1251.pdf
Unknown Volume 183 pages
NOT A CERTIFIED COPY Filing# 68802811 E-Filed 03/05/2018 03:26:43 PM JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. I --------------- IN THE CIRCUIT COURT OF THE FIFTEENTH WDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800:XXXXMBAG MOTION TO STRIKE EPSTEIN'S UNTIMELY SUPPLEMENTAL EXHIBITS AND TO STRIKE ALL EXHIBITS AND ANY REFERENCE TO DOCUMENTS CONTAINING PRIVILEGED MATERIALS LISTED ON EDWARDS' PRIVILEGE LOG Counter-Plaintiff Edwards, through undersigned counsel, hereby files this Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, and in support states as follows: Summary In a transparent attempt to either conduct trial by ambush or sufficiently muddy the waters to request yet another continuance, Epstein has sporadically disclosed new trial exhibits over the past month in direct violation of multiple orders of this Court concerning both the deadline to disclose exhibits and the prohibition against general, catch-all exhibit categories. On February 6, 2018, Edwards was required to file his General Objection to Untimely Composite Exhibits, attached hereto as Exhibit 'A,' in order to preserve his objections to this highly prejudicial conduct. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/05/2018 03:26:43 PM
NOT A CERTIFIED COPY
Edwards adv. Epstein
Case No. 502009CA040800:XXXXMBAG
Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log
Finally, on February 28, 2016, undersigned counsel sent the following communication to Epstein's
counsel:
Your recent efforts to add documents not specifically identified to earlier listed
categories prompts me to remind you that Judge Hafele has required that
documents be identified in a manner that enables the opposing party to know in
advance exactly which documents are intended to be offered in evidence.
We
assume you have complied with that directive and are relying on that compliance.
On March 2, 2018, only two days later and on the eve of trial, Epstein disclosed for the
first time 198 new trial exhibits consisting of at least forty-nine ( 49) privileged e-mails generated
when Edwards was at Rothstein Rosenfeldt Adler ("RRA") and engaged in actively prosecuting
both civil claims against Epstein and the still-pending CVRA challenge to Epstein's extraordinary
sweetheart plea deal. These e-mails have been listed on Edwards' privilege log since February
23, 2011. Epstein filed Edwards' 2011 privilege log with this Court on April 11, 2012 and has not
obtained an order either overruling these privilege assertions or compelling production of these
documents. At this time, it is unknown exactly how Epstein obtained these privileged materials,
although it is clear that he did so in secret and has waited until the last possible moment to reveal
that he is improperly in possession of Edwards' privileged materials.
The late disclosure of these trial exhibits is in direct violation of the Court's July 20, 2017
Order, the Court's December 5, 2017 oral ruling (concerning trial exhibits not-yet-produced and
prohibiting general, catch-all exhibits) and the Court's January 16, 2018 ruling. Furthermore,...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log Undersigned counsel (as well as Paul Cassell, Esq., as counsel for L.M., E.W. and Jane Doe) has since notified Epstein's counsel, Scott Link and Kara Rockenbach, that they are in possession of privileged materials and has requested that counsel take all ethically appropriate steps to turn over this information. That repeated request has been repeatedly denied. Edwards requests that the Court strike all late disclosed trial exhibits, including specifically but not limited to the privileged materials identified on Edwards' 2011 Privilege Log, which Epstein's counsel has acknowledged have been in the possession of Epstein lawyers for years, since at least 2011. Edwards further requests that the Court strike and preclude Epstein's counsel from making any reference to materials that are clearly attorney-client and work-product privileged and which have been listed on Edwards' privilege log for seven (7) years. In addition to the violation of multiple Court orders and the unethical possession of these materials, not a single e-mail has any relevance whatsoever because: (1) Epstein did not have possession of them prior to instituting this malicious lawsuit against Edwards and therefore could not have relied on them to support probable cause, (2) Epstein has never testified that he relied upon them to continue this malicious lawsuit against Edwards, and (3) the communications generated in the course of the prosecution of claims against Epstein relate to conduct subject to the absolute protection of the litigation privilege. Finally, Edwards requests that the Court require Epstein's counsel to show cause why they should not be sanctioned for their attempt to conduct trial by ambush by using improperly ...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log The Court Orders Violated by Epstein 1. On July 20, 2017, the Court entered its Order Specially Setting Trial, which set the case for trial beginning on December 5, 201 7. 2. In its Order, the Court required that the Pre-Trial Stipulation include "each party's numbered list of trial exhibits with specific objections, if any, to schedules attached to the stipulation." (emphasis added). The Court made clear that the parties would be "strictly limited to exhibits ... disclosed ... on the schedules attached to the Pre-Trial Stipulation ... absent agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause shown." ( emphasis added). 3. Thus, the Court's July 20, 2017 Order limited the parties to only those trial exhibits that were specifically identified and disclosed on the Pre-Trial Stipulation. 4. In October and November 2017, the parties began exchanging Exhibit Lists and producing proposed exhibits in connection with the Court's Order. Epstein's Exhibit List listed as Exhibit #13, "miscellaneous," the broadest catch-all provision possible: All documents produced by any party or non-party in this matter. 5. At the December 5, 2017 hearing, the Court instructed that any identified exhibits not previously produced must be provided to opposing counsel by no later than December 19, 2017. See, e.g., 12/5/17 Tr. at 225:21-226:4. The Court also cautioned that general "catch-all" exhibit categories would not be permitted and that, instead, the specific documents covered by 4
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log such exhibits must be separately identified and produced. See, e.g., 12/5/17 Tr. at 223:11- 225:14. The message to the parties was clear: trial by ambush would not be permitted. 1 6. On December 19, 2017, Epstein produced copies of certain listed exhibits pursuant to that directive. 7. Epstein's Exhibit #13 contained twenty-seven (27) RRA emails. None of these emails were listed on Edwards' April 12, 2012 Privilege Log. 8. On December 22, 2017, the parties filed the Pre-Trial Stipulation. Epstein's Exhibit List was attached to the Pre-Trial Stipulation." 9. Thus, pursuant to the Court's December 5, 2017 ruling and the December 19, 2017 exhibit exchange, Epstein's Exhibit #13 was comprised of the 27 emails that had been specifically identified and produced. 10. Moreover, pursuant to the Court's July 20, 2017 Order Specially Setting Trial, Epstein was "strictly limited" to those 27 specific documents absent a showing of good cause, which would necessarily require the filing of some motion seeking relief from the Court. 11. Epstein, as has been consistent over the past few months, chose to ignore these Court Orders and instead began piecemeal producing additional proposed exhibits throughout the month of February, which finally prompted undersigned counsel to send correspondence to Epstein's counsel objecting to these flagrant violations of the Court's rulings. See Ex. 'A'. 1 The Court's oral ruling was memorialized on January 16, 2018, when the Court entered its Order on Epstein's Revised Omnibus Motion in Limine Section B (Edwards' Trial Exhibits). This Order required Edwards to produce all trial exhibits that had not already been produced by December 20, 2018 and to produce all specifi...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log 12. Epstein's continued violation of the Court's Orders culminated on March 2, 2018, with the eve-of-trial production of 198 new emails under Exhibit #13, which include at least forty- nine (49) privileged emails that are listed on Edwards' 2012 Privilege Log. This improper, prejudicial, and unethical conduct should not be permitted by the Court. Timeline of the Privileged Materials at Issue 13. In order to orient the Court regarding Edwards' 2011 Privilege Log2, Edwards has compiled the following timeline concerning the privileged e-mail communications at issue. Because the privileged materials at issue are e-mail communications from RRA, Epstein originally sought these records in the Bankruptcy Court to be produced by the Trustee, appointed to oversee the RRA bankruptcy proceeding. Edwards has highlighted the key State Court docket entries for the Court's convenience: Bankruptcy April 17, 2010 Epstein propounded a broad subpoena to the Trustee for RRA as an interested Court party in the bankruptcy case of In re: Rothstein Rosenfeldt Adler, 09-34791- RBR, requesting tens of thousands of emails (the subpoena was directed to the bankruptcy trustee because the trustee was in possession of all RRA emails). Epstein filed a Motion to Compel that production from the trustee. DE 807. Bankruptcy July 19, 2010 LM (one of Epstein's victims) filed an objection and amended motion for Court protective order, DE 819, explaining that the emails requested were barred from disclosure based on privilege and relevance grounds. Bankruptcy August 13, 2010 Judge Rey in the bankruptcy action entered an order regarding production of Court the emails to a special master, Judge Camey, appointed to oversee th...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log Bankruptcy September 27, 2010 Edwards moved for protective order through counsel Jack Scarola, adopting Court LM's arguments for a protective order and invoking work-product privilege. DE 1022. Bankruptcy September 30, 2010 LM joined in that DE 1022 motion and requested further clarification. DE Court 1038. Bankruptcy October 13, 2010 Hearing on Motion to Clarify before Robert Camey. Court Bankruptcy October 15, 2010 The bankruptcy court entered an Order which clarified its earlier Order, DE Court 1068, requiring that the trustee provide the emails at issue to Farmer Jaffe Weissing Edwards Fistos Lehrman (Edwards's firm at the time which was representing LM) and requesting FJWEFL prepare the log. The order also provided a procedure for the special master to hold a hearing about assertions of privilege. Bankruptcy October 20, 2010 Bankruptcy court cancelled the hearing on the motion for protective order. Court DE 1077. State Court November 23, 2010 Epstein files his amended privilege log. Bankruptcy December 16, 2010 LM filed a motion requesting a stay of the Order directing the preparation of Court a privilege log until after the time when the State court ruled on the then pending Motion for Summary Judgment. DE 1236. Bankruptcy December 22, 2010 Bankruptcy court entered an order extending the time for production of the Court privilege log until January 31, 2011. DE 1260. State Court January 25, 2011 FJWEFL produced 8,408 pages of non-privileged documents to Epstein. Bankruptcy January 26, 2011 FJWEFL served a privilege log, and the sufficiency of that log was challenged Court by Epstein in the bankruptcy court. DE 1442. State Court February 8, 2011 Epstein f...