Priv. 
Nod's of Oct 6-8 depos 
15033-15032 08/05/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Epstein-Depo for 8/17 
Joint W/P Priv. 
15087-15093 08/06/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Epstein-Depo for 8/17 
Joint W/P Priv. 
15094-15100 08/06/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epsteln Depo-New York 
Joint W/P Priv. 
15109-15112 08/10/2009 
Jacquie Johnson 
Adam Horowitz 
RE:Epstein 
Depositions 
for Joint W/P Priv. 
8/14,17,18 in NY & OH 
5 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
I 
I 
t 
Farmer Jaffe Weissinl! Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
15122-15125 
08/11/2009 
Jacquie Johnson 
Kikka Claudio 
RE: 
Ms. 
Maxwell 
Depo 
Joint W/P Priv. 
rescheduled 
15142-15158 
08/11/2209 
Bradley Edwards 
Kikka Claudio 
FW:out of state subpoenas 
Joint W/P Priv. 
1.5166-15170 08/11/2009 
Jacquie Johnson 
Kikka Claudio 
RE:out of state subpoenas 
Joint W/P Priv. 
1.5171-15172 
08/11/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein 
Joint W/P Priv. 
15178-15182 
08/12/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein 
Joint W/P Priv. 
15306-15355 
08/25/2009 
Jacquie Johnson 
Kikka Claudio 
FW:Epstein Depo Notices & Subs 
Joint W/P Priv. 
14951-14952 
08/03/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein Depo-New York 
Joint W/P Priv. 
14954-14972 
09/16/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein-Depo of Mark Epstein 
Joint W/P Priv. 
on 9/21 in NY will take place as 
scheduled 
14979-14981 
08/03/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein Depo-New York 
Joint W/P Priv. 
14983-15015 
08/04/2009 
Jacquie Johnson 
Adam Horowitz 
RE:Epstein Depositions 8/14.17, Joint W/P Priv. 
&18inNY&OH 
16501-16519 
09/15/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Hearing 
Joint W/P Priv. 
16520-16547 
09/09/2009 
Spencer Kuvin 
Jacquie Johnson 
RE:Epstein-Deposition of Jane 
Joint W/P Priv. 
Doe-9/30/2009 
16355-16384 
08/24/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Depo Notices and Subs 
Joint W/P Priv. 
16554-16568 09/16/2009 
Kikka Claudio 
Jacquie Johnson 
RE:Epstein Depo 
Joint W/P Priv. 
6 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
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C 
Farmer Jaffe Weissint Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
16574-16577 09/17/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depo 
Joint W/P Priv. 
16396-16398 09/01/2009 
Margaret Estrada 
Jacquie Johnson 
Alan Dershowitz 
Joint W/P Priv. 
16578-16581 09/17/2009 
Katherine Ezell 
Jacquie Johnson 
RE:Depo 
Joint W/P Priv. 
16582-16585 09/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Deposition 
of 
Jean 
Luc Joint W/P Priv. 
Bruhnel 
16585-16611 09/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depo 
Joint W/P Priv. 
16612-16439 09/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depa of Mark Epstein 
Joint W/P Priv. 
16440 
08/18/2009 
Spencer Kuvin 
Jacquie Johnson 
RE:Epstein Sub to Bear Stearn 
Joint W/P Priv. 
16740-16753 09/22/2009 
Margaret Berk 
Jacquie Johnson 
RE:Epstein Oepos 
Joint W /P Priv. 
16443-16452 09/09/2009 
Katherine Ezell 
Jacquie Johnson 
RE:Epstein-Depos of Marcinkova Joint W/P Priv. 
& Sarah Keller 
16777-16786 09/30/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein 
Joint W/P Priv. 
16793-16794 10/01/2009 
Lisa Rivera 
Jacquie Johnson 
RE:Depo of David Hart Rogers 
Joint W/P Priv. 
16462-16477 09/10/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein-Notice of Production Joint W/P Priv. 
from Non Parties 
16802-16823 10/02/2009 
Margaret Berk 
Jacquie Johnson 
RE:Epstein depos 
Joint W/P Priv. 
16483-16486 09/10/2009 
Katherine Ezell 
Jacquie Johnson 
RE:Epstein-Notice of Production Joint W/P Priv. 
from Non Parties 
I 
7 

NOT A CERTIFIED COPY
Privilege Log - Dated 2·23·2011 
I 
I 
I 
Farmer Jaffe W~issing~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
16874-16880 10/13/2009 
Adam Horowitz 
Jacquie Johnson 
Depo 
Joint W/P Priv. 
16904-16905 
10/14/2009 
Spencer Kuvin 
Jacquie Johnson 
RE:Epstein 
Joint W/P Priv. 
16945 
10/26/2009 
Kikka Claudio 
Jacquie Johnson 
RE:Epstein depos on 10/28 
Joint W/P Priv. 
17033-17034 
10/26/2009 
Kikka Claudio 
Jacquie Johnson 
RE:Epstein depos on 10/28 
Joint W/P Priv. 
02065-02068 
06/08/2009 
Bradley Edwards 
Mercedes Estrada 
FW:Epstein-Conflrming 
AT&T Joint W/P Priv. 
Dial Telephone Conference for 
Mon 6/8/09 at 2:00 p.m. 
02070 
09/02/2009 
Jacquie Johnson 
Spencer Kuvin 
FW:Epstein-Depos 
of Joint W/P Priv. 
Marcinkova & Sarah Kellen 
02071 
08/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Sub to Bear Stems 
Joint W/P Priv. 
02072-02078 
09/04/2009 
Jacquie Johnson 
Spencer Kuvin 
FW:Epstein-Depos 
of Joint W/P Priv. 
Marcinkova & Sarah Kellen 
03466-03468 
05/14/2009 
Spencer Kuvin 
Bradley Edwards 
RE:Actvity 
in 
Case 
9:08-cv-
Joint W/P Priv. 
80893-KAM Doe v. Epstein Order 
on Motion to Stay 
02301-02302 
09/09/2009 
Paul Cassel 
Bradley Edwards 
FW:Epstein 
Joint W/P Priv. 
03122-03123 
06/10/2009 
Adam Horowitz 
Bradley Edwards 
FW: Motion to Dismiss 
Joint W/P Priv. 
02805-02806 
05/26/2009 
Susan Stirling 
Katherine Ezell 
RE:WPB-Confidential-Genereal-
Joint W/P Priv. 
financial Disclosure/Discovery 
02670-02671 
10/21/2009 
Bradley Edwards 
Spencer Kuvin 
FW:Subpoena Info 
Joint W/P Priv. 
02517-02519 
10/02/2009 
Bradley Edwards 
Katherine Ezell 
FW:Meeting w/Stanley Arkin 
Joint W/P Priv. 
8 

NOT A CERTIFIED COPY
------,-,.·-··--···-·· .. 
Privilege Log - Dated 2m23-2011 
Farmer Jaffe. WeissinR. Edwards. Fistos & Lehrman 
C 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
02614-02617 
08/05/2009 
Bradley Edwards 
Kikka Claudio 
FW:Proposal Request 
Joint W/P Priv. 
15702-15704 10/02/2009 
Bradley Edwards 
Katherine Ezell 
FW:Meeting w/Stanley Arkin 
Joint W/P Priv. 
15581-15585 09/28/2009 
Bradley Edwards 
AmyEderi 
FW:Epstein Depo 
Joint W/P Priv. 
15431-15433 09/10/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein-Notice of Production Joint W/P Priv. 
from Non Parties 
15797-15798 10/14/2009 
Spencer Kuvin 
Bradley Edwards 
RE:Epstein 
Joint W/P Priv. 
11560-11562 
10/02/2009 
Bradley Edwards 
Katherine 
Jacquie 
FW:Meeting w/Stanley Arkin 
Joint W/P Priv. 
Johnson 
11444-11448 09/28/2009 
Bradley Edwards 
AmyEderi 
FW:Epstein Depo 
Joint W/P Priv. 
05823 
09/04/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein 
Joint W/P Priv. 
05832 
09/08/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein 
Joint W/P Priv. 
05838 
09/08/2009 
Jacquie Johnson 
Jack Hill 
RE:Epsteln 
Joint W/P Priv. 
05847 
09/09/2009 
Jacquie Johnson 
Katherine Ezell 
RE:Epstein 
Joint W /P Priv. 
05859 
07/23/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein 
Joint W/P Priv. 
05863-05864 07/23/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein 
Joint W/P Priv. 
05886-05887 07/24/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein 
Joint W/P Priv. 
9 

NOT A CERTIFIED COPY
.. _.·.,.·_. _________ _ 
Privilege Log - Dated 2·23-2011 
Farmer1 Jaffe. Weissin~. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05902-05903 07/28/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein 
Joint W/P Priv. 
05906-05907 07/28/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein 
Joint W/P Priv. 
05912 
08/27/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
Joint W/P Priv. 
05928-05930 07/28/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein 
Joint W/P Priv. 
05933-05934 09/18/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
Joint W/P Priv. 
05936 
09/18/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
Joint W/P Priv. 
05938 
09/18/2009 
Bradley Edwards 
Adam Horowitz 
RE:Epstein 
Joint W/P Priv. 
05940-05941 09/18/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
Joint W/P Priv. 
05951 
05/29/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
Joint W/P Priv. 
05957-05960 09/09/2009 
Bradley Edwards 
Kikka Claudio 
RE:Epstein 
Joint W/P Priv. 
05970-05971 10/21/2009 
Jacquie Johnson 
Margaret Berk 
RE:Epstein 
Joint W/P Priv. 
05982-05983 
10/28/2009 
Bradley Edwards 
Spencer Kuvin 
RE:Epstein 
Joint W/P Priv. 
05993-05994 09/09/2009 
Bradley Edwards 
Adam Horowitz 
RE:Epstein 
Joint W/P Priv. 
05997 
08/06/2009 
Bradley Edwards 
Kikka Claudio 
RE:Epstein 
Joint W/P Priv. 
10 

NOT A CERTIFIED COPY
·:_:·.·:_·: __ 
Privilege Log- Dated 2-23-2011 
Farmer Jaffe. Weissine:. Edwards. Fistos & Lehrman 
I 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
01029 
10/08/2009 
Bradley Edwards 
Carolyn Edwards 
Brian Ryalls 
Joint W/P Priv. 
07707 
09/03/2009 
BradleyEdwards 
Kikka Claudio 
RE:Regarding:C.M.A. vs. Epstein. 
Joint W/P Priv. 
Et al.(File# 281849) 
07708-07709 06/22/2009 
Bradley Edwards 
AmyEderi 
RE:Regular Monthly Cong. Call 
Joint W/P Priv. 
on34 
07/24/2009 
Jessica Caldwell 
Bradley Edwards 
RE:Release 
Joint W/P Priv. 
07218-07219 
10/02/2009 
Bradley Edwards 
Katherine Ezell 
RE:Meeting w/Stanley Arkin 
Joint W/P Priv. 
06861-06863 05/12/2009 
Bradley Edwards 
Katherine Ezell 
RE:Jane Doe II v. Epstein 
Joint W/P Priv. 
06876-06879 
05/12/2009 
Bradley Edwards 
Stuart Mermelstein 
RE:Jane Doe II v. Epstein 
Joint W/P Priv. 
06891-06897 
05/12/2009 
Bradley Edwards 
Katherine Ezell 
RE:Jane Doe II v. Epstein 
Joint W/P Priv. 
06901 
09/11/2009 
Bradley Edwards 
Mercedes Estrada 
Re:Jane Doe No. 101 & Jane Doe Joint W/P Priv. 
No. 102 vs. Epstein-Cross Notice 
OfDepos 
06902 
09/15/2009 
Bradley Edwards 
Mercedes Estrada 
RE: Jane Doe No.101 & Jane Doe Joint W/P Priv. 
N0.102 vs. Epstein 
06903 
09/04/2009 
Bradley Edwards 
Mercedes Estrada 
RE: Jane Doe No.101 & Jane Doe Joint W/P Priv. 
N0.102 vs. Epstein-Cross-Notice 
ofTaking Video Deposition 
06806-06807 
09/09/2009 
Bradley Edwards 
Adam Horowitz 
RE:Epstein 
Joint W/P Priv. 
06712 
10/19/2009 
Bradley Edwards 
Kikka Claudio 
RE: Igor Zinoview depo 
Joint W/P Priv. 
06713-06714 09/15/2009 
Bradley Edwards 
Robert Josefberg 
RE:Epstein 
Joint W/P Priv. 
11 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
Farmer Jaffe. WeissinJ?. Edwards. Fistos & Lehrman 
& 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
06720-06727 
10/14/2009 
Bradley Edwards 
Jack Hill 
RE: Igor Zinoview depo 
Joint W/P Priv. 
06728 
09/09/2009 
Bradley Edwards 
Kikka Claudio 
RE:Epstein 
Joint W/P Priv. 
06711 
09/09/2009 
Kikka Claudio 
Bradley Edwards 
RE:Epstein 
Joint W/P Priv. 
06472 
05/08/2009 
Spencer Kuvin 
Bradley Edwards 
RE:FYI Epstein Depo 
Joint W/P Priv. 
06460-06464 05/08/2009 
Bradley Edwards 
Spencer Kuvin 
RE:FYI Epstein Oepo 
Joint W/P Priv. 
06455-06459 05/08/2009 
Spencer Kuvin 
Bradley Edwards 
RE:FYI Epstein Depo 
Joint W/P Priv. 
06448-06452 05/08/2009 
Spencer Kuvin 
Bradley Edwards 
RE:FYI Epstein Depo 
Joint W/P Priv. 
06420-06427 05/08/2009 
Spencer Kuvin 
Bradley Edwards 
RE:FYI Epstein Depo 
Joint W/P Priv. 
06416-06419 05/08/2009 
Spencer Kuvin 
Bradley Edwards 
RE:FYI Epstein Depo 
Joint W/P Priv. 
05925-05926 07/28/2009 
Katherine Ezell 
Bradley Edwards 
FW:Epstein 
Joint W /P Priv. 
05883-05584 07/24/2009 
Katherine Ezell 
Bradley Edwards 
RE:Epstein 
Joint W/P Priv. 
05022-05025 09/10/2010 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein-Notice of Production Joint W/P Priv. 
from Non Parties 
04724-04725 
05/27/2009 
Bradley Edwards 
Katherine Ezell 
RE:Epstein Cases-depostions in Joint W/P Priv. 
federal cases 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
06990-07002 06/11/2009 
Brad Edwards 
Katherine W. Ezell 
June 
1otn 
hearing-WPB-
Joint-privilege 
Confidential 
07003-07006 
06/26/2009 
Amy Ederi 
Brad Edwards 
June 
25tn 
hearing-WPB~ Joint-privilege 
12 

NOT A CERTIFIED COPY
Privilege Log- Dated 2~23·2011 
I 
& 
I 
E 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Confidential 
07030 
09/22/2009 
Bradley 
J. 
Spencer Kuvin 
L.M. v. Epstein -
defendant, Joint-privilege 
Edwards 
Jeffrey Epstein's response to 
plantiff 
07090-07091 
9/29/2009 
Bradley 
J. 
Katherine W. Ezell 
Leslie Wexner 
Joint-privilege 
Edwards 
07092 
10/29/2009 
Stuart 
Bradley J. Edwards 
Leslie Wexner 
Joint-privilege 
Mermelstein 
07093 
09/17/2009 
Bradley 
J. 
Katherine W. Ezell 
Leslie Wexner 
Joint-privilege 
Edwards 
01484 
05/21/2009 
Robert 
C. 
Bradley J. Edwards 
Epstein 
Joint-privilege 
Josefsberg 
01503 
08/24/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein 
Joint-privilege 
01517 
09/18/2009 
Adam Horowitz; 
Bradley J. Edwards 
Epstein 
Joint-privilege 
Spencer Kuvin 
01514 
08/26/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein 
Joint-privilege 
01515 
08/27/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein 
Joint-privilege 
01477 
07/21/2009 
Adam Horowitz; 
Bradley J. Edwards 
Epstein 
Joint-privilege 
Stuart 
Mermelstein 
01489 
08/03/2009 
Adam Horowitz 
Bradley J. Edwards 
Epstein 
Joint-privilege 
07110-07112 
09/25/2009 
Bradley 
J. 
Spencer Kuvin 
LM v EPSTEIN hearing 9/22/09 
Edwards 
07113-07114 
09/25/2009 
Spencer Kuvin 
Bradley J. Edwards 
LM v EPSTEIN hearing 9/22/09 
Joint-privilege 
07115-07116 09/25/2009 
Bradley 
J. 
Spencer Kuvin 
LM v EPSTEIN hearing 9/22/09 
Joint-privilege 
Edwards 
07145-07146 09/22/2009 
Adam Horowitz 
Bradley J. Edwards 
Mark Epstein 
Joint-privilege 
07211-07213 
10/01/2009 
Bradley 
J. 
Spencer Kuvin 
Meeting with Stanley Arkin 
Joint-privilege 
Edwards 
07210 
10/06/2009 
Stuart 
Katherine W. Ezell 
Meeting with Leslie Wexner 
Joint-privilege 
Mermelstein; 
Robert 
C. 
Josefsberg; 
13 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
Farmer Jaffe Weissinl=?. Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Bradley 
J. 
Edwards 
07214-07215 10/01/2009 
Robert 
c. 
Katherine W. Ezell 
Meeting with Stanley Arkin 
Joint-privilege 
Josefsberg 
07216-07217 
10/02/2009 
Bradley 
J. 
Katherine W. Ezell 
Meeting with Stanley Arkin 
Joint-privilege 
Edwards 
07220-07223 10/01/2009 
Spencer Kuvin 
Bradley J. Edwards 
Meeting with Stanley Arkin 
Joint-privilege 
07224-07225 10/02/2009 
Katherine 
w. 
Bradley J. Edwards 
Meeting with Stanley Arkin 
Joint-privilege 
Ezell 
07226-07227 10/01/2009 
Robert 
C. 
Spencer Kuvin 
Meeting with Stanley Arkin 
Joint-privilege 
Josefsberg 
07228-07229 
10/01/2009 
Bradley 
J. 
Robert 
C. 
Meeting with Stanley Arkin 
Joint-privilege 
Edwards 
Josefsberg 
07280-07283 
08/06/2009 
Adam Horowitz 
Bradley J. Edwards 
Motion for protective order 
Jo int-privilege 
07633-07634 08/06/2009 
Bradley 
J. 
Kikka M. Claudio 
Proposal Request 
Joint-privilege 
Edwards 
07710-07733 
06/23/2009 
Katherine 
w. 
Bradley J. Edwards 
Regularly Monthly Cong. Call 
Joint-privilege 
Ezell 
07740-07746 09/18/2009 
Bradley 
J. 
Adam Horowitz 
Report this as a parole violation 
Joint-privilege 
Edwards 
07748-07757 09/18/2009 
Adam Horowitz 
Bradley J. Edwards 
Report thls as a parole violatlon 
Joint-privilege 
07913-07915 08/27/2009 
Bradley 
J. 
Spencer Kuvin 
Sarah Kellen 
Joint-privilege 
Edwards 
07917-07918 
08/27/2009 
Spencer Kuvin 
Jacquie Johnson 
Sarah Kellen 
Joint-privilege 
07965-07966 08/12/2009 
Katherine 
w. 
Bradley J. Edwards 
Subpoena 
directed 
to 
the Joint-privilege 
Ezell 
investigators 
07977-07978 
10/09/2009 
Bradley 
J. 
Spencer Kuvin 
Subpoena Info 
Joint-privilege 
Edwards 
01716 
09/15/2009 
Adam Horowitz 
Elizabeth Villar 
Epstein: Forensics/Investigations Joint-privilege 
INVOICE 
01768 
07/13/2009 
Richard Willits 
Bradley J. Edwards 
Epstein Investigator 
Joint-privilege 
01...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
... 
farmer Jaffe Weissint,? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Edwards 
01998-01999 09/21/2009 
Adam Horowitz 
Margaret Berl< 
Correct 
Number -
Epstein Joint-privilege 
Deposition 
02021 
05/14/2009 
Bradley 
J. 
Mercedes 
C. 
Doe v. Epstein 
Joint-privilege 
Edwards 
Estrada 
02044 
09/04/2009 
Katherine 
w. 
Bradley J. Edwards 
E.W., L.M. Doe v. Epstein -
Joint-privilege 
Ezell 
Letter from Bob Critton 
02048 
09/04/2009 
Robert 
C. 
Bradley J. Edwards 
E.W., L.M. Doe v. Epstein -
Joint-privilege 
Josefsberg 
Letter from Bob Critton 
02054 
05/12/2009 
Spencer Kuvin 
Bradley J. Edwards 
Emailing 
Epstein 
deposition 
Joint-privilege 
revised 
02062 
10/05/2009 
Bradley 
J. 
AmyEderi 
Epstein - Confirming AT&T Dial 
Joint-privilege 
Edwards 
in 
Tel. 
Cont. 
for 
Monday, 
10/5/09 at 4:00 p.m. 
02087 
09/17/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein- Hearing 
Joint-privilege 
02140 
08/04/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein Depo - New York 
Joint-privilege 
02147-02149 09/21/2009 
Bradley 
J. 
AmyEderi 
Epstein Depo 
Joint-privilege 
Edwards 
02174 
07/20/2009 
Adam Horowitz 
Bradley J. Edwards 
Epstein Matter - Cross Notice of Joint-privilege 
Alfredo Rodriguez Deposition 
02209-02210 07/01/2009 
Bert Patton 
William J. Berger 
Epstein v. State of Florida -
Joint-privilege 
Emergency petition for Writ of 
Certiorari; Emergency motion to 
review denial of stay 
02215-02217 07/24/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein 
Joint-privilege 
Edwards 
Estrada 
02290 
09/18/2009 
Bradley 
J. 
Spencer Kuvin 
Epstein 
Joint-privilege 
Edwards 
02355-02356 06/10/2009 
Mercedes 
C. 
Susan K. Stirling 
Hearing 
taken 
on 06/10/09 Joint-privilege 
Estrada 
onmotion to unseal before Judge 
Colbath 
02362-02363 06/09/2009 
Spencer Kuvin 
Katherine W. Ezell 
Hearing to Un-seal 
Joint-privilege 
02374-02375 09/15/2009 
Jack Hill 
Bradley J. Edwards 
Igor Zinov...

