1319.pdf

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Filing# 70209017 E-Filed 04/04/2018 10:14:24 AM 
JEFFREY EPSTEIN, 
Plaintiff/Counter-Defendant, 
v. 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, individually, 
Defendants/Counter-Plaintiff. 
______________ 
/ 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
Case No. 50-2009CA040800:XXXXMBAG 
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S 
SUPPLEMENT1 TO MOTION FOR COURT TO DECLARE RELEVANCE AND NON-
PRIVILEGED NATURE OF DOCUMENTS AND WITH SPECIFIC REQUEST FOR IN 
CAMERA REVIEW TO DETERMINE RELEVANCE, INAPPLICABILITY AND/OR 
WAIVER OF ATTORNEY-CLIENT PRIVILEGE AND ATTORNEY WORK PRODUCT 
WITH REGARD TO SEALED DOCUMENTS 
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves this Court for an in 
camera inspection to confirm the relevance of, and the absence and/or waiver of, any attorney-
client privilege and work-product protection for the 47 documents2 identified on Epstein's Clerk's 
Trial Exhibit List which Counter-Plaintiff Bradley J. Edwards ("Edwards") has improperly 
withheld from discovery, and for the Court to find that all such documents withheld on the basis 
of irrelevance, attorney-client privilege and attorney work product should be unsealed, produced 
and deemed admissible at trial, and states: 
1The original Motion was filed on March 5, 2018, but not ruled on before the March 9, 2018, 
appellate court stay. 
2Edwards identified 49 e-mails on Epstein's Clerk's Trial Exhibit List that he alleged were 
privileged, however, two of those e-mails were pages within other exhibits and the total number ofalleged 
''privileged" exhibits is 47. Epstein may be able to reduce the number of documents for the Court's in 
camera review even further if the Court will unseal the exhibits so Epstein's counsel can review them and 
select those most dispositive of the issues Edwards has made central in this case. 
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 04/04/2018 10:14:2...

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PREFACE 
No Court, not this Court or the Special Master appointed by the Bankruptcy Court, has ever 
conducted an in camera inspection of the documents identified on Edwards' February 23, 2011 
privilege log3 ruled by this Court to be legally deficient and in violation of Florida Rules of Civil 
Procedure and binding legal precedent. Now that the appellate court has made this time available 
to address pending matters, it is up to this Court to determine whether Edwards may continue to 
conceal and withhold from the jury clearly relevant, case-ending evidence that makes it impossible 
for Edwards to satisfy his heavy burden to establish a cause of action against Epstein for malicious 
prosecution. Although Epstein is asking the Court to conduct a limited in camera review of 47 
documents4, none of the documents, in fact, are attorney-client communications, and Edwards has 
waived his work-product protections with regard to those documents. Once this Court confirms, 
as it should, that none of the 4 7 documents reflect communications between Edwards and his 
clients, and therefore that they are not subject to the attorney-client privilege, these documents 
should be permanently unsealed, deemed produced and ruled to be admissible, and Epstein should 
be permitted to introduce them as evidence at trial. 
INTRODUCTION 
The 47 documents (referred to as "e-mails") that Epstein asks this Court to review in 
camera directly relate to the strength of Edwards' clients' cases against Epstein, Edwards' 
3The February 23, 2011 privilege log was prepared by Edwards when he was working at the law 
firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), which is now 
dissolved. While the privilege log is entitled in the name of that firm, for purposes of this Motion, it will 
be referred to as "Edwards' privilege log." 
4Epstein has segregated the newly identified e-mails from his March 5, 2018, Clerk's Trial Exhibit 
List, which inc...

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association and interaction with Scott Rothstein ("Rothstein"), Edwards' damages claim, and the 
overall credibility of Edwards' allegations against Epstein. These e-mails are not only relevant 
and material, they eviscerate Edwards' case, making it impossible for him to satisfy his heavy 
burden to prove the absence of probable cause for Epstein to have filed suit against him. Epstein 
is entitled to have the Court and jury consider these e-mails as it determines whether Epstein 
exceeded the wide latitude which the law confers on all plaintiffs "to use their best judgment in 
prosecuting ... a lawsuit without fear of having to defend their actions in a subsequent civil action 
for misconduct." Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380, 384 
(Fla. 2007)( quoting from Levin, Middlebrooks, Mabie, Thomas, Mayes Mitchell, P.A. v. United 
States Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994)). 
As explained fully below, Edwards has improperly withheld these undeniably relevant e-
mails from valid discovery requests for more than eight years after having waived any even 
remotely arguable protection that might apply to them. Further, in order to ensure that the e-mails 
would never see the light of day, Edwards concealed their existence by hiding them within a 
deceptively worded 1,607-entry, 159-page privilege log that this Court found was insufficient on 
its face and did not comply with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)5 
and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Despite Edwards' efforts, 
however, the e-mails have been discovered (albeit inadvertently). Lacking any legal justification 
for withholding them in the first place, and having concealed this misconduct through a deceptively 
vague and non-compliant privilege log designed to ensure that the existence of these documents 
would never be detected, Edwards is now left with no choice but to protest wildly wit...

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allegations of "stolen" e-mails hoping that this will distract this Court from its duty to conduct an 
examination of the documents Edwards has so improperly withheld and concealed. 
This Court has repeatedly expressed its intention to maintain a level playing field between 
the parties in order to ensure a fair trial. This Court has correctly recognized that in his malicious 
prosecution cause of action against Epstein, Edwards has an onerous burden to establish a total 
absence of probable cause for Epstein to have commenced and continued his lawsuit. In that 
regard, the elements of a malicious prosecution claim are deliberately onerous. It is the only cause 
of action in Florida that escapes application of the litigation privilege and the absolute immunity 
that privilege affords to plaintiffs and their counsel, so that they may feel free to use their best 
judgment to prosecute their claims without fear of a retaliatory civil lawsuit. Echevarria at 384. 
The heavy burdens built into the elements of malicious prosecution are imposed in lieu of the 
absolute litigation privilege, so that a malicious prosecution claim may not be used as a tool to 
chill putative plaintiffs, such as Epstein, from bringing suit. It is not automatically available to all 
who are able to defend against a lawsuit without a resulting recovery against them. Rather, it is 
only available in those extremely rare instances in which a successful defendant can prove that the 
plaintiff had absolutely no basis to file suit against him in the first place. Thus, in order for 
Edwards to recover against Epstein for filing suit against him, Edwards is put to the substantial 
task of demonstrating that Epstein had no probable cause for filing suit against him. 
Because Edwards must demonstrate a complete absence of probable cause to recover 
against Epstein, all Epstein need show to defeat Edwards' counterclaim is the barest showing of 
probable cause, the standard for which ha...

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he has already established probable cause as a matter of law based upon, among other things: (a) 
undisputed extrinsic evidence of Rothstein' s Ponzi scheme; (b) a third-party lawsuit alleging the 
use of case files from Edwards' client cases against Epstein to support the Ponzi scheme; and ( c) 
the identification of specific litigation misconduct by Edwards that corroborates the third-party 
allegations that the purpose of the litigation misconduct was to enhance the value of those cases to 
more effectively use them to lure investors into the Ponzi scheme. 
Edwards disputes none of the evidence proffered by Epstein and provides no direct 
evidence of Epstein's state of mind. Instead, he asserts that Epstein could not have relied on this 
evidence for probable cause. As support for this assertion, Edwards sets up as the central issues 
in the trial of his counterclaim against Epstein: (a) the strength of his clients' cases against Epstein; 
(b) the lack of any association between Rothstein and either Edwards or Edwards' clients' cases 
against Epstein; and (c) the legitimacy of Edwards' litigation conduct in his clients' cases against 
Epstein. Edwards further claims that he has suffered and continues to suffer damages arising out 
of his "anxiety" from Epstein's complaint that was filed more than eight years ago and dismissed 
six years ago because it: (a) falsely characterized Edwards' cases as "weak"; (b) indicated that 
Edwards knew or should have known of Rothstein's Ponzi scheme; and (c) alleged that Edwards 
engaged in litigation conduct to support the Ponzi scheme. 
This Court has already given Edwards substantial latitude to present to the jury 
circumstantial evidence bearing on Epstein's criminal history, his non-prosecution agreement with 
for belief will be required to justify a reasonable man in bringing a civil rather than a criminal suit.... [T]he 
instigator need not have the same degree of certainty as to the facts, or even t...

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the government, settlements with Edwards' three clients, and the existence and settlement of other 
civil claims against Epstein in order to aid Edwards in disputing specific allegations in Epstein's 
original complaint and positing ulterior motives for Epstein's lawsuit against Edwards. For the 
playing field to be level, if there is evidence regarding Edwards' conduct that has a direct bearing 
on whether Epstein had probable cause to commence or continue the lawsuit, whether Edwards in 
fact incurred any damages as a result of Epstein's lawsuit, or indeed whether Edwards' allegations 
against Epstein are at all credible, it is imperative that such evidence be laid bare before the jury. 
To bring to life this Court's intention to level the playing field in a trial where the law imposes an 
onerous burden on Edwards to recover against Epstein for exercising the right that all plaintiffs 
have to seek legal redress through the courts, this Court must allow the jury to review these e-mails 
and fully evaluate Edwards' misconduct, the true value of his clients' cases and the anxiety 
damages claimed by Edwards to justify recovery against Epstein. 
THIS COURT MUST FIND THAT NO WORK-PRODUCT 
PROTECTION EXISTS OR THAT IT WAS WAIVED 
I. 
Edwards Expressly Waived Work Product Obiections for All but New and Ongoing 
Cases against Epstein 
Edwards expressly, and on multiple occasions, waived work-product protections. In 
negotiating the preparation of the privilege log on February 2, 2011, Farmer Jaffe informed 
Epstein's counsel and the Special Master that it would omit from the log any work product 
objections that related to closed cases: 
All work product materials will be turned over to Plaintiff except for materials 
related to new or ongoing cases, AND on the condition that they be produced "For 
Attorneys' Eyes Only. 
(Exhibit B.) Farmer Jaffe told the Special Master he would then only need to review and make 
privilege determinations as to work ...

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Farmer Jaffe confirmed this agreement more than once: 
[February 9, 2011] "We also have 2 more boxes that contain work product 
materials what we will tum over subject to the agreement that Plaintiff will not 
assert any privilege has been waived by turning them over now, and further subject 
to the agreement that they be produced 'For Attorneys' Eyes Only."' (Exhibit C.) 
[February 16, 2011] Farmer: "Do you still want to do the attorney's eyes only? Do 
you want to speed it up or not? You'll get work-product stuff if you agree to the 
attorney's-eyes only." Epstein's counsel confirmed their agreement. (Exhibit D.) 
This representation was significant. At the time Farmer Jaffe made this representation to 
Epstein, the three cases Edwards had been litigating against Epstein while he was Rothstein's 
partner at Rothstein Rosenfeldt & Adler ("RRA") had long been settled (in July 2010). Thus, 
based on Farmer Jaffe's representation, Edwards was supposed to have produced all e-mails 
reflecting work product pertaining to the three closed Epstein cases because they did not pertain 
to "new or ongoing cases." While at the time of the production Edwards had other clients who 
had claims against Epstein, those, too, have now long been settled7, and none of those claims 
remain pending against Epstein. 
Although Edwards did, in fact, produce documents as "attorneys' eyes only" in February 
2011, it has now come to light that Edwards only produced select items, and specifically withheld 
inculpatory e-mails pertaining to his closed cases against Epstein, despite Edwards' agreement not 
to withhold work product pertaining to the closed cases. 8 To the extent that the 4 7 e-mails 
7Edwards settled his last clients' claims against Epstein in August 2011. 
8To the extent that Edwards claims documents relating to L.M. and E.W. were not produced 
because of some tangential privilege based on the pending Crimes Victims' Rights Act ("CVRA") action 
against the Uni...

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identified for the Court's in camera review relate to actual cases Edwards litigated against Epstein, 
they were closed cases. If work-product protection ever even arguably applied to them, the e-
mails were not then work product from "new or ongoing cases," and should have been included in 
the production to Epstein's counsel that Edwards represented included all work product except for 
"new or ongoing cases." Moreover, because all of Edwards' clients' claims against Epstein have 
now settled, in reliance on Edwards' previous waiver and agreement to produce the same, Epstein 
is asking the Court to compel Edwards to produce all such e-mails withheld based on work product, 
or at least to deem the 4 7 e-mails to have been produced, and unseal them. In view of Edwards' 
waiver regarding work product from closed cases, an in camera review of those e-mails is 
unnecessary and the Court need not make any further determinations. For the additional reasons 
explained below, Epstein also asks that this Court rule the 47 e-mails to be admissible at trial. 
IL 
Work-Product Protection Was Waived by Sharing with Third Parties - as Edwards 
Admittedly Did With Razorback 
Additionally, Edwards' counsel conceded on March 8, 2018, that the e-mails were shared 
with the Conrad, Scherer law firm -- counsel for Razorback. Clearly, Razorback sought their 
production to prove its allegations in the Razorback lawsuit that Rothstein used the three cases 
against Epstein, in part, to lure investors into the Ponzi scheme. If Edwards provided the 
documents that he claims are privileged (both attorney-client and work product) in this case to 
Conrad, Scherer, then Edwards waived those privileges when Edwards produced the e-mails to 
Conrad, Scherer. As a result of that waiver, none of the e-mails were properly withheld by 
Edwards on the basis of attorney-client privilege, and all should now be deemed to have been 
produced, unsealed and ruled admissible at trial. 
8 ...