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log additional boxes of "Farmer Jaffe Irrelevant E-Mails" were also produced containing 3,804 pages of documents in the first box and 3,880 pages of documents in the second box. State Court March 30, 2011 Judge Crow entered an order staying the subpoena to the trustee. State Court May 27, 2011 Order setting hearing on all motions relating to discovery and privilege issues for July 13, 2011. State Court July 12, 2011 Epstein's Motion for Leave to Use Attorneys Eyes Only Documents produced under confidentiality agreement. State Court July 14, 2011 Edwards protective order granted. Epstein request for all emails is overbroad and not necessarily calculated to lead to admissible evidence. State Court March 9, 2012 Epstein Motion to Compel and Amend Protective Order relating to the subpoena to the Bankruptcy Trustee. State Court April 10, 2012 Order requiring Edwards to produce any non-privileged documents as identified in paragraph 13 of Edwards's Motion to Compel and Amend Protective Order. State Court April 11, 2012 Epstein files Edwards February 23, 2011 Privilege Log from the Bankruptcy Court in this case. This Privilege Log identifies many of the privileged materials that Epstein is now attempting to use at trial. State Court April 11, 2012 Epstein Motion to Compel production of documents from Edwards and for Sanctions. State Court April 23, 2012 Fowler White Motion to Withdraw State Court May 2, 2012 Agreed Order on Fowler White Withdraw State Court May 7, 2012 Edwards produces 163 pages of additional responsive documents m compliance with April 10, 2012 Order State Court May 8, 2012 Crow Order Requiring Better Privilege Log State Court May 15, 2012 Edwards Motion...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log State Court June 19, 2012 Order Setting hearing on Motion for Clarification. State Court August 3, 2012 Hearing on Motion for Clarification on Discovery Issues. State Court August 14, 2012 Scarola letter to Judge Crow enclosing proposed Order on Motion for Clarification on Discovery Issues Provided before Epstein's voluntarily dismissed his claims against Edwards State Court August 16, 2012 Epstein voluntarily dismisses case against Edwards without prejudice. State August 17, 2012 Judge Crow grants Edwards' Motion for Clarification and Court vacates his May 8, 2012 Order requiring an amended privilege log.3 Edwards' April 12, 2012 Privilege Log remained in full force and effect. Epstein never challenged the sufficiency of that privilege log or made any attempt to overrule Edwards' privilege assertions or compel production of these privile,:e materials. 14. To summarize, Edwards was provided with a total of27,590 emails to evaluate. On January 25, 2011, Edwards produced 8,408 pages of non-privileged emails to Epstein. On February 23, 2011, Edwards produced an additional 12,711 pages of emails, which included 5,027 pages of emails that were designated "Attorney's Eyes Only." Between the January 25 and February 23, 2011 productions, Edwards turned over 21,119 pages of emails to Epstein. Edwards properly listed the remaining 6,471 pages of emails on his privilege log filed on February 23, 2011 in the Bankruptcy Court. Pursuant to Epstein's July 12, 2011 Motion for Leave to Use Attorneys 3 Judge Crow's Order also required Edwards to "file a written response specifically addressing the production sought in Paragraph 13 of Epstein's Motion to Compel and Amend Protective Order ofMarch 9,...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log Eyes Only Documents Produced Under Confidentiality Agreement, the Attorney's Eyes-Only documents are governed by a confidentiality agreement.4 15. On April 11, 2012, Epstein filed Edwards' privilege log in this case. Pursuant to Judge Crow's August 17, 2012 Order vacating his prior Order requiring Edwards' to file a better privilege log, the February 23, 2011 Privilege Log filed in this case on April 11, 2012 remains in full force and effect. 16. As referenced in the chart above, in May 2012, Epstein argued that Edwards' privilege log was insufficiently descriptive resulting in his inability to question the various assertions of privilege. Based on this contention alone, it is clear that Epstein was not in possession of the documents listed on Edwards' privilege log. Therefore, Epstein could not possibly have relied on these privileged documents at any time before the filing or during the continuation of his lawsuit against Edwards, which was voluntarily dismissed only three months later on August 16, 2012. 17. After voluntarily dismissing his claims against Edwards, Epstein never sought to overrule any of these privilege assertions or to compel production of the privileged materials listed on the log. Epstein has obviously been on notice of the privileged nature of those documents, knew they had been withheld from production, and knew that it was unethical to retain the privileged documents regardless of how he had acquired them. 4 Epstein's attempt to "confirm" with David Vitale, Esq., who only recently appeared in this case, that no confidentiality agreement exists further demonstrates the trial by ambush strategy of Epstein's counsel. The attorney to discuss that issue with, and to sp...
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log 18. Yet Epstein now seeks to use at least forty-nine ( 49) clearly privileged emails listed on the February 23, 2011 Privilege Log and has refused repeated requests to identify how he came into possession of the privileged materials as well as repeated requests to turn over and to destroy the privilege materials, as his counsel is ethically required to do. A Comparison of Edwards' Privilege Log and Epstein's March 2, 2018 Untimely Exhibits 19. Epstein and his counsel are knowingly in possession of at least forty-nine ( 49) privileged e-mails that are designated on Edwards' 2012 Privilege Log: Number of Privileged Emails Bates Numbers from Epstein's Bates Number/Range on in Epstein's Possession Untimely Supplemental Edwards' February 23, 2011 (49 TOTAL) Exhibit #13 Privilege Log 1 02645 02633-02646 1 00149 00149 1 01527 01527 1 04493 04491-04518 1 04494 04494 1 04495 04495 1 00014 00014 1 00090 00090 1 00133 00133 1 08006 08000-08011 1 00026 00026 1 01004 01003-01005 1 12289 12289 11
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log 1 26481 26479-26481 1 26480 26479-26481 1 26356 26356 1 26570 26570 1 03731 03719-03736 3 06406-06408 06404-06408 1 01686 01686 3 11123-11125 11123-11136 1 11126 11126 1 25925 25925 1 25874 25874 1 11145 11143-11146 1 03191 03191-03196 5 04398-04402 04387-04402 5 04408-04412 04403-04416 1 267476 26741-26763 1 08042 08033-08070 1 26741 26741-26763 3 08059-08061 08033-08070 3 26756-26758 26741-26763 3 08036-08038 08033-08070 1 26762 26741-26763 1 01117 01112-01117 12
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log 3 08121-08123 08118-08123 4 26749-26752 26741-26763 3 08128-08130 08124-08156 3 08118-08120 08118-08123 3 08131-08133 08124-08156 3 08124-08126 08124-08156 4 08135-08138 08124-08156 1 27494 27494 1 26760 26741-26763 1 25997 25997 1 25937 25937 2 26604-26605 26604-26605 3 07019-07021 07019-07024 Summary of Relief Sought by Edwards 20. Edwards respectfully requests entry of an Order for the following relief: a. (1) Striking all exhibits produced by Epstein after December 20, 2017 in violation of the Court's July 20, 2017 Order, December 5, 2017 Oral Ruling, and January 16, 2018 Order; b. (2) Striking all proposed Epstein exhibits that contain or reference privileged materials specifically listed on Edwards' 2011 Privilege Log; 13
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800:XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log c. (3) Striking any and all pleadings, motions and portions of deposition transcripts, in which Epstein's counsel improperly utilized privileged materials to drive the nature of that discovery; d. (4) Precluding Epstein's counsel from making any mention or use of any struck exhibits or pleadings, including the privileged materials; e. (5) Ordering Epstein, and his counsel, to show cause as to how (and when) they came into possession of materials listed on Edwards' 2011 Privilege Log; f. (6) Awarding Edwards his attorneys' fees and costs from the date Epstein first came into possession of privileged materials, used them in defending his case, and failed to properly disclose his possession of these materials to Edwards and the Court; and g. (7) Any such further relief as the Court deems just and proper given the circumstances. WHEREFORE, Counter-Plaintiff respectfully requests that the Court enter an Order granting this Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log as requested herein. 14
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 5th day of March, 2018. ttorney E-Mails: jsx@searcylaw.com; and mmccann@searcylaw.com Primary E-Mail: _scarolateam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards 15
NOT A CERTIFIED COPY Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log Scott J. Link, Esq. Link & Rockenbach, P.A. Scott@linkrocklaw.com Kara@linkrocklaw.com 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: 561-727-3600 Fax: 561-727-3601 Attorneys for Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury Goldberger & Weiss, P.A. 250 Australian A venue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Nichole J. Segal, Esquire njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Bradley J. Edwards, Esquire staff.efile@pathtojustice.com 425 N Andrews A venue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 16