NOT A CERTIFIED COPY
_____ ··:...-·' ---··· .. 
Privilege Log - Dated 2v23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
02420-02421 
05/08/2009 
Bradley 
J. 
Mercedes 
C. 
Jane Doe II v. Epstein 
Joint-privilege 
Edwards 
Estrada 
02435 
09/15/2009 
Bradley 
J. 
Lisa Rivera 
Jane Does v. Epstein 
Joint-privilege 
Edwards 
02438 
09/18/2009 
Bradley 
J. 
Adam Horowitz 
Jeffrey Epstein DC# W35755 
Joint-privilege 
Edwards 
02462 
09/22/09 
Spencer Kuvin 
Bradley J. Edwards 
L.M. v. Epstein -
Defendant, 
Joint-privilege 
Jeffrey Epstein" s Response to 
Plantiff 
L.M.''s 
Motion 
for 
Protective Order 
02476-02477 
09/25/2009 
Spencer Kuvin 
Bradley J, Edwards 
LM v EPSTEIN hearing 
Joint-privilege 
02516 
10/06/2009 
Bradley 
J. 
Katherine W. Ezell 
Meeting with Leslie Wexner 
Joint-privilege 
Edwards 
02554-02559 
08/03/2009 
Adam Horowitz 
Bradley J. Edwards 
NEW 
ASSIGNMENT -
NEW Joint-privilege 
ALBANY - RUSH? - Fwd: Federal 
Subpoena 
02584 
08/11/2009 
Bradley 
J. 
Kikka M. Claudio 
Out of state subpoenas 
Joint-privilege 
Edwards 
02618 
08/04/2009 
Bradley 
J. 
Kikka M. Claudio 
Proposal Request 
Joint-privilege 
Edwards 
02627-02628 09/18/2009 
Bradley 
J. 
Adam Horowitz 
Report this as a parole violation 
Joint-privilege 
Edwards 
02672-02673 
10/09/2009 
Spencer Kuvin 
Bradley J. Edwards 
Subpoena Info 
Joint-privilege 
02727 
08/03/2009 
Spencer Kuvin 
Bradley J. Edwards 
Transcript of Alfredo Rodriguez 
Joint-privilege 
deposition 
02896 
06/08/2009 
Bradley 
J. 
Spencer Kuvin 
Hearing to Un-seal 
Joint-privilege 
Edwards 
03009-03010 
08/07/2009 
Adam Horowitz 
Jacquie Johnson 
Motion to stay 
Joint-privilege 
03028-03029 
09/21/2009 
Bradley 
J. 
Adam Horowitz 
Mark Epstein 
Joint-privilege 
Edwards 
03038 
10/06/2009 
Bradley 
J. 
Stuart Mermelstein 
Meeting with Leslie Wexner 
Joint-privilege 
Edwards 
03131-03132 
08/06/2009 
Adam Horowitz 
Bradley J. Edwards 
Epsteins assets 
Joint-p...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer, Jaffe. Weissine:. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
03243-03244 
09/09/2009 
Bradley 
J. 
Adam Horowitz 
EPSTEIN 
Joint-privilege 
Edwards 
03397-03400 09/29/2009 
Adam Horowitz 
Bradley J. Edwards 
Activity in case 9:08-cv-80119-
Joint-privilege 
KAM Doe v. Epstein Response in 
Opposition to Motion 
03407-03414 
09/29/2009 
Bradley 
J. 
Adam Horowitz 
Activity in case 9:08-cv-80119-
Joint-privilege 
Edwards 
KAM Doe v. Epstein Response in 
Opposition to Motion 
03451-03452 
05/14/2009 
Bradley 
J. 
Spencer Kuvin 
Activity in Case 9:08-cv-80893-
Joint-privilege 
Edwards 
KAM Doe v. Epstein Order on 
Motion to Stay 
03477-03479 
05/15/2009 
Bradley 
J. 
Spencer Kuvin 
Activity in Case 9:08-cv-80893-
Joint-privilege 
Edwards 
KAM Doe v. Epstein Order to 
Motion to Stay 
03619-03627 
09/15/2009 
Bradley 
J. 
Spencer Kuvin 
BB v. Epstein/EW v. Epstein 
Joint-privilege 
Edwards 
03631-03633 
09/15/2009 
Jacquie Johnson 
William J. Berger 
BB v. Epstein/EW V. Epstein 
Joint-privilege 
03646-03656 
10/19/2009 
Bradley 
J. 
Katherine W. Ezell 
Bill Riley's Subpoena & Depo Joint-privilege 
Edwards 
Notice 
03677-03687 
07/08/2009 
Bradley 
J. 
Adam Horowitz 
Can 
you 
send 
me 
those Joint-privilege 
Edwards 
addresses? 
03719-03736 
09/04/2009 
Bradley 
J. Spencer Kuvin 
CMA - depo notices attached. 
Joint-privilege 
Edwards 
03840-03847 
08/02/2009 
Stuart 
Bradley J. Edwards 
Continuing Deposition of Alfredo Joint-privilege 
Mermelstein 
Rodriguez 
03938-03939 
09/29/2011 
Katherine 
w. 
Bradley J. Edwards 
Deposition of Bill Riley 
Joint-privilege 
Ezell 
03943-03945 
09/18/2009 
Adam Horowitz 
Jacquie Johnson 
Deposition of Jean Luc Bruhnel 
Joint-privilege 
02911-02912 
09/15/2009 
Bradley 
J. Jack P. Hill 
Igor Zinoview depo 
Joint-privilege 
Edwards 
02939 
07/14/2009 
Bradley 
J. 
Adam Horowitz 
Jane Does 2-7 v. Epstein 
Joint-privilege 
Edwards 
02977 
10/16/2009 
K...

NOT A CERTIFIED COPY
__ ....:........:. __ :,_:._ ___ _ 
Privilege log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin.r Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Ezell 
02978 
10/29/2009 
Bradley 
J. 
Stuart Mermelstein 
Leslie Wexner 
Joint-privilege 
Edwards 
02994 
06/10/2009 
Bradley 
J. 
Mercedes 
C. 
Preservation of evidence 
Joint-privilege 
Edwards 
Estrada 
07060 
10/16/2009 
Sid Garcia 
Bradley J. Edwards 
LM. v. Epstein 
Joint-privilege 
06202 
07/13/2009 
Richard Willits 
Bradley J. Edwards 
Scheduling _ various depositions Joint-privilege 
regarding Epstein 
06409-06415 04/15/2009 
Bradley 
J. 
Katherine W. Ezell 
FYI 
Joint-privilege 
Edwards 
06428-06447 05/06/2009 
Spencer Kuvin 
Bradley J. Edwards 
FYI 
Joint-privilege 
06453-06454 04/15/2009 
Spencer Kuvin 
Bradley J. Edwards 
FYI 
Joint-privilege 
06465-06471 04/15/2009 
Katherine 
w. 
Bradley J. Edwards 
FYI 
Joint-privilege 
Ezell 
06476-06490 05/08/2009 
Bradley 
J. 
Spencer Kuvin 
FYI 
Joint-privilege 
Edwards 
06630-06632 09/09/2009 
Spencer Kuvin 
Bradley J. Edwards 
Hearing to Un-seal 
Joint-privilege 
06636-06639 09/09/2009 
Bradley 
J. 
Robert 
c. 
Hearing to Un-seal 
Joint-privilege 
Edwards 
Josefsberg 
0670i-06705 09/16/2009 
Bradley 
J. 
Kikka M. Claudio 
Igor Zinoview & Tommy Matola Joint-privilege 
Edwards 
depos 
06706-06708 10/14/2009 
Bradley 
J. 
Kikka M. Claudio 
Igor Zinoview depo 
Joint-privilege 
Edwards 
06715-06719 10/09/2009 
Jack P. Hill 
Bradley J. Edwards 
Igor Zinoview depo 
Joint-privilege 
06729-06735 10/13/2009 
Bradley 
J. 
Jack P. Hill 
Igor Zinoview depo 
Joint-privilege 
Edwards 
06763 
08/19/2009 
Bradley 
J. 
Stuart Mermelstein 
IME's 
Joint-privilege 
Edwards 
06764-06766 09/10/2009 
Bradley 
J. 
Stuart Mermelstein 
IME's 
Joint-privilege 
Edwards 
06770-06781 09/10/2009 
Stuart 
Bradley J. Edwards 
IME's 
Joint-privilege 
Mermelstein 
06811-06812 08/20/2009 
Katherine 
w. Bradley J. Edwards 
Is Mark Epstein JE' s brother?...

NOT A CERTIFIED COPY
___ 
'•·-•.:...::... ____ ... 
Privilege Log- Dated 2-23-2011 
' 
I 
& 
Farmer Jaffe Weissing Edwards~ Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Ezell 
06817-06819 
09/23/2009 
Adam Horowitz 
Bradley J. Edwards 
Is your client being deposed Joint-privilege 
tomorrow? 
06820-06822 
07/02/2009 
Bradley 
J. 
Margaret Berk 
Jane Doe 2 (Brinson} v. Epstein 
Joint-privilege 
Edwards 
06841-06860 05/12/2009 
Bradley 
J. 
Spencer Kuvin 
Jane Doe IJ v. Epstein 
Joint-privilege 
Edwards 
06864-06875 05/12/2009 
Spencer Kuvin 
Bradley J. Edwards 
Jane Doe II v. Epstein 
Joint-privilege 
06880-06890 05/12/2009 
Bradley 
J. 
Katherine W. Ezell 
Jane Doe II v. Epstein 
Joint-privilege 
Edwards 
06898-06900 05/12/2009 
Bradley 
J. 
Stuart Mermelstein 
Jane Doe II v. Epstein 
Joint-privilege 
Edwards 
06933-06934 
07/14/2009 
Adam Horowitz 
Bradley J. Edwards 
Jane Does 2-7 v. Epstein 
Joint-privilege 
06937-06938 
10/05/2009 
Spencer Kuvin 
Jacquie Johnson 
Jane Does 2-8 v. Epstein - Cross Joint-privilege 
NOD' s of Oct. 6-8 depos 
06944-06952 
09/22/2009 
Bradley 
J. 
Adam Horowitz 
Jeffrey Epstein DC# W35755 
Joint-privilege 
Edwards 
16107 
08/11/2009 
Adam Horowitz 
Jacquie Johnson 
Maxwells deposition 
Joint-privilege 
16123-16124 08/11/2009 
Kikka M. Claudio 
Jacquie Johnson 
Maxwells deposition 
Joint-privilege 
16799-16801 
10/02/2009 
Robert 
C. 
Jacquie Johnson 
Meeting with Stanley Arkin 
Joint-privilege 
Josefbergs 
02947-02948 08/03/2009 
Spencer Kuvin 
Jacquie Johnson 
Epstein Depo - New York 
Joint-privilege 
02891-20906 
10/01/2009 
Bradley 
J. 
Katherine W. Ezell 
Meeting with Stanley Arkin 
Joint-privilege 
Edwards 
20880-20882 
10/02/2009 
Bradley 
J. 
Katherine w. Ezell 
Meeting with Stanley Arkin 
Joint-privilege 
Edwards 
06042-06090 07/02/2009 
William J. Berger 
Spencer Kuvin 
Ew 09-22784 cert.4m dca 
Joint-privilege 
06402-06403 
06/10/2009 
Bradley 
J. 
Katherine w. Ezell 
Hearing to Un-seal 
Joint-privilege 
Ed...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
! 
I 
_, 
I 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Mermelstein 
01319 
08/11/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Oepo 
Joint-privilege 
01316 
08/27/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein Depo 
Joint-privilege 
01314 
10/30/2009 
Stuart 
Jacquie Johnson 
Epstein Oepo of Wexner 
Joint-privilege 
Mermelstein 
01298 
05/26/2009 
Bradley 
J. 
Adam Horowitz 
Epstein cases -
depositions in 
Joint-privilege 
Edwards 
federal cases 
01294 
08/10/2009 
Jack P. Hill 
Bradley J. Edwards 
Epstein Assets 
Joint-privilege 
01273 
07/13/2009 
Katherine 
w. 
Bradley J. Edwards 
Epstein 2255 claims 
Joint-privilege 
Ezell 
01250 
05/13/2009 
Bradley 
J. 
Mercedes 
c. 
Epstein 
Joint-privilege 
Edwards 
Estrada 
01246 
04/08/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein -Telephone Conference 
Joint-privilege 
Edwards 
Estrada 
01233-01234 
07/31/2009 
Bradley 
J. 
Mercedes 
c. 
Epstein -
Monday, 8/3/09 -
Joint-privilege 
Edwards 
Estrada 
Monthly 
call 
in 
telephone 
conference - AT&T Call in No: 
(877) 468-2136 -
participant 
code: 775593. Kathy is the host. 
01224 
06/16/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein -
Monday, 8/3/09 -
Joint-privilege 
Edwards 
Estrada 
Monthly 
call 
in 
telephone 
conference -
AT&T Call in No: 
(877) 468-2136 -
participant 
code: 775593. Kathy is the host. 
01185 
10/30/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein - Confirming AT&T dial Joint-privilege 
Edwards 
Estrada 
in tel. conf. for Monday, 11/2/09 
at4:00 p.m. 
01186 
10/02/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein - Confirming AT&T Dial Joint-privilege 
Edwards 
Estrada 
in 
Tel. 
Cont. 
for 
Monday, 
10/5/09 at 4;00 p.m. 
01187 
05/19/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein - Confirming AT&T Dial 
Joint-privilege 
Edwards 
Estrada 
in Telephone Conference for 
Monday, 6/8/09 at 2:00 p.m. 
20 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
' 
~ 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
01188 
05/12/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein - Confirming AT&T Dial Joint-privilege 
Edwards 
Estrada 
in Telephone Conference for 
Tomorrow 5/13/09 
01189 
09/08/2009 
Bradley 
J. 
Iliana Yarzabal 
Epstein - Confirming AT&T Dial Joint-priVllege 
Edwards 
in Telephone Conference for 
Wednesday, 9/9/09 at 3:00 
01095-01096 04/15/2009 
Spencer Kuvin 
Bradley J. Edwards 
Deposition of Epstein was set for Joint-privilege 
tomorrow 
01045 
07/23/2009 
Bradley 
J. 
Richard Willits 
CMA vs. Epstein 
Joint-privilege 
Edwards 
01649 
07/08/2009 
Bradley 
J. 
Mercedes 
C. 
Epstein 
Joint-privilege 
Edwards 
Estrada 
01641 
06/11/2009 
Bradley 
J. 
Mercedes 
c. 
Epstein 
Joint-privilege 
Edwards 
Estrada 
01639 
05/29/2009 
Bradley 
J. 
Mercedes 
c. Epstein 
Joint-privilege 
Edwards 
Estrada 
01619 
10/28/2009 
Bradley 
J. 
Spencer Kuvin 
Epstein 
Joint-privilege 
Edwards 
01660 
07/22/2009 
Bradley 
J. 
Adam Horowitz 
Epstein 
Joint-privilege 
Edwards 
01666 
04/20/2009 
Spencer Kuvin 
Bradley J. Edwards 
Epstein 
Joint-privilege 
01671 
07/23/2009 
Katherine 
w. Bradley J. Edwards 
Epstein 
Joint-privilege 
Ezell 
01680 
08/24/2009 
Jack P. Hill 
Bradley J. Edwards 
Epstein 
Joint-privilege 
04355-04358 09/04/2009 
Jack Scarola 
Bradley J. Edwards 
Epstein - Depos of Marcinkova Joint-privilege 
and Sarah Kellen 
04446 
09/03/2009 
Bradley 
J. 
Iliana Yarzabal 
Epstein -
Monday 8/3/09 -
Joint-privilege 
Edwards 
Monthly 
Call 
in 
Telephone 
Conference 
04200-04201 09/04/2009 
Bradley Edwards 
Katherine W. Ezell 
Letter from Bob Critton 
Joint W/P Privilege 
04220-
09/04/2009 
Bradley Edwards 
Spencer Kuvin 
Letter from Bob Critton 
Joint W/P Privilege 
04221 
04222-04223 09/04/2009 
Bradley Edwards 
Barry Stone 
Letter from Bob Critton 
Joint W/P Privilege 
21 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
' 
I 
Farmer Jaffe. Weissinj? Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
04264 
05/12/2009 
Bradley Edwards 
Spencer Kuvin 
Epstein Depo 
Joint W/P Privilege 
04298-04299 09/16/2009 
Jacquie Johnson 
Adam Horowitz 
Depo of Epstein 
Joint W/P Privilege 
04304 
09/08/2009 
Jacquie Johnson 
Adam Horowitz 
Epstein 
Joint W/P Priv. 
04335 
10/30/2009 
Bradley Edwards 
Robert Josetsberg 
Epstein- Confirming AT&T Tel. 
Joint W/P Priv. 
Cont. 
04359-04360 09/04/2009 
Jacquie Johnson 
Katherine Ezell 
Depos of Marcinkova & Sarah 
Joint W/P Priv. 
Kellen 
04365 
09/15/2009 
Jacquie Johnson 
Adam Horowitz 
Epstein- Depo in New York 
Joint W/P Priv. 
04417 
09/17/2009 
Bradley Edwards 
Spencer Kuvin 
Epstein- Hearing 
Joint W/P Priv. 
04423-04424 09/09/2009 
Jacquie Johnson 
Adam Horowitz 
Letter regarding Leslie Wexner 
Joint W/P Priv. 
04433-04436 06/16/2009 
Spencer Kuvin 
Bradley Edwards 
Monthly Call in Tele. Conf. 
Joint W/P Priv. 
04447-04450 07/31/2009 
Jacquie Johnson 
Mercedes Estrada 
Monthly Call in Tel. Conf. 
Joint W/P Priv. 
04491-04518 04/08/2009 
Bradley Edwards 
Jack Scarola 
Epstein- Tel. Conf. 
Joint W/P Priv. 
04518 
04/08/2009 
Bradley Edwards 
Robert Josefsberg 
Epstein-Tel Cont. 
Joint W/P Priv. 
04524-04525 05/13/2009 
Katherine Ezell 
Bradley Edwards 
Epstein Depo 
Joint W/P Priv. 
04580 
10/14/2009 
Jacquie Johnson 
Adam Horowitz 
Depo of Larry Visoski 
Joint W/P Priv. 
04640-04641 10/14/2009 
Bradley Edwards 
Adam Horowitz 
Depo of Larry Visoski 
Joint W/P Priv. 
04723 
05/26/2009 
Bradley Edwards 
Katherine Ezell 
Epstein cases- Depos 
Joint W/P Priv. 
04726--04729 
05/26/2009 
Adam Horowitz 
Bradley Edwards 
Epstein cases~ Witness depos 
Joint W/P Priv. 
04750-04754 08/04/2009 
Spencer Kuvin 
Bradley Edwards 
Epstein depo- New York 
Joint W /P Priv. 
04763-04785 08/27/2009 
Spencer Kuvin 
Bradley Edwards 
Epstein Depo Notice 
Joint W/P Priv. 
04797-04799 09/18/2009 ...

NOT A CERTIFIED COPY
Privilege Log- Dated 2a23-20ll 
I 
C 
._ 
Farmer Jaffe Weissing Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
04711 
08/10/2009 
Bradley Edwards 
Jack Hill 
Epstein assests 
Joint W/P Priv. 
04855-04858 08/18/2009 
Bradley Edwards 
Kikka Claudio 
Epstein Depos 
Joint W/P Priv. 
04861 
07/24/2009 
Lisa Rivera 
Jacquie Johnson 
Epstein Depos 
Joint W/P Priv. 
04876-04877 07/27/2009 
Bradley Edwards 
Spencer Kuvin 
Epstein Depos 
Joint W/P Priv. 
04922-04923 09/16/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Hearing 
Joint W/P Priv. 
04925-04926 09/15/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Hearing 
Joint W/P Priv. 
04929-04934 09/25/2009 
Bradley Edwards 
Adam Horowitz 
Epstein Hearing 
Joint W/P Priv. 
04937-04938 09/15/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Hearing 
Joint W/P Priv. 
04969-04972 07/20/2009 
Adam Horowitz 
Bradley Edwards 
Alfredo Rodriguez Oepo 
Joint W/P Priv. 
05026-05027 09/10/2009 
Adam Horowitz 
Jacquie Johnson 
Notice of Production from Non-
Joint W/P Priv. 
Parties 
05031 
09/25/2009 
Bradley Edwards 
Spencer Kuvin 
Epstein Order 
Joint W/P Priv. 
05037-05038 09/25/2009 
Bradley Edwards 
Spencer Kuvin 
Epstein Order 
Joint W/P Priv. 
05042-05043 09/25/2009 
Spencer Kuvin 
Bradley Edwards 
Epstein Order 
Joint W /P Priv. 
05046 
09/25/2009 
Bradley Edwards 
Spener Kuvin 
Epstein Order 
Joint W/P Priv. 
05074-05076 08/18/2009 
Stuart 
Jacquie Johnson 
Epstein Sub. To Bears Stern 
Joint W/P Priv. 
Mermelstein 
23 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
Farmer. Jaffe, Weissina:. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05100-05102 
08/05/2009 
Mercedes 
Bradley Edwards 
Improper Serving of Maxwell 
Joint W/P Priv. 
Estrada 
05105-05107 04/20/2009 
Bradley Edwards 
Spencer Kuvin 
Hearing on Yellow Cab Objection 
Joint W /P Priv. 
05110 
08/06/2009 
Adam Horowitz 
Kikka Claudio 
Address for Nadia Marcinkova 
Joint W/P Priv. 
05118-05119 09/09/2009 
Adam Horowitz 
Bradley Edwards 
Motion for Protective Order 
Joint W/P Priv. 
05157-05158 09/10/2009 
Adam Horowitz 
Bradley Edwards 
Motion for Protective Order 
Joint W/P Priv. 
05167-05168 
05/29/2009 
Bradley Edwards 
Margaret Berk 
Spencer Cross-Examination 
Joint W/P Priv. 
05171-05172 
05/29/2009 
Bradley Edwards 
Mercedes Estrada 
Transcripts 
Joint W/P Priv. 
05201-05202 09/10/2009 
Adam Horowitz 
Bradley Edwards 
Rules on Doe no. 4 
Joint W/P Priv. 
05222-05223 
07/10/2009 
Bradley Edwards 
Katherine Ezell 
File case 
Joint W/P Priv. 
05226 
07/10/2009 
Bradley Edwards 
Spencer Kuvin 
Epstein 5
th Amendment rights 
Joint W/P Priv. 
05229 
07/10/2009 
Bradley Edwards 
Adam Horowitz 
Motions to Compel 
Joint W/P Priv. 
05232-05233 
07/10/2009 
Bradley Edwards 
Adam Horowitz 
Motions fully briefed 
Joint W/P Priv. 
05247 
07/23/2009 
Katherine Ezell 
Bradley Edwards 
Answers to the 1
st set of ROGS 
Joint W/P Priv. 
05251-05252 
07/24/2009 
Katherine Ezell 
Bradley Edwards 
Depo dates 
Joint W/P Priv. 
05258 
07/25/2009 
Katherine Ezell 
Bradley Edwards 
Switzerland Witness regarding 
Joint W/P Priv. 
Epstein Egg Shaped 2 inch PENIS! 
05265-05266 07/22/2009 
Adam Horowitz 
Spencer Kuvin 
Alfredo Rodriguez depo 
Joint W/P Priv. 
24 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
' 
I 
I 
Farmer Jaffe Weissinf:? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05286-05287 
07/28/2009 
Katherine Ezell 
Bradley Edwards 
Switzerland Witness regarding 
Joint W/P Priv. 
training of little girls as sex traps 
05293-05294 07/28/2009 
Katherine Ezell 
Bradley Edwards 
Calling Switzerland witness 
Joint W/P Priv. 
05326-05327 
08/24/2009 
Bradley Edwards 
Spencer Kuvin 
Emails searchable 
Joint W/P Priv. 
05331 
08/06/2009 
Kikka Claudio 
Bradley Edwards 
Epstein address 
Joint W/P Priv. 
05334-05335 
05/29/2009 
Bradley Edwards 
Mercedes Estrada 
1V Interview that is too explicit 
Joint W/P Priv. 
05347 
08/24/2009 
Bradley Edwards 
Spencer Kuvin 
Seeking Computers 
Joint W/P Priv. 
05350 
08/10/2009 
Kikka Claudio 
Bradley Edwards 
Current address for Nadia 
Joint W/P Priv. 
Marcinkova 
05353-05354 09/09/2009 
Katherine Ezell 
Bradley Edwards 
Distribution of Costs 
Joint W/P Priv. 
05367 
09/10/2009 
Jacquie Johnson 
Bradley Edwards 
Voicemail 
Joint W/P Priv. 
05373-05374 08/10/2009 
Kikka Claudio 
Bradley Edwards 
Supoenas for depos 
Joint W/P Priv. 
05391-05393 
04/20/2009 
Spencer Kuvin 
Bradley Edwards 
Yellow Cab stuff 
Joint W/P Priv. 
05400-05401 
10/19/2009 
Adam Horowitz 
Bradley Edwards 
Religious Dildo Washer 
Joint W/P Priv. 
05414-05415 
08/10/2009 
Kikka Claudio 
Bradley Edwards 
Sjoberg's current address 
Joint W/P Priv. 
05437-05439 04/20/2009 
Bradley Edwards 
Spencer Kuvin 
Yellow Cab stuff 
Joint W/P Priv. 
05444-05445 
08/10/2009 
Bradley Edwards 
Kikka Claudio 
Setting Depos 
Joint W/P Priv. 
05451 
05/29/2009 
Mercedes 
Bradley Edwards 
Motion for Status Conf. 
Joint W/P Priv. 
Estrada 
25 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
1: 
05469 
07/08/2009 
Mercedes 
Bradley Edwards 
Judge Marra's July 6m Order 
Joint W/P Priv. 
Estrada 
05476-05494 
07/08/2009 
Spencer Kuvin 
Bradley Edwards 
NPA from Marie Villafana 
Joint W/P Priv. 
05546 
08/03/2009 
Adam Horowltz 
Bradley Edwards 
Haley's affidavit 
Joint W/P Priv. 
05579-05581 
08/24/2009 
Spencer Kuvin 
Bradley Edwards 
Seeking all of Plaintiffs 
Joint W/P Priv. 
computer 
05613-05618 
09/18/2009 
Spencer Kuvin 
Bradley Edwards 
Non-Pros Agreement 
Joint W /P Priv. 
05633 
10/16/2009 
Adam Horowitz 
Bradley Edwards 
Motion to freeze assets 
Joint W/P Priv. 
05638-05639 
10/28/2009 
Spencer Kuvin 
Bradley Edwards 
Daliah Weiss 
Joint W/P Priv. 
05647 
07/09/2009 
Adam Horowitz 
Katherine Ezell 
NPA under seal for in camera 
Joint W /P Priv. 
review 
05656 
08/10/2009 
Bradley Edwards 
Kikka Claudio 
Supoenas for depo 
Joint W/P Priv. 
05659 
08/27/2009 
Bradley Edwards 
Spencer Kuvin 
Order 
Joint W/P Priv. 
05668 
10/16/2009 
Bradley Edwards 
Adam Horowitz 
Florida Science Foundation 
Joint W/P Priv. 
05705 
09/09/2009 
Mercedes 
Kikka Claudio 
Video tape of Epstein 
Joint W/P Priv. 
Estrada 
05724 
05/29/2009 
Bradley Edwards 
Jack Scarola 
Motion for Status Conf. 
Joint W/P Priv. 
05727 
05/29/2009 
Bradley Edwards 
Sid Garcia 
Motion for Status Conf. 
Joint W/P Priv. 
05730-05731 
08/14/2009 
Adam Horowitz 
Jacquie Johnson 
Motion for Status Conf. 
Joint W /P Priv. 
05734 
05/29/2009 
Adam Horowitz 
Jacquie Johnson 
Motion for status conf. 
Joint W/P Priv. 
26 