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III. 
Work-Product Protection Was Waived by Edwards' Issue Iniection 
• 
Anxiety Damages for Being Sued 
• 
"Weak" Cases 
• 
"I Did Nothing Wrong" 
Among other things, the e-mails relate directly to the strength ( or lack thereof) of Edwards' 
now-settled three clients' cases against Epstein, the extent ofRothstein's interaction with Edwards 
as it relates to those cases, and the credibility of Edwards' claims for damages based on "anxiety" 
he claims to have suffered and continues to suffer from Epstein's lawsuit. Repeatedly, Edwards 
has made these central issues in his malicious prosecution counterclaim against Epstein. Because 
the e-mails directly relate to the very issues Edwards injected into his malicious prosecution 
counterclaim, they are critical to a proper evaluation of its merits, and any work-product protection 
that may have applied to them should be deemed to have been waived by reason of Edwards' issue 
injection. 
Both Edwards' and Epstein's counsel are familiar with waiver of work-product protection 
by issue injection, having litigated the issue previously. See Tolz v. Geico General Ins. Co., No. 
08-80663, 2010 WL 384745 (S.D. Fla. Jan. 27, 2010). In Tolz, non-party Searcy Denney argued 
that the "doctrine of waiver by issue injection" did not apply (to attorney-client privilege). Id. at 
*2. After analyzing both the attorney-client privilege and the work-product doctrine, the court 
concluded that the attorney-client privilege had not been waived. Id. at *4. However, the court 
cited federal case law recognizing that the work-product protection "is not inviolate and may be 
invaded when the information contained within the work-product materials is directly at issue." 
Id. ( emphasis added). In Tolz, therefore, the court did exactly what this Court should do - ordered 
an in camera review to determine whether any privilege existed or had been waived by placing the 
information contained in the documents directly at issue i...

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Case law distinguishes between affirmatively injecting an issue rather than simply 
defending one. Home Ins. Co. v. Advance Machine Co., 443 So. 2d 165, 168 (Fla. 1st DCA 
1983) (no waiver in simply bringing or defending an action). Exceptions to the general rule have 
been applied where the party seeking to avoid discovery has injected into the litigation issues going 
to the very heart of the litigation. Id., citing Hearn v. Rhay, 68 F.R.D. 574 (E.D. Wash. 
1975); Pitney-Bowes, Inc. v. Mestre, 86 F.R.D. 444 (S.D. Fla. 1980). 
Here, unlike in Tolz, Edwards has repeatedly injected issues into this litigation in an attempt 
to satisfy Edwards' burden to establish Epstein's lack of probable cause, which goes to the very 
heart of Edwards' malicious prosecution cause of action. Edwards has therefore waived anywork-
product protection of evidence relevant to these issues. The case for waiver by issue injection is 
even stronger because the content of the e-mails in question reflects admissions by Edwards and 
his co-counsel as to the very issues Edwards has injected in this case, the evidence of which is 
simply unavailable through any other means. 
IV. 
Edwards' Deceptive Concealment of the 47 E-mails on a Legally Deficient Privilege Log 
in Violation of Florida Rules of Civil Procedure, Binding Precedent and the Express 
Orders of this Court is a Further Waiver 
Edwards' waiver is further mandated by his deliberate concealment of the e-mails in 
question on a 159-page privilege log that was determined by this Court on May 7, 2012 to be 
legally deficient on its face and to have utterly failed to comply with the legal requirements of 
Florida Rule of Civil Procedure 1.280(b)(5) and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 
4th DCA 2001). (Exhibit F.) It was through this device that Edwards prevented the e-mails from 
ever seeing the light of day despite Edwards' misrepresentations to Epstein's counsel that all e-
mails qualifying as work pro...

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counterclaim against Epstein based on the very issues directly refuted by e-mails Edwards 
concealed from existence. Edwards should not be rewarded for such unethical gamesmanship. 
The TIG court denied a petition for a writ of certiorari seeking review of an order requiring 
TIG to produce documents for which objections on the basis of attorney-client and work-product 
privileges were made. The Fourth District Court of Appeal noted that Florida Rule of Civil 
Procedure 1.280(b)(5) [now (6)] is identical to its federal counterpart, Federal Rule of Civil 
Procedure 26(b)(5), whose Advisory Committee Notes state that: "To withhold materials without 
such notice is contrary to the rule, subjects the party to sanctions under rule 37(b)(2) and may be 
viewed as a waiver of the privilege or protection." TIG at 340. The TIG court further observed 
that Local Rule 26.l(G)(3)(b) of the United States District Court for the Southern District of 
Florida spelled out the requirements for a valid privilege log: 
Where a claim of privilege is asserted in objecting to any interrogatory or document 
demand, or sub-part thereof, and an answer is not provided on the basis of such 
assertion: 
(i) The attorney asserting the privilege shall in the objection to the interrogatory or 
document demand, or sub-part thereof, identify the nature of the privilege 
(including work product) which is being claimed and if the privilege is being 
asserted in connection with a claim or defense governed by state law, indicate the 
state's privilege rule being invoked; and 
(ii) The following information shall be provided in the objection, unless divulgence 
of such information would cause disclosure of the allegedly privileged information: 
(A) For documents: (1) the type of document; (2) general subject matter of the 
document; (3) the date of the document; (4) such other information as is sufficient 
to identify the document for a subpoena duces tecum, including, where appropria...

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... also describe the document's subject matter, purpose for its production, and a 
specific explanation of why the document is privileged or immune from discovery. 
These categories, especially this last category, must be sufficiently detailed to allow 
the court to determine whether the discovery opponent has discharged its burden of 
establishing the requirements expounded upon in the foregoing discussion. 
Accordingly, descriptions such as "letter re claim," "analysis of claim," or "report 
in anticipation of litigation"-with which we have grown all too familiar-will be 
insufficient. This may be burdensome, but it will provide a more accurate 
evaluation of a discovery opponent's claims and takes into consideration the fact 
that there are no presumptions operating in the discovery opponent's favor. Any 
failure to comply with these directions will result in a finding that the plaintiff-
discovery opponents have failed to meet their burden to establish the applicability 
of the privilege. 
Id. at *3 ( citations omitted). 
Simply put, a privilege log must be sufficient on its face to allow the reviewer to understand 
enough to determine whether a privilege claim should be challenged. 
On August 17, 2012, the Court vacated the May 7, 2012, Order, but did not relieve Edwards 
of the requirement to provide a new fully compliant privilege log. In fact, the Court's August 17, 
2012, Order provides, in pertinent part: 
EDWARDS shall file a written response specifically addressing the production 
sought in Paragraph 13 of EPSTEIN's Motion to Compel and Amend Protective 
Order of March 9, 2012 as Ordered in this Court's April 10, 2012 Order. The 
response shall identify non-privileged responsive documents previously produced, 
shall be accompanied by all non-privileged responsive documents not previously 
produced, if any and shall identify, in a proper privilege log as referenced in 
this Court's May 7, 2012 Order, responsive documents withheld fro...

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wholly deficient. It misstates objections, improperly identifies or altogether excludes the required 
identities of the document authors and recipients, and its document descriptions are deceptively 
vague and misrepresent the true nature of the documents listed on the privilege log. Had Edwards 
ever provided a legally sufficient privilege log, Epstein would have been afforded the opportunity 
to identify as early as February 23, 2011, the improper assertions of attorney-client privilege, 
work-product protection and irrelevancy made by Edwards with respect to the 47 e-mails. 
Because the e-mails are under seal, Epstein cannot specifically address the content of each to 
demonstrate how Edwards was able to conceal them through his legally deficient and non-
compliant privilege log. However, the following few examples of the numerous defects in the 
privilege log will enable this Court to readily confirm the complete deficiency of Edwards' invalid 
privilege log, both generally and particularly as it relates to the 47 e-mails in question9: 
• 
Individuals who were copied either by cc or bee on e-mails were not 
identified on the privilege log. Throughout the privilege log, Edwards also 
generally referred to the sender or recipients of the e-mails using unlawful 
group descriptions such as "Attorneys at RRA," or "RRA Staff," or 
identified them as "Confidential Sources" without any basis in law for such 
identification. In fact, 189 entries refer to a "Confidential Source" to which 
a work product objection was asserted. 10 Such vague identification made it 
possible to conceal from Epstein the highly relevant fact that Rothstein was 
either the author or a recipient of the e-mails in question. 
• 
Edwards provided wholly insufficient document descriptions on his 
privilege log. For example, 394 entries included the document description 
"Litigation Strategy." Many of these are included in the 47 e-mails for the 
Court's review (e.g., Appendix #...

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Bates 
1527 
Bates 
04403-
04416 
Date 
To 
From 
Description 
Objection 
04/27/2009 
Marc 
Bradley 
New Victim 
W /P; Attorney Client 
Nurik 
Edwards 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights. 
• 
Edwards objected to 938 entries on the privilege log on the basis of the 
documents being "irrelevant & not reasonably calculated to lead to the 
discovery of admissible evidence." The 47 e-mails Epstein asks this Court 
to review in camera are highly relevant and do lead to the discovery of 
admissible evidence and the Court's review alone of this limited number of 
documents will confirm that. In fact, by just getting a flavor of the e-mails, 
this Court already determined them to be detrimental to Edwards' 
counterclaim and beneficial to Epstein's defense of the same. 
The 
following is but one example of how the document shown to the Court at 
the March 8, 2018, hearing (Appendix #I/Trial Exhibit 13-67) is portrayed: 
Date 
To 
From 
Description 
Objection 
10/17/09 
Paul 
Bradley 
Punitive Damages 
W /P; Attorney Client Privilege; 
Cassell 
Edwards 
irrelevant and not reasonably 
calculated to lead to the 
discovery of admissible 
evidence; protected by privacy 
rights 
• 
Edwards objected to 994 entries on the basis of "work product" and 
"attorney-client" privilege, however, only 19 of those entries were with a 
client. As set forth above, Edwards' "work product" objections throughout 
the privilege log, if even remotely applicable, were waived by reason of 
Farmer Jaffe's express agreement to produce work product documents for 
claims that were no longer pending, the prior production of the same 
documents to Razorback's counsel or Edwards' issue injection. In addition, 
the failure to identify the client as an author or recipient of the document, 
coupled with a vague and misleading document description ensures that no 
specific claim of attorney-clien...

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to the 4 7 e-mails, unseal that evidence, deem it to have been produced to Epstein and rule it 
admissible at trial. 
NO ATTORNEY-CLIENT PRIVILEGE EXISTS 
Despite Edwards' and Paul Cassell's (counsel for the intervenors) protestations to the 
contrary, the 47 e-mails are not attorney-client privileged communications between Edwards (or 
any other co-counsel) and his three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of 
the documents are e-mails among attorneys and staff within RRA, with Mr. Cassell, and with 
media sources and do not qualify for that protection as codified in section 90.502 of the Florida 
Statutes. 
Under Florida's Evidence Code, "[a] client has a privilege to refuse to disclose, and to 
prevent any other person from disclosing, the contents of confidential communications when such 
other person learned of the communications because they were made in the rendition of legal 
services to the client."§ 90.502(2), Fla. Stat. (2017). A communication between lawyer and client 
is "confidential" if it is not intended to be disclosed to third persons other than: 
1. Those to whom disclosure is in furtherance of the rendition oflegal services 
to the client. 
2. Those reasonably necessary for the transmission of the communication. 
Las Glas River House Condo. Ass'n, Inc. v. Lorh, LLC, 181 So. 3d 556, 557-58 (Fla. 4th DCA 
2015); § 90.502(1)(c), Fla. Stat. (2017). The second exception applies to agents of the client-for 
example, when a family member acts on behalf of an incapacitated relative, Witte v. Witte, 126 So. 
3d 1076 (Fla. 4th DCA 2012), or when a messenger is needed for a client to contact 
counsel, Gerheiser v. Stephens, 712 So. 2d 1252 (Fla. 4th DCA 1998). Nothing in the description 
of the 4 7 e-mails, including the identification of the sender or recipients of the same, or the 
description of the e-mails themselves, provides any basis to conclude that the documents constitute 
or reflect attorney-client com...

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Furthermore, the attorney-client privilege may be disregarded under certain circumstances. 
For instance, the privilege may be disregarded where client permission was granted to disclose a 
privileged communication to an adverse third party, as was apparently true in the case of Edwards' 
disclosure of the e-mails to Conrad, Scherer, or as was also true in the case of Edwards' disclosure 
of attorney-client communications with L.M. and E.W. in filings in the CVRA action. 
Additionally, there is no privilege for an attorney-client communication if the lawyers' services 
were "sought or obtained to enable or aid anyone to commit or plan to commit what the client 
knew was a crime or fraud."§ 90.502(4)(a), Fla. Stat. This is known as the "crime fraud" exception 
to the privilege. See Douberley v. Perlmutter, 219 So. 3d 854 (Fla. 4th DCA 2017). 
Thus, several bases to challenge Edwards' assertion of the attorney-client privilege were 
available to Epstein had there been a legally compliant and adequate description in the privilege 
log of any document as to which Edwards asserted that privilege. This Court's in camera review 
of the 47 e-mails will confirm that no attorney-client privilege applies. Moreover, in the event that 
this Court isolates an e-mail to which the attorney-client privilege might conceivably apply, it may 
consider Edwards' refusal to provide a privilege log in which that e-mail was sufficiently identified 
in a manner that complies with Florida Rules of Civil Procedure and the binding precedent of the 
TIG case. As confirmed in TIG, Edwards' refusal to provide a TJG-compliant identification may 
be viewed as a waiver, either as a concession by Edwards that no valid attorney-client privilege 
ever existed with respect to that e-mail or that, if it ever did, it was waived, including under any of 
the circumstances described above. 
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IN CAMERA REVIEW IS MANDATED BY LAW, WAS AGREED TO BY THE 
PARTIES AND IS APPROPRIATE UNDER THE CIRCUMSTANCES 
No court or special master has ever determined the relevancy, privilege or waiver of thee-
mails identified on Edwards' privilege log, but it is well within this Court's jurisdiction to do so 
now. Indeed, if a party seeks to compel the disclosure of documents that the opposing party claims 
are protected by attorney-client privilege and/or work-product protection, a trial court's 
in camera review of the documents prior to disclosure is required by law. Bennett v. Berges, 84 
So. 3d 373, 375 (Fla. 4th DCA 2012); Old Holdings, Ltd. v. Taplin, Howard, Shaw & Miller, 
P.A., 584 So. 2d 1128, 1128-29 (Fla. 4th DCA 1991) (finding that where documents may be 
protected by both the attorney-client privilege and the work-product doctrine, the petitioners are 
entitled to an in camera review of the documents by the trial court prior to disclosure). 
Moreover, Edwards has already agreed to an in camera review: 
... we're not attempting to hide anything. You want to conduct an in-camera 
inspection, we want you to conduct an in-camera inspection because it will confirm 
that we're not attempting to hide anything. 
(3/8/18, Aft. Tr. (Scarola), p. 15.) (Excerpt, Exhibit J.) Epstein now expressly moves for the 
Court to conduct that review limited to the 47 e-mails. 
This entitlement to in camera inspection of materials claimed to be privileged is a two-
way street and a right that either party is entitled to under Florida law. See Zanardi v. Zanardi, 64 7 
So. 2d 298 (Fla. 3d DCA 1994)(petition for writ of certiorari granted when trial court denied 
motion to copy computer diskettes on basis of attorney-client privilege and trial court did not 
determine in camera whether assertion of the privilege was valid). This reciprocal approach is fair 
and logical because without the review, the party objecting to disclosure of potentially privileged 
materi...