NOT A CERTIFIED COPY IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800:XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, ________________ / GENERAL OBJECTIONS TO UNTIMELY COMPOSITE EXHIBITS Counter-Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this General Objections to Untimely Composite Exhibits, and as grounds therefor states as follows: 1. At the December 5, 2017 special-set hearing, the Court ordered Counter-Plaintiff to produce copies of any exhibits that had not previously been produced by no later than December 20, 2017. (12/5/17 Tr. 216,219,226,228). 2. That ruling was memorialized m the Court's January 16, 2018 Order on Plaintiff/Counter-Defendant Jeffrey Epstein's Revised Omnibus Motion in Limine Section B (Edwards' Trial Exhibits), as follows: On or before December 20, 2017, Edwards shall produce to Epstein all trial exhibits that have not been previously produced in the form to be introduced at trial .. . 3. Yet on February 2, 2018, undersigned counsel received letter correspondence from Epstein's counsel, which enclosed a flash drive "containing additional documents for [Epstein]'s EXHIBIT "A"
NOT A CERTIFIED COPY Case No.: 502009CA040800XXXXMBAG General Objection to Untimely Composite Exhibits Page2 of4 trial Exhibit Nos. 18, 35, 48, 323 and 324. We are still obtaining additional public records and will provide those to you upon our receipt." The numbered exhibits are 'catch-alls' as follows: a. #18 - Court docket and all court filings referenced therein for L.M. v Jeffrey Epstein, case no. 50-2008-CA-028051; b. #35 - Court docket and all court filings referenced therein for E.W. v. Jeffrey Epstein, case no. 50-2008-CA-028058; c. #48 - Court docket and all court filings reference therein for Jane Doe v. Jeffrey Epstein, case no. 08-cv-80893; d. #323 - All public records and news articles relating to Scott Rothstein, Rothstein Rosenfeldt Adler, Bradley J. Edwards and any witnesses listed by either party; e. #324 - All court dockets and filings in all matters against Jeffrey Epstein relating to any victim's claims. 4. Edwards objects to all such late produced exhibits, whether contained in the February 2, 2018 flash drive or intended to be produced in the future, as violative of the Court's December 5, 2017 ruling and January 16, 2018 order. 5. Additionally, the Court has previously ruled that, with regard to any "catch-all" exhibits listed on either party's exhibit list, the party must separately identify and list individually each exhibit sought to be relied upon by the listing party. 6. Edwards therefore reserves all objections to all composite exhibits that fail to comply with this order by the Court.
NOT A CERTIFIED COPY Case No.: 502009CA040800XXXXMBAG General Objection to Untimely Composite Exhibits Page 3 of4 I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 6th day of February, 2018. JAc?s<iAROLA , Flo_rld;(Bar No.: 169440 DAVID p. VITALE JR. / Florida Bar No.: 115179 Attorney E-Mail(s): jsx@searcylaw.com and mmccann@searcylaw.com Primary E-Mail: ScarolaTeam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Plaintiff(s)
NOT A CERTIFIED COPY Case No.: 502009CA040800:XXXXMBAG General Objection to Untimely Composite Exhibits Page 4 of5 Bradley J. Edwards, Esquire staff.efile@pathtojustice.com 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury Goldberger & Weiss, P.A. 250 Australian A venue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Nichole J. Segal, Esquire njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Scott J. Link, Esquire Eservice@linkrocklaw.com; Scott@linkrocklaw.com; Kara@linkrocklaw.com; Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com Link & Rockenbach, P.A. 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: (561)-727-3600 Fax: (561)-727-3601 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire marc@nuriklaw.com One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301
NOT A CERTIFIED COPY Case No.: 502009CA040800XXXXMBAG General Objection to Untimely Composite Exhibits Page 5 of5 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein
NOT A CERTIFIED COPY / IN THE,CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROT STEIN, individually, artd BRADLEY J. EDWARDS, individually, Defen ants/Counter-Plaintiffs. -----+---------__;_-.:/ PLAIN FF JEFFREY EPSTEIN'S NOTICE OF FILING PRIVILEGE LOG OF F RMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN DATED FEBRUARY 23, 2011 IN SUPPORT OF PLAINTIFF'S OTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plainti f, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby gives notice of filing the Privilege Log of Farmer, Jaffe, Weissing, Ed ards, Fistos & Lehrman Dated February 23, 2011 (attached hereto as Exhibit 1) in Support of P aintiff s Motion to Compel Production of Documents From Defendant Bradley Edwards and or Sanctions. Dated April 10, 2012. seph L. Ackerman, Jr. Florida Bar No. 235954 FOWLERWHITE BURNETT, P.A. EXHIBIT "B"
NOT A CERTIFIED COPY Epstein v. Rothstein and Edwards Case No. 502009CA040800:XXXXMB/Div. AG FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff Jeffrey Epstein and Christopher E. Knight Florida Bar. No. 607363 FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Plaintiff Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via Federal Express on this 10th day of April, 2012 to: Lilly Ann Sanchez, Esq., The L•S Law Firm, Four Seasons Tower, 15th Floor, 1441 Brickell Avenue, Miami, FL 33131; Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301. 2
NOT A CERTIFIED COPY INRE: 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 CHAPTERll I PRIVILEGE LOG FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN Dated: February 23, 2011 Total of 159 pages EXHIBIT j 1
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 WPS-Confidential-General- Joint W/P Priv. Financial Disclosure/Discovery 08319-08324 10/16/2009 Bradley Edwards Amy Ederi WPB-General-Confidential Joint W/P Priv. 08398 09/01/2009 Bradley Edwards Kikka Claudio C.M.A. vs. Epstein, et Joint W/P Prlv. 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 Depo Joint W/P Priv. 10192 08/11/2009 Adam Horowitz Jacquie Johnson Trump Depo 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 Farmer. Jaffe. Weissinf!. Edwards. Fistos & Lehrman BATES 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 Oepo 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-depo 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 I I I Farmer Jaffe Weissinl:? 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 Kuvln 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 vs.Jane 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 Farmer. Jaffe. WeissinJ?. Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 15981-15988 08/04/2009 Spencer Kuvin Jacquie Johnson Attachment: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. NV&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 Oepo-NY;2 Attachments Joint W/P Priv. 15866-15881 08/03/2009 Adam Horowitz Jacquie Johnson Epstein Depos 08/14,17,18 in Joint W/P Priv. NV&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-Oepos 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 t I I Farmer Jaffe Weissini? 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 Rf :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 Jacquie 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 2-8v. Epstein-Cross Joint W/P Prlv. 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:Epstein 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 s
NOT A CERTIFIED COPY I .. -. Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissint?. 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. 15166-15170 08/11/2009 Jacquie Johnson Kikka Claudio RE:out of state subpoenas Joint W/P Priv. 15171-15172 08/11/2009 Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv. 15178-15182 08/12/2009 Jacquie Johnson Kikka Claudio RE:E.pstein Joint W /P Prlv. 15306-15355 08/25/2009 Jacquie Johnson Kikka Claudio FW:Epstein Depo Notices & Subs Joint W/P Priv. 14951-14.952 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 NV 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:Epsteln Depositions 8/14.17, Joint W/P Priv. &18 in NV &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:Epsteln Depo Joint W/P Priv. 6
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer, Jaffe. Weissin~. 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 Prlv. 16612-16439 09/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo 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 Depos 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 7
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe WeissinJ:? Edwards Flstos & 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-Confirming 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: Epste in-Depos of Joint W/P Priv. Marcinkova & Sarah Kellen 02071 08/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns 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 2-23-2011 ' ' ' ' Farmer Jaffe Weissini? Edwards Fistos & Lehrman 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 Amy Ederi 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 Amy Ederi 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:Epstein 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 Farmer. Jaffe. Weissinf!. 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 Prlv. 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 Prlv. 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. Weissin.r?. Edwards, Fistos & Lehrman 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 Amy Ederi RE:Regular Monthly Cong. Call Joint W/P Priv. 07734 07/24/2009 Jessica Caldwell Bradley Edwards RE:Release Joint W/P Priv. 07218-07219 10/02/2009 Bradley Edwards Katherine Ezell RE:Meetlng 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 Of Depos 06902 09/15/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe No.101 & Jane Doe Joint W/P Prlv. NO.102 vs. Epstein 06903 09/04/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe No.101 & Jane Doe Joint W/P Priv. NO.102 vs. Epstein-Cross-Notice of Taking 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 I I I I Farmer Jaffe Weissint? 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 Prlv, 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 Depo 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 04724-04 725 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-WPS- Joint-privilege Confidential 07003-07006 06/26/2009 Amy Ederi Brad Edwards June 2stn hearing-WPS- Joint-privilege . 12
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 & & Farmer Jaffe Weissini;?. 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 I Farmer Jaffe Weissin~ 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 Joint-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 this as a parole violation 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 Weissini? Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Edwards 01998-01999 09/21/2009 Adam Horowitz Margaret Berk 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 Kuvln Bradley J. Edwards Emailing Epstein deposition Joint-privilege revised 02062 10/05/2009 Bradley J. Amy Ederi Epstein - Confirming AT&T Dial Joint-privilege Edwards in Tel, Conf. 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. Amy Ederi 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 Z...