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DESCRIPTION 
OBJECTION 
05737 
08/12/2009 
Adam Horowitz 
Jacquie Johnson 
NPNP and sub to Palm Beach 
Joint W/P Priv. 
Natl Bank 
05750 
05/29/2009 
Mercedes 
Spencer Kuvin 
Motion for status conf. 
Joint W/P Priv. 
Estrada 
05770 
07/08/2009 
Bradley Edwards 
Spencer Kuvin 
NPA in camera review 
Joint W/P Priv. 
05774-05776 
09/04/2009 
Katherine Ezell 
Jacquie Johnson 
Marcinkova being rescheduled 
JointW/P Priv. 
05782-05783 
07/09/2009 
Bradley Edwards 
Spencer Kuvin 
Motion to appoint commissioner 
Joint W/P Priv. 
05788-05790 07/09/2009 
Bradley Edwards 
Spencer Kuvin 
Notice and serve everyone 
Joint W/P Priv. 
05802 
09/04/2009 
Adam Horowitz 
Jacquie Johnson 
Bill being split up evenly 
Joint W/P Priv. 
05806 
09/04/2009 
Jacquie Johnson 
Spencer Kuvin 
Bill will be split evenly for each 
Joint W/P Priv. 
case 
05812 
09/04/2009 
Adam Horowitz 
Jacquie Johnson 
Bill will be split evenly 
Joint W/P Priv. 
05814 
08/03/2009 
Bradley Edwards 
Adam Horowitz 
Haley's affidavit 
Joint W/P Priv. 
05818-05819 
09/09/2009 
Bradley Edwards 
Robert Josefsberg 
CMAOrder 
Joint W/P Priv. 
01781 
05/01/2009 
Bradley Edwards 
William Berger 
Epstein Depo 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
07619 
07/13/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
27 

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DATE 
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FROM 
DESCRIPTION 
OBJECTION 
03181 
09/14/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03181 
09/14/2009 
William Berger 
Paul Cassell 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03182-03185 
07/14/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03186-03188 05/01/2009 
William Berger 
Bradley Edwards 
Epstein Depo 
work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13860-13874 05/28/2009 
Elizabeth Kim 
Christinia Fitch 
litigation Strategy 
work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
14173 
10/21/2009 
Gary Farmer 
Bradley Edwards 
Stanely Arkin 
work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13419 
08/11/2009 
Denis Kleinfeld 
Bradley Edwards 
Trump's Depa 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03087 
06/29/2010 
Investigators 
Bradley Edwards 
Litigation Strategy 
work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admis...

NOT A CERTIFIED COPY
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DATE 
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FROM 
DESCRIPTION 
OBJECTION 
Team 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03089-03099 05/03/2009 
Attorneys 
and 
Russell Adler 
RE: Setting Depos 
Work 
Product;attorney 
client 
Staff 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13445-13453 08/19/2009 
Denis Kleinfeld 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
12281-12291 07/30/2009 
earl Under 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
09337-09340 08/10/2009 
Barry Stone 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
09350 
10/21/2009 
Barry Stone 
Bradley Edwards 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
09335 
08/06/2009 
Barry Stone 
Bradley Edwards 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
11983 
08/06/2009 
Carl Linder 
Jacquie Johnson 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
'l'\ ~? 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
11984-11988 08/06/2009 
Carl Linder 
Bradley Edw...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
' 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
11995 
08/19/2009 
Carl Under 
Bradley Edwards 
Litigation Strategy 
Work 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
12012 
10/21/20009 
Carl Linder 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
11879 
10/21/2009 
Cara Holmes 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy r[ghts 
11868 
08/19/2009 
Cara Holmes 
Bradley Edwards 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
10938 
05/28/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13592 
10/21/2009 
Denis Kleinfeld 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
04421 
05/21/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25814 
05/28/2009 
William Berger 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reaso...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
evidence;protected by privacy rights 
25778-25782 
07/30/2009 
William Berger 
Bradley Edwards 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25792-25797 05/28/2009 
William Berger 
Bradley Edwards 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25798 
08/06/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25799-25802 
08/10/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25773 
10/21/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
-
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25738 
08/03/2009 
William Berger 
Beth Williamson 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25739-25740 08/11/2009 
William Berger 
Bradley Edwards 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
17940 
07/30/2009 
Jonathan 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
Birkman 
privilege;irrelevant & reason...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
Farmer Jaffe. Weissine. Edwards. Fistos & Lehrman 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
17917-17927 08/03/2009 
Jonathan 
Bradley Edwards 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
Birkman 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
17932-17934 05/28/2009 
Jonathan 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
Birkman 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
17935 
05/28/2009 
Jonathan 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
Birkman 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
17936-17938 07/30/2009 
Jonathan 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
Birkman 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00014 
05/01/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00015 
05/04/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00016 
05/04/2009 
Bradley Edwards 
Paul Cassell 
Litigation Stratgey 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00017 
05/06/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
...

NOT A CERTIFIED COPY
·.-:· 
. -·--------·-·· 
Privilege Log - Dated 2-23-2011 
I 
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Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00019-00021 05/07/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00022 
06/23/3009 
Bradley Edwards 
Paul cassell 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00023 
07/13/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00024 
07/13/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00025-00029 
05/01/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00030 
05/02/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00031 
05/03/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00032 
05/03/2009 
Bradley Edwards 
William Berge...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00033-00034 05/03/3009 
Bradley Edwards 
Rob Buschel 
litigation Strategy 
Work 
P roduct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00035 
05/05/2009 
Bradley Edwards 
Susan Sterling 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00036 
05/06/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00037-00040 05/25/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Product;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00041 
07/06/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;lrrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00042 
07/06/2009 
Bradley Edwards 
Rob Busche! 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
0043 
05/05 
Bradley Edwards 
Susan Sterling 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
/2009 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00044 
08/17/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irr...

NOT A CERTIFIED COPY
Privilege Log - Dated 2 .. 23-2011 
Farmer Jaffe. Weissimz. Edwards. Fistos & Lehrman 
' 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
evidence;protected by privacy rights 
00045 
05/01/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00046 
05/01/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00047-00049 
05/01/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00050 
05/05/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00051 
05/05/2009 
Bradley Edwards 
Paul cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calc1,.1lated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00052 
05/05/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00053 
05/05/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privUege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00054 
05/05/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
th...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
& 
I 
I 
Farmer Jaffe Weissinf? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
00055 
04/29/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00056 
05/05/2009 
Bradley Edwards 
Paul cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00057 
05/05/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00058 
05/05/2009 
Bradley Edwards 
Russell Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00059 
05/05/2009 
Bradley Edwards 
Rob Busche! 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00060 
05/05/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Prod uct;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00061-0064 
05/06/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00065 
05/12/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evid...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
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I 
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SATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00067 
05/12/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00068 
05/12/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00069-00070 05/13/2009 
Bradley Edwards 
Paul Cassell 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00071 
05/13/2009 
Bradley Edwards 
Rob Busche! 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
00072 
05/15/2009 
Bradley Edwards 
Susan Sterling 
Litigation Strategy 
evidence;protected by privacy rights 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00073 
05/15/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00074 
05/18/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00075 
05/18/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
& 
I 
I 
I 
Farmer Jaffe Weissinfl Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00076 
05/18/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00077 
04/04/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00078 
05/18/2009 
Bradley Edwards 
Paul Cassell 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00079 
05/19/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00080 
05/19/2009 
Bradley Edwards 
Beth Williamson 
Litigation Strategy 
Work 
Product;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
00081-00082 
05/20/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
evidence;protected by privacy rights 
work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
00083·00085 
05/21/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
evidence;protected by privacy rights 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00086-00087 
05/25/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privileg...

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FROM 
DESCRIPTION 
OBJECTION 
evidence;protected by privacy rights 
00088 
04/30/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00089 
05/28/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00090 
05/28/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00091 
05/28/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00092 
05/28/2099 
Bradley Edwards 
Rob Buschell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00093 
06/01/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00094-00095 06/23/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00096 
07/06/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
...

NOT A CERTIFIED COPY
:··_:,:-:··:.-____ ..... . 
Privilege Log - Dated 2-23-2011 
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DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
00097 
07/06/2009 
Bradley Edwards 
Rob Busche! 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00098-00100 07/07/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00101 
07/09/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00102-00106 07/09/2009 
Bradley Edwards 
Paul Cassell 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00107 
07/10/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod u ct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00108 
07/10/2009 . 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00109 
07/10/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00110 
07/10/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00112-00120 05/012009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00121 
05/12/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00122 
05/12/2009 
Bradley Edwards 
Rob Busche! 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00123 
05/12/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00124-00125 05/12/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00126 
05/22/2009 
Bradley Edwards 
Russell Adler 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00127 
05/26/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
41 

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DATE 
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OBJECTION 
00128-00131 
5/26/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00132 
5/21/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00133 
06/23/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00134 
06/03/2009 
Bradley Edwards 
Rob Buschel 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00135-00137 06/03/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00138-00140 06/08/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00141 
06/12/2009 
Bradley Edwards 
RobBuschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00142 
06/13/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidenc...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00146 
06/29/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00147 
06/29/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00148 
04/22/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irreJevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00149 
04/26/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00150 
04/24/2009 
litigation Team 
Rob Busche! 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00151-00152 
06/26/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
01036-01039 04/26/2009 
Susan Sterling 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13313-13314 07/30/2009 
Denis Kleinfeld 
Bradley Edwards 
Litigation Strat...

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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13315 
08/03/3009 
Denis Kleinfeld 
Beth Williamson 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
01080-01081 06/22/2009 
Robert C. Busche! 
Bradley J. Edwards 
Jane Doe brother 
Attorney/Client privilege and/or work product 
01077 
05/28/2009 
Robert C. Busche! 
Bradley J. Edwards 
Doe family member 
Attorney/Client privilege and/or work product 
02445-02446 05/05/2009 
Bradley 
1. 
Susan K. Stirling 
Jones v. Atlantic asphalt 
Attorney/Client privilege and/or work product 
Edwards 
03049 
09/21/2009 
Bradley 
J. 
D.F. 
New addition to the case 
Attorney/Client privilege and/or work product 
Edwards 
02425-02426 06/17/2009 
Susan K. Stirling 
Bradley J. Edwards 
Jane Doe v. Dukenik 
Attorney/Client privilege and/or work product 
02669 
09/24/2009 
Bradley 
J. 
Jacquie Johnson 
Subpoena for Adriana Mucinska 
Attorney/Client privilege and/or work product 
Edwards 
02647 
08/06/2009 
Mike Fisten 
Bradley J. Edwards 
Samantha lee Rivera info 
Attorney/Client privilege and/or work product 
03688-03691 04/03/2009 
Robin 
T. 
Bradley J. Edwards 
Case number assignments 
Attorney/Client privilege and/or work product 
Kempner 
03692-03693 05/06/2009 
Bradley 
J. 
Susan K. Stirling 
Case list 
Attorney/Client privilege and/or work product 
Edwards 
15678-15680 09/29/2009 
Jacquie Johnson 
Bradley J. Edwards 
Subpoena for Adriana Mucinska 
Attorney/Client privilege and/or work product 
15689 
10/01/2009 
Jacquie Johnson 
Bradley J. Edwards 
Client information 
Attorney/Client privilege and/or work product 
02546-02547 09/22/2009 
D.F. 
Bradley J. Edwards 
Client communication 
Attorney/Client privilege and/...

NOT A CERTIFIED COPY
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Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
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DESCRIPTION 
OBJECTION 
08364-08368 10/01/2009 
Jacquie Johnson 
Bradley J. Edwards 
Client info 
Attorney/Client privilege and/or work product 
08370 
09/14/2009 
Bradley 
J. 
Pat Roberts 
Client info 
Attorney/Client privilege and/or work product 
Edwards 
08374-08375 10/01/2009 
Bradley 
J. 
Jacquie Johnson 
Client info 
Attorney/Client privilege and/or work product 
Edwards 
03878 
06/12/2009 
Bradley 
J. 
Robert C. Busche! 
Curtis Rivera 
Attorney/Client privilege and/or work product 
Edwards 
02955 
04/20/2009 
Susan K. Stirling 
Bradley J. Edwards 
Juskowich 
Attorney/Client privilege and/or work product 
02932 
07/17/2009 
Christina Fitch 
Bradley J. Edwards 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
11544-11545 09/28/2009 
Jacquie Johnson 
Bradley J, Edwards 
Client info 
Attorney/Client privilege and/or work product 
07432-07435 
09/25/2009 
D.F. 
Bradley J. Edwards 
New addition to the case 
Attorney/Client privilege and/or work product 
06906-06909 
07/17/2009 
Christina Fitch 
Bradley J. Edwards 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
06913-06914 06/22/2009 
Bradley 
J, 
Susan K. Stirling 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
Edwards 
06030-06031 05/04/2009 
Susan K. Stirling 
Bradley J. Edwards 
Espina -Walmart case 
Attorney/Client privilege and/or work product 
05646 
07/08/2009 
Bradley 
J. 
William J. Berger 
Client meeting 
Attorney/Client privilege and/or work product 
Edwards 
05573 
09/18/2009 
Mike Fisten 
Bradley J. Edwards 
Client meeting 
Attorney/Client privilege and/or work product 
05540 
07/31/2009 
Amy Swan 
Bradley J. Edwards 
Client info 
Attorney/Client privilege and/or work product 
05273-05276 07/28/2009 
Amy Swan 
Bradley J. Edwards 
Client info 
Attorney/Client privileg...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
01118-01120 09/22/2009 
Bradley 
J. 
MG 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
Edwards 
01986-01989 04/02/2009 
Bradley 
J. 
Robin T. Kempner 
Conflict check 
Attorney/Client privilege and/or work product 
Edwards 
01984-01985 04/02/2009 
Bradley 
J. 
Robin T. Kempner 
Conflict check 
Attorney/Client privilege and/or work product 
Edwards 
25925 
09/30/2009 
All Staff 
Robin T. Kempner 
Conflict check 
Attorney/Client privilege and/or work product 
25874 
09/30/2009 
All Staff 
Robin T. Kempner 
Additional 
name 
added 
to Attorney/Client privilege and/or work product 
conflict check 
08356-08357 09/16/2009 
Bradley Edwards 
NR 
Client Meeting 
Attorney/Client privilege and/or work product 
16760-16761 09/23/2009 
Bradley Edwards 
Jacquie Johnson 
New Client 
Attorney/Client privilege and/or work product 
08005 
06/05/2009 
Bradley Edwards 
MG 
New Client 
Attorney/Client privilege and/or work product 
06915-06920 06/17/2009 
MG 
Bradley Edwards 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
08360-08363 09/16/2009 
NR 
Bradley Edwards 
Client Meeting 
Attorney/Client privilege and/or work product 
04101-04107 09/28/2009 
Bradley Edwards 
MG 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
04708-04710 09/18/2009 
Bradley Edwards 
MG 
Epstein Article 
Attorney/Client privilege and/or work product 
06910-06912 
06/17/2009 
MG 
Bradley Edwards 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
07909 
08/10/2009 
Jane Doe 
Bradley Edwards 
Same silver car tag 
Attorney/Client privilege and/or work product 
07637-07642 
09/10/2009 
Bradley Edwards 
NR 
NR Interview 
Attorney/ Client Privilege 
06795-06799 
08/19/2009 
Anthony P 
Bradley Edwards 
Client Meeting 
Attorney/Client privilege and/or work product 
06542-06548 09/15/2009 
Bradley Edw...

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DATE 
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FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence 
02298-02299 07/08/2.009 
Bradley Edwards 
Confidential Source 
Other Rape Victims 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
02291 
06/04/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery of admissible evidence 
02442-02443 
08/17/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
02440-02441 10/02/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
04318-04321 09/24/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05111 
06/02/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05152 
06/03/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05164 
06/03/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05166 
06/03/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05169-05170 06/03/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05173-05174 06/03/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calcul...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23a2011 
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DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05227-05228 07/08/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Molestations 
discovery of admissible evidence 
05230-05231 07/08/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Molestations 
discovery of admissible evidence 
05303 
08/06/2009 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05344-05346 06/23/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal for Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05408 
07/06/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal for Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05425-05429 
05/28/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05433-05436 
05/29/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05433-05436 
05/29/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05446 
07/07/2009 
Bradley Edwards 
Confidential Source 
Other Rape Victims 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05452-05464 05/29/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05535-05536 
07/30/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence 
05693-05695 05/28/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05698 
08/21/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05706-05709 05/28/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05720-05721 05/29/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Prlv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05738-05739 05/29/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05743-05745 
05/29/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05754 
08/03/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
0S759-05762 06/01/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05765-05768 06/23/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05771-05773 06/03/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery of admissible evidence 
05777-05779 06/03/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reas...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05848 
07/28/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05852-05853 
07/29/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05857-05858 
07/31/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05952-05953 
08/25/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
06192-06197 06/23/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
06198-06201 06/24/2009 
Confidential 
Bradley Edwards 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
06203 
07/23/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
06401 
09/23/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
06643-06651 
09/17/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
06788-06789 09/28/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
06942-06943 09/26/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Molestations 
dis...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
e 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence 
07017-07018 09/04/2009 
Confide ntia I 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admisslble evidence 
07143-07144 10/01/2009 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
07147-07150 09/18/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
075089-
10/13/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
07513 
Source 
discovery of admissible evidence 
07605-07615 09/07/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
07646-07647 09/08/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
07674-07697 09/08/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
08376 
10/04/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
08380 
09/18/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
08427-08430 09/24/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
08450 
05/17/2009 
Bradley Edwards 
Confidential Source 
Provi~ing New Witnesses 
W/P Priv.; not reasonably calculated to lea...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinR Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
01608 
07/03/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01606 
07/02/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01510 
08/25/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01506 
08/24/2009 
Confidential 
Bradley Edwards 
Other Rape Victims 
W /P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01493 
08/10/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01488 
08/03/2009 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01486 
07/28/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01483 
07/28/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Molestations 
discovery of admissible evidence 
01479 
07/22/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
01449 
05/22/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal for Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
01433 
10/20/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery ...

NOT A CERTIFIED COPY
····-----i·_:,··.-_______ _ 
Privilege log - Dated 2-23-2011 
I 
I 
& 
I 
Farmer Jaffe Weissina: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Epstein Molestations 
discovery of admissible evidence 
01755-01756 10/02/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery of admissible evidence 
01756 
06/22/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
01770 
10/08/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
03126 
09/18/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Strategy 
discovery of admissible evidence 
02006 
06/23/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02060 
09/23/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
03487-03494 09/19/2009 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02269 
08/26/2009 
Confidential 
Bradley Edwards 
Other Rape Victims 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02322-02323 
10/16/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02595-02596 09/07/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
02866-02867 09/25/2009 
Confidential 
...

NOT A CERTIFIED COPY
.. •· 
···-----------
BATES 
03081-03082 
03144 
03189-03190 
04015 
02913 
02956-02957 
02975 
04031-04055 
04057 
04060 
02979-02980 
02998 
05626 
05630-05631 
05664-05665 
07976 
06655 
DATE 
09/21/2009 
10/08/2009 
10/14/2009 
09/08/2009 
09/28/2009 
08/31/2009 
10/21/2009 
08/12/2009 
08/11/2009 
08/12/2009 
10/02/2009 
07/21/2009 
10/12/2009 
10/12/2009 
10/12/2009 
08/14/2009 
06/09/2009 
Privilege Log - Dated 2-23-2011 
' 
' 
I 
& 
Farmer Jaffe Weissin!! Edwards Fistos & Lehrman 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Bradley Edwards 
Confidential Source 
Providing Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
Confidential 
Bradley Edwards 
Providing Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W /P Priv .; not reasonably calculated to lead to 
Epstein Strategies 
discovery of admissible evidence 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W /P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery of admissible evidence 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calcu...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine- Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Source 
discovery of admissible evidence 
19986-19987 09/28/2009 
Confidential 
Mike Fisten 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Molestations 
discovery of admissible evidence 
04905-04906 07/15/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
04946-04951 
10/28/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05148 
05/22/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05151 
05/26/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05161 
05/28/2009 
Bradley Edwards 
Confidential Source 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05203 
06/23/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05207-05208 06/23/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05220-05221 
06/23/2009 
Confidential 
Bradley Edwards 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05224-05225 06/24/2009 
Confidential 
Bradley Edwards 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05239 
06/23/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasona...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissimz Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
01280-01288 09/18/2009 
Confide ntia I 
Bradley Edwards 
Litigation Strategy 
w /P Privilege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
01131-01134 10/08/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
00988 
04/25/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Privilege; Not reasonably calculated to lead 
to discovery of admissible evidence. 
10163-10167 08/12/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Privilege; Not reasonably calculated to lead 
to discovery of admissible evidence. 
10181-10188 08/12/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W /P Privilege; Not reasonably calculated to lead 
to discovery of admissible evidence. 
10245-10251 09/08/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Privilege; Not reasonably calculated to lead 
to discovery of admissible evidence. 
10364-10367 09/17/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
10586-10591 09/24/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
10625-10632 10/02/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
10698-10699 10/13/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestatio...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Epstein Molestations 
to discovery of admissible evidence. 
11075-11076 07/29/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
11080-11082 07/31/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
11085-11097 09/04/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Privilege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
11123-11136 09/17/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Source 
Epstein Molestations 
to discovery of admissible evidence. 
11140-11142 
10/04/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Source 
Epstein Molestations 
to discovery of admissible evidence. 
11150-11151 
10/12/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Privllege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
10390-10393 
09/19/2009 
Bradley Edwards 
Confidential Source 
Additional 
lnformatlon 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Epstein Molestations 
to discovery of admissible evidence. 
11157-11165 
10/25/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Privilege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
11170-11174 06/23/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Privilege; Not reasonably calculated to lead 
Source 
Epstein Molestations 
to discovery of admissible evidence. 
11184-11185 05/27/2009 
Confidentia...