NOT A CERTIFIED COPY
go[es] to the heart of their case such that no other documents can be substituted for those remaining 
in respondent's custody." See Acevedo v. Doctors Hosp., Inc., 68 So. 3d 949, 951 (Fla. 3d DCA 
2011 )( certiorari granted because denial of in camera review was departure from essential 
requirements of law and irreparable harm demonstrated by showing information critical to case 
would not be known or available to appellate court for review otherwise). Here, both parties seek 
in camera review, but for different reasons. Edwards claims he has "nothing to hide" and seeks 
review to confirm this. Epstein believes these e-mails go to the heart of this case, his probable 
cause for bringing the original civil proceeding and continuing it, as well as and Edwards' absence 
of damages and complete lack of credibility. 
Additional equitable considerations make in camera review even more appropriate. The 
Court has already recognized that some of the documents were detrimental to Edwards' 
counterclaim and beneficial to Epstein's defense of the same: 
And I understand what you're going to tell me because I've gotten a flavor for some 
of these documents that have been provided. . .. And that is that they are detrimental 
to the position taken by Mr. Edwards and that they are helpful to the position taken 
by Mr. Epstein. 
(3/8/18, Aft. Tr. 51 :23-52:5) (Excerpt Exhibit J). Without these 4 7 e-mails, Edwards will gain an 
unfair advantage in satisfying his heavy burden to establish the complete absence of probable cause 
for Epstein to have filed suit. Epstein will be denied his right to present crucial evidence that goes 
to the very heart of the reasons for Epstein's lawsuit against Edwards, as well as the veracity of 
Edwards' disingenuous claims that Epstein lacked probable cause to sue Edwards, and the false 
claim by Edwards that he was damaged as a result of this lawsuit. It will tilt the playing field 
heavily against Epstein, who is to be given...

NOT A CERTIFIED COPY
therefore necessary to confirm the relevance and admissibility of the 47 e-mails and ensure a fair 
trial. 
The Binger issue previously raised by the Court as a potential basis to deny an in camera 
review is inapplicable here, where the e-mails were primarily authored or received by Edwards, 
and/or in Edwards' possession since 2009. Based on this, Edwards - an officer of the court, who 
took an oath to "never seek to mislead the judge or jury by any artifice or false statement of fact" 
- can certainly not claim "surprise." 11 
Only when all relevant facts regarding misconduct by Rothstein, Edwards and his co-
counsel "are before the judge and jury can the 'search for truth and justice' be accomplished." 
Katzman v. Rediron Fabrication, Inc., 76 So. 3d 1060, 1063 (Fla. 4th DCA 2011); Loureiro v. 
State, 133 So. 3d 948, 956 (Fla. 4th DCA 2013)("A trial must be a search for the truth."). Here, 
the relevant facts exist in case-ending e-mails that go to the very heart of Epstein's probable cause, 
Edwards' lack of damages for Epstein's lawsuit against Edwards, and Edwards' credibility at issue 
in this action. Accordingly, this Court is equipped by the controlling law and equitable principles 
to perform the now substantially narrowed request for an in camera review of the sealed 47 e-
mails, and to confirm the critically relevant nature of these e-mails and the absence or waiver of 
any attorney-client privilege or work-product protection for the same. 
THE JURISDICTION OF THE BANKRUPTCY COURT 
IS NOT AN ISSUE BEFORE THIS COURT 
What is not before this Court and therefore not an issue upon which Edwards should be 
permitted to rely in seeking to prevent this Court's in camera review is the issue pertaining to the 
11Oath 
of 
Admission 
to 
The 
Florida 
Bar, 
https:/lwebprod.floridabar.org/wp-
content/uploads/2017 /04/oath-of-admission-to-the-florida-bar-ada.pd[ 
19 

NOT A CERTIFIED COPY
chain of custody and possession of the 47 e-mails before Link & Rockenbach appeared in this 
case. 
At Edwards' election, upon motion filed by him, Farmer Jaffe, and the intervenors, that 
issue is now being addressed in the Bankruptcy Court. 12 The Bankruptcy Court will determine if 
there has been a violation of one of its orders and, if necessary, the appropriate relief. That review, 
however, has nothing to do with this Court's jurisdiction and duty to conduct an in camera 
inspection to determine the relevance, absence or waiver of attorney-client privilege and work-
product protection, and admissibility with respect to the 47 e-mails. How the Fowler White firm 
obtained the disc from where the 47 e-mails originated is something which Edwards has decided 
that the Bankruptcy Court should sort out. Epstein agrees that the Bankruptcy Court is the proper 
forum for that inquiry. Clearly, neither the Fowler White firm nor Epstein ever used the alleged 
privileged documents, otherwise, this case would have ended long ago. Furthermore, it has already 
been established how Link & Rockenbach obtained the disc, and this Court found all of Link & 
Rockenbach's conduct once it discovered the information on the disc to be entirely proper. 
CONCLUSION 
Epstein, joined previously by Edwards, is simply asking the Court to review in camera the 
47 e-mails to confirm that the attorney-client privilege is wholly inapplicable to all of them. As for 
work-product protection, to the extent that it ever applied to the 47 e-mails, this Court's in camera 
review will confirm that Edwards expressly waived it in February 2011 and he should be 
compelled to produce those documents now, or such documents should be deemed to have been 
produced by him. Epstein further asks this Court to conduct an in camera review of the 47 e-mails 
12 During the appellate stay, Edwards, on behalf of Farmer Jaffe, filed a Motion for Issuance of an 
Order to Show Cause in the Bankruptcy...

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to confirm that they are relevant and admissible and that Epstein should be allowed to present the 
e-mails to the jury in order to ensure a fair trial of this matter. 
Finally, Epstein requests that he be allowed to conduct limited discovery of Edwards and 
Farmer Jaffe to determine why former work product documents were not produced, contrary to the 
parties' agreement, and who authored the deceptive and misleading privilege log descriptions. 
CERTIFICATE OF SERVICE 
I certify that the foregoing document has been furnished to the attorneys listed on the 
Service List below on April 4, 2018, through the Court's e-filing portal pursuant to Florida Rule 
of Judicial Administration 2.516(b )(1 ). 
LINK & ROCKENBACH, PA 
1555 Palm Beach Lakes Boulevard, Suite 301 
West Palm Beach, Florida 33401 
(561) 727-3600; (561) 727-3601 [fax] 
By: Isl Scott J. Link 
Scott J. Link (FBN 602991) 
Kara Berard Rockenbach (FBN 44903) 
Rachel J. Glasser (FBN 577251) 
Primary: Scott@linkrocklaw.com 
Primary: Kara@linkrocklaw.com 
Primary: Rachel@linkrocklaw.com 
Secondary: Tina@linkrocklaw.com 
Secondary: Troy@linkrocklaw.com 
Secondary: Eservice@linkrocklaw.com 
Trial Counsel for Plaintiff/Counter-Defendant 
Jeffrey Epstein 
21 

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SERVICE LIST 
Jack Scarola 
Karen E. Terry 
David P. Vitale, Jr. 
Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, FL 33409 
mep@searcylaw.com 
jsx@searcylaw.com 
dvitale@searcylaw.com 
scarolateam@searcylaw.com 
terryteam@searcylaw.com 
Co-Counsel for Defendant/Counter-Plaintiff 
Bradley J. Edwards 
Bradley J. Edwards 
Edwards Pottinger LLC 
425 N. Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301-3268 
brad@epllc.com 
Co-Counsel for Defendant/Counter-Plaintiff 
Bradley J. Edwards 
Jack A. Goldberger 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian A venue S., Suite 1400 
West Palm Beach, FL 33401 
j goldberger@agwpa.com 
smahoney@agwpa.com 
Co-Counsel for Plaintiff/Counter-Defendant 
Jeffrey Epstein 
22 
Philip M. Burlington 
Nichole J. Segal 
Burlington & Rockenbach, P.A. 
Courthouse Commons, Suite 350 
444 West Railroad A venue 
West Palm Beach, FL 33401 
pmb@FLAppellateLaw.com 
njs@FLAppellateLaw.com 
kbt@FLAppellateLaw.com 
Co-Counsel for Defendant/Counter-Plaintiff 
Bradley J. Edwards 
Marc S. Nurik 
Law Offices of Marc S. Nurik 
One E. Broward Boulevard, Suite 700 
Ft. Lauderdale, FL 33301 
marc@nuriklaw.com 
Counsel for Defendant Scott Rothstein 
Paul Cassell 
383 S. University 
Salt Lake City, UT 84112-0730 
cassellp@law. utah. edu 
Limited Intervenor Co-Counsel for L.M, E.W. 
and Jane Doe 
Jay Howell 
Jay Howell & Associates 
644 Cesery Blvd., Suite 250 
Jacksonville, FL 32211 
jayhowell.com 
Limited Intervenor Co-Counsel for L.M, E.W. 
and Jane Doe 

NOT A CERTIFIED COPY
Ex. 
A 
B 
C 
D 
E 
F 
G 
H 
I 
J 
K 
L 
M 
INDEX OF EXHIBITS TO EPSTEIN'S SUPPLEMENT TO MOTION 
FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED 
NATURE OF DOCUMENTS, ETC. 
Date 
Document 
N/D 
List of 47 e-mails identified on Epstein's 3/5/18 Clerk's Trial Exhibit 
List that Epstein seeks an in camera review of compared to Edwards' 
2/23/11 Privilege Log 
2/2/11 
Email from Farmer Jaffe 
2/9/11 
Email from Farmer Jaffe 
2/16/11 
Transcript Excerpt of Meeting with Special Master 
N/D 
Docket Excerpt -Jane Doe v. United States, S.D. Fla. Case No. 9:08-
CV-80736-KAM (CVRA Action) 
5/7/12 
Order on Epstein's Motion to Compel Production of Documents from 
Edwards and for Sanctions 
8/17 /12 
Order on Outstanding Discovery Motions 
2/23/11 
Farmer Jaffe's Privilege Log 
N/D 
List of 85 e-mails Edwards produced in May 2012 that are contained 
on his Privilege Log and that Epstein identified on his November 2017 
Exhibit List 
3/8/18 
Hearing Transcript-Afternoon Session Excerpts: pp. 1-2, 15, 51-52 
3/19/18 
Farmer Jaffe's Motion for Issuance of an Order to Show Cause Why 
Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of 
Court, to Permit Discovery, to Assess Sanctions and Costs, and for 
Other Appropriate Relief (without exhibits) rBR D.E. 63231 
3/20/18 
Bradley Edwards' J oinder in Motion for Issuance of an Order to Show 
Cause rBR D.E. 63251 
3/30/18 
L.M., E.W. and Jane Doe's Joinder in Motion for Order to Show Cause 
and Motion for Discovery, to Assess Sanctions and Costs for Other 
Appropriate Relief rD.E. 63451 