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 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 .latquie 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-privilege 16
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 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. Hilt 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...
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 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 L.M. 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 06702-06705 09/16/2009 Bradley J. Kikka M. Claudio Igor Zlnoview & 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? Joint-privilege 18
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 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 II 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 Depa - 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.4th dca Joint-privilege 06402-06403 06/10/2009 Bradley J. Katherine W. Ezell Hearing to Un-seal Joint-privilege Edwards 01365-01366 0...
NOT A CERTIFIED COPY c.., Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinj? Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein 01319 08/11/2009 Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege 01316 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo Joint-privilege 01314 10/30/2009 Stuart Jacquie Johnson Epstein Depo 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 at 4:00 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 Mondav, 6/8/09 at 2:00 p.m. 20
NOT A CERTIFIED COPY I'...-,., Privilege Log - Dated 2-23-2011 I l Farmer Jaffe Weissln~. Edwards. Flstos & 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-privilege 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 Farmer. Jaffe Weissinf?. Edwards. Fistos & Lehrman I 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 Depa 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 Josefsberg Epstein- Confirming AT&T Tel. Joint W/P Priv. Conf. 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- Depa ln 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 Prlv. 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 Depa Joint W/P Priv. 04580 10/14/2009 Jacquie Johnson Adam Horowitz Depa of Larry Visoski Joint W/P Priv. 04640-04641 10/14/2009 Bradley Edwards Adam Horowitz Depa 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 Ku"'.in Bradley Edwards Epstein Depa Notice Joint W/P Priv. 04797-04799 09/18/2009 ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinl? 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 Depo Joint W/P Priv. 05026-05027 09/10/2009 Adam Horowitz Jacquie Johnson Notice of Production from Non- JointW/P Priv. Parties 05031 09/25/2009 Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Prlv. 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 Prlv. Mermelstein 23
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I & t I Farmer Jaffe Weissint? 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 5th 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 1st set of ROGS Joint W/P Priv. 05251-05252 07/24/2009 Katherine Ezell Bradley Edwards Depa 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 Kuvln Alfredo Rodriguez depo Joint W/P Priv. 24
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe Weissini?. 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 TV 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 /llf Privilege Log - Dated 2-23-2011 I & I I Farmer Jaffe Welsslm! Edwards Flstos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION I: 05469 07/08/2009 Mercedes Bradley Edwards Judge Marra' s July 61n 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 Horowitz 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 Claudia Supoenas far 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 Claudia Video tape of Epstein Joint W/P Priv. Estrada 05724 05/29/2009 Bradley Edwards Jack Scarola Motion far Status Conf. Joint W/P Priv. 05727 05/29/2009 Bradley Edwards Sid Garcia Motion for Status Canf. Joint W/P Priv. 05730-05731 08/14/2009 Adam Horowitz Jacquie Johnson Motion far Status Conf. Joint W/P Priv. 05734 05/29/2009 Adam Horowitz Jacquie Johnson Motion far status canf. Joint W/P Priv. 26
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 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 Joint W/P Priv. 05782-05783 07/09/2009 Bradley Edwards Spencer Kuvln 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 Prlv. 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 prlvilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin2. Edwards. Fistos & Lehrman BATES DATE TO 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 03i81 09/14/2009 William Berger Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights 03182-03185 07/14/2009 William Berger Bradley Edwards Litigation Strategy Work Product;attorney client prlvilege;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 Product;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 prlvilege;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 Depo 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 admissible evidence;protected by pr...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe, Weissinf?. Edwards, Fistos & Lehrman BATES DATE TO 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 prlvilege;lrrelevant & 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 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 09337-09340 08/10/2009 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 09350 10/21/2009 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 09335 08/06/2009 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 11983 08/06/2009 Carl Linder Jacquie Johnson Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to • .,~· .,.t lead to the discovery of admissible I,, evidence;protected by privacy rights . ' 11984-11988 08/06/2009 Carl Linder Br...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissint?, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights 11995 08/19/2009 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 12012 10/21/20009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client privllege;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 rights 11868 08/19/2009 Cara Holmes Bradley Edwards Litigation Strategy Work Product;attorney client privllege;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 Prod uct;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 Prod uct;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 & reasonably...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman 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 Product;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;lrrelevant & reasonably calculated to lead to the discovery of admissible evldence;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 evldence;protected by privacy rights 25738 08/03/2009 William Berger Beth Williamson Litigation Strategy Work Product;attorney client privllege;lrrelevant & 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 & reasonably c...
NOT A CERTIFIED COPY .. Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissin2 Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 17917-17927 08/03/2009 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 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;lrrelevant & 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 Product;attorney 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 Product;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 Product;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 priviiege;irrelevant & reasonably calculated to lead to the discovery ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe, Weissing. 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 Product;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 prlvilege;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;attorney 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 Berger Litigation Strategy Work Prod...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I Farmer Jaffe Weissim~. Edwards. Fistos & Lehrman 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 Busche! Litigation Strategy Work Product;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;lrrelevant & 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;attorney 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 ev\dence;protected by privacy rights 00042 07/06/2009 Bradley Edwards Rob Busche! Litigation Strategy Work Product;attorney client privilege;lrrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 0043 05/05 Bradley Edwards Susan Sterling Litigation Strategy Work Product;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;irrelevan...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin~. 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 Product;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 Buschel Litigation Strategy Work Prod uct;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights 00047-00049 05/01/2009 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 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 calculated 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 privilege;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 the discover...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe, Weissin2. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 00055 04/29/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privilege;lrrelevant & reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights 00056 05/05/2009 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 00057 05/05/2009 Bradley Edwards William Berger Litigation Strategy Work Product;attorney client privllege;irrelevant & reasonably calculated to lead to the discovery of admissible evldence;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 Buschel Litigation Strategy Work Product;attorney client privilege;lrrelevant & 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 Product;attorney client prlvilege;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 Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;prot...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. 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 00067 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 00068 05/12/2009 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 00069-00070 05/13/2009 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 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 evidence;protected by privacy rights 00072 05/15/2009 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 00073 05/15/2009 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 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 P...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?, 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 Product;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 Prod uct;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;attorney client privilege;irrelevant & reasonably calculate$i to lead to the discovery of admissible evidence;protected by privacy rights 00081-00082 05/20/2009 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 00083-00085 05/21/2009 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 00086-00087 05/25/2009 Bradley Edwards Paul Cassell Litigation Strategy Work Product;attorney client privilege;irrele...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin,i. Edwards. Fistos & Lehrman BATES DATE TO 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 prlvilege;lrrelevant & 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 Product;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;lrrelevant & reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights 00093 06/01/2009 Bradley Edwards William Berger Litigation Strategy Work Prod uct;attorney client prlvllege;irrelevant & reasonably calculated to lead to the discovery of admissible evldence;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 Product;attorney client privilege;irrelevant & reasonably calculated to lead to the disc...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin~. Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 00097 07/06/2009 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 00098-00100 07/07/2009 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 00101 07/09/2009 Bradley Edwards Mike Flsten Litigation Strategy Work Product;attorney client privllege;lrrelevant & 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 uct;attorney client privilege;lrrelevant & 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 Product;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 Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protec...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe Weissine:. Edwards. Fistos & Lehrman I 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 evldence;protected by privacy rights 00121 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 00122 05/12/2009 Bradley Edwards Rob Busche! Litigation Strategy Work Prod uct;attorney client prlvilege;irrelevant & reasonably calculated to lead to the discovery of admissible evldence;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 prlvilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00126 0S/22/2009 Bradley Edwards Russell Adler Litigation Strategy Work Product;attorney client prlvilege;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
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Welssln~ Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 00128-00131 5/26/2009 Bradley Edwards Rob Busche! Litigation Strategy Work Product;attorney client privllege;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 privllege;lrrelevant & 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 WIiiiam 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 eviden...
NOT A CERTIFIED COPY .. Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin2. 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 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 Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & 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 prlvllege;irrelevant & reasonably calculated to lead to the discovery of admissible evldence;protected by privacy rights 00151-00152 06/26/2009 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 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 Strategy Wo...
NOT A CERTIFIED COPY , . Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin~. Edwards. Fistos & Lehrman 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;lrrelevant & 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. Buschel Bradley J. Edwards Doe family member Attorney/Client privilege and/or work product 02445-02446 05/05/2009 Bradley J. 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/o...