NOT A CERTIFIED COPY
Privilege Log-Dated 2-23-2011 
Farmer Jaffe. Weissine. Edwards. Fistos & Lehrman 
E 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
11372-11373 08/11/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Privilege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
11380-11383 08/12/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Privilege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
11438-11442 09/17/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W /P Privilege; Not reasonably calculated to lead 
Source 
Epstein Molestations 
to discovery of admissible evidence. 
11549-11550 10/01/2009 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Privilege; Not reasonably calculated to lead 
source 
to discovery of admissible evidence. 
11574-11579 10/13/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Privilege; Not reasonably calculated to lead 
Source 
to discovery of admissible evidence. 
BOX2 
~ 
DATE 
TO 
FROM 
DESCRIPTION 
OBJEQION 
08029-08032 
09/14/2009 
Bradley Edwards 
Tami Wolfe 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08026-08028 
05/01/2009 
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 
07738-07739 
05/13/2009 
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 
07747 
09/17/2009 
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...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
I 
& 
& 
Farmer Jaffe Weissing Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
fBQM 
DESCRIPTION 
OBJECTIQN 
discovery of admissible evidence; protected by 
privacy rights 
07760-07765 
09/11/2009 
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 
07766 
10/11/2009 
Jacquie Johnson 
Attorneys at RRA 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
07767-07784 
05/01/2009 
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 
07785-07790 
06/26/2009 
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 
07791 
04/04/2009 
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 
07792-07793 
04/01/2009 
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 
07794-07841 
04/04/2009 
Paul Cassell 
Bradley Edwards 
Full draft of motion to stay 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
07842-07848 
06/16/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to le...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
& 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
EBQM 
DESCRIPTION 
OBJECTION 
privacy rights 
07849-07852 
04/10/2009 
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 
07853-07856 
06/10/2009 
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 
07857 -07862 
09/11/2009 
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 
07863-07864 
06/10/2009 
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 
07685-07874 
05/14/2009 
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 
07875-07876 
04/14/2009 
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 
07877-07884 
08/03/2009 
Jacquie Johnson 
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 
07886-07888 
08/02/2009 
Cara Holmes 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; p...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
a 
I 
Farmer Jaffe Weissimi Edwards Fistos & Lehrman 
~ATES 
DATE 
TO 
fB.QM 
DESCRIPTION 
OBJECTIQN 
07889-07892 
05/01/2009 
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 
07893-07904 
07/27/2009 
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 
07905-07908 
07/22/2009 
Jacquie Johnson 
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 
07910-07912 
08/10/2009 
Bradley Edwards 
Mike Fisten 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
07916 
10/16/2009 
Jacquie Johnson 
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 
07919 
08/27/2009 
Jacquie Johnson 
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 
07920-07930 
10/18/2009 
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 
05399 
10/17/2009 
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 righ...

NOT A CERTIFIED COPY
_____ :-:·-'·_. ____ _ 
Privilege Log - Dated 2-23-2011 
Farmer. Jaffe, Weissing. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05375-05378 
09/10/2009 
Jacquie Johnson 
Bradley Edward 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05372. 
04/20/2009 
MarcNurik 
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 
05380-05381 
09/11/2009 
Jacquie Johnson 
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 
05384-05385 
09/15/2009 
Jacquie Johnson 
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 
05348 
09/15/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05341 
09/04/2009 
Jacquie Johnson 
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 
05329-05330 
04/09/2009 
Beth Williamson 
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 
05332-05333 
05/20/2009 
William Berger 
Bradley Edwards 
litigation Strategy 
W/P; Attorney Client Pri...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
I 
' 
I 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
05320-05323 
07/30/2009 
Bradley Edwards 
Amy Swan 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05312-05313 
07/22/2009 
Nora Batian 
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 
05306-05307 
07/22/2009 
Nora Batian 
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 
05302 
07/22/2009 
Attorney 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 
05281 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Review of litigation materials 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05282-05283 
04/09/2009 
Beth Williamson 
Bradley Edwards 
Jane Doe v. Us 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05288-05291 
07/22/2009 
Bradley Edwards 
William Berger 
Dr. Swan 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05292 
07/22/2009 
Attorneys at RRA 
Ken Jenne 
RE: Epstein Meeting 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of ad...

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DATE 
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FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
05295-05297 
07/23/2009 
Attorneys at RRA 
Priscilla 
RE: Epstein Conference Room 
W/P; Attorney Client Privilege; Irrelevant and 
Nascimento 
Reserved 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05298 
08/03/2009 
MikeFisten 
Bradley Edwards 
Discussion of Epstein strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05261 
07/23/2009 
Amy Swan 
Bradley Edwards 
Victim Psychological Assessment 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18358-18359 
07/24/2009 
Bradley Edwards 
Ken Jenne 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04431-04432 
08/14/2009 
Jacquie Johnson 
Bradley Edwards 
RE: Epstein-Maxwell Subpoena 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04419-04420 
04/09/2009 
Bradley Edwards 
Paul Cassell 
RICO Statement 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04403-04416 
10/17/2009 
Paul Cassell 
Bradley Edwards 
Punitive Damages 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04387-04402 
08/19/2009 
Paul Cassell 
Bradley Edwards 
Victim 
Complaints, 
Forensic W/P; Attorney Client Privilege; Irrelevant and 
accountants, 
& 
Ep...

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Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
MU. 
TO 
FROM 
DESCRIPTION 
OBJECTION 
01082 
09/02/2009 
Jacquie Johnson 
Mike Fisten 
Subpoenas 
for 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
Housekeepers 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04363 
09/14/2009 
Jacquie Johnson 
Bradley Edwards 
LM 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04343-04344 
09/04/2009 
Bradley Edwards 
Jacquie Johnson 
Investigation 
into 
Epstein's W /P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04340-04342 
09/04/2009 
Jacquie Johnson 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04339 
09/03/2009 
Mike Fisten 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
00989 
09/04/2009 
Bradley Edwards 
William Berger 
Alessi Depa 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04325-04328 
07/30/2009 
Paul Cassell 
Bradley Edwards 
RE: 
Epstein· 
beneficiaries 
& 
W /P; Attorney Client Privilege; Irrelevant and 
response to asset freeze motion 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
00155 
06/25/2009 
Bradley Edwards 
Paul Cassell 
20 Cases & Bond 
W/P; Attorney Client Privilege; Irreleva...

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DATE 
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FROM 
DESCRIPTION 
OBJECTIQN 
Assets 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04314-04317 
09/11/2009 
Paul Cassell 
Bradley Edwards 
RE: Epstein- Add to our motion W/P; Attorney Client Privilege; Irrelevant and 
for a protective order • 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04307-04308 
04/08/2009 
Bradley Edwards 
Paul Cassell 
Motion 
to 
stay-response 
& W/P; Attorney Client Privilege; Irrelevant and 
motion to unseal Fed Civil Case 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04309-04311 
05/26/2009 
Paul Cassell 
Bradley Edwards 
Epstein 
Assets 
& 
Forensic 
Accounting 
04295 
09/11/2009 
Jacquie Johnson 
Bradley Edwards 
thoughts on Epstein's Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04305-04306 
04/08/2009 
Paul Cassell 
Bradley Edwards 
Motion to Strike references to W/P; Attorney Client Privilege; Irrelevant and 
the NPA & Revised response to not reasonably calculated to lead to the 
the motion to stay 
discovery of admissible evidence; protected by 
privacy rights 
04274-04276 
05/06/2009 
William Berger 
Bradley Edwards 
Sandy Berger Telephone call 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18334-18336 
07/24/2009 
KenJenne 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client- Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04216-04219 
09/08/2009 
William Berger...

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Farmer Jaffe Weissimz Edwards. Fistos & Lehrman 
BATES 
Q8.Il. 
IQ 
EB.QM 
DESCRIPTION 
Q~JECTION 
04202-04206 
09/08/2009 
Bradley Edwards 
William Berger 
Epstein's 
attorneys 
& 
Bob 
W/P; Attorney Client Privilege; Irrelevant and 
Josephsberg have filed several 
not reasonably calculated to lead to the 
motions on limits of the no discovery of admissible evidence; protected by 
contact order 
privacy rights 
04207-04215 
09/04/2009 
Attorneys at RRA 
Paul Cassell 
Letter to Critton RE: Protective 
W/P; Attorney Client Privilege; Irrelevant and 
Order 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04191-04193 
09/04/2009 
Paul Cassell 
William Berger 
Finding out who is protected by W/P; Attorney Client Privilege; Irrelevant and 
the order 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04194-04195 
09/04/2009 
Attorneys at RRA 
Steven Jaffe 
Seek Court Intervention 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to· lead to the 
discovery of admissible evidence; ·protected by 
privacy rights 
04196-04199 
09/08/2009 
Bradley Edwards 
William Berger 
Finding out who is protected by 
W/P; Attorney Client Privilege; Irrelevant and 
the order 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25937 
10/25/2009 
Scott Rothstein 
KenJenne 
Epstein's house staff 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25923 
09/09/2009 
Attorneys at RRA 
Maribel Matiska 
legal opinion RE: Epstein 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25832-25838 
06/01/2009 
Bradley Edwards 
William Berger 
contact ...

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BATES 
DATE 
IQ 
FROM 
DESCRIPTIOM 
OBJECTION 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19649-19651 
07/24/2009 
Bradley Edwards 
KenJenne 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19658-19661 
08/03/3009 
Bradley Edwards 
Ken Jenne 
Copperfield Depo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25809-25810 
10/04/2009 
William Berger 
Bradley Edwards 
Trail Prep 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04466-04469 
08/18/2009 
Bradley Edwards 
Paul Cassell 
Epstein Assets Subpoena 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01296 
10/02/2009 
Mike Fisten 
Michael Wheeler 
Subpoena of Detective Recarey 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04439-0442 
09/16/2009 
Bradley Edwards 
Paul Cassell 
RE: Epstein-Notice Of !ME 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04445 
07/31/2009 
Jacquie Johnson 
Bradley Edwards 
RE:Epstein 
Reminder-Mon W/P; Attorney Client Privilege; Irrelevant and 
8/3/09-Monthly 
Call 
in 
not reasonably calculated to lead to the 
Telephone Conference 
discovery of admissible evidence; protected by 
privacy rights 
04425-04428 
09/18/2009 
Paul Cassell 
Bradley Edwards...

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& 
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BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJEglON 
discovery of admissible evidence; protected by 
privacy rights 
04429 
10/07/2009 
Bradley Edwards 
Paul Cassell 
Motion for Sanctions 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25770-25772 
10/05/2009 
William Berger 
Bradley Edwards 
Victims for Tria I 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25768-25769 
10/05/2009 
Bradley Edwards 
William Berger 
Victims for Trail 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
26716-26717 
09/04/2009 
Mikefisten 
KenJenne 
NR as a victim 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
26714-26715 
10/13/2009 
Attorneys at RRA 
Russell Adler 
Trial date procured 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
20907-20908 
10/05/2009 
Bradley Edwards 
William Berger 
Victims for Trial 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19857-19860 
10/17/2009 
Mike Fisten 
Pat Roberts 
Epstein's Palm Beach Property 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19861-19862 
10/23/2009 
Paul Cassell 
Bradley Edwards 
Larry Visoski Depo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
dis...

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TO 
FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
19713-19715 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Copperfield Subpoena 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19720-19729 
09/30/2009 
Mike Fisten 
Jacquie Johnson 
Tentative Subpoena dates and 
W/P; Attorney Client Privilege; Irrelevant and 
people list 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19706-19707 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Dershowitz Subpoena ready to be 
W/P; Attorney Client Privilege; Irrelevant and 
signed 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19693-19695 
09/04/2009 
Mike Fisten 
Bradley Edwards 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19696-19697 
09/04/2009 
Jacquie Johnson 
Bradley Edwards 
Setting Up Depa Times 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19698-19700 
09/04/2009 
Mike Fisten 
Bradley Edwards 
Investigation in Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19685-19688 
08/27/2009 
Bradley Edwards 
KenJenne 
RE: Witness information that we W/P; Attorney Client Privilege; Irrelevant and 
need to use 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19689-19690 
09/02/2009 
Mike Fisten 
Jacquie Johnson 
Awaiting dates for the 2 other W/P; Attorney Client...

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DATE 
TO 
FROM 
DESCRIPTION 
OBJECfJON 
19691-19692 
09/02/2009 
Mike Fisten 
Pat Diaz 
Bill Riley Subpoena 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19673-19674 
08/10/2009 
Jacquie Johnson 
Bradley Edwards 
Depo List 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19654-19655 
08/03/2009 
Mike Fisten 
Bradley Edwards 
Setting Up Copperfield Oepo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19656-19657 
08/03/2009 
Mike Fisten 
Bradley Edwards 
list of people to subpoena 
W/P; Attorney Qient Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19662-19663 
08/03/2009 
Mike Fisten 
Bradley Edwards 
Setting Up Copperfield Depa 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19652-19653 
08/26/2009 
Jacquie Johnson 
Bradley Edwards 
Witness information that we 
W/P; Attorney Client Privilege; Irrelevant and 
need to use 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18348-18349 
08/27/2009 
Bradley Edwards 
KenJenne 
RE: Witnesses information that W/P; Attorney Client Privilege; Irrelevant and 
we need to use 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04272 
06/30/2009 
William Berger 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to le...

NOT A CERTIFIED COPY
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DATE 
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FROM 
DESCRIPTION 
OBJEglQN 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19856 
10/17/2009 
Mike Fisten 
Mike Fisten 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
20888 
09/12/2009 
Russell Adler 
Bradley Edwards 
Potential New witnesses 
W/P; Attorney Client Privilege~ Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
20946 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05807-05810 
07/23/2009 
Attorneys at RRA 
Priscila 
Conference room reserved 
W/P; Attorney Client Privilege; Irrelevant and 
Nascimento 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05262-05263 
07/22/2009 
Bradley Edwards 
Jacquie Johnson 
Investigator information 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25829 
05/11/2009 
Bradley Edwards 
William Berger 
Motion to unseal criminal records W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25830-25831 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25811-25813 
05/11/2009 
Attorneys at RR...

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DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
25815-25822 
06/01/2009 
William Berger 
Bradley Edwards 
Depa information 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18358-18359 
07/24/2009 
Bradley Edwards 
KenJenne 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05382 
09/12/2009 
Bradley Edwards 
Mike Fisten 
Potential new witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08033-08070 
10/23/2009 
Attorneys at RRA 
Mike Fistos 
Legal Research RE: Causes of W/P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
25997 
10/23/2009 
Scott Rothstein 
Russell Adler 
Legal Research 
privacy rights 
RE: causes of W/P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
26741-26763 
10/23/2009 
Attorneys at RRA 
Bradley Edwards 
legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
25774-25777 
05/12/2009 
Bradley Edwards 
Susan Stirling 
Filed Motions 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18177-18179 
08/24/2009 
KenJenne 
Bradley Edwards 
Eps...

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B_ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
18174-18176 
08/24/2009 
Ken Jenne 
Mike Fisten 
Epstein Probation 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18172-18173 
08/24/2009 
Mike Fisten 
Bradley Edwards 
Epstein Probation 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18170 
08/24/2009 
Bradley Edwards 
Mike fisten 
Epstein Probation 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03106 
06/03/3009 
Bradley Edwards 
Shawn Gilbert 
Epstein Case Info 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02593-02594 
05/13/2009 
Bradley Edwards 
Shawn Gilbert 
Discussion 
with 
secretary 
W/P; Attorney Client Privilege; Irrelevant and 
regarding client information 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08014 
Undated 
Unknown Staff 
Bradley Edwards 
Miscellaneous case info 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
27494 
10/23/2009 
Attorneys at RRA 
Mike Fistos 
Legal Research RE: Causes of W/P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18166-18167 
08/04/2009 
Bradley Edwards 
Mike Fisten 
Copperfield Depo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of...

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Privilege Log - Dated 2-23-2011 
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I 
Farmer Jaffe Weissinf:?. Edwards. Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
18164-18165 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Copperfield Depo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18771-18773 
04/27/2009 
Marc Nurik 
Bradley Edwards 
Legal Research RE: causes of W /P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18742-18744 
09/10/2009 
Jacquie Johnson 
Bradley Edwards 
Dershowitz Depo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18737-18741 
09/10/2009 
Jacquie Johnson 
Bradley Edwards 
Depo technicalities 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
20263-20282 
10/14/2009 
Pat 
Roberts, 
Ronald Wise 
Vehicle Registrations-Visoski 
W/P; Attorney Client Privilege; Irrelevant and 
Mike Fisten 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
20219-20262 
10/14/2009 
Pat 
Roberts, 
Ronald Wise 
Visoski Research & Questions 
W/P; Attorney Client Privilege; Irrelevant and 
Mike Fisten 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
17225-17230 
07/22/2009 
Bradley Edwards 
Jacquie Johnson 
Wayne Black Retainer 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
17038-17040 
10/29/2009 
Cara Holmes 
Jacquie Johnson 
RE: 
Subpoenas 
for 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
attorneys 
not rea...

NOT A CERTIFIED COPY
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Mill 
DATE 
TO 
FROM 
DESCRIPTION 
OBJEg:IQN 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16795-16796 
10/01/2009 
Bradley Edwards 
Jacquie Johnson 
Trump Depo 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16455-16759 
09.10/2009 
Bradley Edwards 
Jacquie Johnson 
Depo Dates 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16436-16437 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Dershowitz Depo 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16400-16404 
09/02/2009 
Mike Fisten 
Jacquie Johnson 
lnvestigatio n 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16394-16395 
08/31/2009 
Bradley Edwards 
Jacquie Johnson 
Depo Dates 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01046 
08/25/2009 
Cara Holmes 
Bradley Edwards 
Computer information 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01048-01050 
07/28/2010 
William Berger 
Bradley Edwards 
Hard drive of Plaintiffs computer 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01052 
09/09/2009 
Attorneys at RRA 
Maribel Matiska 
legal Opinion RE: Epstein 
W/P; Attorney Client Pr...

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DATE 
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DESCRJPTION 
QBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
01100 
10/19/2009 
Russell Adler 
Bradley Edwards 
Dershowitz Involvement 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01105 
08/11/2009 
Bradley Edwards 
Alan Garten 
Potential New Witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01111 
05/13/2009 
Bradley Edwards 
Paul Cassell 
Legal research 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01112-01117 
05/12/2009 
Bradley Edwards 
William Berger 
Dr.Swan 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01139-01142 
04/29/2009 
Staff 
Bradley Edwards 
Epstein Depo revised 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
01151 
09/11/2009 
Beth Williamson 
Bradley Edwards 
privacy rights 
Motion for protective order final 
W/P; Attorney Client Privilege; Irrelevant and 
draft 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01167 
09/11/2009 
Bradley Edwards 
Jacquie Johnson 
Epstein MPO 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01216 
05/21/2009 
Bradley Edwards 
William Berger 
Immunity for testimony about W/P; Attorney Client Privilege; Irrelevant and 
prostitution 
not reasonably calculated to lead to the...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
01247 
09/30/2009 
Bradley Edwards 
Jacquie Johnson 
Therapy Notes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01268-01269 
10/22/2009 
Bradley Edwards 
Marc Nurik 
Epstein meeting 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01293 
08/19/2009 
KenJenne 
Bradley Edwards 
Epstein Assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01299 
04/21/2009 
Bradley Edwards 
Carolyn Edwards 
Order denying the motion to W/P; Attorney Client Privilege; Irrelevant and 
reassign or transfer 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01305 
08/24/2009 
Paul Cassell 
Bradley Edwards 
Epstein Computers 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01313 
09/02/2009 
Attorneys at RRA 
Jacquie Johnson 
Epstein Depa 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01333 
08/03/3009 
Jacquie Johnson 
Bradley Edwards 
Epstein Depa 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01335 
08/03/2009 
Mike Fisten 
Bradley Edwards 
Investigation into Epstein planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
...

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Privilege log - Dated 2-23-2011 
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FROM 
DESCRIPTION 
OBJEg]ON 
01337 
08/10/2009 
Jacquie Johnson 
Bradley Edwards 
Epstein Depo list 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01363 
09/08/2009 
Ken Jenne 
Bradley Edwards 
Motion to freeze assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01414-01416 
98/18/2009 
Bradley Edwards 
Mike Fisten 
Epstein Potential Witness List 
W/P; Attorney Client Privilege; Irrelevant and 
& Ken Jenne 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01417 
08/24/2009 
Mike Fisten 
Bradley Edwards 
Potential Witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01429 
09/09/2009 
Attorneys at RRA 
Bradley Edwards 
Epstein 
telephone 
conference 
W/P; Attorney Client Privilege; Irrelevant and 
today 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01431 
07/31/2009 
Jacquie Johnson 
Bradley Edwards 
Epstein case info 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
01432 
09/15/2009 
Bradley Edwards 
Pat Diaz 
privacy rights 
New Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01434 
10/19/2009 
Marc Nurik 
Bradley Edwards 
Epstein Evidence 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence...

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OBJECTIQN 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01466 
07 /31/20009 
William Berger 
Bradley Edwards 
Epstein Presentation 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01471 
07/18/2009 
Wayne Black 
Bradley Edwards 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01480 
07/22/2009 
Attorneys at RRA 
Bradley Edwards 
Epstein Meeting 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01482 
07/24/2009 
KenJenne 
Bradley Edwards 
Investigation into Epstein planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01491 
08/10/2009 
Ken Jenne 
Bradley Edwards 
Investigative fees 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01492 
08/10/2009 
Jacquie Johnson 
Bradley Edwards 
The Mar-a-Lago Club Depo 
W/P; Attorney Client Privile,e; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01495 
08/11/2009 
MarcNurik 
Bradley Edwards 
Potential Witness 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01498 
08/17/2009 
Marc Nurik 
Bradley Edwards 
Legal opinion re:Epstein 
W/P; Attorney Client Privilege; Irrelevant and 
not r...

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BATES 
Qfil. 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
·, 
discovery of admissible evidence; protected by 
privacy rights 
01502 
08/21/2009 
Marc Nurik 
Bradley Edwards 
Epstein Evidence 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01513 
08/25/2009 
Jacquie Johnson 
Bradley Edwards 
Discovery for the girls 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01522 
08/14/2009 
Bradley Edwards 
Marc Nurik 
Legal opinion 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01522 
10/08/2009 
Ken Jenne 
Bradley Edwards 
New Victim 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01523-01524 
10/26/2009 
Marc Nurik 
Bradley Edwards 
Meeting on Epstein 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01527 
04/27/2009 
Marc Nurik 
Bradley Edwards 
New Victim 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01540 
05/01/2009 
William Berger 
Bradley Edwards 
Litigation Strategy on punitive 
W/P; Attorney Client Privilege; Irrelevant and 
damages 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01553 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
Letter from JP Morgan Chase 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to iead to the 
discovery of admissible ...

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l;JATES 
DATE 
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ffiQM 
DESCRIPTION 
QBJEctlON 
privacy rights 
01566 
05/11/2009 
Wayne Black 
Bradley Edwards 
New Victim 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01586 
05/26/2009 
Paul Cassell 
Bradley Edwards 
Opposition to the continuance of W/P; Attorney Client Privilege; Irrelevant and 
the trial date 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
15690-15691 
10/01/2009 
Jacquie Johnson 
Bradley Edwards 
Trump Depa 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01607 
10/17/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy on motions 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01621 
04/19/2009 
Marc Nurik 
Bradley Edwards 
Potential New Witness 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01622 
06/09/2009 
Susan Stirling 
Bradley Edwards 
Important phone call due today 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01624 
06/11/2009 
Robert Busche! 
Bradley Edwards 
Motion for bond asset transfer 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01627 
05/06/2009 
Bradley Edwards 
Marc Nurik 
Dateline interest into epstein 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissibl...