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EXHIBIT A 

NOT A CERTIFIED COPY
EXHIBIT A 
47 DOCUMENTS FROM EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT 
LIST THAT EPSTEIN IS SEEKING AN IN CAMERA REVIEW OF COMPARED TO 
EDWARDS' PRIVILEGE LOG 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-1 
4/9/09 
E-mail chain - from Bradley J. Edwards to Russell Adler 
p. 123 
3:50 p.m. 
(02645) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02633-
5/1/09 
Paul Cassell 
Bradley 
Response to 
Work product; 
02646 
Edwards 
Motion to 
attorney/client privilege; 
Consolidate + 
irrelevant and not reasonably 
Cassell strategy 
calculated to lead to the 
Memo for Jay 
discovery of the admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-4 
4/26/09 
E-mail chain - from Russell Adler to Bradley Edwards 
p.43 
7:35 p.m. 
(00149) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
00149 
4/26/09 
Bradley 
Russell Adler 
Litigation 
Work Product; attorney 
Edwards 
Strategy 
client privilege; irrelevant & 
[not] reasonably calculated 
to lead to the discovery of 
admissible evidence; 
protected by privacy rights 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-5 
4/27/09 
E-mail chain - from Bradley Edwards to Marc Nurik 
p.81 
2:16 p.m. 
(01527) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01527 
4/27/09 
Marc Nurik 
Bradley 
New Victim 
W/P; Attorney Client 
Edwards 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-6 
4/28/09 
E-mail chain - from Bradley Edwards to Katherine Ezell 
p.22 
6:17 p.m. 
(4493-4495) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04491-
4/8/09 
Bradley 
Jack Scarola 
Epstein- Tel. 
Joint W/P Priv. 
04518 
Edwards 
Conf. 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-7 
5/1/09 
E-mail chain - from Rob to Bradley Edwards (00014) 
p.32 
5:23 p.m. 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
00014 
5/1/09 
Bradley 
Rob Buschel 
Litigation 
Work Product; attorney client 
Edwards 
Strategy 
privilege; irrelevant & [not] 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
2 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-11 
5/28/09 
E-mail chain - from William Berger to Bradley Edwards 
p.39 
5:45 p.m. 
(00090) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
00090 
5/28/09 
Bradley 
William 
Litigation 
Work Product; attorney client 
Edwards 
Berger 
Strategy 
privilege; irrelevant & [not] 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-13 
6/3/09 
E-mail chain - from Paul Cassell to Bradley Edwards 
p.42 
11:47 a.m. 
(00133) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
00133 
6/23/09 
Bradley 
Paul Cassell 
Litigation 
Work Product; attorney 
Edwards 
Strategy 
client privilege; irrelevant & 
[not] reasonably calculated 
to lead to the discovery of 
admissible evidence; 
protected by privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-15 
6/3/09 
E-mail chain - from Wayne Black to Bradley Edwards 
p. 149 
6:24 p.m. 
(08006) 
3 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08006-
6/3/09 
Bradley 
Wayne Black 
Getting 
Work product; 
08011 
Edwards 
addresses for 
attorney/client privilege; 
people for us to 
irrelevant and not reasonably 
serve subpoenas 
calculated to lead to the 
discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-17 
7/13/09 
E-mail chain - from Paul Cassell to Bradley Edwards 
p.33 
2:13 p.m. 
(00026) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
00025-
5/1/09 
Bradley 
Paul Cassell 
Litigation 
Work Product; attorney client 
00029 
Edwards 
Strategy 
privilege; irrelevant & [not] 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-19 
7/14/09 
E-mail chain - from Bradley Edwards to William Berger 
p. 155 
2:06 p.m. 
(01004) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01003-
10/12/ 
Bradley 
Paul Cassell 
Asset movement 
Work product; 
01005 
09 
Edwards 
by Jeffrey Epstein 
attorney/client privilege; 
irrelevant and not reasonably 
calculated to lead to the 
discovery of admissible 
evidence; protected by 
privacy rights 
4 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-25 
8/3/09 
E-mail chain - from Beth to Carl Linder (12289) 
p.29 
11:17 a.m. 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
12281-
7/30/09 
Carl Linder 
Bradley 
Litigation 
Work product; attorney 
12291 
Edwards 
Strategy 
client privilege; irrelevant & 
[not] reasonably calculated 
to lead to the discovery of 
admissible evidence; 
protected by privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-30 
8/11/09 
E-mail chain - from Marc Nurik to Scott Rothstein 
p. 150 
9:26 p.m. 
(26481) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
I 
From 
Description 
Objection 
26479-
8/19/09 Attorneys at 
Ken Jenne 
Assistance on the 
Work product; 
26481 
RRA 
Epstein Case 
attorney/client privilege; 
irrelevant and not reasonably 
calculated to lead to the 
discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-34 
8/13/09 
E-mail chain - from Marc Nurik to Scott Rothstein 
p. 150 
4:51 p.m. 
(26480) 
5 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26479-
8/19/09 
Attorneys at 
Ken Jenne 
Assistance on the 
Work product; 
26481 
RRA 
Epstein Case 
attorney/client privilege; 
irrelevant and not reasonably 
calculated to lead to the 
discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-35 
8/13/09 
E-mail chain - from Russell Adler to Scott Rothstein 
p. 86 
5:31 p.m. 
(26356) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26356 
8/13/09 
Scott 
Russell Adler 
Legal Research 
W/P; Attorney Client 
Rothstein 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-36 
8/13/09 
E-mail chain - from Marc Nurik to Scott Rothstein 
p. 150 
6:02 p.m. 
(26570) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26570 
8/13/09 
Scott 
Marc Nurik 
Discussions 
Work product; 
Rothstein 
about Epstein 
attorney/client privilege; 
irrelevant and not reasonably 
calculated to lead to the 
discovery of the admissible 
evidence; protected by 
privacy rights 
6 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-44 
9/4/09 
E-mail chain - from Bradley Edwards to Spencer Kuvin 
p. 17 
6:59 p.m. 
(03731-03732) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
03719-
9/4/09 
Bradley J. 
Spencer 
CMA- depo 
Joint-privilege 
03736 
Edwards 
Kuvin 
notices attached. 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-45 
9/10/09 
E-mail chain - from Bradley Edwards to red rum 
p.46 
9:48 a.m. 
( 06406-06408) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06404-
9/10/09 
Bradley 
Pat Diaz 
NR Interview 
Attorney/Client privilege 
06408 
Edwards 
and/or work product 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-46 
9/11/09 
E-mail chain - from Bradley Edwards to Mike Fisten 
p.84 
6:06 p.m. 
(01686) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01686 
9/11/09 
Mike Fisten 
Bradley 
Potential new 
W/P; Attorney Client 
Edwards 
witnesses 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of 
admissible evidence; 
protected by privacy rights 
7 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-47 
9/17/09 
E-mail chain - from Bradley Edwards to Dana Peterson 
p.57 
8:35 a.m. 
(11123 - 11125) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
11123-
9/17/09 
Confidential 
Bradley 
Additional 
W/P Privilege; Not 
11136 
Source 
Edwards 
Information RE: 
reasonably calculated to lead 
Epstein 
to discovery of admissible 
Molestations 
evidence 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-49 
9/19/09 
E-mail chain - from Bradley Edwards to Dana Peterson 
p.57 
7:54 a.m. 
(11126-11127) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
11123-
9/17/09 
Confidential 
Bradley 
Additional 
W/P Privilege; Not 
11136 
Source 
Edwards 
Information RE: 
reasonably calculated to lead 
Epstein 
to discovery of admissible 
Molestations 
evidence 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-52 
9/30/09 
E-mail chain - from Robin T. Kempner to All Staff 
p.46 
3:35 p.m. 
(25925) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
25925 
9/30/09 
All Staff 
Robin T. 
Conflict check 
Attorney/Client privilege 
Kempner 
and/or work product 
8 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-53 
9/30/09 
E-mail chain - from Robin T. Kempner to All Staff 
p.46 
3:51 p.m. 
(25874) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
25874 
9/30/09 All Staff 
Robin T. 
Additional name 
Attorney/Client privilege 
Kempner 
added to conflict 
and/or work product 
check 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-56 
10/5/09 
E-mail chain - from Bradley Edwards to William Berger 
p.114 
7:16 a.m. 
(11145) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
11143-
10/4/09 
William 
Bradley 
11/28 Discovery 
Work product; 
11146 
Berger 
Edwards 
Cutoff 
attorney/client privilege; 
irrelevant and not reasonably 
calculated to lead to the 
discovery of the admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-60 
10/14/09 
E-mail chain - from Bradley Edwards to Paul Cassel 
p.95 
7:36 a.m. 
(03191-03192) 
9 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
03191-
10/14/0 
Paul Cassell 
Bradley 
Litigation 
W/P; Attorney Client 
03196 
9 
Edwards 
Strategy 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-66 
10/17/09 
E-mail chain - from Bradley Edwards to Paul Cassell 
p.64 
1:00 p.m. 
(04398-04402) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04387-
8/19/09 
Paul Cassell 
Bradley 
Victim 
W/P; Attorney Client 
04402 
Edwards 
Complaints, 
Privilege; Irrelevant and not 
Forensic 
reasonably calculated to lead 
accountants, & 
to the discovery of admissible 
Epstein's 
evidence; protected by 
Fraudulent 
privacy rights 
Transfers 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-67 
10/17/09 
E-mail chain - from Bradley Edwards to Paul Cassell 
p.64 
1:58 p.m. 
(04408-04412) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04403-
10/17/09 
Paul Cassell 
Bradley 
Punitive 
W/P; Attorney Client 
04416 
Edwards 
Damages 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
10 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-86 
10/23/09 
E-mail chain - from Matthew Weissing to Mark Fistos, 
p. 73 
11:37 a.m. 
Russell Adler, Bradley Edwards, Scott Rothstein and 
Steven Jaffe (26747) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
I 
To 
From 
Description 
Objection 
26741-
10/23/09 
Attorneys 
Bradley 
Legal Research 
W/P; Attorney Client 
26763 
at RRA 
Edwards 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-88 
10/23/09 
E-mail chain - from Matthew Weissing to Mark Fistos 
p. 73 
12:11 p.m. 
and Bradley Edwards (08042-08044) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08033-
10/23/09 
Attorneys 
Mike Fistos 
Legal Research 
W/P; Attorney Client Privilege; 
08070 
at RRA 
RE: Causes of 
Irrelevant and not reasonably 
action against 
calculated to lead to the 
Epstein 
discovery of admissible 
evidence; protected by privacy 
rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-89 
10/23/09 
E-mail chain - from Bradley J. Edwards to Scott 
p. 73 
12:12 p.m. 
Rothstein, Steven Jaffe and Mark Fistos (26741-26742) 
11 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26741-
10/23/09 Attorneys 
Bradley 
Legal Research 
W/P; Attorney Client 
26763 
at RRA 
Edwards 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-90 
10/23/09 
E-mail chain - from Bradley Edwards to Matthew 
p. 73 
12:16 p.m. 
Weissing (08059-08061) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08033-
10/23/09 
Attorneys 
Mike Fistos 
Legal Research 
W/P; Attorney Client 
08070 
at RRA 
RE: Causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-93 
10/23/09 
E-mail chain - from Bradley Edwards to Scott Rothstein, 
p. 73 
12:27 p.m. 
Steven Jaffe and Mark Fistos (26756-26758) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26741-
10/23/09 
Attorneys 
Bradley 
Legal Research 
W/P; Attorney Client 
26763 
at RRA 
Edwards 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
12 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-94 
10/23/09 
E-mail chain - from Bradley Edwards to Mark Fistos 
p. 73 
12:36 p.m. 
(08036-08038) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08033-
10/23/09 Attorneys 
Mike Fistos 
Legal Research 
W/P; Attorney Client 
08070 
at RRA 
RE: Causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-97 
10/23/09 
E-mail chain - Bradley J. Edwards to Russell Adler, Scott 
p. 73 
1:26 p.m. 
Rothstein and Mark Fistos (26762) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26741-
10/23/09 Attorneys 
Bradley 
Legal Research 
W/P; Attorney Client Privilege; 
26763 
at RRA 
Edwards 
RE: causes of 
Irrelevant and not reasonably 
action against 
calculated to lead to the 
Epstein 
discovery of admissible 
evidence; protected by privacy 
rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-98 
10/23/09 
E-mail chain - from Matthew Weissing to Bradley 
p. 77 
1:31 p.m. 
Edwards, Russell Adler, Mark Fistos and Steven Jaffe 
(01117) 
13 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01112-
5/12/09 
Bradley 
William 
Dr. Swan 
W/P; Attorney Client Privilege; 
01117 
Edwards 
Berger 
Irrelevant and not reasonably 
calculated to lead to the discovery 
of admissible evidence; protected 
by privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-100 
10/23/09 
E-mail chain - from Mark Fistos to Bradley Edwards and 
p.101 
1:59 p.m. 
Russell Adler (08121-08123) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08118-
10/23/09 
Attorneys 
Russell Adler 
Litigation 
W/P; Attorney Client 
08123 
at RRA 
Strategy 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-101 
10/23/09 
E-mail chain - from Scott Rothstein to Bradley Edwards, 
p. 73 
2:02 p.m. 
Steven Jaffe and Mark Fistos (26749-26752) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26741-
10/23/09 Attorneys 
Bradley 
Legal Research 
W/P; Attorney Client 
26763 
at RRA 
Edwards 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
14 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-102 
10/23/09 
E-mail chain - from Mark Fistos to Bradley Edwards and 
p.101 
2:05 p.m. 
Russell Adler (08128-08130) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08124-
10/23/09 
Attorneys 
Steven Jaffe 
Litigation 
W/P; Attorney Client Privilege; 
08156 
at RRA 
Strategy 
Irrelevant and not reasonably 
calculated to lead to the 
discovery of admissible 
evidence; protected by privacy 
rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-103 
10/23/09 
E-mail chain - from Russell Adler to Bradley Edwards 
p.101 
2:06 p.m. 
and Mark Fistos (08118-08120) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08118-
10/23/09 
Attorneys 
Russell Adler 
Litigation 
W/P; Attorney Client 
08123 
at RRA 
Strategy 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-104 
10/23/09 
E-mail chain - from Mark Fistos to Bradley Edwards and 
p.101 
2:09 p.m. 
Russell Adler (08131-08133) 
15 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08124-
10/23/09 
Attorneys 
Steven Jaffe 
Litigation 
W/P; Attorney Client 
08156 
at RRA 
Strategy 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-105 
10/23/09 
E-mail chain - from Steven Jaffe to Bradley Edwards, 
p.101 
2:09 p.m. 
Mark Fistos and Russell Adler (08124-08126) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08124-
10/23/09 
Attorneys 
Steven Jaffe 
Litigation 
W/P; Attorney Client 
08156 
at RRA 
Strategy 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-106 
10/23/09 
E-mail chain - from Matthew Weissing to Bradley 
p.101 
2:10 p.m. 
Edwards, Mark Fistos and Russell Adler (08135-08138) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
08124-
10/23/09 
Attorneys 
Steven Jaffe 
Litigation 
W/P; Attorney Client 
08156 
at RRA 
Strategy 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
16 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-107 
10/23/09 
E-mail chain - from Mark Fistos to Steve Jaffe, Scott 
p. 74 
2:24 p.m. 
Rothstein, Russell Adler, Bradley Edwards and Matthew 
Weissing (27494) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
27494 
10/23/09 
Attorneys 
Mike Fistos 
Legal Research 
W/P; Attorney Client 
at RRA 
RE: Causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to lead 
Epstein 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-108 
10/23/09 
E-mail chain - from Mark Fistos to Steven Jaffe, Scott 
p. 73 
2:45 p.m. 
Rothstein, Russell Adler, Bradley Edwards and Matthew 
Weissing (26760) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26741-
10/23/09 
Attorneys 
Bradley 
Legal Research 
W/P; Attorney Client 
26763 
at RRA 
Edwards 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to 
Epstein 
lead to the discovery of 
admissible evidence; 
protected by privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-110 
10/23/09 
E-mail chain - from Russell Adler to Scott Rothstein 
p. 73 
3:43 p.m. 
(25997) 
17 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
25997 
10/23/09 Scott 
Russell Adler 
Legal Research 
W/P; Attorney Client 
Rothstein 
RE: causes of 
Privilege; Irrelevant and not 
action against 
reasonably calculated to 
Epstein 
lead to the discovery of 
admissible evidence; 
protected by privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-111 
10/25/09 
E-mail chain - from Ken Jenne to Scott Rothstein 
p.67 
3:21 p.m. 
(25937) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
25937 
10/25/09 
Scott 
Ken Jenne 
Epstein's house 
W/P; Attorney Client 
Rothstein 
staff 
Privilege; Irrelevant and not 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by 
privacy rights 
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-113 
10/27/09 
E-mail chain - from Ken Jenne to Phaedra Xanthos 
p. 150 
5:23 p.m. 
(26604-26605) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
26604-
10/27/09 
Phaedra 
Ken Jenne 
Political 
Work product; 
26605 
Xanthos 
Contributions/ad 
attorney/client privilege; 
vertisement for 
irrelevant and not reasonably 
the rental on 
calculated to lead to the 
Little St. James 
discovery of the admissible 
Island 
evidence; protected by 
privacy rights 
18 