NOT A CERTIFIED COPY . , Privilege Log - Dated 2-23-2011 I I Farmer Jaffe Weissint?. Edwards. Fistos & Lehrman BATES DATE TO FROM 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. Buschel Curtis Rivera Attorney/Client privilege and/or work product Edwards 029S5 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 privilege and/or work product 05264 07/27/2009 Amy Swa...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Welssln£? Edwards Fistos & Lehrman BATES 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 Edwa...
NOT A CERTIFIED COPY .. Privilege Log - Dated 2-23-2011 Farmer, Jaffe, Weissini?, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 02298-02299 07/08/2009 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 discoverv 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 discoverv 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 calculated...
NOT A CERTIFIED COPY ' . Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf!. Edwards. Fistos & Lehrman BATES 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 Prlv.; 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 05S35-05536 07/30/2009 Confidential Bradley Edwards Additional Information RE: W/P Priv.; n...
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 discovery of admissible evidence 05693-0569S 0S/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 Priv.; not reasonably calculated to lead to discoverv of admissible evidence 05738-05739 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Prlv.; 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 05759-05762 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 Prlv.; 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 Prlv.; n...
NOT A CERTIFIED COPY , . Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin2. 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 Prlv.; not reasonably calculated to lead to Source Epstein Molestations discover...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinl! Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence 07017-07018 09/04/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible 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 le...
NOT A CERTIFIED COPY , I Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Welsslni? Edwards Flstos & 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 admlsslble 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 discoverv 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 disco...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissint?. 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 Prlv.; 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 admisslble evidence 02006 06/23/2009 Confidential Bradley Edwards Litigation Strategy W/P Prlv.; 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 Prlv.; 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 Prlv.; not reasonably calculated to lead to discovery of admissible evidence 02866-02867 09/25/2009 Confidential Bradley Edwards Providing New Witness...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe Weissin2. Edwards. Fistos & Lehrman I BATES DATE TO FROM DESCRIPTION OBJECTION 03081-03082 09/21/2009 Bradley Edwards Confidential Source Providing Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 03144 10/08/2009 Confidential Bradley Edwards Providing Witnesses W /P Priv .; not reasonably calculated to lead to Source discovery of admissible evidence 03189-03190 10/14/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Strategies discoverv of admissible evidence 04015 09/08/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 02913 09/28/2009 Bradley Edwards· Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02956-02957 08/31/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 02975 10/21/2009 Confidential Bradley Edwards Litigation Strategy W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 04031-04055 08/12/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 04057 08/11/2009 Confidential Bradley Edwards Providing New Witnesses W/P Priv.; not reasonably calculated to lead to Source discovery of admissible evidence 04060 08/12/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discoverv of admissible evidence 02979-02980 10/02/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to ...
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 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 Prlv.; 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 reasonably...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinl? Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 01280-01288 09/18/2009 Confidential 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 Molestati...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weisslne:. 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 Privilege; Not reasonably calculated to lead Source to discovery of admissible evidence. 10390-10393 09/19/2009 Bradley Edwards Confidential Source Additional Information 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 Confidential Bra...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. Edwards. Fistos & Lehrman 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 BATES Qm IQ FROM DESCRIPTION OBJEQIQN 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 priva...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe Weissin~. Edwards. Fistos & Lehrman l BATES .Qfil TO FROM 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 lead ...
NOT A CERTIFIED COPY •· Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman BATES DATE TO FROM 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; prote...
NOT A CERTIFIED COPY Privilege Log - Dated 2 .. 23.2011 Farmer Jaffe. Weissinf?, Edwards. Fistos & Lehrman E PATES DATE IQ FROM 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 PrivHege; 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 rights 05...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinl? Edwards Fistos & Lehrman ill§ 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 Marc Nurik 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 WIiiiam Berger Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevan...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION 05320-05323 07/30/2009 Bradley Edwards Amy Swan Litigation Strategy 05312-05313 07/22/2009 Nora Batian Bradley Edwards Litigation Strategy 05306-05307 07/22/2009 Nora Batian Bradley Edwards Litigation Strategy 05302 07/22/2009 Attorney at RRA Bradley Edwards Litigation Strategy 05281 08/03/2009 Bradley Edwards Mike Fisten Review of litigation materials 05282-05283 04/09/2009 Beth Williamson Bradley Edwards Jane Doe v. Us 05288-05291 07/22/2009 Bradley Edwards William Berger Dr. Swan 05292 07/22/2009 Attorneys at RRA Ken Jenne RE: Epstein Meeting 63 OBJECTION discovery of admissible evidence; protected by privacy rights W /P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W /P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights W/P; Attorney Client Privilege; Irrelevant and not reasonably calcula~ed to lead to the discovery of adm...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf?. Edwards. Fistos & Lehrman BATES DATE TO fRQ.M 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 Mike Fisten 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, & Epste...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. Edwards, Fistos & Lehrman BATES DATE 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 Depo 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; Irrelevant and not reasonably calculated to lead t...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeisslnJ:?. Edwards. Fistos & Lehrman BATES DATE TO 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 Ken Jenne 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 Bradley Edwards State Judge ord...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe WeissinR", Edwards. Fistos & Lehrman I 6.A_I__ES Q&i TO FROM DESCRIPTION OBJECTION 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 In...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION 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 IME 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 Jane ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinl?, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTIQN OBJECTION 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 Trial 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 Mike Fisten 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 discovery ...
NOT A CERTIFIED COPY , . Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissine:. Edwards. Fistos & Lehrman BATES DATE 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 Depo 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 Clien...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weisslnt?. Edwards. Flstos & Lehrman BATES Mm TO FROM DESCRIPTION OBJECTION 19691-19692 09/02/2009 Mike Fisten Pat Diaz Bill RIiey 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 Depo 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 Client 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 Oepo 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 Ken Jenne 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 lead to th...
NOT A CERTIFIED COPY , . Privilege Log - Dated 2-23-2011 I I I Farmer Jaffe Weissinj? Edwards. Fistos & Lehrman Mill DATE TO FROM DESCRIPTION OBJECTIQN 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 0S807-05810 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 WIiiiam 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 ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I Farmer Jaffe WeisslnR Edwards. Flstos & Lehrman BATES nm IQ FROM DESCRIPTION QBJECTIQN discovery of admissible evidence; protected by privacy rights 25815-25822 06/01/2009 William Berger Bradley Edwards Depo 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 Mlkefisten 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 privacy rights 25997 10/23/2009 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 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 Ken Jenne Bradley Edwards Epstei...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WelsslnR. Edwards, Flstos & Lehrman BATES 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 Depa 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 Farmer. Jaffe. Weissinl?, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 18164-18165 08/03/2009 Bradley Edwards Mike Fisten Copperfield Depa 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 Depa 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 admissib,le evidence; protected by privacy rights 20219-20262 10/14/2009 Pat Roberts, Ronald Wise Visoskl 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 reasona...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin2. Edwards. Flstos & Lehrman BATES DATE TO FROM DEStRIPTION OBJECTION 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 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 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 Plaintiff's 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 Privilege; ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissim? Edwards Fistos & Lehrman §AI§ DATE TO FROM DESCRIPTION OBJECTION 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 privacy rights 01151 09/11/2009 Beth Williamson Bradley Edwards 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 th...
NOT A CERTIFIED COPY ,.. Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissint! Edwards Fistos & Lehrman 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 privacv rights 01293 08/19/2009 Ken Jenne 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 Depo 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 Depo 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 privac...
NOT A CERTIFIED COPY Privilege Log- Dated 2-23-2011 Farmer. Jaffe. Weissim:?. Edwards. Fistos & Lehrman - BATES DATE TO FROM DESCRIPTION OBJECTION 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 privacy rights 01432 09/15/2009 Bradley Edwards Pat Diaz 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; protected by privacy rights 01461 ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissine:. Edwards. Fistos & Lehrman PATES DATE TO .EBQM DESCRIPTION OBJECTION 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 Ken Jenne Bradley Edwards Investigation into Epstein planes W /P; Attorney Client Pfivllege; 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 Privilege; Irrelevant and not reasonably calculated 'to lead to the discovery of admissible evidence; protected by privacy rights 01495 08/11/2009 Marc Nurik 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...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinl? Edwards Fistos & Lehrman BATES DATE IQ FROM DESCRIPTION OBJECTION : discovery of admissible evidence; protected by privacy rights 01502 08/21/2009 Marc Nurlk 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 lead to the discoverv of admissib...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissin,;~ Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTIQN QBJECTION 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 orivacy rights 15690~15691 10/01/2009 Jacquie Johnson Bradley Edwards Trump Depo 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 admissib...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinr:?. Edwards. Flstos & Lehrman BATES DATE - TO FROM DESCRIP!IQN OBJECTION 01628 06/15/2009 Robert 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; protected ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissina. Edwards. Fistos & Lehrman BATES MU TO FROM DESCRIPTION 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 privacy rights 01681 08/03/20009 Mike Flsten Bradley Edwards Positing regarding litigation W/P; Attorney Client Privilege; Irrelevant and preparation not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01682 09/04/2009 Paul Cassell Bradley Edwards 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 reason...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe, Weissine:, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJEalON 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 evidenc...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Welsslnf?. Edwards. Fistos & Lehrman BATES ·12AR 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 calcu...