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DESCRIPTION 
OBJECTION 
01628 
06/15/2009 
Roben Buschel 
Bradley Edwards 
Investigations 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01635 
05/21/2009 
Bradley Edwards 
Carolyn Edwards 
Personal Conversation 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01636 
06/23/2009 
Susan Stirling 
Bradley Edwards 
Motion to unseal 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01638 
06/29/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy RE: Motion to 
W/P; Attorney Client Privilege; Irrelevant and 
unseal 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01644 
07/06/2009 
Confidential 
Bradley Edwards 
Request for admission 
W/P; Attorney Client Privilege; Irrelevant and 
Source 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01646 
07/06/2009 
Confidential 
Bradley Edwards 
Secret Plea deal for Bear Stearns 
W/P; Attorney Client Privilege; Irrelevant and 
Source 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01648 
07/11/2009 
Wayne Black 
Bradley Edwards 
Investigating Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01650 
07/13/2009 
Carl Linder 
Bradley Edwards 
Epstein's Assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protecte...

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OBJECTION 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01663 
07/18/2009 
Mike Fisten 
Bradley Edwards 
Epstein's cars 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01668 
07/29/2009 
Bradley Edwards 
Wayne Black 
Sarah Kellen number 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01764 
07/31/2009 
Bradley Edwards 
Carolyn Edwards 
Case Numbers 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01676 
10/17/2009 
Paul Cassell 
Bradley Edwards 
Motions 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
01681 
08/03/20009 
Mike Fisten 
Bradley Edwards 
Positing 
privacy rights 
regarding 
litigation 
W/P; Attorney Client Privilege; Irrelevant and 
preparation 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
01682 
09/04/2009 
Paul Cassell 
Bradley Edwards 
privacy rights 
Litigation Strategy-Order 242 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01684 
09/11/2009 
Jacquie Johnson 
Bradley Edwards 
Plaintiff firms the notices of W/P; Attorney Client Privilege; Irrelevant and 
depos 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01686 
09/11/2009 
Mike Fisten 
Bradley Edwards 
Potential new witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not re...

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FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
01692 
09/12/2009 
William Berger 
Bradley Edwards 
Proposal for settlement 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01698 
05/05/2009 
Paul Cassell 
Bradley Edwards 
Epstein Victim Depos 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01702 
09/17/2009 
Paul Cassell 
Bradley Edwards 
Epstein Depos 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01705 
05/14/2009 
William Berger 
Bradley Edwards 
Statutory Rape 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01711 
04//01/2009 
Carolyn Edwards 
Bradley Edwards 
Third party subs 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01737 
07/14/2009 
Richard Wolfe 
Bradley Edwards 
Facebook/Myspace 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01564 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
Investigation Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01603 
10/15/2009 
Bradley Edwards 
Adam Horowitz 
Testimony RE: Vehicles 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible...

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Privilege Log - Dated 2-23-2011 
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Farmer Jaffe. Weissimz Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
.ffiQM. 
DESCRIPTION 
OBJECTION 
privacy rights 
01742 
10/12/2009 
Beth Williamson 
Bradley Edwards 
Filing fee check 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01743 
10/29/2009 
Beth Williamson 
Bradley Edwards 
New folder for Jane Doe Created 
W/P; Attorney Client Privilege; Irrelevant and 
& 
Jacquie 
not reasonably calculated to lead to the 
Johnson 
discovery of admissible evidence; protected by 
privacy rights 
01745 
10/15/2009 
Bradley Edwards 
Paul Cassell 
Epstein's Cars 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05726 
08/14/2009 
Bradley Edwards 
William Berger 
Legal opinion 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
27395 
08/13/2009 
Marc Nurik 
Scot Rothstein 
Legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
26356 
08/13/2009 
Scott Rothstein 
Russell Adler 
Legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and 
action against Epstein 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04225 
06/15/2009 
Bradley Edwards 
Wayne Black 
Epstein Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04229-04233 
06/16/2009 
Wayne Black 
Bradley Edwards 
Epstein secret plea deal with 
W/P; Attorney Client Privilege; Irrelevant and 
Bear Stearns 
not reasonably ca...

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DATE 
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FROM 
DESCRIPTION 
OBJECTION 
04237-04242 
06/15/2009 
Bradley Edwards 
Wayne Black 
Epstein secret plea deal with W/P; Attorney Client Privilege; Irrelevant and 
Bear Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04246 
06/15/2009 
Wayne Black 
Bradley Edwards 
Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and 
-Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04250 
06/15/2009 
Wayne Black 
Bradley Edwards 
Epstein Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04255-04256 
06/15/2009 
Wayne Black 
Bradley Edwards 
Epstein secret plea deal for Bear 
W/P; Attorney Client Privilege; Irrelevant and 
Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04260 
06/15/2009 
Bradley Edwards 
Wayne Black 
Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and 
Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04523 
05/14/2009 
Bradley Edwards 
Wayne Black 
Investigating Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05088-05090 
10/27/2009 
Attorneys at RRA 
KenJenne 
Epstein's assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05108 
04/01/2009 
Bradley Edwards 
Carolyn Edwards 
Victims employment 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to t...

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Privilege Log - Dated 2-23-2011 
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DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05145 
05/21/2009 
Bradley Edwards 
Carolyn Edwards 
Epstein Hearing 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05237 
07/20/2009 
Wayne Black 
Bradley Edwards 
Investigating Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02648-02650 
08/10/2009 
Jacquie Johnson 
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 
02651 • 
07/29/2009 
Bradley Edwards 
Wayne Black 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02661-02662 
05/12/2009 
Russell Adler 
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 
02674-02677 
08/18/2009 
Jacquie Johnson 
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 
02678-02679 
04/10/2009 
Russell Adler 
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 
02682-02683 
08/10/2009 
Jacquie Johnson 
Bradley Edwards 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
...

NOT A CERTIFIED COPY
Privilege log - Dated 2-23-2011 
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BATES 
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FROM 
DESCRIPTION 
OBJECTIQ~ 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02728-02729 
08/04/2009 
Bradley Edwards 
Spencer Kuvin 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02746 
07/22/2009 
Bradley Edwards 
Adam Steinberg 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02813-02814 
08/26/2009 
Bradley Edwards 
Pat Diaz 
Providing New Witnesses 
W/P; Attorney Client Privi°iege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02817-02826 
08/04/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02827-02832 
05/12/2009 
Attorneys at RRA 
William Berger 
Litigaticm Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02833-02835 
08/23/2009 
Bradley Edwards 
Pat Diaz 
Other Rape Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02874-02876 
05/23/2009 
Bradley Edwards 
William Berger 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02887-02888 
08/26/2009 
Bradley Edwards 
Pat Diaz 
Litigation Strategy 
W/P; Attorney Client Privilege; Irr...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissimt Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJErTION 
discovery of admissible evidence; protected by 
privacy rights 
02889-02890 
10/14/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02891 
10/12/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; jprotected by 
privacy rights 
02892 
08/03/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02894 
09/09/2009 
Mike Fisten 
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 
02899 
09/29/2009 
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 
03001-03002 
05/15/2009 
Susan Stirling 
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 
03003 
04/15/2009 
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 
03004 
06/23/2009 
Wayne Black 
Bradley Edwards 
privacy rights 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admi...

NOT A CERTIFIED COPY
Privilege log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinR Edwards Fistos & Lehrman 
MI§ 
DATE 
TO 
FROM 
DESCRIPTION 
OBJEg:ION 
privacy rights 
03005-03006 
08/03/2009 
Mike Fisten 
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 
03007 
10/07/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Cllent Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03008 
04/23/2009 
Susan Stirling 
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 
03013 
05/25/2009 
Bradley Edwards 
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 
03014 
10/08/2009 
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 
03015 
04/24/2009 
Steven Jaffe 
Susan Stirling 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03017-03018 
08/18/2009 
Mike Fisten 
Bradley Edwards 
Providing New witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; JProtected by 
03019 
09/19/2009 
Bradley Edwards 
Pat Diaz 
privacy rights 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
91...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
Farmer Jaffe. Weissin~ Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
03020 
09/16/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03021-03027 
09/19/2009 
Bradley Edwards 
Pat Diaz 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03031-03034 
09/18/2009 
Pat Diaz 
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 
03035 
09/29/2009 
Russell Adler 
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 
03039 
06/05/2009 
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 
03040 
09/04/2009 
MikeFisten 
William Berger 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03044 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03045-03047 
09/30/2009 
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 
03048 
04/21/2009 
Pa...

NOT A CERTIFIED COPY
___ .• ··.·_:'.·:··,·. __ ._ .. 
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinR Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03050~03052 
10/16/2009 
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 
03053 
10/17/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03054 
10/13/2009 
Attorneys at RRA 
Grant Smith 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03056 
09/04/2009 
Bradley Edwards 
Mikefisten 
Other Rape Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03072 
06/22/2009 
Bradley Edwards 
Wayne Black 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
-
discovery of admissible evidence; protected by 
privacy rights 
03073 
09/01/2009 
Bradley Edwards 
Mike Fisten 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03074-03075 
10/28/2009 
Jacquie Johnson 
Michael Wheeler 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03100 
10/15/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
W/P; Attorney Client Privilege; Irre...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
& 
& 
E 
' 
Farmer Jaffe Weissint! Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJEQJQN 
discovery of admissible evidence; protected by 
privacy rights 
'03102.-03103 
07/21/2009 
Bradley Edwards 
Paul Cassell 
Other Rape Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03107-03113 
07/24/2009 
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 
03114 
08/04/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03115-03118 
05/16/2009 
Bradley Edwards 
Susan Stirling 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03124 
06/23/2009 
Bradley Edwards 
Wayne Back 
Litigation Strategy 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03125 
09/08/2009 
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 
03127-03128 
05/19/2009 
Susan Stirling 
Bradley Edwards 
privacy rights 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03135-03136 
08/04/2009 
Mike Fisten 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
' 
• 
i 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
Qfil 
TO 
FROM 
DESCRIPTION 
QBJECTION 
privacy rights 
03137 
08/22/2009 
Wayne Black 
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 
03138 
10/08/2009 
Beth Williamson 
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 
03145 
10/30/2009 
Jacquie Johnson 
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 
03146 
08/22/2009 
Bradley Edwards 
Wayne Black 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03147-03154 
10/07/2009 
Bradley Edwards 
Beth Williamson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03155-03155 
10/08/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03158-3159 
04/28/2009 
Bradley Edwards 
Susan Stirling 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
03191-03196 
10/14/2009 
Paul Cassell 
Bradley Edwards 
privacy rights 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected ...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
Farmer Jaffe Weissine Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
03197-03199 
08/14/2009 
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 
03205-03211 
09/13/2009 
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 
03212 
08/11/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03213 
10/28/2009 
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 
03214-03218 
10/27/2009 
Paul Cassell 
Ronald Wise 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03223-03232 
04/15/2009 
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 
03233-03242 
09/28/2009 
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 
03245 
06/01/2009 
William Berger 
Bradley Berger 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights ...

NOT A CERTIFIED COPY
····-----·--··· ___ .. 
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
OATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03303 
07/30/2009 
Bradley Edwards 
Beth Williamson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03306-03307 
09/04/2009 
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 
03308-03309 
09/04/2009 
Beth Williamson 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney dient Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03310-03314 
09/04/2009 
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 
03389 
07/30/2009 
Beth Willlamson 
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 
03392-03393 
09/04/2009 
Bradley 
Beth Williamson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
Williamson 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03461-03463 
09/19/2009 
Bradley Edwards 
Susan Stirling 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03464-03465 
06/14/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
W...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
Farmer. Jaffe. Weissine:. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
03469-03486 
05/15/2009 
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 
03495 
08/27/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03496-03501 
10/28/2009 
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 
03502-03506 
10/27/2009 
Paul Cassell 
Ronald Wise 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03507-03510 
10/28/2009 
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 
03511-03513 
10/28/2009 
Bradley Edwards 
Ronald Wise 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03514-03516 
10/26/2009 
Paul cassell 
Ronald Wise 
Litigation Strategy 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03520-03523 
07/04/2009 
Bradley Edwards 
Paul Cassell 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the ...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
& 
I 
' 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BAilS 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
03524 
09/04/2009 
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 
03525-03530 
09/05/2009 
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 
03532 
08/24/2009 
Jacquie Johnson 
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 
03536 
07/19/2009 
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 
03539-03540 
08/26/2009 
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 
03541-03544 
10/12/2009 
Attorneys at RRA 
Ronald Wise 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03545-03547 
06/26/2009 
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 
03548-03549 
04/11/2009 
Wayne Black 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protecte...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: 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 eviden...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
' 
Farmer Jaffe WeissinJ!. Edwards Fistos & Lehrman 
-
BATES 
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. 
Jane Doe II v. Epstein 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Activity in case 9:08-cv-80893-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein Motion to irrelevant and not reasonably calculated to lead 
Dismiss 
to the discovery of the admissible evidence; 
protected by privacy rights 
01918- 01919 
04/15/2009 
Attorneys at RRA 
Bradley 
J. 
Activity in case 9:08-cv-80893-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein Motion to irrelevant and not reasonably calculated to lead 
Compel 
to the disc...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
C 
I 
I 
' 
Farmer Jaffe Weissin1? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
ERQM 
DESCRIPTION 
OBJECTION 
Motion to Strike 
to the discovery of the admissible evidence; 
protected by privacy rights 
01925 
08/26/2009 
Jacquie Johnson 
Bradley 
J. 
Adriana Surveillance/lnteiview 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Alfredo Rodriguez address 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01930 
09/05/2009 
Bradley 
J. 
William J. Berger 
Client info 
Work 
product; 
attorney /client 
privilege; 
Edwards 
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. 
Witness Info 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Epstein assets 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Call from sources of information 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Cassell Draft 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
01973-0...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
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Farmer Jaffe Weissini! Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTIQN 
protected by privacy rights 
01975 
08/10/2009 
Jacquie Johnson 
Bradley 
J. 
Computers 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Paul cassell 
Conference call 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Russell Adler 
Conflict check for Brad Edwards Work 
product; 
attorney/client 
privilege; 
Edwards 
files 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
0199() 
05/14/2009 
Bradley 
J. 
Paul Cassell 
Consolidation order 
Work 
product; 
attorney/ciient 
privilege; 
Edwards 
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. 
Oates for Subpoena -
Epstein's Work 
product; 
attorney/client 
privilege; 
Edwards 
housekeepers 
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. 
David Copperfield 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Deposition of Bill Riley 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02017-02018 
05/18/2...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
I 
I 
I 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
QBJECTION 
02023 
05/14/2009 
Attorneys at RRA 
Bradley 
J. 
Sid's deposition of Epstein 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
E.W., L.M. Doe v. Epstein - Letter Work 
product; 
attorney/ client 
privilege; 
Edwards 
from Bob Critton 
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. 
E.W., L.M. Doe v. Epstein - Letter 
Work 
product; 
attorney/client 
privilege; 
Edwards 
from Bob Critton 
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. 
Epstein-Confirming AT&T Dial in 
Work 
product; 
attorney/client 
privilege; 
Edwards 
Telephone 
Conference 
for irrelevant and not reasonably calculated to lead 
Monday, 6/8/09 at 2:00 p.m. 
to the discovery of the admissible evidence; 
protected by privacy rights 
02089-02090 
09/17/2009 
Paul Cassell 
Bradley 
J. 
Epstein hearing 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Epstein -
Monthly cau 
in Work 
product, 
attorney/client 
privilege; 
Edwards 
Telephone Conference 
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. 
Epstein -Telephone Conference 
Work 
product; 
attorney/ client 
priVilege; 
Edwards 
irreleva...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
Q~JECTION 
Edwards 
in New York for the following 
irrelevant and not reasonably calculated to lead 
week 
to the discovery of the admissible evidence; 
protected by privacy rights 
02112-02116 
09/10/2009 
Bradley 
J. 
Jacquie Johnson 
Epstein -
Yearbook picture of Work 
product; 
attorney/client 
privilege; 
Edwards 
Epstein rape victims 
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. 
Epstein (AUSA) 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Bradley 
J. 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Williamson 
Edwards 
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. 
Epstein cases-
depositions in Work 
product; 
attorney/client 
privilege; 
Edwards 
federal cases 
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. 
Epstein depo - New York 
Work 
product; 
attorney/ die nt 
privilege; 
Edwards 
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. 
Epstein Depa 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Epstein Depo 
Work 
product; 
attorney/c...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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I 
I 
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Farmer Jaffe WeissinJ:? Edwards Fistos & Lehrman 
-
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
02256-02257 
07/22/2009 
Jacquie Johnson 
Bradley 
J. 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Epstein - coordinating meetings 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Epstein -Video Deposition of S.K. 
Work 
product; 
attorney/client 
privilege; 
Edwards 
in NY 
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. 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Nora Batian 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Nascimento 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
02284-02855 
05/11/2009 
Susan K. Stirling 
Bradley 
J. 
Epstein info 
protected by privacy rights 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
01769 
10/30/2009 
...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
C 
I 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
§ATES 
DATE 
TO 
ffiQM 
DESCRIPTION 
QBJECTION 
protected by privacy rights 
01780 
09/14/2009 
Bradley 
J. 
William J. Berger 
Discussion of belief that Epstein 
Work 
product; 
attorney/client 
privilege; 
Edwards 
is transferring assets to avoid 
irrelevant and not reasonably calculated to lead 
judgments 
to the discovery of the admissible evidence; 
protected by privacy rights 
01787-01788 
09/04/2009 
Ken Jenne 
Bradley 
J. 
1. Accountants 2. Motion for IME 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Paul Cassell 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein Notification irrelevant and not reasonably calculated to lead 
of ninety days expiring 
to the discovery of the admissible evidence; 
protected by privacy rights 
01804-01805 
09/04/2009 
Beth 
s. 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney /client 
privilege; 
Williamson 
Edwards 
KAM Doe v. Epstein - Order on 
irrelevant and not reasonably calculated to lead 
motion for Medical Exam 
to the discovery of the admissible evidence; 
protected by privacy rights 
01806-01807 
09/09/2009 
Paul Cassell 
Bradley 
J. Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein - Motion for irrelevant and not reasonably calculated to lead 
protective order 
to the discovery of the admissible evidence; 
protected by privacy rights 
01808-01809 
09/10/2009 
Paul Cassell 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein - Order on 
irrelevant and not reasonably calculated to lead 
Motion for Extension of Time to to the discovery of the ad...

NOT A CERTIFIED COPY
____ • .. ·.L_··_: __________ _ 
Privilege Log- Dated 2-23-2011 
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Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTIQN 
OBJECTION 
01840-01841 
07/16/2009 
Paul Cassell 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein - Order on 
irrelevant and not reasonably calculated to lead 
Motion to Stay 
to the discovery of the admissible evidence; 
protected by privacy rights 
01867-01868 
09/28/2009 
Paul Cassell 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein -
Notice 
irrelevant and not reasonably calculated to lead 
(Other} 
to the discovery of the admissible evidence; 
protected by privacy rights 
03662-03663 
08/10/2009 
Attorneys at RRA 
Bradley 
J. 
Meeting with clients 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
litigation 
strategy 
and 
Work 
product; 
attorney/client 
privilege; 
Edwards 
preparation 
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. 
Weds filing 
Work 
product; 
attorney/ client 
privilege; 
Edwards 
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. 
Jacquie Johnson 
Wexner deposition for 14th 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Paul Cassell 
Motion to unseal/Motion to stay 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not re...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
§:.ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJEglON 
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. 
Paul Cassell 
Epstein - complaint 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Paul Cassell 
Epstein fraudulent transfer 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Paul Cassell 
Revisited sexual history memo 
Work 
product; 
attorney/ client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evid_ence; 
protected by privacy rights 
08401 
07/22/2009 
Bradley 
J. 
Paul Cassell 
Reply memo on asset transfers 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Cara L. Holmes 
Rodriguez Deposition 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08421 
06/02/2009 
Bradley 
J. 
William J. Berger 
Strategy 
Work 
product; 
attorney/client 
privilege; 
Edwards 
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. 
Mike Fisten 
Subpoena info 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to t...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
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 
Work 
product; 
attorney/client 
privilege; 
Epstein Affidavit 
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 
privllege; 
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 
Work 
product; 
attorney/client 
privilege; 
Transcript 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
023...

NOT A CERTIFIED COPY
_..·.·:_.;• ___ :.:_·: ________ . 
Privilege Log-Dated 2-23-2011 
I 
I 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
QAll 
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/ die nt 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02292-02293 
05/19/2009 
Or. 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 
Fo rensics/lnvestigatio ns 
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/...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
ftP.TES 
.Mn 
IQ 
ffi.QM 
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-
Work 
product; 
attorney/client 
privilege; 
Emergency Petition for Writ of irrelevant and not reasonably calculated to lead 
Certiorari 
to the discovery of the admissible evidence; 
protected by privacy rights 
02224 
07/28/2009 
Jacquie Johnson 
Bradley Edwards 
Witness of Epstein rapes from 
Work 
product; 
attorney/client 
privilege; 
Switzerland 
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 ...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
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' 
Farmer Jaffe Weissini? Edwards Fistos & Lehrman 
~ATES 
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 
privllege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected b...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
E 
E 
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' 
Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCBIPTION 
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 
Work 
product; 
attorney/client 
privilege; 
attorney 
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 
...

NOT A CERTIFIED COPY
Privilege tog- Dated 2 .. 23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
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/...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
~TES 
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/clien...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
' 
I 
Farmer Jaffe Weissint? Edwards. Fistos & Lehrman 
BATES 
DAT£ 
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 Work 
product; 
attorney/client 
privilege; 
Attorneys 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
08072-08075 
07/22/2009 
Paul Cassell 
Bradley Edwards 
Total counts for E.W. 
protected by privacy rights 
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; 
08114-08117 
08/18/2009 
P...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
[SATES 
DATE 
IQ 
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 I cl lent 
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 
Work 
product; 
attorney/client 
privilege; 
Forum 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
15827-15837 
07/22/2009 
Jacquie J...

NOT A CERTIFIED COPY
·--:: .
.. 
___ 
, __ ,_. 
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
SATES 
_..,,......, 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
15820-15822 
10/29/2009 
Jacquie Johnson 
Cara Holmes 
Subpoenas 
for 
Epstefn's Work 
product; 
attorney/client 
privilege; 
Attorneys 
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 
Work 
product; 
attorney/client 
privilege; 
wexner atty 
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 Adriana Mucinska 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
t 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DfStRIPTION 
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 
work 
product; 
attorney/client 
privilege; 
Fraudulent Transfers 
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 
work 
product; 
attorney/client 
privilege; 
wexner 
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/c...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
t 
t 
I 
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 rights 
03905-03920 
09/08/2009 
William Berger 
Bradley Edwards 
E.W., L.M. Doe v. Epstein 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
03937 
08/1...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
C 
I 
Farmer Jaffe Weissin2 Edwards Fistos & Lehrman 
BATES 
M!E 
TO 
FROM 
DESCRIPTION 
OBJEglON 
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 D...

NOT A CERTIFIED COPY
·--- ·;··. ,: ... _, ...... . 
Privilege Log - Dated 2-23-2011 
,. 
I 
I 
I 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
!1ATE5 
QAis 
TO 
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 
Seth 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 Work 
product; 
attorney/client 
privilege; 
Consolidate + Cassell strategy 
irrelevant and not reasonably calculated to lead 
Memo for Jay 
to the discovery of the admissible evidence; 
protected by priva...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
t 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
~ATES 
Rm 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
07967-07975 
09/22/2009 
Jacquie Johnson 
MikeFisten 
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 dlent 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 
Work 
product; 
attorney/client 
privilege; 
- RC - Bear Sterns" 
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 
Work 
product; 
attorney/ client 
privilege; 
accountant 
detecting 
Epstein 
irrelevant and not reasonably calculated to lead 
fraudulent transfers 
to the discovery of the admissible evidence; 
protected by privacy ri...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23·2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
10 
FROM 
DESCRIPTION 
OBJECTION 
Visoski depo 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
0 7595-07604 
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 
privllege; 
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 Work 
product; 
attorney/client 
privilege; 
Consolidate + Cassell Strategy 
irrelevant and not reasonably calculated to lead 
Memo for Jay 
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 t...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissinl? Edwards Fistos & Lehrman 
BATES 
DATE 
!Q 
fBQM 
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/ die nt 
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 ...