NOT A CERTIFIED COPY
EPSTEIN'S MARCH 5, 2018, CLERK'S TRIAL EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
13-116 
10/29/09 
E-mail chain - from Paul Cassell to Bradley Edwards 
p. 129 
7:44 p.m. 
(07019-07021) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07019-
10/29/09 
Bradley 
Paul Cassell 
L.M. and E.W. v. 
Work product; attorney/client 
07024 
Edwards 
Epstein - I'm on 
privilege; irrelevant and not 
it 
reasonably calculated to lead 
to the discovery of admissible 
evidence; protected by privacy 
rights. 
19 

NOT A CERTIFIED COPY
EXHIBIT B 

NOT A CERTIFIED COPY
., 
,., 
.-- Joseph L. Ackerman, Jr. 
From: 
Sent: 
To: 
Subject: 
Gary Farmer <gary@pathtojustice.com> 
Wednesday, February 02, 20111:49 PM 
ROBERT CARNEY; Jack Scarola; Seth Lehrman; Lilly Ann Sanchez; Joseph L. Ackerman, Jr.; 
Brad Edwards 
RE: It's time to meet 
Judge, I apologize for the delay in replying, I was out of the office most of the day yesterday, and could not get 
with my partners and our clients to discuss all issues. We have now done so. We are certainly happy to meet, 
but maybe a conference call can accomplish the same thing. But even before that,llefmelayout a proposal 
(thafTtliinkshoulcfoe accepta6Ietoallparties. Here is what we propose ... and it essentially includes the "aye, 
aye" you requested, with some additiona·I provisions. 
We will agree to prepare a revised log in which we add dates for the emails and a description ofthe subject 
matter & parties. But we will also Q.!!!.i! from the log any work product privilege objections, subject to the 
following agreement. (Allworl<j)rocJuct materialswilroe turnea over to PlaTiitiff except for materialsrelater.lro 
(new or ongoing cases, AND on tlie conaition tliat tney fie proaucecr''For Attorneys.-Eyes OnlW' such that no 
copies or images will be made of them, and Epstein will not see these documents, unless and until such time 
as Judge Crow and/or Judge Ray has overruled any privilege claim (following your recommended report, or 
course). If the objections are sustained, the documents will be returned to us and no copies retained by 
)Plaintiff's attorneys; ifthe objections are overruled and the documents otherwise deemed discoverable, 
Plaintiff gets them. The Plaintiff and his attorneys will also agree that by entering into this agreement and 
producing these documents a~ described, Plaintiff will not take the position that we have waived any 
privilege. (Th~heonlyifemsYourRonor wilrtiave to review anamakeprivilegedeterminations woulffbeas 
(to worl< proauct materials f...

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

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

NOT A CERTIFIED COPY
EXHIBIT C 

NOT A CERTIFIED COPY
' • , 
Joseph L. Ackerman, Jr . 
• -....*rom: 
Sent: 
To: 
Subject: 
Gary Farmer <gary@pathtojustice.com> 
Wednesday, February 09, 20114:27 PM 
ROBERT CARNEY; Joseph L. Ackerman, Jr.; Lilly Ann Sanchez; Jack Scarola; CHRISTOPHER 
E. KNIGHT; Seth Lehrman; Brad Edwards 
RE: Suggestion 
Hello all. I wanted to provide and update, and get written confirmation from the Plaintiff's counsel of the deal that was 
verbally agreed to on Friday and put into an email by me on Monday. I have not received any reply to my Monday 
email. I will resend it after this. 
But by way of update I can tell you that we have four (4) boxes of documents that are ready to be turned over now (or 
when we get them back from a copy center that is scanning them) under the ag~eement. To be specific, we have 2 
boxes of documents that contain materials that we believe to be irrelevant but that implicate privacy rights of the 
parties or non-parties (mostly staff at the old RRA). These will be turned over subject to a confidentiality order (and that 
needs to be drafted, BTW), s.uch that Plaintiff & his counsel can immediately begin reviewing same. (Wealsohave2J 
@ofe"'boxestliat contain work"Vocuct materialsffiat we will turn over su6jecttol:lie agreement thaf Plaiirtiffwillnot1 
(assert tliat any_Rrivilege lias IJeen waivea oy turning tliem over now, ana furtlier su6ject to tlie agreement tliat tliey_g 
(i:1roclucea "For AttorneysrEyes Only.J Should Plaintiff or his attorneys believe that a document is not confidential or 
privileged, that objection will be brought before Judge Carney and he will issue a recommended order to both Judges 
Crow and Ray . 
... We have also completed what I would estimate to be 1/5 of the revised privilege log, and are prepared to make those 
" 
pocuments available immediately for Judge Carney to begin reviewing, and we will produce that portion of the privilege 
• log to Plaintiff as well. We estimate that the privilege log will be completed by Tue...

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

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EXHIBIT D 

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

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1 
2 
3 
4 
5 
6 
I 
7 
I I' 
8 
9 
10 
11 
12 
I 
13 
14 
15 
16 
17 
18 
191 
20 
'1 
21: I 
22 I 
I 
23
1 
24 
I 
I 
25
1 
41 
to 
Let me see if we can cut quickly to the chase 
here. 
I 
The confidentiality, can we get the confidentiality 
I 
1 
worked out so that we get something in writing so 
everyone is happy, in writing by next Friday at the 
latest? 
MR. ACKERMAN: 
That will be fine. 
MR. FARMER: 
How about this Friday? 
MRS. SANCHEZ: 
The documents are ready to go. 
Write 
up whatever you want and we'll -- we don't have a· 
problem with that. 
MR. FARMER: 
You guys have to have 19,000 
confidentiality orders done in other cases and you get 
paid by the hour to do this. 
MRS. SANCHEZ: 
I don't have a problem, but we will 
get an order to you by tomorrow and you can get the 
documents to us by Friday, and that's done. 
MR. FARMER: 
{fuCvou still want to do th~ 
(attorney's-eyes onlyj) ~ou want to speed it up~ 
(not~ (You'll 
0
get work-product stuff if you agree to th~ 
(attorney's-eyes only] 
MRS. SANCHEZ: 
Yes. 
MR. KNIGHT: 
We need to get the ball rolling. 
MR. ACKERMAN: 
Let's do that. 
MRS. SANCHEZ: 
Yes. 
United Reporting, Inc. 
954-525-2221 
• I 

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EXHIBIT E 

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CM/ECF - Live Database - flsd 
Page 1 of 47 
REF _SETTLEMENT,WM 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE#: 9:08-cv-80736-KAM 
Doe v. United States of America 
Assigned to: Judge Kenneth A. Marra 
Referred to: Magistrate Judge Dave Lee Brannon 
(Settlement) 
Case in other court: USCA, 13-12923-C 
USCA, 13-12926-C 
USCA, 13-12928-C 
Cause: no cause specified 
Petitioner 
Date Filed: 07/07/2008 
Jury Demand: None 
Nature of Suit: 440 Civil Rights: Other 
Jurisdiction: U.S. Government 
Defendant 
Jane Doe 
represented by Bradley James Edwards 
V. 
Respondent 
United States of America 
represented by 
Farmer Jaffe Weissing Edwards Fistos 
&Lehrman PL 
425 N Andrews A venue 
Suite 2 
Fort Lauderdale, FL 33301 
954-524-2820 
Fax: 954-524-2822 
Email: brad@pathtojustice.com 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jay C. Howell 
Jay Howell & Associates PA 
644 Cesery Boulevard 
Suite 250 
Jacksonville, FL 32211 
Email: jay@jayhowell.com 
PROHACVICE 
ATTORNEY TO BE NOTICED 
Paul G. Cassell 
Email: cassellp@laW.utah.edu 
PROHACVICE 
ATTORNEY TO BE NOTICED 
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?961881247922712-L _I_ 0-1 
10/23/2017 

NOT A CERTIFIED COPY
CM/ECF - Live Database - flsd 
Page 8 of 47 
Clerks Notice of Docket Correction and Instruction to Filer re 30 
Response/Reply (Other), Response/Reply (Other) filed by Jane Doe. Error -
Wrong Event Selected; Correction - Redocketed by Clerk as Reply to 
Response to Motion. Instruction to Filer - In the future, please select the proper 
event. It is not necessary to refile this document. (ls) (Entered: 10/17/2008) 
12/05/2008 
33 
Sealed Document. (rb) (Entered: 12/05/2008) 
12/05/2008 
SYSTEM ENTRY - Docket Entry 32 restricted/sealed until further notice. ( dj) 
(Entered: 11/03/2010) 
12/09/2008 
34 Clerks Notice of Docket Correction re 33 Sealed Document. Error(s): Sealed 
Document Filed in Wrong Case; Correction - Original document restricted and 
refiled in correct case. (rb) (Entered: 12/09/2008) 
12/22/2008 
35 AFFIDAVIT signed by : A. Marie Villafana. re 14 Affidavit, .Ll. 
Response/Reply (Other) Supplemental Declaration by United States of 
America. (Attachments: # l Certification Certificate of Service )(Villafana, Ann 
Marie) (Entered: 12/22/2008) 
02/12/2009 
36 ORDER denying 28 Motion to Unseal Document. Signed by Judge Kenneth A. 
Marra on 2/12/2009. (ir) (Entered: 02/12/2009) 
(04i'09i'2009) 
(37) 'NOTICffoy Jane Doe of_CJiange oIFirm '74.Jjj_liation c:gawaras";"Braclley)) 
TEnterea:ff4i'09i'2009)) 
09/08/2010 
38 Administrative Order Closing Case. Signed by Judge Kenneth A. Marra on 
9/8/2010. (tb) (Entered: 09/09/2010) 
[09i'f3l20T0) 
(12.) 'NOTICffoy Jane Doe re 38-Admiiiistrative Order In "ResRonse to; 
Aamm1straflve Oraer Closing Case @awaras, Braclley) (Enterea: 09/131/2010)) 
10/12/2010 
40 ORDER TO SHOW CAUSE for lack of prosecution. Show Cause Response 
due by 10/27/2010. Signed by Judge Kenneth A. Marra on 10/8/2010. (ir) 
(Entered: 10/12/2010) 
10/27/2010 
41 
STATUS REPORT by Jane Doe (Edwards, Bradley) Modified to add missing 
event 42 Response to Order to Show Cause on 10/28/2010 (ls). (Entered: 
10/27/2010) 
10/27/201...

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EXHIBIT F 

NOT A CERTIFIED COPY
IN THECIRCUIT COURT OF THE 15th JUDICIAL ClllCUIT 
IN AND FORPALM BEACH:Cc:>UNTY, FLORIDA .. I 
• ' CIVIL DIVISION AG 
.CASE N0.'502009CA040800xxxxMB 
Judge David F. Crow -
JEFFREY EPSTEIN: 
Plaintiff/Cm..mter-Defend.ant, 
,. : 
:• v. 
SCOTT ROTHSTEIN, 'individually; and 
'BRADLEY J; EDWARDS, individually, 
-An4£ J7+ ~l),,-1v,-'4y?1 6:Jif. i..i'' 1.-isii-/6&d-·tM· ·dt 
c Au. .. Mz,:.L, 4Usa M-4- 0-:p?J wdu A u311,.,.,....b 
-~-
PP.~C!.,P' l.2&0(!,)(s-J.·a;1a • Tl~ Y1r.s#·Cfir~~- • , . 
:iJ rs/4,i,;rn i 799 Su·2c/ 33 CJ (Fl£... 9-tl /Jc-A ;Mo 1) .. ~ 
n 

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

NOT A CERTIFIED COPY
EXHIBIT G 

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

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

NOT A CERTIFIED COPY
Edwards adv, Epstein 
Case No.:. 502009CA040800XXXXMBAG 
Order on Outstanding Discovery Motions· 
COUNSEL LIST 
Jack A. Goldberger, Esquire 
jgoldt,erger@agwpa;coni; •.· 
·stnahoney@agwpa.com 
• i\tterlJury, Goldberger & Weiss; P .A 
250 Australian Avenue South, Suite 1400. 
·west Palm Beach., FL 33401 
Phone: (561)-659.:8300 
Fa;,i;: (561)-835-8691 
Bn1dley J. Edwards, Esquire· 
brad@pathtoJustice.co1ri 
Farmer, Jaffe, Weissing, Edwards, Fistos & 
Lehnnan,EL 
425 North Andrews·Avehue, Suite 2 
ForiLauderdale; FL 33301 -
Phone: .. (954)-524-2820 
Fax: (954):-s24~2822 
Tonja Haddad Coleman; Esquire 
tonja@tonj ahaddadpa.cotn 
s·i. 4. s. Andr.ewsAv. e1111e, Suit.e ~l. 
Fort Lauderdale, l<L 333Ql 
_ ~ ~ 
Phone: < .. 954)'..46. 7-.1223, ~. 
< • . 
.Fax: (954)-337-3716 . o~ 
.Lilly.Ann.Sanche,'!)lirc· 
·lsanchez@thelsfirm:com 
The L-S La~ifrn 
I 4411Jl.ibkcill-:A,~enue, 15th Floor 
Miip(1, 1Eh, 33'[31 
1'!§~: (395)-503-5503 
. ~ 
c:1'.lisi-so3-6so1 
~1k Scarola, Esquire 
. 
-Searcy Denney Scarola Barnhart & Shipley 
M.· ar.c .S··.· Nim 
.•.• k .. ~ Esq··.u .. ir··. e. 
. . . . .~· 
• . 
_2139 P.a. Im. Be.ach. L. a. k 
.. es B 
.•. o.ulevard 
marc@nuriklaw.com 
/2- . • · • : · 
West Palrri 13each; FL33409 
.on 
. e E Browar<iB. ).vd., Suite 700 ""'~~-
.. •• • 
Phone:·561-686-6300 
Fo·.·rt. ·.La.ud. e.··rdale.·, FL 33301 ·G· · ·. 
Fax:. 561-383-9451 
Phone: (954)-745-5849 
·.·-. 
• 
Attorneys for Edwards 
Fax: (954}-745-3556 
• • --
• .  ·~ 
3 