NOT A CERTIFIED COPY , .... Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weisslnt?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 04237-04242 06/1S/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 06/1S/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 Ken Jenne 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 t...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissfni? Edwards Fistos & Lehrman BATES 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 b...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinl!. Edwards. Flstos & Lehrman .Mm .Mn TO FROM DESCRIPTION OBJECTIQN 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 Privilege; 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 Litigation 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; Irrelevant a...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissini? Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN 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; protected 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 privacy rights 03004 06/23/2009 Wayne Black Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of ad...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman BATES QA]] TO FROM DESCRIPTION OBJECTION 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 Client 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; protected by privacy rights 03019 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...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissine:. 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 Mike Fisten 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 Paul...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf:?. Edwards. Fistos & Lehrman BATES DATE TO fB.QM 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 Mike Fisten 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; Irrelevant and not reasonably cal...
NOT A CERTIFIED COPY .... Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissim~. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN 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 Flsten 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 privacy rights 03127-03128 05/19/2009 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 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 d...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I Farmer Jaffe WeissinR, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 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 privacy rights 03191-03196 10/14/2009 Paul Cassell Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculat~d to lead to the discovery of admissible evidence; protected by...
NOT A CERTIFIED COPY ... Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf!, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJEQ:ION 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 ri...
NOT A CERTIFIED COPY ... Privilege Log - Dated 2-23-2011 I I Farmer Jaffe Weissint?. Edwards. Fistos & Lehrman BATES DATE 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 Client 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 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 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/P; Attorney Client Pr...
NOT A CERTIFIED COPY ... Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf?. Edwards. Fistos & Lehrman §AI§ MU TO FROM DESCRIPTION OBJECTION discovery of admissible evidence; protected by privacy rights 03469-03486 06/15/2009 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 Pri~ilege; 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 ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissine Edwards Fistos & Lehrman BATES DATE IQ , 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 privacv 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 Privllegei Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacv 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; protec...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissini?. Edwards. Flstos & Lehrman PATES 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 03S89-03604 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 0360S-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 ta lead to the discovery of admissible evidence; protected by privacy rights 03613-03615 10/29/2009 Bradley Edwards Cara Holmes Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by ·privacy rights 03616-03618 10/01/2009 Pat Diaz Bradley Edwards Providing New Witnesses , W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Welssim?. Edwards. Fistos & Lehrman BATES QAli IQ 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 discovery of...
NOT A CERTIFIED COPY BATES 01925 08/26/2009 01928-01929 08/03/2009 01930 09/05/2009 01940 09/10/2009 01944-01952 04/10/2009 01969 05/04/2009 01971-01972 05/13/2009 01973-01974 07/23/2009 Privilege Log - Dated 2-23-2011 Farmer, Jaffe, Weissin£?. Edwards, Fistos & Lehrman TO FROM DESCRIPTION Motion to Strike Jacquie Johnson Bradley J. Adriana Surveillance/Interview Edwards Jacquie Johnson Bradley J. Alfredo Rodriguez address Edwards Bradley Edwards J. William J. Berger Client info Russell Adler Bradley Edwards Russell Adler Bradley Edwards· Susan K, Stirling Bradley Edwards Attorneys at RRA Bradley Edwards Mike Fisten Bradley Edwards J. Witness Info J. Epstein assets J. Call from sources of information J. Cassell Draft J. CMA vs. Epstein - new investigator info 102 OBJECTION to the discovery of the admissible evidence; protected by privacy rights Work product; attomey/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irreleva...
NOT A CERTIFIED COPY .. Privilege Log - Dated 2-23-2011 Farmer. Jaffe Weissin~. Edwards. Fistos & Lehrman I BATES DATE TO FROM DESCRIP!ION 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 01990 05/14/2009 Bradley J. Paul Cassell Consolidation order Work product; attorney/ client 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. Dates 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 ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weisslne: Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION QBJECTIQN 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 can 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 irrele...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer Jaffe, Weissing, Edwards. Fistos & Lehrman I BATES PATE TO FROM DESCRIPTION OBJECTION 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/client 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 Depo 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/client pri...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf?. Edwards. Fistos & Lehrman BATES DATE IQ FROM DE~CRIPTION 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; protected by privacy rights 02284-02855 05/11/2009 Susan K. Stirling 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 017...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin2. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN 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 admissible ev...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Welssinf?. Edwards. Fistos & Lehrman BATES DATE IQ FROM DESCRIPTION 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 J>rlvacy 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 reasonably calculated to lead to the disco...
NOT A CERTIFIED COPY BATES DATE TO Edwards 08381-08383 09/06/2009 Bradley Edwards 08384-08388 04/13/2009 Bradley Edwards 08389-08397 05/14/2009 Bradley Edwards 08401 07/22/2009 Bradley Edwards 08409-08410 08/01/2009 Bradley Edwards 08421 06/02/2009 Bradley Edwards 08423-08425 10/09/2009 Bradley Edwards 08426 08/10/2009 Bradley Edwards Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinl?. Edwards. Fistos & Lehrman ffi.QM DESCRIPTION J. Paul Cassell Epstein - complaint J. Paul Cassell Epstein fraudulent transfer J. Paul Cassell Revisited sexual history memo J. Paul Cassell Reply memo on asset transfers J. Cara L. Holmes Rodriguez Deposition J. William J. Berger Strategy J. Mike Fisten Subpoena info J. Mike Fisten Synopsis 109 OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 • Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights Work product; attorney/client privil...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissimt. Edwards. Fistos & Lehrman BATES Qm, 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 privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02335-02338 05/08/2009 William Berger Bradley Edwards Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02360-02361 06/09/2009 Susan Stirling Bradley Edwards Hearing to Un-seal- Criminal Plea Work product; attorney/client privilege; Transcript irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02368-02373 ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 02376-02392 10/14/2009 Mike Fisten Bradley Edwards Igor Zinoview depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02401-02410 05/08/2009 William Berger Bradley Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02414-02419 05/12/2009 Attorneys at RRA Bradley Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03669-03670 10/08/2009 Carolyn Edwards Bradley Edwards Epstein house arrest monitor Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02288-02289 05/26/2009 Susan Stirling Bradley Edwards Motion date Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02292-02293 05/19/2009 Dr. Lee (Expert) Bradley Edwards Pimp and His Game Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02304-02308 09/17/2009 Bradley Edwards Jacquie Johnson Forensics/Investigations Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02313-02316 07/01/2009 Bradley Edwards William Berger Conf...
NOT A CERTIFIED COPY Privilege Log - Dated 2·23-2011 I I Farmer Jaffe WeissinR:. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Susan Stirling Bradley Edwards Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02173 09/04/2009 Attorneys at RRA Mike Fisten Epstein Juan Alessi Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02187 07/26/2009 Bradley Edwards Wayne Black Epstein matter Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02195-02197 09/17/2009 Jacquie Johnson Bradley Edwards Epstein Order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02199-02203 09/18/2009 Jacquie Johnson Bradley Edwards Epstein Order Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the. admissible evidence; protected by privacy rights 02211-02214 07/01/2009 Paul Cassell Bradley Edwards Epstein v. State of Florida- 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 Johns...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I Farmer Jaffe Weissin~. Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10904-10905 05/11/2009 Attorneys at RRA Bradley Edwards RICO Enterprise Work product; attorney/ client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10908-10909 05/11/2009 Attorneys at RRA Bradley Edwards RICO Enterprise Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacv rights 10912-10913 05/11/2009 Attorneys at RRA Bradley Edwards RICO Enterprise Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10955-10963 06/01/2009 Bradley Edwards William Berger Plaintiffs Witness list Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10979-10981 06/03/2009 Bradley Edwards Wayne Black Serve Subpoenas Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11022-11025 06/26/2009 Bradley Edwards Wayne Black Info on 2 MC2 Workers Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 11036-11037 07/21/2009 Bradley Edwards Wayne Black Serve Subpoenas Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by priv...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to th~ 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 . 112os~11201 0...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinl?. 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/client ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissinl? Edwards Fistos & Lehrman BATES DATE· TO fB.QM 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 admissitile 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...