NOT A CERTIFIED COPY
Privilege log - Dated 2-23-2011 
I 
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Farmer Jaffe WeissinR: Edwards Fistos & Lehrman 
BATES 
DATE 
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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 2n° 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 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 
07319 
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 
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 
Work 
product; 
attorney/client 
privilege; 
week? 
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 
07247-072S1 
09/08/2009 
Pau...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
IQ 
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 Work 
product; 
attorney/client 
privilege; 
and memo final 
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 
Work 
product; 
attorney /client 
privilege; 
Compel 
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 
L.M. and E.W. 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 Work 
product; 
attorney/client 
privilege; 
Compel 
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 
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 
07066-07070 
07/23/2009 
Bradley E...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
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TO 
FROM 
DESCRIPTION 
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 
LM. and E.W. v. Epstein - I'm on 
Work 
product; 
attorney/dient 
privilege; 
it 
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 Work 
product; 
attorney/client 
privilege; 
Extension 
of 
Time 
to 
File 
irrelevant and not reasonably calculated to lead 
Response/Reply/ Answer 
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 Work 
product; 
attorney/client 
privilege; 
Madoff - Running a giant Ponzi 
irrelevant and not reasonably calculated to lead 
scheme?" 
to the discovery of the admissible evidence; 
protected by privacy rights 
06804-06805 
09/13/2009 
Paul Cassell 
Bradley Edwards...

NOT A CERTIFIED COPY
Privilege Log-Dated 2-23-2011 
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Farmer Jaffe Weissinf? Edwards Fistos & Lehrman 
BATES 
Q8Il 
TO 
fBQM 
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 Work 
product; 
attorney/client 
privilege; 
IME 
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; 
06767-06769 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
IME's 
protected by privacy rights 
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 
Work 
product; 
attorney/client 
privilege; 
Memo on Asset Protection Issues 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
06744-06747 
05/01/2009 
Paul Cassell 
Bradley Edwards 
Depa of Jeffrey Epstein 
protected by privacy rights 
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 disc...

NOT A CERTIFIED COPY
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Privilege Log - Dated 2-23-2011 
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DATE 
IQ 
FROM 
DESCRIPTION 
QBJEglON 
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 

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Privilege Log - Dated 2-23-2011 
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Mrs 
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 
Work 
product; 
attorney/client 
privilege; 
...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Mm 
TO 
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/dient 
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 Work 
product; 
attorney/client 
privilege; 
Critton on Motion 
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 
Work 
product; 
attorney/client 
privilege; 
INVOICE 
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 Nur...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
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Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman 
BATES 
QAis 
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 
AmySwan 
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 ...

NOT A CERTIFIED COPY
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Privilege Log - Dated 2-23-2011 
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Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
!!li,TES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05890 
07/27/2009 
Bradley Edwards 
Amy Swan 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calcuf ated to lead 
to the discoverv 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 
KenJenne 
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; 
attor...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
E 
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& 
Farmer Jaffe Weissin2: Edwards Fistos & Lehrman 
[SATES 
Mn 
IQ 
FROM 
DESCRIPTION 
OBJEglON 
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 
KenJenne 
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 
MarcNurik 
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 
Wo...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
Farmer Jaffe Weissini 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 
05680-05682 
05/11/2009 
Bradley Edwards 
William Berger 
Subpoena Clinton 
Work 
product; 
attorney/dient 
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 
Work 
product; 
attorney/client 
privilege; 
meeting 
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 
Work 
product; 
attorney/clien1t 
privilege; 
juvenile reports 
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 
Work 
product; 
attorney/client 
privilege; 
of Epstein 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
05610-05612 
04/27/2009 
Susan Stirling 
Bradley Edwards 
Request for Copies 
protected by privacy rights 
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 d...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
& 
& 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
§ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
QBJECTION 
05575-05576 
08/21/2009 
MarcNurik 
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 Work 
product; 
attorney/client 
privilege; 
counsel regarding depo for Sarah 
irrelevant and not reasonably calculated to lead 
Kellen 
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 
Work 
product; 
attorney/client 
privilege; 
meeting 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05512-05513 
07/23/2009 
Priscila 
Nora Batian 
Assemble...

NOT A CERTIFIED COPY
····-·-·•·;····l-•:•: ______ _ 
Privilege Log - Dated 2-23-2011 
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I 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJEg:ION 
to the discovery of the admissible evidence; 
protected by privacy rights 
0S502-05507 
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 
Work 
product; 
attorney/ client 
privilege; 
dateline 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
0S471-05472 
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 
Work 
product; 
attorney/client 
privilege; 
can postpone one party's depo irrelevant and not reasonably calculated to lead 
until the other is completed 
to the discovery of the admissible evidence; 
protected by privacy rights 
05409-05412 
08/17/2009 
Bradley Edwards 
Marc Nurik 
Legal 
opinion 
regarding 
Work 
product; 
attorney/client 
privilege; 
discovery 
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...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
' 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
§ATES 
DATE 
IQ 
ERQM 
DESCRIPTION 
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 
Depa Dates to take SR, LM, and 
Work 
product; 
attorney/client 
privilege; 
cw 
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 
KenJenne 
Judge's order on the Epstein 
Work 
product; 
attorney/client 
privilege; 
probation 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
05197-05199 
08/24/2009 
Attorneys at RRA 
Ken Jenne 
Michael Reiter info 
protected by privacy rights 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
140 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Flstos & Lehrman 
.§ATES 
DATE 
IQ 
fRQM 
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 Work 
product; 
attorney/client 
privilege; 
rulings 
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 Work 
product; 
attorney/client 
privilege; 
continue the trial 
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 Work 
product; 
attorney/client 
privilege; 
continue is due 6/8 
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 Work 
product; 
attorney/client 
privilege; 
Sid Garcia's witness list 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
pr...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer Jaffe. Weissin~. Edwards. Fistos & Lehrman 
I 
!}.ATES 
Qfil 
TO 
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 Work 
product; 
attorney/client 
privilege; 
the sex information of his clients 
irrelevant and nQt 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 
VZdepo 
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 Work 
product; 
attorney/client 
privilege; 
Epstein went 
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 -
Work 
product; 
attorney/client 
privilege; 
Emergency Petition for Writ of irrelevant and not reasonably calculated to lead 
Certiorari; Emergency Motion to to the discovery of the admissible evidence; 
Review Denial of Stay 
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 reaso...

NOT A CERTIFIED COPY
Privilege log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinR: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
Q8JECTIQN 
to the discovery of the admissible evidence; 
protected by privacy rights 
05054-05065 
08/18/2009 
Attorneys at RRA 
Mike Flsten 
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 
Work 
product; 
attorney/client 
privilege; 
witnesses 
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 
Work 
product; 
attorney/client 
privilege; 
burglary report 
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 -
Work 
product; 
attorney/client: 
• privilege; 
accountant affidavit will be sent 
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 
Work 
product; 
attorney/client 
privilege; 
amounts, etc. 
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 c...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
& 
I 
Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
rurr§ 
DATE 
TO 
EB.QM 
DESCRIPTION 
OBJECTION 
04893-04896 
09/10/2009 
Jacquie Johnson 
Bradley ~dwards 
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 
Work 
product; 
attorney/client 
privilege; 
case 
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 
Work 
product; 
attorney/client 
privilege; 
computers 
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 calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04642-04646 
09/11/2009 
Bradley Edwards 
Beth Williamson 
Discussions 
ab...

NOT A CERTIFIED COPY
Privilege Log - Dated 2~23~2011 
& 
& 
I 
Farmer Jaffe Weissin~ Edwards. Fistos & Lehrman 
BATES 
MJ]. 
TO 
FROM 
D~SCRIPTION 
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 Work 
product; 
attorney/client 
privilege; 
response on form 
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 Work 
product; 
attorney/client 
privilege; 
the 
ground 
-epstein's 
asset 
irrelevant and not reasonably calculated to lead 
transfers 
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 evidenc...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
ffiQM 
OESCRIPTIQN 
O~JECTION 
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 
Work 
product; 
attorney /client 
privilege; 
the case 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05541 
07/31/2009 
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 
Work 
product; 
attorney/client 
privilege; 
your expertise 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rightsO 
146 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
& 
' 
I 
Farmer Jaffe Weissing Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
fRQM. 
DESCRIPTION 
OBJECTION 
05640 
10/29/2009 
Pat Diaz 
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 Work 
product; 
attorney/client 
privilege; 
other 
girls 
on 
the 
list 
of irrelevant and not reasonably calculated to lead 
prospective clients 
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 
Work 
product; 
attorney/client 
privilege; 
in the case 
irrelevant and not reasonably calculated to lead 
147 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
' 
I 
' 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
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 
Work 
product; 
attorney/client 
privilege; 
in the case 
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 
Work 
product; 
attorney/client 
privilege; 
they interviewed pilots 
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/ dient 
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 
Work 
product; 
attorney/client 
privilege; 
and Mom 
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 
Work 
product; 
attorney/client 
privilege; 
and Mom 
irrelevant and not reasonably calculated to lead 
to the discovery of the_ admissible evidence; 
protected by privacy rights 
148 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
' 
I 
l 
Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
BATES 
Qfil 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
05995 
04/01/2009 
Bradley Edwards 
Carolyn Edwards 
Third 
party 
subpoenas 
for Work 
product; 
attorney /client 
privilege; 
Tatum/Courtney 
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 
Work 
product; 
attorney/client 
privilege; 
the case 
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 
Work 
product; 
attorney/client 
privilege; 
Fraudulent transfers + Affidavit 
irrelevant and not reasonably calculated to lead 
from you 
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 Work 
product; 
attorney/client 
privilege; 
us to serve subpoenas 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
C 
' 
t 
Farmer Jaffe Weissinl! Edwards Fistos & Lehrman 
i,iATES 
Qfil 
TO 
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 
KenJenne 
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 
KenJenne 
Political 
Work 
product; 
attorney/client 
privilege; 
Contributions/advertisement for irrelevant and not reasonably calculated to lead 
the rental on little St. James to the discovery of the admissible evidence; 
Island 
protected by privacy rights 
26570 
08/13/2009 
Scott Rothstein 
MarcNurik 
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 Work 
product; 
attorney/client 
privilege; 
moving offices 
irrelevant and not re...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
& 
& 
I 
Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman 
SATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
06679-06682 
08/26/2009 
Bradley Edwards 
Shawn Gilbert 
Personal convo in regards to 
Work 
product; 
attorney /client 
privilege; 
moving offices 
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 
Work 
product; 
attorney/client 
privilege; 
boyfriends house 
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 Work 
product; 
attorney/client 
privilege; 
subcontracted by Riley 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
08399 
07/23/2009 
Bradley Edwards 
Paul Cassell 
Epstein...

NOT A CERTIFIED COPY
: ....... _. 
.· .. 
·····-··-·•.· .... ·-······· 
Privilege Log - Dated 2-23-2011 
! 
I 
' 
I 
Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
@ATES 
gfil 
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. 
Work 
product; 
attorney/ client 
privilege; 
Louis to see expert 
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 Flsten 
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 Oershowitz 
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 
Work 
product; 
attorney/client 
privilege; 
Palm Beach 
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 
Work 
product; 
attorney/client 
privilege; 
and questions to consider during irrelevant and not reasonably calculated to lead 
the depo 
to the discovery of the admissible evidence; 
protected by privacy rights 
20092-20099 
08/24/2009 
Attorneys at RRA 
KenJenne 
Epstein travel 
Work 
product; 
attorney/client 
...

NOT A CERTIFIED COPY
:._:.,:-:-· 
·--·-···--·-·-·-···-·-·-·-··-·· 
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
SATES 
DATE 
TO 
FROM 
DESCRIPTION 
OB!ECTIQN 
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 
KenJenne 
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; 
20201-20204 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Serving Dershowitz 
protected by privacy rights 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
153 

NOT A CERTIFIED COPY
_____ _.:.;-_.,:_,.;-
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
MI! 
TO 
FROM 
DESCRIPTION 
OBJECTION 
20193-20200 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Proof of him being out of FL -
Work 
product; 
attorney/client 
privilege; 
Violation of the agreement 
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 
Mikefisten 
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 
Work 
product; 
attorney/client 
privilege; 
info 
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 Work 
product; 
attorney/client 
privilege; 
surgery 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20187-20189 
08/24/2009 
Attor...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
C 
& 
I 
I 
Farmer Jaffe WeissinE Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
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 Work 
product; 
attorney/client 
privilege; 
Epstein 
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 
Work 
product; 
attorney /client 
privilege; 
for their fees and accompanying 
irrelevant and not reasonably calculated to lead 
documents 
to the discovery of the admissible evidence; 
protected by privacy rights 
01042 
07/22/2009 
Marc Nurik 
Bradley Edwards 
New Info that our investigators Work 
product; 
attorney/client 
privilege; 
obtained from current FBI agents 
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...

NOT A CERTIFIED COPY
______ ,_·.-··.· .. :.:. ____ _ 
Privilege Log- Dated 2-23-2011 
t 
E 
I 
' 
Farmer Jaffe Weissing Edwards Fistos & Lehrman 
QATES 
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 
CW Personal information 
Work 
product; 
attorney/ die nt 
privilege; 
Asst. 
to 
Jay 
irrelevant and not reasonably calculated to lead 
Howell, 
Co-
to the discovery of the admissible evidence; 
Counsel} 
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 Work 
product; 
attorney/client 
privilege; 
potential 
witnesses 
and 
the irrelevant and not reasonably calculated to lead 
issuance of subpoena's for them. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18344-18347 
08/24/2009 
Bradley Edwards 
Mike Fisten 
Investigative 
information 
and 
Work 
product; 
attorney /client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
156 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer. Jaffe. Weissin2. Edwards. Fistos & Lehrman 
BATES 
.QAll 
TO 
fBQM 
DESCRIPTION 
OBJECTION 
18339-18340 
08/24/2009 
KenJenne 
Bradley Edwards 
Investigative 
information 
and 
Work 
product; 
att~rney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18341-18343 
08/24/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
information 
and 
Work 
product; 
attorney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18853-18854 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
Concerning 
the 
names 
of Work 
product; 
attorney/client 
privilege; 
potential 
witnesses 
and 
the Irrelevant and not reasonably calculated to lead 
issuance of subpoena's for them. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18337-18338 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Investigative 
information 
and 
Work 
product; 
attorney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
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 
Work 
product; 
attorney/client 
privilege; 
case and names of potential 
irrelevant and not reasonably calculated to lead 
witnesses. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18307 
10/17/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein Assets. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
157 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer. Jaffe. Weissimr. Edwards. Fistos & Lehrman 
[!ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
18308-18309 
10/18/2006 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein Assets. 
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: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein witnesses and 
irrelevant and not reasonably calculated to lead 
names of potential witnesses. 
to the discovery of the admissible evidence; 
protected by privacy-rights 
18184-18185 
08/26/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/ client 
privilege; 
finding of Epstein witnesses and 
irrelevant and not reasonably calculated to lead 
names of potential witnesses. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18186-18187 
08/31/2009 
Bradley Edwards 
Jacquie Johnson 
Discussion of potential witnesses Work 
product; 
attorney/ client 
privilege; 
and the process of subpoena for irrelevant and not reasonably calculated to lead 
depo's. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18180-18183 
08/24/2009 
Bradley Edwards 
Mike Fisten 
Investigative 
Discussion 
re: Work 
product; 
atto roey /client 
privilege; 
finding of Epstein witnesses and 
irrelevant and not reasonably calculated to lead 
names of potential witnesses. 
to the discovery of the admissible evidence; 
protected by privacy rights 
05256-05257 
07/21/2009 
Bradley Edwards 
Wayne Black 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/ die nt 
privilege; 
strategy of case. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
158 

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Privilege Log - Dated 2·23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05253 
08/24/2009 
Bradley Edwards 
Wayne Black 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
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: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
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: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
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: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
159 

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EXHIBIT 10 

NOT A CERTIFIED COPY
) 
Conrad & Scherer 
Attorneys at Law 
Ft. Lauderdale, Florida • WasWngton, DC • Quito, Ecuador 
VIA E-Mall:/sx(j&earcevlaw.com 
Jack Scarola 
Searcy Denney Barnhart & Shipley 
2139 Palm Beach Lakes Blvd. 
West Palm Beach, FL 33409 
Re: 
Epstein/Rothstein/Edlvards 
Dear Jack: 
April 8, 2011 
James D, Silver 
954,847.3324 Direct Line 
Js!lver@conradschcrer.com 
You sent me a proposal by letter dated April 7, 2011 regarding production to me and my 
firm of all of the documents that had been turned over to the Special Master. Judge Camey (the 
"Special Master"), in the special master process that has been on~going before Judge Ray in the 
RRA bankruptcy case. We spoke by telephone at length late today and reached agreement to 
your proposal, subject to the modified language that wo discussed. I have taken the language 
from your letter and revised it below based on what we had discussed, Of course, I also had to 
change the language to reflect that the letter is now being written by me, 
Accordingly, this letter is inten:ded to confinn the tenns and conditions of the production 
by your client, Bradley Edwards, to us of all documents, without redaction, and notwithstanding 
any claim of privilege made or that could be made, that the Bankruptcy Trustee Herbert Stettin 
caused to be turned over or delivered to 1he Special Master pursuant to the special master process 
described above and any further documents that Bradley Edwards has in Ws possession, custody 
or control responsive to our subpoena (collectively~ the "Epstein Related Documents.,), The 
terms and conditions of o~ agreement are as follows: 
1. 
We will stipulate to stay enforcement of our current subpoena solely as it relates 
to the Epstein Related Documents subject to the terms and conditions of this agreement; 
2. 
You will produce to us all of the Epstein Related Documents for an "attorneys 
eyes only" review with the express agreement that the production is pursuant to the common 
...

NOT A CERTIFIED COPY
Jack Scarola 
April 8, 2011 
Page2 
3, 
We will preserve the strict confidentiality of all materials produced to us pursuant 
to this agreement unless: 
a. 
the same infol'll1ation is or was obtained from an independent sourcej 
b. 
you agree to release or modify the restriction on our use of particular 
materials or; 
c-
we obtain a court order authorizing our use of the materials or detennining 
that the materials in question are not privileged. 
d. 
we are compelled to produce or disclose the materials or information 
derived from them. 
4. 
We agree· that neither the documents themselves nor any information obtained 
from the documents produced to us pursuant to this agreement, subject to paragraph 3 above1 
will be shared with our clients unless they expressly agree to be bound by the tenns and 
conditions of this agreement. 
5. 
No copies will be made of the documents unless one or more of the conditions of 
paragraph 3 above have been satisfied, or to the extent we provide copies to a client or clients 
pursuant to paragraph 4 above; 
\ 
6. 
Nothing in this agreement will restrict our disclosing any document(s) for in 
camera review in, yOllllectioh witb.:any privilege·objection you seek to maintain, or in connection 
with any request we:1mtke to use t\le documents without restriction and/or to determine that such 
documents are not-prote.cted.from disclosure by nny privilege or otherwise; 
7. 
Stay of the enforcement of our subpoena may be lifted at any time to seek 
additional documents that may come into your possession or control or to satisfy the conditions 
of Paragraph 3c; 
8. 
The tenns of this agreement may be disclosed as we may deem appropriate, and 
we intend to disclose the terms to Judge Ray at Monday's hearing in connection with announcing 
our resolution of the issues that were to be considered at that hearing; 
9, 
In the event that any third-party seeks to compel production of materials disclosed 
to us pursuant to this ...

NOT A CERTIFIED COPY
) 
JackScorola 
April 8, 2011 
Page3 
11, 
Since this agreement relates to documents requested in a bankruptcy subpoena 
issued by us m the RRA bankruptcy case, it is agreed and understood that all disputes relating to 
this agreement as well as its enforcement will be detennined exclusively by Judge Ray in 1he 
RRA bankruptcy case. Without limiting the foregoing, to the extent we seek to use or disclose 
any of the Epstein Related Documents (and you do not consent) and/or to obtain a determination 
of any issues relating to any claimed privilege regarding those documents, such determinations 
shall be made exclusively by Judge Ray in the RR.A bankruptcy case. 
If you agree with the terms and conditions set forth above, please sign this letter below 
and indicate that it is "Agreed" or send me an e-mail indicating your agreement, 
JDS/ra 
Conrad & Scherer 
l,t!Olt1l)'HILlW 

NOT A CERTIFIED COPY
) 
James D. Silver 
From: 
Sent: 
To: 
Cc: 
Subjed: 
Jack, 
James D. Silver 
Sunday, April 10, 201112:45 PM 
'Jack Scarola' 
brad@pathtojustlce.com 
RE: Agreement regarding Epstein Related Documents 
Confirming our phone conversation of yesterday we now have an agreement and will appear at the hearing tomorrow 
morning where I will announce our agreement to Judge Ray. As for the issue regarding how the documents are to be 
provided, you will provide the electronic documents on disc and we can copy for ourselves from that disk as we deem 
appropriate. As for additional responsive documents that are not on disk, you agree that they can be copied by a copy 
service of my choosing, at my side's expense·. 
I am glad that we were able to amicably resolve our issues regarding the documents set forth in our letter 
agreement. Have a nice rest of your weekend and I will see you at bankruptcy court tomorrow morning. 
Jim Silver 
From: Jack Scarola [mallto:JSX@SearcyLaw.comJ 
Sent: Saturday, April 09, 201112:41 PM 
To: James D. Silver 
Cc: brad@pathtojustice.com 
Subject: Re: Agreement regarding Epstein Related Documents 
The letter agreement as redrafted by you is acceptable with one clarification regarding paragraph 10. Electronic documents will be 
provided on a disc. Hard copy documents will be made available for your inspection and copying at your expense- rather than we 
. being. required to "deliver" the documents to you. 
----~ Original Message-·---
From: Jnmes D. Silver <JSilver@conradschercr.com> 
To: Jack Scarola 
Sent: Fri Apr 08 20: l l :36 20 J I 
Subject: Agreement regarding Epstein Related Documents 
Jack, 
See attached letter and let me know if it accurately sets forth the terms of our agreement. As we were finalizing the document we had 
a computer issue and the Word version was lost. Due to the lateness of the hour we did not want to retype the entire letter. As a 
result, [ was unable to correct the mistake in your e-mail address listed...