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EXHIBIT H 

NOT A CERTIFIED COPY
INRE: 
UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
www.tlsb.uscourts.gov 
ROTHSTEIN ROSENFELDT ADLER, P.A., 
Debtor. 
CASE NO.: 09-34791-RBR 
CHAPTER 11 
-----------~' 
PRIVILEGE LOG 
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & 
LEHRMAN 
Dated: February 23, 2011 
Total of 159 pages 
EXHIBITQ. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.·.·:·:,·;,·· 
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BATES 
05737 
05750 
05770 
05774-05776 
05782-05783 
05788-05790 
05802 
05806 
05812 
05814 
05818-05819 
01781 
07619 
DATE 
08/12/2009 
05/29/2009 
07/08/2009 
09/04/2009 
07/09/2009 
07/09/2009 
09/04/2009 
09/04/2009 
09/04/2009 
08/03/2009 
09/09/2009 
05/01/2009 
07/13/2009 
Privilege Log - Dated 2~23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Adam Horowitz 
Jacquie Johnson 
NPNP and sub to Palm Beach 
Joint W/P Priv. 
Natl Bank 
Mercedes 
Spencer Kuvin 
Motion for status conf. 
Joint W/P Priv. 
Estrada 
Bradley Edwards 
Spencer Kuvin 
NPA in camera review 
JointW/P Priv. 
Katherine Ezell 
Jacquie Johnson 
Mardnkova being rescheduled 
Joint W/P Priv. 
Bradley Edwards 
Spencer Kuvin 
Motion to appoint commissioner 
Joint W/P Priv. 
Bradley Edwards 
Spencer Kuvin 
Notice and serve everyone 
Joint W/P Priv. 
Adam Horowitz 
Jacquie Johnson 
Bill being split up evenly 
Joint W/P Priv. 
Jacquie Johnson 
Spencer Kuvin 
Bill will be split evenly for each 
Joint W/P Priv. 
case 
Adam Horowitz 
Jacquie Johnson 
Bill will be split evenly 
Joint W/P Priv. 
Bradley Edwards 
Adam Horowitz 
Haley's affidavit 
JointW/P Priv. 
Bradley Edwards 
Robert Josefsberg 
CMAOrder 
Joint W/P Priv. 
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 
Paul Cassell 
Bradley Edwards 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
27 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
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SATES 
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 
03181 
09/14/2009 
William Berger 
Paul Cassell 
litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03182-03185 
07/14/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evldence;protected by privacy rights 
03186-03188 05/01/2009 
William Berger 
Bradley Edwards 
Epstein Depo 
work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13860-13874 05/28/2009 
Elizabeth Kim 
Christinia Fitch 
Litigation Strategy 
work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
14173 
10/21/2009 
Gary Farmer 
Bradley Edwards 
Stanely Arkin 
work 
Product;attorney 
client 
priVilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13419 
08/11/2009 
Denis Kleinfeld 
Bradley Edwards 
Trump's Depa 
Work 
Product;attorney 
client 
priVilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
03087 
06/29/2010 
Investigators 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;pro...

NOT A CERTIFIED COPY
Privilege Log - Dated 2•23-2011 
' 
& 
I 
I 
Farmer Jaffe Weissim~ 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 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13445-13453 08/19/2009 
Denis Kleinfeld 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
12281-12291 07/30/2009 
earl Under 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
09337-09340 08/10/2009 
Barry Stone 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
09350 
10/21/2009 
Barry Stone 
Bradley Edwards 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
09335 
08/06/2009 
Barry Stone 
Bradley Edwards 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
11983 
08/06/2009 
Carl Linder 
Jacquie Johnson 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
'l'\ ~? 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
11984-11988 08/06/2009 
Carl Linder 
Bradley Edw...

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
I 
I· 
& 
Farmer Jaffe Weissin~ 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 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25798 
08/06/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25799-25802 
08/10/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25773 
10/21/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
-
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25738 
08/03/2009 
William Berger 
Beth Williamson 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
25739-25740 08/11/2009 
William Berger 
Bradley Edwards 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
17940 
07/30/2009 
Jonathan 
Bradley Edwards 
Litigation Strategy 
Work 
Product;attorney 
client 
Birkman 
privilege;irrelevant & reason...

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

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

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

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine 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 Busche! 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00047-00049 05/01/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00050 
05/05/2009 
Bradley Edwards 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00051 
05/05/2009 
Bradley Edwards 
Paul cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably 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 
Prod uct;atto rney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00054 
05/05/2009 
Bradley Edwards 
Rob Busche! 
litigation Strategy 
Work 
Product;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the ...

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

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

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
' 
I 
' 
Farmer Jaffe Weissine: 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 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00091 
05/28/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00092 
05/28/2099 
Bradley Edwards 
Rob Buschell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00093 
06/01/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00094-00095 06/23/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00096 
07/06/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
...

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

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

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
E 
Farmer Jaffe WeissinJ! Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
00128-00131 
5/26/2009 
Bradley Edwards 
Rob Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00132 
5/21/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attomey 
client 
privi!ege;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;attomey 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
--
00134 
06/03/2009 
Bradley Edwards 
Rob Buschel 
litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00135-00137 06/03/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00138-00140 06/08/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Prod uct;atto rney 
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 
evide...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin,z Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
0BJEOI0N 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00146 
06/29/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00147 
06/29/2009 
Bradley Edwards 
Mike Fisten 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00148 
04/22/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Prod uct;atto rney 
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 Buschel 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
00151-00152 
06/26/2009 
Bradley Edwards 
Rob Busche! 
Litigation Strategy 
Work 
Prod uct;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
01036-01039 04/26/2009 
Susan Sterling 
Russell Adler 
Litigation Strategy 
Work 
Product;attorney 
client 
privilege;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
13313-13314 07/30/2009 
Denis Kleinfeld 
Bradley Edwards 
litigation Strat...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissinaz 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;irrelevant & reasonably calculated to 
lead 
to 
the 
discovery 
of 
admissible 
evidence;protected by privacy rights 
01080-01081 06/22/2009 
Robert C. Buschel 
Bradley 1. Edwards 
Jane Doe brother 
Attorney/Client privilege and/or work product 
01077 
05/28/2009 
Robert C. Busche! 
Bradley J. Edwards 
Doe family member 
Attorney/Client privilege and/or work product 
02445-02446 05/05/2009 
Bradley 
J. 
Susan K. Stirling 
Jones v. Atlantic asphalt 
Attorney/CUent privilege and/or work product 
Edwards 
03049 
09/21/2009 
Bradley 
J. 
D.F. 
New addition to the case 
Attorney/Client privilege and/or work product 
Edwards 
02425-02426 06/17/2009 
Susan K. Stirling 
Bradley J. Edwards 
Jane Doe v. Dukenik 
Attorney/Client privilege and/or work product 
02669 
09/24/2009 
Bradley 
J. 
Jacquie Johnson 
Subpoena for Adriana Mucinska 
Attorney/Client privilege and/or work product 
Edwards 
02647 
08/06/2009 
Mike Fisten 
Bradley J. Edwards 
Samantha Lee Rivera info 
Attorney/Client privilege and/or work product 
03688-03691 04/03/2009 
Robin 
T. 
Bradley J. Edwards 
Case number assignments 
Attorney/Client privilege and/or work product 
Kempner 
03692-03693 05/06/2009 
Bradley 
J. 
Susan K. Stirling 
Case list 
Attorney/Client privilege and/or work product 
Edwards 
15678-15680 09/29/2009 
Jacquie Johnson 
Bradley J. Edwards 
Subpoena for Adriana Mucinska 
Attorney/Client privilege and/or work product 
15689 
10/01/2009 
Jacquie Johnson 
Bradley J. Edwards 
Client information 
Attorney/Client privilege and/or work product 
02546-02547 09/22/2009 
D.F. 
Bradley J. Edwards 
Client communication 
Attorney/Client privilege and...

NOT A CERTIFIED COPY
·:--·;.· 
······-····--·-·-·--·----· 
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin2 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 
02955 
04/20/2009 
Susan K. Stirling 
Bradley J. Edwards 
Juskowich 
Attorney/Client privilege and/or work product 
02932 
07/17/2009 
Christina Fitch 
Bradley J. Edwards 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
11544-11545 09/28/2009 
Jacquie Johnson 
Bradley J. Edwards 
Client info 
Attorney/Client privilege and/or work product 
07432-07435 09/25/2009 
D.F. 
Bradley J. Edwards 
New addition to the case 
Attorney/Client privilege and/or work product 
06906-06909 07/17/2009 
Christina Fitch 
Bradley J. Edwards 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
06913-06914 06/22/2009 
Bradley 
J, 
Susan K. Stirling 
Jane Doe v. Roe 
Attorney/Client privilege and/or work product 
Edwards 
06030-06031 05/04/2009 
Susan K. Stirling 
Bradley J. Edwards 
Espina -Walmart case 
Attorney/Client privilege and/or work product 
05646 
07/08/2009 
Bradley 
J. 
William J. Berger 
Client meeting 
Attorney/Client privilege and/or work product 
Edwards 
05573 
09/18/2009 
Mike Fisten 
Bradley J. Edwards 
Client meeting 
Attorney/Client privilege and/or work product 
05540 
07/31/2009 
Amy Swan 
Bradley J. Edwards 
Client info 
Attorney/Client privilege and/or work product 
05273-05276 07/28/2009 
Amy Swan 
Bradley J. Edwards 
Client info 
Attorney/Client privilege and/or work pr...

NOT A CERTIFIED COPY
____ :,··:- _ _. ______ _ 
Privilege Log - Dated 2-23-2011 
I 
I 
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Farmer Jaffe WeissinJ? 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 
06542-0...

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
I 
Farmer Jaffe. Weissim? 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 Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05344-05346 06/23/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal for Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05408 
07/06/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal for Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05425-05429 
05/28/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05433-05436 
05/29/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05433-05436 
05/29/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05446 
07/07/2009 
Bradley Edwards 
Confidential Source 
Other Rape Victims 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
05452-05464 05/29/2009 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
05535-05536 
07/30/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; ...

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

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
' 
Farmer Jaffe Weissina: 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 admiss°lble 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 lead...

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

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 
Epstein Molestations 
discovery of admissible evidence 
01755-01756 10/02/2009 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery of admissible evidence 
01756 
06/22/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
01770 
10/08/2009 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
03126 
09/18/2009 
Confidential 
Bradley Edwards 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Source 
Epstein Strategy 
discovery of admissible evidence 
02006 
06/23/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02060 
09/23/2009 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
03487-03494 09/19/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02269 
08/26/2009 
Confidential 
Bradley Edwards 
Other Rape Victims 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02322-02323 
10/16/2009 
Confidential 
Bradley Edwards 
Litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
02595-02596 
09/07/2009 
Bradley Edwards 
Confidential Source 
Secret Plea Deal For Epstein 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
02866-02867 09/25/2009 
Confidential 
...

NOT A CERTIFIED COPY
.. ,. 
··------------
BATES 
03081-03082 
03144 
03189-03190 
04015 
02913 
02956-02957 
02975 
04031--04055 
04057 
04060 
02979-02980 
02998 
05626 
05630-05631 
05664-05665 
07976 
06655 
DATE 
09/21/2009 
10/08/2009 
10/14/2009 
09/08/2009 
09/28/2009 
08/31/2009 
10/21/2009 
08/12/2009 
08/11/2009 
08/12/2009 
10/02/2009 
07/21/2009 
10/12/2009 
10/12/2009 
10/12/2009 
08/14/2009 
06/09/2009 
Privilege Log-Dated 2-23-2011 
I 
& 
I 
& 
Farmer Jaffe Weissin.1? Edwards Fistos & Lehrman 
TO 
FROM 
DESCRIPTION 
OBJECTION 
Bradley Edwards 
Confidential Source 
Providing Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
Confidentlal 
Bradley Edwards 
Providing Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Strategies 
discovery of admissible evidence 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W /P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
discovery of admisslble evidence 
Confidential 
Bradley Edwards 
litigation Strategy 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Additional 
Information 
RE: 
W/P Priv.; not reasonably calculated to lead to 
Epstein Molestations 
discovery of admissible evidence 
Confidential 
Bradley Edwards 
Providing New Witnesses 
W/P Priv.; not reasonably calculated to lead to 
Source 
discovery of admissible evidence 
Bradley Edwards 
Confidential Source 
Providing New Witnesses 
W/P Priv.; not reasonably calcula...

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
Farmer Jaffe WeissinR Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECflON 
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 Molestations ...

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
Farmer. Jaffe. Weissine. Edwards. Fistos & Lehrman 
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 ofadmissible 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 
~ 
Rm 
TO 
FROM 
DESCRIPTION 
OBJECTION 
08029-08032 
09/14/2009 
Bradley Edwards 
Tami Wolfe 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08026-08028 
05/01/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
07738-07739 
05/13/2009 
Paul Cassell 
Bradley Edwards 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
07747 
09/17/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy ...

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
Qfil 
TO 
fBQM 
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; pro...

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

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

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

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Farmer Jaffe Weissine:. Edwards. Fistos & Lehrman 
BATES 
DATE 
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FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
05295-05297 
07/23/2009 
Attorneys at RRA 
Priscilla 
RE: Epstein Conference Room 
W/P; Attorney Client Privilege; Irrelevant and 
Nascimento 
Reserved 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05298 
08/03/2009 
MikeFisten 
Bradley Edwards 
Discussion of Epstein strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05261 
07/23/2009 
Amy Swan 
Bradley Edwards 
Victim Psychological Assessment 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
18358-18359 
07/24/2009 
Bradley Edwards 
Ken Jenne 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04431-04432 
08/14/2009 
Jacquie Johnson 
Bradley Edwards 
RE: Epstein-Maxwell Subpoena 
W/P; Attorney Cllent 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, 
& 
Epstei...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer. Jaffe. Weissine:. Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
fBQ.M 
DESCRIPTION 
OBJECTION 
01082 
09/02/2009 
Jacquie Johnson 
Mike Fisten 
Subpoenas 
for 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
Housekeepers 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04363 
09/14/2009 
Jacquie Johnson 
Bradley Edwards 
LM 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04343-04344 
09/04/2009 
Bradley Edwards 
Jacquie Johnson 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04340-04342 
09/04/2009 
Jacquie Johnson 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04339 
09/03/2009 
Mike Fisten 
Bradley Edwards 
Investigation 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
00989 
09/04/2009 
Bradley Edwards 
William Berger 
Alessi Depa 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04325-04328 
07/30/2009 
Paul Cassell 
Bradley Edwards 
RE: 
Epstein• 
beneficiaries 
& W/P; Attorney Client Privilege; lnelevant 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 ...