NOT A CERTIFIED COPY Privilege Log - Dated 2-2.3-2011 Farmer. Jaffe. Weissim?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTIQN 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; protected by privacy rights 08072-08075 07/22/2009 Paul Cassell Bradley Edwards Total counts for E.W. Work product; attorney/ client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08090-08091 10/05/2009 William Berger Bradley Edwards Trial Prep Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 08...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissini? Edwards Fistos & Lehrman §ATES DATE TO FROM QESCRIPTI0N 0BIEOI0N to the discovery of the admissible evidence; protected by privacy rights 08157-08159 06/03/2009 Carla Martinez Bradley Edwards Vanity Fair Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected bv orivacy 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 KenJenne 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 KenJenne 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 Johnson Br...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissine: Edwards Fistos & Lehrman BATES DATE TO .EBQM DESCRIPTION OBJECTION protected by privacy rights 15820-15822 10/29/2009 Jacquie Johnson Cara Holmes Subpoenas for Epstein'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 bv privacv 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 bv 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 rights 10621-10624 10/02/2009 Bradle...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissine:. Edwards. Fistos & Lehrman BAT~ QAll TO FROM DESCRIPTION OBJECTION 10633-10638 10/05/2009 Bradley Edwards William Berger Trial Prep Work product; attorney/client privilege; • irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10681-10692 10/07/2009 Jacquie Johnson Mike Fisten Depositions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 10777-10786 10/16/2009 Bradley Edwards Paul Cassell New Evidence of Epstein 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 Visoskl 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 pr:ivilege; 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/client ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe, Weissin2. Edwards. Flstos & Lehrman §Alli 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; protected by priva...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. Edwards, Flstos & Lehrman BATES DATE TO FROM DESCRIPTION 04005-04011 05/13/2009 Bradley Edwards William Berger Discovery 04070-04093 04/07/2009 Bradley Edwards Paul Cassell Motion to Strike 03754 07/08/2009 Paul Cassell Bradley Edwards Conference Call 03848-03858 09/09/2009 Bradley Edwards Jacquie Johnson Cooperfield Service 03642-03643 09/04/2009 Paul Cassell Bradley Edwards 1. Accounts/ 2. Motion for IME 03657-03661 09/04/2009 Attorneys at RRA Paul Cassell Litigation Strategy 02475 06/15/2009 Susan Stirling Bradley Edwards Litigation Strategy 02494-02515 09/20/2009 Bradley Edwards Pat Diaz Mark Epstein Info 122 OBJECTION to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected bv 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; prote...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissini! Edwards Fistos & Lehrman .M,TES DATE 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 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02560-02565 07/31/2009 Bradley Edwards Jacquie Johnson Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02568-02570 10/13/2009 Jacquie Johnson Bradley Edwards New Times Article Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02578-02583 05/28/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02619-02622 09/09/2009 Jacquie Johnson Bradley Edwards New client Retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02633-02646 05/01/2009 Paul Cassell Bradley Edwards Response to Motion to 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 07959-07964 09/24/...
NOT A CERTIFIED COPY Privilege Log - Dated 2 .. 23-2011 Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman BATES DATE IO FROM DESCRIPTION OBJECTION 07967-07975 09/22/2009 Jacquie Johnson Mike Fisten Subpoena on Epstein case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07979-08000 08/18/2009 Bradley Edwards Jacquie Johnson Subpoenas for Pilots Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07735-07736 07/24/2009 Bradley Edwards Jacquie Johnson Releases for therapist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07643-07645 09/09/2009 Bradley Edwards Jacquie Johnson New client Retainer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07698-07706 09/06/2009 Paul Cassell Bradley Edwards Answer to the C:omplaint 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 right...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinj!. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Visoski depo irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07595-07604 05/20/2009 Bradley Edwards Paul Cassell Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07616 07/22/2009 Paul Cassell Bradley Edwards Litigation Strategy Work product; attorney/client privilege;. Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07530-07549 06/11/2009 Bradley Edwards Susan Stirling Overtime Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07470-07507 07/09/2009 Paul Cassell Bradley Edwards Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07447~07469 10/13/2009 Attorneys at RRA Russell Adler New Times Article on epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07444-07446 05/01/2009 Bradley Edwards Paul Cassell Response to Motion to 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 the discov...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I Farmer Jaffe Weissint?, Edwards Fistos & Lehrman SATES DATE TO fB.QM DESCRIPTION OBJECTIQN to the discovery of the admissible evidence; protected by privacy rights 07424-07431 09/26/2009 Bradley Edwards Paul Cassell Need Depo Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07412-07423 04/08/2009 Bradley Edwards Paul Cassell Draft Motion to Strike Work product; attorney /client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07403-07411 04/08/2009 Paul Cassell Bradley Edwards Draft Motion to Strike Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07394-07402 07/10/2009 Bradley Edwards Paul Cassell Multiple 2255 Counts Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07386-07392 05/28/2009 William Berger Bradley Edwards Motion to Unseal Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07378-07385 04/07/2009 Bradley Edwards Paul Cassell Motion to Unseal Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07370-07377 04/07/2009 Paul Cassell Bradley Edwards Motion to Unseal Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07354-07369 10/28/2009 Beth Wi...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissim?. Edwards. IFistos & Lehrman §AI§ DATE TO ffiQM DESCRIPTION OBJECTION protected by privacy rights 07346 10/28/2009 Beth Williamson Bradley Edwards Motion to protect 2nd depo Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07337 10/28/2009 Bradley Edwards Jacquie Johnson Motion to protect 2nd depo Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 07328 10/28/2009 Bradley Edwards Beth Williamson Motion to protect 2°a 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 prlvacv 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 07247-07251 09/08/2009 Paul Cassell B...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I ' I I Farmer Jaffe Weissint? Edwards Fistos & Lehrman ~ DATE TO 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 LM.'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 Edwa...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe Weissine: Edwards fistos & Lehrman BATES DATE IQ fRQM 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 L.M. and E.W. v. Epstein - I'm on Work product; attorney/client 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 WIiiiamson 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 Ed...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissim?. Edwards. Flstos & Lehrman BATES DATE TO FROM DEStRIPTION OBJECTIO~ 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; protected by privacy rights 06767-06769 09/10/2009 Bradley Edwards Jacquie Johnson IME's Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06782-06787 04/10/2009 Paul Cassell Bradley Edwards Confidential Detailed Strategy Work product; attorney/client privilege; Memo on Asset Protection Issues Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06744-06747 05/01/2009 Paul Cassell Bradley Edwards Depo of Jeffrey Epstein Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06736-06739 05/01/2009 Bradley Edwards Paul Cassell Asset Protection Issue Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06709-06710 10/14/2009 Bradley Edwards Mike Fisten Igor Zinoview depo Work product; attorney/client . privilege; irrelevant and not reasonably calculated to lead to the discovery o...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissine. Edwards. Fistos & Lehrman BATES DATE IQ FROM DESCRIP!ION OBJECTION 06691-06696 07/09/2009 Bradley Edwards Paul Cassell How many 2255 claims? Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06683-06686 07/08/2009 Paul Cassell Bradley Edwards Hiding Assets Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06654 07/24/2009 Paul Cassell Bradley Edwards Secretary Contact Info Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06599-06600 07/08/2009 Bradley Edwards Paul Cassell Hiding Assets Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06574-06590 04/07/2009 Paul Cassell Bradley Edwards Motion to Unseal Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06567-06570 07/09/2009 Bradley Edwards Paul Cassell Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06558-06561 07/09/2009 Paul Cassell Bradley Edwards Motion to Compel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 131
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weisslni?. Edwards. Flstos & Lehrman BATES DATE IQ 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 Vlsoskl 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; Complain...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I Farmer Jaffe Weissinl?. Edwards Fistos & Lehrman .§ATES DATE TO FROM DESCBIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Macys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06113-06117 07/14/2009 Bradley Edwards Richard Wolfe Facebook/Myspace Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06106-06112 05/19/2009 Amy Swan William Berger Expert Witness Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06091 08/04/2009 William Berger Paul Cassell EW and LM v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 06001-06011 07/18/2009 Paul Cassell Bradley Edwards Epstein's Address and Position of 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 Mar...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissing, Edwards. Fistos & Lehrman .MI§ DATE TO FROM DESCRIPTION 05968 10/17/2009 Bradley Edwards William Berger litigation Strategy 05944-05947 05/01/2009 William Berger Bradley Edwards Litigation Strategy 05927 09/1M2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist 05931-05932 07/27/2009 Amy Swan Bradley Edwards Client's Cell Phone Number 05919-05920 07/28/2009 Bradley Edwards Amy Swari Client's Cell Phone Number 05915 04/22/2009 Bradley Edwards Marc Nurik Litigation Strategy 05911 05/28/2009 Bradley Edwards William Berger Litigation Strategy 134 OBJECTION irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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 Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 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