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EXHIBIT 11 

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'' Case 9:08-cv-80893-KAM Document 214-3 
Entered on FLSD Docket 09/02/2010 Page 1 of 
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2 
3 
4-
j 
6 lnlte: 
IJm'l1m STATBS DhNKIWl'TCY COURT 
SOITTllBRN DlSTIUCTOP f,I.Oll.JDA 
CJ\SaNo.: 0M479MlKC-RDR 
7 ROlil'STlltNROSllNl'flLl>T Al)LBJ\, P.A., 
s 
Del>tot. 
' 
10 
II 
I 
Pago! 
I 
2 
3 
4 
5 
6 
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8 
9 
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11 
Pogcl ( 
THB COURT: Rothstoln Rosenfeldt& Adler, 
All right. May I have appearnnces, please? 
M'.R, LICHTMAN: Oood momlng1 Judge. 
Cbuok Lichtman, Berger Slngennan, for the trustee. 
MR. NBlWlR.THI Ooodmommg. your Honor. 
Ronald Nelwlrlli, Fowler Whlto Bumett, oh behalf of 
the rnovant, Epstein. and witl1 mB today are two of my 
pal'tncl'8, Chris Knight and Lilly Ann Sanchei-
MS. SANCHEZ: Oood morning, your Honor. 
MR, KNIGHT: Good moming, four Honor, 
MR, NEI\Vl.R.TH: - both of whom are more 
I 
,. 
I 
MOTION TO COMPl!L l'R.ODlJCtlON OF DoCUMBNTS PROM mosrm 12 
12 PURSUANTTO'DOCUMllNf PRODUCflONPR~<)COI,ll$TAl3LISHJ;I) l3 
BYDil#572 (B07);AMl?NDl!O MOTION l'OltfROTBCTtVBORi>Ell. 
J4 
familiar with th<i State Court 11ngle on this than I 
am, so they oame along to bo able to elueldflte that 
end ofit, 
13 
(319) 
15 
1,! 
1.:. 
MR. PARMB~~ Good rooming, you~ Honor, 
081)' Farmer on behalfofLM, l3rad F..dwards, and 
the F!lllller Juff1,1 Weissing Jaw fiim, We.o.re tm 
intero5ted Parlt and l1ave filed a motion for 
proteotlve order as 10 the subpoeno that ls at 
, 
Au~i4,2010 
.,, 
16 
17 
17 
The obovc-c1>1Wod CllllQ (;Allie on for 
18 
18 h™lng bofo111 dio HONOMBX.~ IV.YMONDB, nAY, 
JS) 
Ill onoof1h~ Ju4suoflhc UNlTBP Sl'ATBSBANKRUl'TOY 
20 
20 COURT, hinnd fartllo SOIJTHl3RNDISTRICTOl'PL0llfOA, 
21 is:me hero today, 
21 
JI 299 Hall Broww! lllvd .• l'oi1 L~udtrdnlo, BTO\Vll/0 
22 
2
2! Ci>unty, Florida, on Tu«day, AuiUJI 4, 2010, 
2~ 
1:HB COURT: All right, Xmofur as lhe 
TD Bank motkm, Docket Entry 780, that ha.9 been tho 
1 
subject matter ofan 11greed ordor that was submitted 
tome, 
, en1nmenofn11n1or a~ou19:loa.m.,1111d llr~l...

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Case 9:os~cv-80B93-KAM Doc.urnent 214-3 
Entered on FLSD Docl<et 09/02/2010 Pages of 
10 
. 
. 
l'age!7 
input, plcaso, 
MR, LICHTMAN: rm going to let Mr. Scherer 
go first. 
I 
• MR. SCHERER: I think he wants mo to go 
i first 
i 
THE COURT: All right. 
f 
MR, SCHBRBR~ Your Honor, in November\ 
J 'we flied a lawsuit in State Court and we nllcged : 
) ~' that as a part of Mr, Rothstein nnd the finn, and . 
0 _tho finn's employees, and maybci some of the 
, i 
1 firm's attorneys, conspired to uso the Bpstein/LM 
2 litigation In order to lure $13.S million worth j 
.3 ,ofmy victims, my clients, into making , · 
14 investments in these pl1ono;y settlements'. 
IS 
• 
And l\S we alleged in that Stato Court 
16 proce~lng, andwc'vo shtu"pened the allegl\tlons 
17 
!IS we'vtJ IUllendcd a few times, we allege that· 
18 sometlmo In latu October, tl111t my cllenls were 
19 invited Into the Rothstein firm wlU1 
20 ·Mr, Rotlisteln1 and he elCplalned that he had a 
21 litigation golrig In Stntc Court wlU1 Mr. Edwards 
22 representing LM, a victim of Mr, Epstein, and 
23 these arc kind of sensational allegations and 
24 it's been printed widely, 
2S 
And niy clients, a nwnber of them 111\d 
Pngo 18 
l their lawYer, went into the Rothstein conference 
2 room wid _Mr, Rothstein bro\lght down- summoned 
3 the investigators, two of them, two odluee of 
4 them, to bring down tho Bpsteln file, And tho 
5 lawyer that m)' clients brought from n. national 
6 finn, wetlt through' tho LM boxes, ten cfthem thnt 
7 the investigators bl'ouglit dQwn, and concluded 
8 that the Epstein case was I\ real case, 
9 
And WhlxtMi'. RoU1stoin did with Uiat 
10 real case, of' course1 ls he told everybody that 
11 riot only did ho have the LM client of 
12 Mr, Edwards, that there were o number of other 
13 young ladle$, that vi~ widely published In the 
l'8&C l9 
I • allegations in th~ LM case tl1nt they know were l 
2 , not true, In order to entice my olionts into 
', 
3 ,_believing t...

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l 
·case 9:08-cV~80893-KAM Document 214-3 
Entered on FLSD Docket 09/02/2010 Page ·e-of 
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2S 
their duo diligence, short due diligence to 
settle these cnsos with 'IJ1ose young ladles -
thuse putattve young ladies who had to set the 
money nnd .leave town beoause of whatever the 
stories wore, tllat there were other members of 
tho finn that told my clients that they, Indeed, 
had oven ideiltified more of those victims that 
Mr. Rothstein 'didn't even know about nt that 
time, So wo know it Wllllll'tjust Mr. Rothstein 
:iplnning tho tnle, thore wcro 11 lot of people In 
theflnn . 
. We've alleged almost all of this In our 
Stnto Court 11Ctlon that wo filed in November, up 
to whore we aie right now, but, your Honor, I 
think your Honor is going to h_avo to deal with 
thes5 lssucs In tl1ls co_urt ai1d I would urge you 
to have tho trustee ·got Involved and let tho 
truslco do ltsjob with respect to wfielhertlu:rc 
are prtyllegcs that need to bo protected, work-
produo\or nttomey/olient privileges, given 
whal's going on, and I believe the tnlstco wlll 
\le h1vestlgntlng Whether the trUstee wants to 
bring any claims. on behalf of tho ll$tate by • 
vlrtuti ofwhat I'vejustlald out for you. 
Thonkyou; 
P~go21 
l'oge22 
. t 
THE COURT; So your lawsuit in State Court 
2 munos these people as defendants? 
, 
3 
MR. SCHERER; It: names Rothstein. It I 
4 does not name Mr. Edwards. It just names 
5 Rothstein, not the finn, and lays outthe facts 
6 • and snys other people in the finn', Wo did not 
7 name tllom because we want to seo the documents . 
8 \ • nnd sec whether they had lnvolvcmont. : 
9 -
But the fucts thnt I have alleged for 
lo you, your l-ro11.or; l11 pretty much What I've alleged 
11 filmy fuat through third nfuended cioinplaint in 
12 State Court, 
13 
. • THR COUR,T1 So, in essence, your posftlon 
14 In this matter would ho to support the motion to· ...

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EXHIBIT 12 

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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, FLORIDA 
Case No. 502009CA040800XXXXMB 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually; 
BRADLEY EDWARDS, individually, 
Defendants/Counter-Plaintiffs. 
I 
------------------
VOLUME I 
VIDEOTAPED DEPOSITION 
OF 
BRADLEY EDWARDS 
Taken on Behalf of Plaintiff 
Friday, November 10th, 2017 
10:02 a.m. -
6:16 p.m. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Examination of the witness taken before 
Sonja D. Hall 
Palm Beach Reporting Service, Inc. 
1665 Palm Beach Lakes Boulevard, Suite 1001 
West Palm Beach, FL 33401 
(561) 471-2995 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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A 
No. 
MR. SCAROLA: 
Excuse me. 
Has there 
been a notice of withdrawal? 
Because I 
haven't seen it either. 
MR. LINK: 
I think we represented it to 
Judge Hafele on Wednesday with the 8:45 when 
Kara was in front of them. 
MR. SCAROLA: 
I have seen no notice of 
withdrawal. 
So as we sit here today, there 
are a total of, I think, six law firms that 
are representing Mr. Epstein. 
BY MR. LINK: 
Q 
And one really good one. 
The one you saw 
the card on this week, right? 
Okay. 
So I want to focus on this anxiety. 
We all have anxiety in life, right? 
I wake up every 
morning with anxiety about something. 
How my kid's 
doing in college. 
Did he get home last night. 
Is 
my son going to get a hit today on the baseball 
team. 
I want to talk about a different kind of 
anxiety. 
The anxiety that you feel in November 2017 
that relates back to the lawsuit that was filed in 
December 2009. 
Can you separate that anxiety that I 
am talking about? 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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A 
Just an anxious feeling to get this over 
with. 
Q 
And you had that anxious feeling every 
single day from December 2009 through today 
November 10th, 2017? 
A 
The more reminders that I have of the case, 
and the fact that there still looms this false 
allegation over my head, that is clearly a trigger. 
Q 
You said it looms this false allegation. 
What is the false allegation looming over your head? 
A 
That I was a participant in a Ponzi scheme 
with one of the individuals that might be the most 
hated person in South Florida, especially amongst our 
profession. 
Q 
Mr. Rothstein? 
A 
Right. 
Q 
But why is there an allegation hanging over 
your head? 
The case against you was dismissed in 
2012, correct? 
MR. SCAROLA: 
Excuse me. 
Which case? 
BY MR. LINK: 
Q 
The case against you by Mr. Epstein was 
dismissed in 2012, was it not? 
A 
Right. 
The case was dismissed. 
Q 
Five years ago the case was dismissed, 
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Q 
A 
Q 
2017? 
Correct. 
So I want to get back to anxiety. 
And you 
understand what I've meant that I have anxiety every 
day. 
Everybody in life has levels of anxiety. 
You 
agree with that? 
A 
I suppose. 
Q 
I had a lot of anxiety when I took the bar 
exam. 
You may not have. 
A 
In some different form -- I think that's a 
word that's used that describes a bunch of different 
feelings. 
Q 
Absolutely. 
I agree. 
What I'm really trying to understand 
is -- I want to compartmentalize this. 
I'm focused 
now on 2012, once Mr. Epstein dismissed his claims 
against you in court. 
So from that date through 
today, that cloud is no longer hanging over your 
head. 
I would like to understand what your anxiety 
is that relates to the lawsuit filed in 2009. 
How 
it's impacting you on a day-to-day basis. 
A 
It's hard for me to answer your question, 
while along the way I'm disagreeing with the various 
statements that you're making. 
Q 
Tell me what you disagree with, sir. 
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You're making a statement the cloud is no 
longer over my head. 
That's the basis -- that's the 
predicate for your ultimate question. 
That's just not 
true. 
Q 
So as you sit here today, there's a cloud 
over your head as a result of the 2009 lawsuit that 
was filed that was dismissed in 2012? 
A 
For sure. 
Q 
And how does it impact you? 
What I am 
trying to understand is, you are going to ask the 
jury to award money to you based on your level of 
anxiety, right? 
That's one of the things you want the jury 
to do, is to say, I have anxiety and I want to be 
compensated. 
A 
As lawyers, what we have is our reputation. 
That's what was destroyed. 
Q 
A 
We are going to get to reputation. 
That's 
MR. SCAROLA: 
Excuse me. 
Please --
MR. LINK: 
I'm sorry. 
I apologize. 
I'm just trying to streamline this. 
We will 
get to reputation. 
MR. SCAROLA: 
Well, what will 
streamline it is if you ask a question and 
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allow Mr. Edwards to complete his answer 
before you interrupt him. 
MR. LINK: 
I got it. 
Thank you. 
BY MR. LINK: 
Q 
So I want to make sure that I understand --
I want you to tell us -- you are asking the jury to 
award you an amount of money based on your having 
suffered every day anxiety as a result of the lawsuit 
that was filed in December 2009. 
Do I have that 
right? 
A 
related 
Do you have that right? 
The anxiety is 
directly related to the harm done to my 
reputation as a consequence of the filing of this false 
lawsuit making up that I am a criminal associated with 
who is known to be a terrible and horrible person. 
mean, that is the -- the anxiety is related to that. 
I 
Q 
I understand that generally. 
But I need to 
know specifically. 
Let me start by this. 
How much are you asking the jury to award 
you for your day-in-and-day-out anxiety from 
December 2009 through today? 
A 
An amount of money that fairly and fully 
would measure the magnitude of the harm done to my 
reputation, and any consequential feelings that have 
resulted or continue to exist because of the damage 
Palm Beach Reporting Service, Inc. 
561-471-2995 
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EXHIBIT 13 

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Case: 15-90031 
Date Filed: 03/23/2018 
Page: 1 of 28 
[PUBLISH] 
IN THE UNITED STATES COURT OF APPEALS 
FOR THE ELEVENTH CIRCUIT 
Nos. 16-11090, 15-90031 
D.C. Docket No. 2:11-cv-03695-RDP-TMP 
DRUMMOND COMPANY, INC., 
Plaintiff - Appellee, 
versus 
CONRAD & SCHERER, LLP, 
Defendant - Appellant. 
Appeal from the United States District Court 
for the Northern District of Alabama 
(March 23, 2018) 
Before WILSON, JILL PRYOR and BARTLE,* Circuit Judges. 
JILL PRYOR, Circuit Judge: 
* Honorable Harvey Bartle III, United States District Judge for the Eastern District of 
Pennsylvania, sitting by designation. 

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Drummond, Inc., sued Conrad & Scherer, LLP ("C&S"), a law firm, and its 
partner, Terrence Collingsworth, for defamation. In this appeal, C&S seeks 
interlocutory review of the district court's order concluding that the crime-fraud 
exception could defeat the firm's and Collingsworth's assertions in discovery of 
attorney-client privilege and attorney work product protection. The district court 
made a preliminary determination that the crime-fraud exception may apply to 
overcome their assertions of privilege and attorney work product protection and 
ordered a special master to perform an in camera review to determine whether the 
crime-fraud exception does apply. Although non-final orders generally are not 
immediately appealable, the district court certified its order for immediate appeal, 
and a motions panel of this Court granted C&S permission to bring an 
interlocutory appeal under 28 U.S.C. § 1292(b ). 
After full briefing by the parties and with the benefit of oral argument, we 
conclude that interlocutory review is appropriate to address only one aspect of the 
district court's order. We vacate as improvidently granted the motion panel's order 
in part and elect not to exercise our discretion to review the question posed in that 
part: whether the district court erred in applying agency principles to conclude that 
C&S intended to commit a crime or fraud and created attorney work product or 
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made communications in furtherance of the crime or fraud. 1 We decline to review 
this issue because it does not present a pure question of law suitable for review on 
an interlocutory basis under§ 1292(b ). Accordingly, we vacate the motion panel's 
earlier order in part and deny C&S's petition in part. 
We do address the other issue on which interlocutory review was granted, 
whether the crime-fraud exception may be applied to overcome C&S's assertion, 
as a defendant in this case, that its materials related to other lawsuits where it 
served as counsel are protected as attorney work product when the firm's clients in 
those lawsuits were innocent of any wrongdoing. 2 This question presents the pure 
legal issue of whether work product protection may be invoked when a lawyer and 
law firm are found to have engaged in a crime or fraud but there is no such finding 
as to the client or clients they represented. Following our precedent and persuasive 
decisions from other circuits, we conclude that the crime-fraud exception may 
defeat work product protection in this circumstance. We thus affirm the part of the 
district court's order determining that the crime-fraud exception could be applied 
1 As the merits panel, we have the authority to vacate as improvidently granted the 
motions panel's decision to permit the interlocutory appeal. See McFarlin v. Conseco Servs., 
LLC, 381 F.3d 1251, 1253 ("Like all motions initially ruled upon by a motions panel, [an order 
by a motions panel granting permission for an interlocutory appeal under§ 1292(b)] is subject to 
being vacated as improvidently granted by the merits panel to which the case is assigned for 
decision."); see also 11th Cir. R. 27-l(g) ("A ruling on a motion or other interlocutory matter 
... is not binding upon the panel to which the appeal is assigned on the merits, and the merits 
panel may alter, amend, or vacate it."). 
2 We note...