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

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

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

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

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TO 
FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
19713-19715 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Copperfield Subpoena 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19720-19729 
09/30/2009 
Mike Fisten 
Jacquie Johnson 
Tentative Subpoena dates and 
W/P; Attorney Client Privilege; Irrelevant and 
people list 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19706-19707 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Dershowitz Subpoena ready to be 
W /P; Attorney Client Privilege; Irrelevant and 
signed 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19693-19695 
09/04/2009 
Mike Fisten 
Bradley Edwards 
Investigation 
into 
Epstein's W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
19696-19697 
09/04/2009 
Jacquie Johnson 
Bradley Edwards 
Setting Up 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 Cli...

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

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

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

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

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

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
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BATES 
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TO 
FROM 
DESCRIPTION 
OBJEg!QN 
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 
Depa 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 Depa 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16400-16404 
09/02/2009 
Mike fisten 
Jacquie Johnson 
lnvestigatio n 
into 
Epstein's 
W/P; Attorney Client Privilege; Irrelevant and 
planes 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
16394-16395 
08/31/2009 
Bradley Edwards 
Jacquie Johnson 
Depo Dates 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01046 
08/25/2009 
Cara Holmes 
Bradley Edwards 
Computer information 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01048-01050 
07/28/2010 
William Berger 
Bradley Edwards 
Hard drive of Plaintiffs computer 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
01052 
09/09/2009 
Attorneys at RRA 
Maribel Matiska 
privacy rights 
legal Opinion RE: Epstein 
W/P; Attorney Client Priv...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
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BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
QBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
01100 
10/19/2009 
Russell Adler 
Bradley Edwards 
Dershowitz Involvement 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01105 
08/11/2009 
Bradley Edwards 
Alan Garten 
Potential New Witnesses 
W /P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01111 
05/13/2009 
Bradley Edwards 
Paul Cassell 
Legal research 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01112-01117 
05/12/2009 
Bradley Edwards 
William Berger 
Dr.Swan 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
01139-01142 
04/29/2009 
Staff 
Bradley Edwards 
privacy rights 
Epstein Depa 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 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
privacy rights 
01247 
09/30/2009 
Bradley Edwards 
Jacquie Johnson 
Therapy Notes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01268-01269 
10/22/2009 
Bradley Edwards 
Marc Nurik 
Epstein meeting 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01293 
08/19/2009 
KenJenne 
Bradley Edwards 
Epstein Assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01299 
04/21/2009 
Bradley Edwards 
Carolyn Edwards 
Order denying the motion to W/P; Attorney Client Privilege; Irrelevant and 
reassign or transfer 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01305 
08/24/2009 
Paul Cassell 
Bradley Edwards 
Epstein Computers 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01313 
09/02/2009 
Attorneys at RRA 
Jacquie Johnson 
Epstein Depo 
W/P; Attorney Client Prlvilege; 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 
privacy rights...

NOT A CERTIFIED COPY
_____ • --····· ·-·-·--·-··-····· 
Privilege log - Dated 2-23-2011 
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Farmer Jaffe Weissinf! 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 eviden...

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Privilege Log - Dated 2-23~2011 
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Farmer Jaffe Weissin2 Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
.E!l.QM 
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 
KenJenne 
Bradley Edwards 
Investigation into Epstein planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01491 
08/10/2009 
Ken Jenne 
Bradley Edwards 
Investigative fees 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01492 
08/10/2009 
Jacquie Johnson 
Bradley Edwards 
The Mar-a-Lago Club Depo 
W/P; Attorney Client Privile9e; 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 
n...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
12.m 
TO 
FROM 
DESCRIPTION 
OBJECTION 
·, 
discovery of admissible evidence; protected by 
privacy rights 
01502 
08/21/2009 
Marc Nurik 
Bradley Edwards 
Epstein Evidence 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01513 
08/25/2009 
Jacquie Johnson 
Bradley Edwards 
Discovery for the girls 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01522 
08/14/2009 
Bradley Edwards 
MarcNurik 
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 !ead to the 
discovery of admissible evidence; protected by 
privacy rights 
01527 
04/27/2009 
Marc Nurik 
Bradley Edwards 
NewVictim 
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 
discovery of admissible evide...

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Farmer Jaffe Weissini! Edwards Fistos & Lehrman 
§ATES 
DATE 
TO 
FROM 
DESCRIPTION 
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 
privacy 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 
discoverv of admissible...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
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TO 
FROM 
DESCRIPTION 
OBJECTION 
01628 
06/15/2009 
Roben Buschel 
Bradley Edwards 
Investigations 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01635 
05/21/2009 
Bradley Edwards 
Carolyn Edwards 
Personal Conversation 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01636 
06/23/2009 
Susan Stirling 
Bradley Edwards 
Motion to unseal 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01638 
06/29/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy RE: Motion to 
W/P; Attorney Client Privilege; Irrelevant and 
unseal 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01644 
07/06/2009 
Confidential 
Bradley Edwards 
Request for admission 
W/P; Attorney Client Privilege; Irrelevant and 
Source 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01646 
07/06/2009 
Confidential 
Bradley Edwards 
Secret Plea deal for Bear Stearns 
W/P; Attorney Client Privilege; Irrelevant and 
Source 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01648 
07/11/2009 
Wayne Black 
Bradley Edwards 
Investigating Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01650 
07/13/2009 
Carl Linder 
Bradley Edwards 
Epstein's Assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protecte...

NOT A CERTIFIED COPY
____ ··-·:.: 
:; · .. , 
Privilege Log- Dated 2-23-2011 
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Mm 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECflON 
not reasonably calculated to lead to the 
discoveiy 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 
discoveiy 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 
discoveiy of admissible evidence; protected by 
privacy rights 
01681 
08/03/20009 
Mike Fisten 
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 
discoveiy 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 
discoveiy of admissible evidence; protected by 
privacy rights 
01686 
09/11/2009 
Mike Fisten 
Bradley Edwards 
Potential new witnesses 
W/P; Attorney Client Privilege...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
discovery of admissible evidence; protected by 
privacy rights 
01692 
09/12/2009 
William Berger 
Bradley Edwards 
Proposal for settlement 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01698 
05/05/2009 
Paul Cassell 
Bradley Edwards 
Epstein Victim Depos 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01702 
09/17/2009 
Paul Cassell 
Bradley Edwards 
Epstein Depos 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01705 
05/14/2009 
William Berger 
Bradley Edwards 
Statutory Rape 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01711 
04//01/2009 
Carolyn Edwards 
Bradley Edwards 
Third party subs 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01737 
07/14/2009 
Richard Wolfe 
Bradley Edwards 
Facebook/Myspace 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01564 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
Investigation Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
01603 
10/15/2009 
Bradley Edwards 
Adam Horowitz 
Testimony RE: Vehicles 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible...

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
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BATES 
DATE 
IQ 
fRQM 
DESCRIPTION 
OBJECTION 
04237-04242 
06/15/2009 
Bradley Edwards 
Wayne Black 
Epstein secret plea deal with W/P; Attorney Client Privilege; Irrelevant and 
Bear Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04246 
06/15/2009 
Wayne Black 
Bradley Edwards 
Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and 
-Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04250 
06/15/2009 
Wayne Black 
Bradley Edwards 
Epstein Victims 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04255-04256 
06/15/2009 
Wayne Black 
Bradley Edwards 
Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and 
Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04260 
06/15/2009 
Bradley Edwards 
Wayne Black 
Epstein secret plea deal for Bear W/P; Attorney Client Privilege; Irrelevant and 
Stearns 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
04523 
05/14/2009 
Bradley Edwards 
Wayne Black 
Investigating Epstein's planes 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05088-05090 
10/27/2009 
Attorneys at RRA 
KenJenne 
Epstein's assets 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the 
discovery of admissible evidence; protected by 
privacy rights 
05108 
04/01/2009 
Bradley Edwards 
Carolyn Edwards 
Victims employment 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to lead to the...

NOT A CERTIFIED COPY
Privilege Log - Dated 2·23-2011 
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BATES 
DATE 
TO 
fHQM 
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 
I 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
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; Irr...

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

NOT A CERTIFIED COPY
Privilege log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe WeissinR Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
ffiQM 
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; JProtected 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 
9...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
Farmer Jaffe. Weissin~ Edwards. Fistos & Lehrman 
BATES 
QA1] 
TO 
fBQ.M. 
DESCRIPTION 
OBJECTI~ 
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 
...

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

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
& 
E 
& 
Farmer Jaffe Weissine 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 Fisten 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03115-03118 
05/16/2009 
Bradley Edwards 
Susan Stirling 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03124 
06/23/2009 
Bradley Edwards 
Wayne Back 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03125 
09/08/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Prlvilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
03127-03128 
05/19/2009 
Susan Stirling 
Bradley Edwards 
privacy rights 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03135-03136 
08/04/2009 
Mike Fisten 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the ...

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

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

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

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

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

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
03550-03574 
09/09/2009 
Attorneys at RRA 
Paul Cassell 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03575-03588 
10/19/2009 
Kendall Coffey 
Bradley Edwards 
Providing New Witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03589-03604 
04/11/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03605-03606 
10/16/2009 
Attorneys at RRA 
Bradley Edwards 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03607-03610 
10/16/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03611-03612 
10/16/2009 
Attorneys at RRA 
Bradley Edwards 
litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03613-03615 
10/29/2009 
Bradley Edwards 
Cara Holmes 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03616-03618 
10/01/2009 
Pat Diaz 
Bradley Edwards 
Providing New Witnesses 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible eviden...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
' 
Farmer Jaffe WeissinJ!. Edwards Fistos & Lehrman 
-
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
03638-03641 
09/08/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08454 
10/23/2010 
Attorneys at RRA 
Mark Fistos 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08118-08123 
10/23/2009 
Attorneys at RRA 
Russell Adler 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
08124-08156 
10/23/2009 
Attorneys at RRA 
Steven Jaffe 
Litigation Strategy 
W/P; Attorney Client Privilege; Irrelevant and 
not reasonably calculated to 
lead to the 
discovery of admissible evidence; protected by 
privacy rights 
02411-02413 
05/12/2009 
Attorneys at RRA 
Bradley 
J. 
Jane Doe II v. Epstein 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01913-01914 
06/15/2009 
Susan K. Stirling 
Bradley 
J. 
Activity in case 9:08-cv-80893-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein Motion to irrelevant and not reasonably calculated to lead 
Dismiss 
to the discovery of the admissible evidence; 
protected by privacy rights 
01918- 01919 
04/15/2009 
Attorneys at RRA 
Bradley 
J. 
Activity in case 9:08-cv-80893-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein Motion to irrelevant and not reasonably calculated to lead 
Compel 
to the disc...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
C 
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Farmer Jaffe Weissin1? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
ERQM 
DESCRIPTION 
OBJECTION 
Motion to Strike 
to the discovery of the admissible evidence; 
protected by privacy rights 
01925 
08/26/2009 
Jacquie Johnson 
Bradley 
J. 
Adriana Surveillance/lnteiview 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01928-01929 
08/03/2009 
Jacquie Johnson 
Bradley 
J. 
Alfredo Rodriguez address 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01930 
09/05/2009 
Bradley 
J. 
William J. Berger 
Client info 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01940 
09/10/2009 
Russell Adler 
Bradley 
J. 
Witness Info 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01944-01952 
04/10/2009 
Russell Adler 
Bradley 
J. 
Epstein assets 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01969 
05/04/2009 
Susan K. Stirling 
Bradley 
J. 
Call from sources of information 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01971-01972 
05/13/2009 
Attorneys at RRA 
Bradley 
J. 
Cassell Draft 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
01973-0...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
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Farmer Jaffe Weissini! Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTIQN 
protected by privacy rights 
01975 
08/10/2009 
Jacquie Johnson 
Bradley 
J. 
Computers 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01976-01978 
07/06/2009 
Bradley 
J. 
Paul cassell 
Conference call 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01981-01982 
04/01/2009 
Bradley 
J. 
Russell Adler 
Conflict check for Brad Edwards Work 
product; 
attorney/client 
privilege; 
Edwards 
files 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
0199() 
05/14/2009 
Bradley 
J. 
Paul Cassell 
Consolidation order 
Work 
product; 
attorney/ciient 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02000 
09/03/2009 
Jacquie Johnson 
Bradley 
J. 
Oates for Subpoena -
Epstein's Work 
product; 
attorney/client 
privilege; 
Edwards 
housekeepers 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02001-02003 
10/09/2009 
Jacquie Johnson 
Bradley 
J. 
David Copperfield 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02009-2010 
09/09/2009 
Pasquale Diaz 
Bradley 
J. 
Deposition of Bill Riley 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02017-02018 
05/18/2...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
I 
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Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
QBJECTION 
02023 
05/14/2009 
Attorneys at RRA 
Bradley 
J. 
Sid's deposition of Epstein 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02045-02046 
09/04/2009 
Attorneys at RRA 
Bradley 
J. 
E.W., L.M. Doe v. Epstein - Letter Work 
product; 
attorney/ client 
privilege; 
Edwards 
from Bob Critton 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02049-02053 
09/04/2009 
Paul Cassell 
Bradley 
J. 
E.W., L.M. Doe v. Epstein - Letter 
Work 
product; 
attorney/client 
privilege; 
Edwards 
from Bob Critton 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02063-02064 
05/19/2009 
William J. Berger 
Bradley 
J. 
Epstein-Confirming AT&T Dial in 
Work 
product; 
attorney/client 
privilege; 
Edwards 
Telephone 
Conference 
for irrelevant and not reasonably calculated to lead 
Monday, 6/8/09 at 2:00 p.m. 
to the discovery of the admissible evidence; 
protected by privacy rights 
02089-02090 
09/17/2009 
Paul Cassell 
Bradley 
J. 
Epstein hearing 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02091-02092 
06/16/2009 
Attorneys at RRA 
Bradley 
J. 
Epstein -
Monthly cau 
in Work 
product, 
attorney/client 
privilege; 
Edwards 
Telephone Conference 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02106-02108 
04/29/2009 
Susan K. Stirling 
Bradley 
J. 
Epstein -Telephone Conference 
Work 
product; 
attorney/ client 
priVilege; 
Edwards 
irreleva...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Farmer Jaffe Weissinf? Edwards Fistos & Lehrman 
BATES 
Rfil 
IQ 
FROM 
DESCRIPTION 
Q~JECTION 
Edwards 
in New York for the following irrelevant and not reasonably calculated to lead 
week 
to the discovery of the admissible evidence; 
protected by privacy rights 
02112-02116 
09/10/2009 
Bradley 
J. Jacquie Johnson 
Epstein -
Yearbook picture of Work 
product; 
attorney/client 
privilege; 
Edwards 
Epstein rape victims 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02117-02118 
10/23/2009 
Jacquie Johnson 
Bradley 
J. 
Epstein (AUSA) 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02119-02121 
09/08/2009 
Beth 
s. Bradley 
J. 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Williamson 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02130-02137 
05/26/2009 
Susan K. Stirling 
Bradley 
J. 
Epstein cases-
depositions in 
Work 
product; 
attorney/client 
privilege; 
Edwards 
federal cases 
irrelevant and not reasonably calculated to lead 
" 
to the discovery of the admissible evidence; 
protected by privacy rights 
02138-02139 
08/04/2009 
Jacquie Johnson 
Bradley 
J. 
Epstein depo - New York 
Work 
product; 
attorney/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 Depa 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02229 
05/05/2009 
Paul Cassell 
Bradley 
J. 
Epstein Depo 
Work 
product; 
attorney/clie...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Farmer Jaffe WeissinJ:? Edwards Fistos & Lehrman 
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BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
02256-02257 
07/22/2009 
Jacquie Johnson 
Bradley 
J. 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02260-02261 
07/22/2009 
Nora Batian 
Bradley 
J. 
Epstein - coordinating meetings 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
-
02263-02265 
07/23/2009 
Attorneys at RRA 
Nora Batian 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02266 
07/30/2009 
Jacquie Johnson 
Bradley 
J. 
Epstein -Video Deposition of S.K. 
Work 
product; 
attorney/client 
privilege; 
Edwards 
in NY 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02273-02276 
09/18/2009 
Jacquie Johnson 
Bradley 
J. 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02278-02279 
07/23/2009 
Priscila 
A. 
Nora Batian 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
Nascimento 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
02284-02855 
05/11/2009 
Susan K. Stirling 
Bradley 
J. 
Epstein info 
protected by privacy rights 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
01769 
10/30/2009 
...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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DATE 
TO 
ffiQM 
DESCRIPTION 
QBJECTION 
protected by privacy rights 
01780 
09/14/2009 
Bradley 
J. 
William J. Berger 
Discussion of belief that Epstein 
Work 
product; 
attorney/client 
privilege; 
Edwards 
is transferring assets to avoid 
irrelevant and not reasonably calculated to lead 
judgments 
to the discovery of the admissible evidence; 
protected by privacy rights 
01787-01788 
09/04/2009 
Ken Jenne 
Bradley 
J. 
1. Accountants 2. Motion for IME 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01799-01801 
10/14/2009 
Bradley 
J. 
Paul Cassell 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein Notification irrelevant and not reasonably calculated to lead 
of ninety days expiring 
to the discovery of the admissible evidence; 
protected by privacy rights 
01804-01805 
09/04/2009 
Beth 
s. 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney /client 
privilege; 
Williamson 
Edwards 
KAM Doe v. Epstein - Order on 
irrelevant and not reasonably calculated to lead 
motion for Medical Exam 
to the discovery of the admissible evidence; 
protected by privacy rights 
01806-01807 
09/09/2009 
Paul Cassell 
Bradley 
J. Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein - Motion for irrelevant and not reasonably calculated to lead 
protective order 
to the discovery of the admissible evidence; 
protected by privacy rights 
01808-01809 
09/10/2009 
Paul Cassell 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein - Order on 
irrelevant and not reasonably calculated to lead 
Motion for Extension of Time to to the discovery of the ad...