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 I I I I Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman §ATES DATE TO FROM DESCRIPTION OBJECTIQN 05890 07/27/2009 Bradley Edwards Amy Swan Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05893-05894 07/27/2009 Bradley Edwards Amy Swan Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05898-05899 07/28/2009 Bradley Edwards Amy Swan Litigation Strategy Work product; attorney/client privilege; Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05885 09/15/2009 Bradley Edwards Jacquie Johnson Litigation Strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05874-05879 07/23/2009 Bradley Edwards Jacquie Johnson Litigation StratE!gy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by prlvacv 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 Matlska Litigation strategy Work product; attorney/client privilege; irrele...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissint?. Edwards. Fistos & Lehrman §ATES .Qfil TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05845 07/24/2009 Bradley Edwards KenJenne 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 Marc Nurik Alfredo Rodriguez Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence·; protected by privacy rights 05690-05691 05/11/2009 Bradley Edwards Susan Stirling Motion to Unseal Work p...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin~. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05680-05682 05/11/2009 Bradley Edwards William Berger Subpoena Clinton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05676 08/24/2009 Attorneys at RRA Mike Fisten Topics for Meeting Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05648 07/23/2009 Attorneys at RRA Gary Farmer Assemble Epstein Litigation 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/client 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; protected by privacy rights 05610-05612 04/27/2009 Susan Stirling Bradley Edwards Request for Copies Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05588-05590 08/24/2009 Attorneys at RRA Bradley Edwards Travel restrictions Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Welsslm?. Edwards. Flstos & Lehrman BATES DATE TO FROM DESCRIPIIQN OBJECTION 05575-05576 08/21/2009 Marc Nurik Bradley Edwards Alfredo Rodriguez Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05582 09/11/2009 Bradley Edwards Mike Flsten 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/ cllent 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 Epstei...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011- I & I I Farmer Jaffe Weissint? Edwards Fistos & Lehrman §AI§ Mm TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 05502-05507 07/22/2009 Jacquie Johnson Bradley Edwards Wayne Black's email Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05475 04/21/2009 MarcNurik 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 05471-05472 08/14/2009 Marc Nurik William Berger Legal expert regarding legal issue Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05447 08/14/2009 Marc Nurik William Berger Communication with legal expert Work product; attorney /client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05420-05423 05/20/2009 William Berger Bradley Edwards Research on cases saying a judge Work product; attorney/client privjlege; 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; irrelevant and not reasonably calcula...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. Edwards. Fistos & Lehrman 8.ATE_S DATE TO FROM DESCRIPTION OBJE~ION , 05399 10/17/2009 William Berger Bradley Edwards Proposal for settlement Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05399 10/17/2009 William Berger Bradley Edwards Proposal for settlement Work product; . attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05271-05272 07/22/2009 Bradley Edwards Jacquie Johnson Depo Dates to take SR, LM, and 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; protected by privacy rights 05197-05199 08/24/2009 Attorneys at RRA Ken Jenne Michael Reiter info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 140
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf:?. Edwards. Fistos & Lehrman BATES DATE TO ....:, FROM DESCRIPTION OBJECTION 05155-05156 04/20/2009 Russell Adler Bradley Edwards Set Epstein's depo duces tecum Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05159-05160 05/28/2009 William Berger Bradley Edwards Right to move to reconsider all 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; ...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinl!. Edwards. Flstos & Lehrman ,!;!ATES DATE 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 n~t 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 Farmer. Jaffe. Weissine:. Edwards. Fistos & Lehrman ~TES DATE TO FROM DESCRIPTION OBJECTIQN to the discovery of the admissible evidence; protected by privacy rights 05054-05065 08/18/2009 Attorneys at RRA Mike Fisten Epstein Potential witnesses Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05049-05053 08/18/2009 Mike Fisten Bradley Edwards Subpoenas for potential 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 calculated to l...
NOT A CERTIFIED COPY , Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf?. Edwards. Fistos & Lehrman BATES .Qm TO FROM 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 about Bra...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin«. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 04607-04617 09/11/2009 Jacquie Johnson Bradley Edwards Holding Fed Subs until we get 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 prlvacv rights 04488-04490 07/18/2009 Bradley Edwards Paul Cassell Taking the 5tn 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 evidence; pro...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissin~. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTIQN OBJECTION Rodriguez irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05501 07/21/2009 Wayne Black Bradley Edwards Litigation strategy Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05524-05533 07/23/2009 Wayne Black Bradley Edwards Addresses for people involved in 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 rights0 146
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Welssint?. Edwards. Fistos & Lehrman BATES DATE IQ ffiQM DESCRIPTION OBJECTION 10/29/2009 Work product; attorney/client privilege; ; 05640 Pat Diaz Bradley Edwards New Epstein victim 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 Farmer, Jaffe, Weissint?, 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/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05869-05870 04/01/2009 Carolyn Edwards Bradley Edwards Personal convo between Brad 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 I I I Farmer Jaffe Weissinl? Edwards Fistos & Lehrman BATES DATE TO 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 prlvacv 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 evidenc:e 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 Farmer. Jaffe. Weissim?. Edwards. Flstos & 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 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 reasonably calc...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. WeissinJ?. Edwards. Fistos & Lehrman BATES DATE TO 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 GIibert 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; protected by privacy rights 08399 07/23/2009 Bradley Edwards Pau...
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinl!. Edwards. Fistos & Lehrman llATES .Mn TO FROM QE~tBIPTIQN 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 Fisten Meeting with client Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 20330-20334 08/24/2009 Bradley Edwards Pat Roberts Serving Alan Deirshowltz 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 Ken Jenne Epstein travel Work product; attorney/client privilege; irrelevant and not reasonably calculated to lea...
NOT A CERTIFIED COPY Privilege Log - Dated 2-:~3-2011 & & Farmer Jaffe Weissini?. Edwards. Fistos & Lehrman BATES ·DATE TO FROM DESCRIPTION OBJECTIQN 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 Flsten 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; protected by privacy rights 20201-20204 08/24/2009 Attorneys at RRA Bradley Edwards Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 153
NOT A CERTIFIED COPY Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf!. Edwards. Fistos & Lehrman .f!A!§ DATE IQ ffiQM DESCRIPTION OBJECTION 20193-20200 08/24/2009 Attorneys at RRA Bradley Edwards Proof of him being out of FL - Work product; attorney/clie_nt 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 Mike Flsten 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 Attorneys at RRA KenJenne ...
NOT A CERTIFIED COPY • Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf?. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected by privacy rights 19959-19961 07/24/2009 Attorneys at RRA Bradley Edwards Flight logs for Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 00156-00157 07/09/2009 Bradley Edwards Paul Cassell 2255 Problem Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 15366-15367 09/04/2009 Attorneys at RRA Bradley Edwards Witness Info that we need to use Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01003-01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey 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 calcula...
NOT A CERTIFIED COPY Privilege Log - Dated 2 .. 23-2011 Farmer. Jaffe. Weissint?. Edwards. Fistos & Lehrman BATES gm IQ 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/client 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. Weissinf?. Edwards. Fistos & Lehrman Mm DATE TO FROM 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 KenJenne 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 I I I I Farmer Jaffe Weissinl? Edwards Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 18308-18309 10/18/2006 Mike Flsten 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 Flsten lnve stigative 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 05256-05257 07/21/2009 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 158
NOT A CERTIFIED COPY .. Privilege Log - Dated 2-23-2011 Farmer. Jaffe. Weissinf!. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OftJ~CTION 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 cast~. 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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Objects: Text, Page | Text: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman | BATES | TO | DATE |
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Objects: Text, Page | Text: Privilege Log-Dated 2-23-2011 | Farmer,Jaffe, Weissing, Edwards, Fistos
- Abuse Litigation (p.142) 50%
- Accountant Work (p.151) 50%
- Activity In (p.125) 50%
- Adam Horowitz (p.25) 75%
- Adam Horowitz (p.26) 75%
- Adam Horowitz (p.27) 75%
- Adam Horowitz (p.28) 75%
- Adam Horowitz (p.29) 75%
- Adam Horowitz (p.30) 75%
- Adam Horowitz (p.31) 75%
- Adam Horowitz (p.32) 75%
- Adam Horowitz (p.33) 75%
- Adam Horowitz (p.34) 75%
- Adam Horowitz (p.35) 75%
- Adam Horowitz (p.36) 75%
- Adam Horowitz (p.37) 75%
- Adam Horowitz (p.38) 75%
- Adam Horowitz (p.39) 75%
- Adam Horowitz (p.40) 75%
- Adam Horowitz (p.41) 75%
- ...and 2321 more
- 012009 Bradley Edwards Paul Cassell Litigation St (p.65) address
- 05 Bradley Edwards Susan Sterling Litigation St (p.58) address
- 08014 Undated Unknown St (p.98) address
- 1395 Brickell Avenue (p.23) address
- 1441 Brickell Avenue (p.23) address
- 1555 Palm Beach Lakes Boulevard (p.16) address
- 1555 Palm Beach Lakes Boulevard (p.20) address
- 200 Bradley Edwards Confidential Source Litigation St (p.72) address
- 20009 Bradley Edwards Confidential Source Litigation St (p.70) address
- 20009 Carl Linder Bradley Edwards Litigation St (p.54) address
- 2009 All St (p.69) address
- 2009 All St (p.70) address
- 2009 Barry Stone Bradley Edwards Litigation St (p.53) address
- 2009 Beth Williamson Bradley Edwards Litigation St (p.86) address
- 2009 Beth Williamson Bradley Edwards Litigation St (p.119) address
- 2009 Beth Williamson Bradley Edwards Litigation St (p.121) address
- 2009 Bradlev Edwards Seth Lehman Litigation St (p.112) address
- 2009 Bradley Beth Williamson Litigation St (p.121) address
- 2009 Bradley Edwards Adam Steinberg Litigation St (p.113) address
- 2009 Bradley Edwards Amy Swan Litigation St (p.87) address
- ...and 599 more
- File Path
- additional_files/1251.pdf
- File Size
- 6,493 KB
- Processed
- 2025-12-21 02:01
- Status
- completed
-
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