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to overcome C&S' s claim of work product protection for materials related to 
lawsuits where C&S served as counsel despite the fact that its clients were 
innocent of wrongdoing. 
I. 
FACTUAL AND PROCEDURAL BACKGROUND 
This appeal arises out of a complex dispute that began when Collingsworth, 
a C&S partner, represented Colombian citizens who sued Drummond, an Alabama 
company, in federal court in Alabama, alleging that Drummond had supported 
paramilitary groups in Colombia that murdered private citizens. To provide the 
necessary context for our discussion, we recount the relevant history of the 
Colombian citizens' lawsuits against Drummond and Drummond's later lawsuit 
against Collingsworth and C&S. 
A. 
Collingsworth and C&S's Representation of Colombians Suing 
Drummond 
In his law practice, Collingsworth primarily represents victims of human 
rights abuses. He joined C&S as a partner to litigate such cases. Although the 
firm is based in Florida, he worked out of and managed its Washington D.C. 
office. 
While a partner at C&S, Collingsworth filed on behalf of Colombian citizens 
several lawsuits (the "alien tort cases") against Drummond, which operates coal 
mines around the world, including in Colombia. The plaintiffs sued Drummond 
under the Alien Tort Statute, 28 U.S.C. § 1350, and the Torture Victim Protection 
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Act of 1991, Pub. L. No. 102-256, 106 Stat. 73 (1992) (codified at 28 U.S.C. 
§ 1350 note), alleging that Drummond hired members of the paramilitary to 
provide security services around its mines in Colombia and that these individuals, 
acting as the agents of Drummond, killed civilians in violation of the laws of 
nations. See generally Doe v. Drummond Co., 782 F.3d 576, 579-81 (11th Cir. 
2015). 
Collingsworth acted as the lead C&S attorney in these cases. William 
Scherer, the firm's managing partner, and other C&S attorneys entered 
appearances in the cases. As managing partner, Scherer delegated to 
Collingsworth the authority to litigate the cases. 
To support the claims against Drummond, Collingsworth developed 
evidence connecting Drummond to the paramilitary's violent actions. He secured 
testimony from several former members of the paramilitary, including Jairo de 
Jesus Charris, Libardo Duarte, Jose Gelvez Albarracin, Alcides Manuel Mattos 
Tabaraes ("Samaria"), and Jhon Jairo Esquivel Cuadrado ("El Tigre"). These 
witnesses offered testimony that implicated Drummond. Additionally, 
Collingsworth relied on testimony from Jamie Blanco, who worked as a contractor 
for Drummond in Colombia. Blanco testified that Drummond sent him money that 
he was directed to use to pay the paramilitary for security services. 
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In the alien tort cases, Drummond sought discovery about whether the 
plaintiffs or their attorneys had paid or given anything of value to these witnesses 
in exchange for their testimony. In response, the plaintiffs identified three 
witnesses who had been paid-Charris, Duarte, and Gelvez. 3 The plaintiffs 
claimed these payments were made to provide security to the family members of 
the witnesses who were in danger as a result of the witnesses' testimony. The 
plaintiffs in the alien tort cases did not identify any payments they made to 
Samaria, El Tigre, or Blanco. 
Ultimately, Drummond prevailed in each of the alien tort cases. 4 But the 
dispute between Drummond, on the one hand, and C&S and Collingsworth, on the 
other, was only beginning. 
3 The plaintiffs also identified a fourth potential witness who received money from C&S, 
but C&S stopped paying this potential witness when it determined that he was not credible and 
would not be used as a witness. 
4 Balcero Giraldo v. Drummond Co., No. 2:09-CV-1041, 2013 WL 3873960 (N.D. Ala. 
July 25, 2013) (granting summary judgment in favor of Drummond), aff'd sub nom. Doe v. 
Drummond Co., 782 F.3d 576 (11th Cir. 2015); Baloco v. Drummond Co., No. 7:09-CV-00557, 
2012 WL 4009432 (N.D. Ala. Sept. 12, 2012) (dismissing case in part and granting summary 
judgment in favor of Drummond), aff'd 767 F.3d 1229 (11th Cir. 2014); Order, Melo Penaloza v. 
Drummond Co., No. 2:13-cv-393 (N.D. Ala. Jan. 26, 2016), ECF No. 59 (dismissing case with 
prejudice), aff'd in part, rev'd in part, vacated in part, and remanded with instructions 662 F. 
App'x 673 (11th Cir. 2016). 
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B. 
Drummond's Defamation Action Against Collingsworth and C&S 
1. 
Drummond Files a Defamation Action and Seeks Discovery About 
Witness Payments. 
While the alien tort cases were pending, Collingsworth wrote letters on C&S 
stationary to the Dutch government and a Japanese company accusing Drummond 
of supporting paramilitary groups that murdered hundreds of Colombian citizens. 
After Collingsworth sent these letters, Drummond sued Collingsworth and C&S 
for defamation in federal court in Alabama (the "defamation case"). 
At the beginning of the defamation case, Collingsworth and C&S were 
jointly represented by outside counsel. Because of Collingsworth's central role in 
the underlying litigation and in writing the allegedly defamatory letters, he was the 
C&S partner primarily responsible for working with outside counsel. In their joint 
answer, Collingsworth and C&S denied liability and raised several defenses, 
including that the statements in the letters were true and that they had not acted 
maliciously. 
Attempting to prove that Collingsworth had known the statements in his 
letters were false and that he had acted with malice, Drummond served discovery 
requests about the methods Collingsworth and his litigation team had used in the 
alien tort cases to secure testimony from the witnesses, including information 
about any payments made to the witnesses. Collingsworth and C&S responded 
that they had previously disclosed all payments made to witnesses, pointing to their 
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disclosures that payments had been made to Charris, Duarte, and Gelvez. In 
hearings and other filings with the district court, Collingsworth and C&S 's outside 
counsel repeated that only Charris, Duarte, and Gelvez had received payments. 
2. 
Through Discovery, Additional Witness Payments Are Uncovered. 
As it turns out, all of these statements made in discovery were false. 
Eventually, Collingsworth and C&S admitted that El Tigre, Samaria, and Blanco 
had also received payments. The payments were uncovered after Drummond 
subpoenaed a law firm that had served as C&S 's co-counsel in the alien tort cases. 
That law firm produced an email showing that Collingsworth had asked co-counsel 
and Scherer for permission to pay approximately $100,000 in attorney's fees on 
Blanco' s behalf in a pending criminal case in Colombia. The co-counsel, copying 
Scherer, directed Collingsworth not to pay the fees because they would have to 
disclose these payments in the alien tort cases, which would damage Blanco' s 
credibility and likely be seen as bribery. 
Drummond used this email, which Collingsworth and C&S had failed to 
produce in discovery, to argue that Collingsworth and C&S had been hiding 
information about witness payments. A few months later, Collingsworth and C&S 
admitted that El Tigre, Samaria, and Blanco had received payments. 
At Collingsworth's direction, C&S had sent and continued to send Samaria 
and El Tigre $1,000 each per month. C&S wired the money from its operating 
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account to an intermediary in Colombia, who delivered the money to Samario and 
El Tigre. C&S began making these payments during the alien tort cases and 
continued to make them while the defamation case was ongoing. 
Multiple partners and employees at C&S were aware of these payments. 
Shortly after the monthly payments began, Collingsworth sent an email to his co-
counsel in the alien tort cases, copying Scherer, informing them that El Tigre and 
Samario would receive money each month until they were deposed. This email 
was forwarded to Scherer' s son, another C&S partner, who then apparently had an 
associate research the propriety of witness payments. C&S employees who were 
responsible for sending the monthly wires also were aware that C&S was sending 
money to the intermediary to pay El Tigre and Samario. 
Blanco received no money directly from C&S or Collingsworth; instead, he 
received money from Albert van Bilderbeek, another Colombian client of 
Collingsworth's. After being told by co-counsel not to pay Blanco's attorney's 
fees, Collingsworth introduced Blanco to van Bilderbeek. Van Bilderbeek 
subsequently paid $150,000 ofBlanco's legal fees. While these payments were 
being made, Collingsworth served as intermediary between Blanco and van 
Bilderbeek. At one point, Blanco-waiting for money from van Bilderbeek-told 
Collingsworth that he would not finalize his declaration until van Bilderbeek paid 
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him. After van Bilderbeek paid, Blanco signed a declaration that Collingsworth 
used in the alien tort cases. 
3. 
Drummond Seeks Sanctions and Raises the Crime-Fraud Exception. 
After C&S and Collingsworth disclosed these additional witness payments, 
Drummond moved for sanctions, asserting that Collingsworth and C&S had made 
false statements to the court by failing to disclose these payments. 5 The court 
allowed Drummond to depose Collingsworth and Scherer about the witness 
payments and related issues. 
At his deposition, Collingsworth admitted that there had been payments 
made to witnesses that he and C&S had failed to disclose. With regard to the 
payments to El Tigre and Samaria, Collingsworth testified that he had forgotten 
about the payments to the witnesses because they were made through an 
intermediary. With regard to van Bilderbeek's payments to Blanco for legal fees, 
Collingsworth claimed that he failed to disclose the payments because he thought 
that he had only been asked to identify payments that he made directly to 
witnesses, rather than payments made by third parties like van Bilderbeek. 
Scherer, who was deposed as the representative of C&S, explained that he had not 
5 As sanctions, Drummond asked the court to enter a default judgment against 
Collingsworth and C&S, hold Collingsworth in contempt of court, and award Drummond its 
reasonable attorney's fees. 
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known about the witness payments and that once he learned of the payments, he 
made sure that C&S promptly disclosed them to the court. 
Although Collingsworth and Scherer provided this general information, they 
refused to answer many categories of questions posed in discovery, claiming that 
the information Drummond sought was protected by the attorney-client privilege 
or the attorney work product doctrine. For example, Collingsworth refused to 
answer questions regarding communications about the witness payments that he 
had had with Ivan Otero, a Colombian attorney who served as a conduit for 
payments from C&S to El Tigre and Samario, or to identify who was involved in 
drafting the filings in the defamation action that contained misrepresentations 
about the witness payments. And Collingsworth and Scherer refused to answer 
questions about what caused them to realize that they had made inaccurate 
statements about the witness payments or the process that led them to correct their 
misstatements, claiming the information sought was privileged or protected from 
discovery. Drummond asked the court to hold that the crime-fraud exception 
vitiated Collingsworth and C&S' s claims of attorney-client privilege and work 
product protection. 
4. 
The District Court Applies the Crime-Fraud Exception. 
After a hearing, the district court issued an order applying the crime-fraud 
exception to both Collingsworth and C&S. In reaching this conclusion, the district 
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court followed our circuit's two-part test for applying the crime-fraud exception 
and determined that Drummond had ( 1) made a prima facie showing that 
Collingsworth and C&S had engaged in criminal or fraudulent conduct when 
seeking the advice of counsel and creating attorney work product in the alien tort 
and defamation cases and (2) identified categories of communications and attorney 
work product that may not be protected from discovery because they were used to 
further a crime or fraud. 
First, the district court pointed to evidence that both Collingsworth and C&S 
had engaged in criminal or fraudulent conduct when they sought the advice of 
outside counsel in the defamation case and created attorney work product in both 
the alien tort and defamation cases. The district court determined that the crime-
fraud exception's first prong was satisfied as to three crimes: fraud on the court, 
witness bribery, and suborning perjury. The court emphasized that it was not 
holding that a crime or fraud actually had been committed, but only that a prima 
facie case had been established. 
In determining that there was a prima facie case of fraud on the court, the 
district court identified numerous false statements Collingsworth and C&S had 
made to the court. The court identified misstatements regarding witness payments 
that Collingsworth had made to the court in the alien tort cases when he was acting 
as a C&S partner, as well as misstatements that Collingsworth and outside counsel 
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had made in the defamation action. The court found that both Collingsworth and 
C&S had made these false statements knowingly. 
In a lengthy footnote, the district court explained that there was sufficient 
evidence to find that C&S had knowingly made misstatements. First, the court 
explained that because Collingsworth was a partner in C&S and was acting for the 
firm's benefit, his actions and knowledge were attributable to the firm under 
agency principles. Second, the court cited evidence showing that other firm 
partners and employees, including Scherer, had been aware of the monthly 
payments being made to the witnesses and explained that it was unbelievable that 
no one at the firm other than Collingsworth had known of the payments. 
As for the witness bribery and suborning perjury crimes, the district court 
determined that Drummond had established a prima facie case with evidence 
showing that the witnesses had received payments from the litigation team under 
suspicious circumstances. The court once again relied on agency principles to 
establish the prima facie showing that C&S had bribed witnesses and suborned 
perjury, explaining that every action taken by Collingsworth in the case had been 
in his capacity as a partner and agent of C&S. 
The district court then turned to the second prong of the test, which required 
a showing that the communication was made or attorney work product was created 
in furtherance of the criminal or fraudulent activity. Because the court did not 
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have before it the specific materials that Collingsworth and C&S claimed were 
privileged or protected from discovery, in lieu of a document-by-document 
analysis the court considered whether the categories of discovery Drummond 
sought were sufficiently related to the allegations of fraud, witness bribery, and 
suborning perjury. The court found that each category of discovery Drummond 
identified was sufficiently related to the allegations of fraud on the court, witness 
bribery, and suborning perjury. These categories of information included: 
• Collingsworth's communications with Ivan Otero, the Colombian 
attorney who served as the intermediary for payments from C&S to El 
Tigre and Samario and from van Bilderbeek to Blanco; 
• Collingsworth and C&S' s withholding and redaction of documents 
produced to Drummond in the defamation case showing payments to 
El Tigre and Samario; 
• Collingsworth and C&S 's drafting of pleadings and papers in the alien 
tort and defamation cases that included misrepresentations regarding 
the scope, nature, and extent of witness payments; 
• Collingsworth's email informing Scherer and his co-counsel that 
Samario and El Tigre would receive ongoing monthly payments and 
what was done with the email after it sent; 
• Collingsworth's communications with attorney Paul Wolf about 
witness payments; 
• Collingsworth's disclosure of payments to El Tigre, Samario, and 
Blanco to outside counsel in the defamation case; 
• Collingsworth's payment of $100,000 to a consulting attorney in 
Colombia who assisted in obtaining access to prisoners in Colombia 
in order to interview and depose them in the alien tort cases; 
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• Collingsworth's communications with van Bilderbeek regarding 
payments to Blanco; and 
• Collingsworth and C&S 's search for documents in the defamation 
case. 
After determining that the crime-fraud exception may apply, the district 
court ordered a special master to review in camera the documents that 
Collingsworth and C&S claimed were privileged or protected as attorney work 
product to determine whether each individual document was in furtherance of or 
closely related to a fraud on the court or crime and therefore should be produced to 
Drummond. The court also set forth a procedure for the special master to assess a 
witness's assertion of attorney-client privilege or attorney work production 
protection in a deposition. The court directed that when necessary a witness 
should give in camera testimony, potentially ex parte, so that the special master 
could appropriately assess any privilege issues while limiting disclosure only to 
information used or created in furtherance of the crime or fraud. 
After explaining why the crime-fraud exception applied, the district court 
certified that its order involved controlling questions of law as to which there may 
be a substantial ground for difference of opinion and that an immediate appeal may 
materially advance the litigation. In addressing certification, the district court did 
not identify the specific controlling questions of law that it believed warranted 
interlocutory review. 
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5. 
A Motions Panel of This Court Granted C&S Permission for an 
Interlocutory Appeal. 
Collingsworth and C&S filed separate petitions for review with our Court, 
seeking permission to file interlocutory appeals from the district court's order. A 
motions panel denied Collingsworth's petition. A separate motions panel granted 
C&S's petition as to the following two questions: 
1. 
Can agency principles be used to impute the application of the 
crime-fraud exception to an agent's principal where the 
principal has separately-held privileges as a co-defendant in the 
suit and there is no finding that the exception applies directly to 
the principal? 
2. 
Can agency principles be used to impute the application of the 
crime-fraud exception to an agent's principal where the agent is 
operating as an attorney and there is no finding that the client's 
behavior triggered the crime-fraud exception or that the 
exception applies directly to the principal? 
II. 
BACKGROUND ON THE ATTORNEY-CLIENT PRIVILEGE, 
ATTORNEY WORK PRODUCT DOCTRINE, AND CRIME-FRAUD 
EXCEPTION 
The issues in this appeal center on how the attorney-client privilege, attorney 
work product doctrine, and crime-fraud exception apply to a partnership and what 
role, if any, agency principles play in the application of the crime-fraud exception. 
To provide context for these issues, we pause for background on the attorney-client 
privilege and the attorney work product doctrine, as well as the crime-fraud 
exception. 
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The attorney-client privilege attaches, of course, to confidential 
communications between an attorney and client for the purposes of securing legal 
advice or assistance.6 See In re Grand Jury Investigation, 842 F.2d 1223, 1224 
(11th Cir. 1987). The purpose of the privilege is "to encourage full and frank 
communication between attorneys and their clients and thereby promote broader 
public interests in the observance of law and administration of justice." United 
States v. Zolin, 491 U.S. 554, 562 (1989) (internal quotation marks omitted). 
Attorney work product protection extends to material obtained or prepared 
by counsel in the course of their legal duties provided that the work was done with 
an eye toward litigation.7 See Fed. R Civ. P. 26(b)(3)(A); Cox v. Adm 'r U.S. Steel 
& Carnegie, 17 F.3d 1386, 1421-22 (11th Cir. 1994). Work product protection 
prevents most inquiries into an attorney's work files and mental impressions. 
Hickman v. Taylor, 329 U.S. 495, 510 (1947). The purpose of this protection is to 
protect the integrity of the adversary process by allowing a lawyer to work "with a 
6 There are two sets of attorney-client communications claimed to be privileged that are 
potentially at issue in this appeal. First, there are communications between C&S and its clients 
in Colombia in the alien tort cases. Second, there are communications between C&S and its 
outside counsel in the defamation case. In the first category, C&S is serving as the attorney; in 
the second C&S is the client. With respect to the attorney-client privilege, as opposed to the 
protections for attorney work product, Drummond seeks discovery of attorney-client privileged 
materials only from the defamation case-that is, Drummond seeks to use the crime-fraud 
exception to pierce the attorney-client privilege only with respect to communications where C&S 
was the client. We thus do not address whether the...

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certain degree of privacy, free from unnecessary intrusion by opposing parties and 
their counsel." Id. 
But the protection afforded to work product is not absolute. Discovery may 
be had into factual work product upon a party showing "substantial need for the 
materials to prepare its case" and that it "cannot, without undue hardship, obtain 
their substantial equivalent by other means." Fed. R. Civ. P. 26(b)(3)(A). Greater 
protection is given to the attorney's opinion work product-that is, materials 
containing "the mental impressions, conclusions, opinions, or legal theories of a 
party's attorney or other representative concerning the litigation." Fed. R. Civ. P. 
26(b )(3)(B). Such materials "enjoy[] a nearly absolute immunity and can be 
discovered only in very rare and extraordinary circumstances." Cox, 17 F.3d at 
1422 (internal quotation marks omitted). 
The crime-fraud exception allows a party-in rare circumstances-to obtain 
discovery that otherwise would be protected by the attorney-client privilege or the 
attorney work product doctrine. The crime-fraud exception applies when a two-
part test is satisfied: 
First, there must be a prima facie showing that the client was engaged 
in criminal or fraudulent conduct when he sought the advice of 
counsel, that he was planning such conduct when he sought the advice 
of counsel, or that he committed a crime or fraud subsequent to 
receiving the benefit of counsel's advice. Second, there must be a 
showing that the attorney's assistance was obtained in furtherance of 
the criminal or fraudulent activity or was closely related to it. 
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In re Grand Jury Investigation, 842 F.2d at 1226. Stated simply, the crime-fraud 
exception removes the "seal of secrecy" from attorney-client communications or 
work product materials when they are made in furtherance of an ongoing or future 
crime or fraud. Zolin, 491 U.S. at 563; see Cox, 17 F.3d at 1422 (recognizing that 
the crime-fraud exception "applies to work-product in the same way that it applies 
to the attorney-client privilege"). When the crime-fraud exception applies, an 
attorney's opinion work product is discoverable. Cox, 17 F .3d at 1422. With these 
principles in mind, we now tum to the questions raised in this appeal. 
III. 
SCOPE OF INTERLOCUTORY REVIEW UNDER§ 1292 
The federal courts of appeals "have jurisdiction of appeals from all final 
decisions of the district courts of the United States." 28 U.S.C. § 1291. "A final 
decision is one by which a district court disassociates itself from the case .... " 
Doe No. 1 v. United States, 749 F.3d 999, 1004 (11th Cir. 2014) (internal quotation 
marks omitted). It "ends the litigation on the merits and leaves nothing more for 
the court to do but execute the judgment." Id. (internal quotation marks omitted). 
"Discovery orders are ordinarily not final orders that are immediately appealable." 
Id. 
There are, however, exceptions to the rule that only final decisions are 
appealable. We have discretion to hear interlocutory appeals from district court 
orders under the certification procedure in 28 U.S.C. § 1292(b ): 
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When a district judge, in making in a civil action an order not 
otherwise appealable under this section, shall be of the opinion that 
such order involves a controlling question of law as to which there is 
substantial ground for difference of opinion and that an immediate 
appeal from the order may materially advance the ultimate 
termination of the litigation, he shall so state in writing in such order. 
The Court of Appeals which would have jurisdiction of an appeal of 
such action may thereupon, in its discretion, permit an appeal to be 
taken from such order, if application is made to it within ten days after 
the entry of the order .... 
28 U.S.C. § 1292(b). We have explained that when deciding whether to permit an 
appeal under § 1292(b) after a district court has entered an order certifying the 
appeal and a party has filed a timely application for permission to appeal, we are 
considering not whether we have jurisdiction to hear the appeal but instead 
whether to exercise our discretion under § 1292(b ). See McFarlin v. Conseco 
Servs., LLC, 381 F.3d 1251, 1255 (11th Cir. 2004). 
Our precedent identifies several principles to guide us when deciding 
whether to exercise our discretion under § 1292(b) to allow for a rare interlocutory 
appeal. Id. at 1264. In general, we exercise our discretion only when (1) the 
appeal presents a pure question of law, (2) the question is controlling of at least a 
substantial part of the case, (3) the district court identifies the question in its order, 
(4) there are substantial grounds for differences of opinion on the question, and 
( 5) resolution of the question may reduce the amount of litigation necessary on 
remand. Id. But even if all of these factors are present, we still have discretion to 
disallow the appeal. See id. 
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After considering these guiding principles, we conclude that the motions 
panel improvidently granted permission to appeal, vacate in part that earlier order, 
and decline to exercise our discretion to decide the first question presented in this 
appeal. Paraphrased, the first question asks whether a court may apply the crime-
fraud exception to a partnership by imputing to the partnership the actions and 
knowledge of a partner. C&S argues that the district court improperly used agency 
principles to impute Collingsworth's intent to commit a fraud or crime to C&S in 
determining that a crime or fraud occurred and that the relevant communications or 
work product were made in furtherance of that fraud. 
At first blush, the core issue of whether, in applying the crime-fraud 
exception, a court may impute a partner's knowledge and intent to a partnership 
appears to raise a purely legal question. But C&S concedes that in some 
circumstances, such as when a firm's managing partner or partner charged with 
responsibility to make the decisions at issue participates in the fraud, a partner's 
intent may be imputed to the partnership. So it cannot be that this appeal presents 
the abstract, purely legal issue whether agency principles ever may be used to 
impute a partner's knowledge and intent to a partnership for purposes of applying 
the crime-fraud exception. 
Instead, C&S seeks in effect to have us review whether, given the nature of 
Collingsworth's relationship with the firm, the record supported the district court's 
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application of agency principles to impute his intent and actions to C&S. This 
question is not purely one of law about whether agency principles can be imputed 
for the purpose of applying the crime-fraud exception. 
To the contrary, the question posed here requires a fact-specific inquiry into 
whether the evidence in this case-which showed, at a minimum, that 
Collingsworth was the C&S partner to whom Scherer, the managing partner, had 
delegated responsibility for the alien tort cases and who also served as the primary 
point of contact for the firm's outside counsel in the defamation cases-is 
sufficient to support the application of agency principles in the crime-fraud 
context. To answer it would require the court to apply law to the particular facts of 
the case and thus to take a deep dive into this case's voluminous record. The 
purpose of§ 1292(b) is not to provide interlocutory appellate review of such fact-
driven issues. See McFarlin, 381 F.3d at 1262. Accordingly, we conclude that 
permission to appeal on this issue was improvidently granted, and we decline to 
exercise our discretion to hear an interlocutory appeal related to the first question. 
IV. 
LEGALANALYSIS 
We now tum to the second question raised in this appeal, which we do 
exercise our discretion to answer. To clarify the question, we rephrase it slightly 
as follows: 
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Can the crime-fraud exception be applied to overcome attorney work 
product protection when the attorney or law firm was engaged in the 
crime or fraud but the client was not? 
With this question, C&S in effect seeks to bar the disclosure of work product 
materials created in the alien tort actions, claiming that because its clients in those 
cases were innocent of any wrongdoing, work product protection is maintained 
despite the firm's participation in the wrongdoing. 8 
We hold that the district court properly concluded that the crime-fraud 
exception may be applied because illegal or fraudulent conduct by an attorney 
alone may suffice to overcome attorney work product protection. 9 We have 
previously recognized that in cases of attorney misconduct there is no protection 
for the attorney's work product. See Parrott v. Wilson, 707 F.2d 1262, 1271 (11th 
Cir. 1983). In Parrott, a party claimed that his attorney's secret recordings of 
conversations with two witnesses were protected from discovery as work product. 
Id. at 1270-71. We disagreed, concluding that because the attorney's clandestine 
recordings were unethical, 10 regardless of whether they were work product, they 
8 Again, this issue relates only to materials from the alien tort cases, not the defamation 
case. 
9 We review de nova a question certified for interlocutory review under§ 1292(b). 
Johnson v. City of Fort Lauderdale, 148 F.3d 1228, 1229 n.3 (11th Cir. 1998). 
10 At the time we decided Parrott, an ABA opinion concluded that it was unethical for an 
attorney to make a clandestine recording, even when such recording was legal under state law. 
707 F.2d at 1271 n.19 (11th Cir. 1983). That ABA opinion has since been withdrawn. See ABA 
Comm. on Ethics and Prof'l Responsibility, Formal Op. 01-422 (2001). We express no opinion 
whether an attorney who makes a clandestine recording today acts unethically. 
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were not protected. We relied on a D.C. Circuit decision recognizing that "in some 
circumstances, a lawyer's unprofessional conduct may vitiate" the protection 
afforded to attorney work product. Id. (quoting Moody v. I.R.S., 654 F.2d 795, 
799-801 (D.C. Cir. 1981). The D.C. Circuit explained in Moody that "[a]n attorney 
should not be able to exploit [ work product protection] for ends outside of and 
antithetical to the adversary system any more than a client who attempts to use the 
privilege to advance criminal or fraudulent ends." Moody, 654 F.2d at 800. Based 
on this rationale, an attorney may not exploit work product protection when she 
engages in illegal conduct or a fraud upon the court even if her client is innocent. 
11 
Of course, for the crime-fraud exception to apply, a court must find that the 
specific document or testimony that the court is ordering to be produced reflects 
work of the attorney that was performed in furtherance of the criminal or 
fraudulent activity or that was closely related to it. 
To support its contrary position, C&S cites several cases holding that an 
innocent client's privilege cannot be overcome by the crime-fraud exception. But 
most of these cases consider the scope of the attorney-client privilege rather than 
11 Our conclusion today is consistent with the holdings of other circuits that the crime-
fraud exception may vitiate the protection afforded attorney work product in cases where an 
attorney commits a crime or fraud. See In re Impounded Case (Law Firm), 879 F.2d 1211, 1213-
14 (3d Cir. 1989) (allowing crime-fraud exception to overcome work product protection for 
"materials relating solely to possible criminal activity of [a] law firm"); In re Doe, 662 F.2d 
1073, 1079 ( 4th Cir. 1981) ( concluding that fraud exception allowed disclosure of work product 
when the lawyer, not client, was alleged to have engaged in the fraud). 
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the relationship between the crime-fraud exception and the attorney work product 
doctrine. Moody, the case on which we relied in Parrott, warrants further 
discussion, however. 
In Moody, the D.C. Circuit recognized that the work product doctrine 
"create[ d] a legally protectable interest in non-disclosure in two parties: lawyer and 
client." 654 F.2d at 801. The D.C. Circuit explained that "the conclusion that an 
attorney has no right to object to the disclosure of work product made possible by 
his misconduct does not necessarily mean that the work product privilege is 
inapplicable to such documents" because "the client's interest in preventing 
disclosures about his case may survive the misfortune of his representation by an 
unscrupulous attorney." Id. C&S relies on this reasoning to argue that the crime-
fraud exception may not be used to pierce work product protection when the 
underlying client is innocent because the innocent client may still invoke the 
doctrine. 
We disagree with C&S's position. Moody went on to explain that to 
determine whether an innocent client may rely on the work product doctrine to 
shield materials after his attorney engaged in a crime or a fraud, "[a] court must 
look to all the circumstances of the case ... to decide whether the policy favoring 
disclosure outweighs the client's legitimate interest in secrecy" and prevent 
disclosure when it "would traumatize the adversary process more than the 
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underlying legal misbehavior." Id. Rather than adopting a blanket rule that the 
crime-fraud exception does not apply when there is an innocent client, the D.C. 
Circuit adopted a balancing test to weigh the client's interest in secrecy against the 
reasons for disclosure. Because we agree with the D.C. Circuit's application of 
this balancing test, the crime-fraud exception may apply to work product when the 
attorney but not her client is accused of misconduct.
12 We therefore reject C&S's 
argument that the client's innocence is an absolute bar to piercing attorney work 
product protection through the crime-fraud exception. 13 
We resolve the pure legal issue presented in this interlocutory appeal by 
holding that the crime-fraud exception may be applied to eliminate work product 
12 To support its position that the crime-fraud exception cannot apply to overcome work 
product protection when a client is innocent, C&S also points to several decisions holding that an 
innocent attorney may invoke work product protection even if his client committed a crime or 
fraud using his services. See, e.g., In re Grand Jury Proceedings #5 Empanelled Jan. 28, 2004, 
401 F.3d 247,252 (4th Cir. 2005) ("[T]hose seeking to overcome the opinion work product 
privilege [using the crime-fraud exception] must make a prima facie showing that the attorney in 
question was aware of or a knowing participant in the criminal conduct." (internal quotation 
marks omitted)). According to C&S, because an innocent attorney may continue to rely on the 
attorney work product doctrine when his client engaged in a crime or fraud, the converse must 
also be true: an innocent client may invoke work product protection even if her attorney 
committed a crime or fraud while providing services. We disagree. C&S 's position would, in 
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protection based on attorney misconduct when the client is innocent. Accordingly, 
we affirm the district court's order.
14 
V. 
CONCLUSION 
Regarding the first question certified on appeal, we decline to exercise our 
discretion to answer whether agency principles may be used to apply the crime-
fraud exception under the facts of this case. We will not answer this question 
because it does not present a purely legal question. This Court's earlier order 
granting permission to appeal is vacated as improvidently granted as to that 
question, and permission to appeal on that question is denied. 
Regarding the second question certified on appeal, we conclude that the 
crime-fraud exception may in appropriate cases be applied to overcome work 
product protection based on attorney misconduct, even if the attorney's client is 
innocent of any wrongdoing. Accordingly, we affirm the district court's order on 
the crime-fraud exception. 
14 On remand, under the district court's order, the special master will perform an in 
camera review of certain categories of documents that C&S and Collingsworth contend are 
protected by the attorney client privilege or work product protection. To conclude that the 
crime-fraud exception applies to require disclosure of any specific document, the special master 
must find that the document either (1) reflects a communication used to further a crime or fraud 
or was closely related to it or (2) was created to further a crime or fraud or was closely related to 
it. See Cox, 17 F.3d at 1422; In re Grand Jury Investigation, 842 F.2d at 1227. 
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Question 1 is DECLINED, the earlier order granting permission to appeal is 
VACATED, and the petition for permission to review is DENIED. 
Question 2 is ANSWERED. 
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