NOT A CERTIFIED COPY
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Privilege Log- Dated 2-23-2011 
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Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTIQN 
OBJECTION 
01840-01841 
07/16/2009 
Paul Cassell 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein - Order on 
irrelevant and not reasonably calculated to lead 
Motion to Stay 
to the discovery of the admissible evidence; 
protected by privacy rights 
01867-01868 
09/28/2009 
Paul Cassell 
Bradley 
J. 
Activity in case 9:08-cv-80119-
Work 
product; 
attorney/client 
privilege; 
Edwards 
KAM Doe v. Epstein -
Notice 
irrelevant and not reasonably calculated to lead 
(Other} 
to the discovery of the admissible evidence; 
protected by privacy rights 
03662-03663 
08/10/2009 
Attorneys at RRA 
Bradley 
J. 
Meeting with clients 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03664-03668 
09/18/2009 
Paul Cassell 
Bradley 
J. 
litigation 
strategy 
and 
Work 
product; 
attorney/client 
privilege; 
Edwards 
preparation 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08166-08168 
10/28/2009 
Paul Cassell 
Bradley 
J. 
Weds filing 
Work 
product; 
attorney/ client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08169-08170 
08/06/2009 
Bradley 
J. 
Jacquie Johnson 
Wexner deposition for 14th 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08190-08196 
04/07/2009 
Bradley 
J. 
Paul Cassell 
Motion to unseal/Motion to stay 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not re...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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§:.ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJEglON 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08381-08383 
09/06/2009 
Bradley 
J. 
Paul Cassell 
Epstein - complaint 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights • 
08384-08388 
04/13/2009 
Bradley 
J. 
Paul Cassell 
Epstein fraudulent transfer 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08389-08397 
05/14/2009 
Bradley 
J. 
Paul Cassell 
Revisited sexual history memo 
Work 
product; 
attorney/ client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evid_ence; 
protected by privacy rights 
08401 
07/22/2009 
Bradley 
J. 
Paul Cassell 
Reply memo on asset transfers 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08409-08410 
08/01/2009 
Bradley 
J. 
Cara L. Holmes 
Rodriguez Deposition 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08421 
06/02/2009 
Bradley 
J. 
William J. Berger 
Strategy 
Work 
product; 
attorney/client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08423-08425 
10/09/2009 
Bradley 
J. 
Mike Fisten 
Subpoena info 
Work 
product; 
attorney /client 
privilege; 
Edwards 
irrelevant and not reasonably calculated to lead 
to t...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
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Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
08441-08446 
10/05/2009 
Attorneys at RRA 
William J. Berger 
Trial Prep 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03672-03673 
06/26/2009 
Wayne Black 
Bradley Edwards 
Brunel information 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03706-03718 
08/05/2009 
Bradley Edwards 
Paul Cassell 
Cf. Response to Motion to File 
Work 
product; 
attorney/client 
privilege; 
Epstein Affidavit 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03737 
08/25/2009 
Bradley Edwards 
Cara Holmes 
Computers 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03746-03753 
08/02/2009 
Bradley Edwards 
William Berger 
Computers 
Work 
product; 
attorney/client 
privllege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02335-02338 
05/08/2009 
William Berger 
Bradley Edwards 
Litigation strategy 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02360-02361 
06/09/2009 
Susan Stirling 
Bradley Edwards 
Hearing to Un-seal- Criminal Plea 
Work 
product; 
attorney/client 
privilege; 
Transcript 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
023...

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Privilege Log-Dated 2-23-2011 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
QAll 
TO 
FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
02376-02392 
10/14/2009 
Mike Fisten 
Bradley Edwards 
Igor Zinoview depo 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02401-02410 
05/08/2009 
William Berger 
Bradley Edwards 
Jane Doe II v. Epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02414-02419 
05/12/2009 
Attorneys at RRA 
Bradley Edwards 
Jane Doe II v. Epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03669-03670 
10/08/2009 
Carolyn Edwards 
Bradley Edwards 
Epstein house arrest monitor 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02288-02289 
05/26/2009 
Susan Stirling 
Bradley Edwards 
Motion date 
Work 
product; 
attorney/ die nt 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02292-02293 
05/19/2009 
Or. lee (Expert) 
Bradley Edwards 
Pimp and His Game 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02304-02308 
09/17/2009 
Bradley Edwards 
Jacquie Johnson 
Fo rensics/lnvestigatio ns 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02313-02316 
07/...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
ftP.TES 
.Mn 
IQ 
ffi.QM 
DESCRIPTION 
OBJECTION 
02331-02334 
05/08/2009 
Susan Stirling 
Bradley Edwards 
Critton order Transcript 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02173 
09/04/2009 
Attorneys at RRA 
Mike Fisten 
Epstein Juan Alessi 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02187 
07/26/2009 
Bradley Edwards 
Wayne Black 
Epstein matter 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02195-02197 
09/17/2009 
Jacquie Johnson 
Bradley Edwards 
Epstein Order 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02199-02203 
09/18/2009 
Jacquie Johnson 
Bradley Edwards 
Epstein Order 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02211-02214 
07/01/2009 
Paul Cassell 
Bradley Edwards 
Epstein v. 
State 
of Florida-
Work 
product; 
attorney/client 
privilege; 
Emergency Petition for Writ of irrelevant and not reasonably calculated to lead 
Certiorari 
to the discovery of the admissible evidence; 
protected by privacy rights 
02224 
07/28/2009 
Jacquie Johnson 
Bradley Edwards 
Witness of Epstein rapes from 
Work 
product; 
attorney/client 
privilege; 
Switzerland 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10787-10799 
10/19/2009 
Bradley Edwards 
Jacquie ...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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~ATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10904-10905 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
RICO Enterprise 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10908-10909 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
RICO Enterprise 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10912-10913 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
RICO Enterprise 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10955-10963 
06/01/2009 
Bradley Edwards 
William Berger 
Plaintiffs Witness list 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10979-10981 
06/03/2009 
Bradley Edwards 
Wayne Black 
Serve Subpoenas 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11022-11025 
06/26/2009 
Bradley Edwards 
Wayne Black 
Info on 2 MC2 Workers 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11036-11037 
07/21/2009 
Bradley Edwards 
Wayne Black 
Serve Subpoenas 
Work 
product; 
attorney/ client 
privllege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected b...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
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' 
Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCBIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
11083-11084 
09/04/2009 
Attorneys at RRA 
Bradley Edwards 
Witness info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11105-11110 
09/09/2009 
Jacquie Johnson 
Bradley Edwards 
Disseminate letter from Wexner 
Work 
product; 
attorney/client 
privilege; 
attorney 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11137-11139 
10/03/2009 
Paul Cassell 
Bradley Edwards 
Zorro Trust research info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11143-11146 
10/04/2009 
William Berger 
Bradley Edwards 
11/28 Discovery Cutoff 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11155-11156 
10/18/2009 
Attorneys at RRA 
Bradley Edwards 
New Property 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11175-11183 
04/27/2009 
Marc Nurik 
Bradley Edwards 
Epstein Case info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11196-11197 
05/28/2009 
Susan Stirling 
Bradley Edwards 
Jail Visitors 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11205-11207 
...

NOT A CERTIFIED COPY
Privilege tog- Dated 2 .. 23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
11215 
06/01/2009 
William Berger 
Bradley Edwards 
Activity in Case 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11238-11239 
06/03/2009 
Wayne Black 
Bradley Edwards 
Depo Info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11246-11247 
06/22/2009 
Wayne Black 
Bradley Edwards 
Epstein Article 
work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11251-11254 
06/23/2009 
Wayne Black 
Bradley Edwards 
Info on 2 MC2 workers 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11267-11268 
06/30/2009 
William Berger 
Bradley Edwards 
Witness list revised 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11282-11315 
07/18/2009 
Wayne Black 
Bradley Edwards 
Confidential Info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11326-11331 
08/03/2009 
Jacquie Johnson 
Bradley Edwards 
Donald Trump depo 
Work 
product; 
attorney/client 
priVilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11337-11339 
08/04/2009 
Mike Fisten 
Bradley Edwards 
Confidential Info 
Work 
product; 
attorney/...

NOT A CERTIFIED COPY
Privilege Log-Dated 2-23-2011 
& 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
W\,TES 
DATE 
TO 
f.l!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 admissible evidence; 
protected by privacy rights 
11377-11379 
08/12/2009 
Jacquie Johnson 
Bradley Edwards 
Issuing Subpoenas 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11390-11395 
08/17/2009 
Jacquie Johnson 
Bradley Edwards 
Witness depos 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11400-11415 
08/18/2009 
Jacquie Johnson 
Bradley Edwards 
Subpoenas for pilots 
work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11420-11426 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Serving Alan Dershowitz 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11428-11429 
08/26/2009 
Attorneys at RRA 
Bradley Edwards 
Witness info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11568 
10/07/2009 
Paul Cassell 
Bradley Edwards 
Meeting with Leslie Wexner 
Work 
product; 
attorney/cli...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
' 
l 
l 
Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11861-11865 
10/23/2009 
Attorneys at RRA 
Bradley Edwards 
Witness list 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11870-11871 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Epstein info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11874 
08/24/2009 
Jacquie Johnson 
Bradley Edwards 
Confidential info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11876 
08/24/2009 
Attorneys at RRA 
Ken Jenne 
Confidential Info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
11967-11972 
10/29/2009 
Cara Holmes 
Jacquie Johnson 
Subpoenas 
for 
Epstein's 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 righ...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
[SATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
08157-08159 
06/03/2009 
Carla Martinez 
Bradley Edwards 
Vanity Fair 
Work 
product; 
attorney I cl lent 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08499-08501 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Witness list 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10063-10068 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Confidential Info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10090-10091 
08/31/2009 
Attorneys at RRA 
Jacquie Johnson 
Witness Info 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10103-10104 
08/27/2009 
Attorneys at RRA 
Ken Jenne 
Witness Info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10106-10137 
08/24/2009 
Attorneys at RRA 
Ken Jenne 
Meetings/ Confidential Info 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
12569 
07/30/2009 
Carl Linder 
Bradley Edwards 
Epstein 
Sex 
Abuse 
Litigation 
Work 
product; 
attorney/client 
privilege; 
Forum 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
15827-15837 
07/22/2009 
Jacquie J...

NOT A CERTIFIED COPY
·--:: .
.. 
___ 
, __ ,_. 
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
SATES 
_..,,......, 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
15820-15822 
10/29/2009 
Jacquie Johnson 
Cara Holmes 
Subpoenas 
for 
Epstefn's Work 
product; 
attorney/client 
privilege; 
Attorneys 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
15401-15412 
09/09/2009 
Jacquie Johnson 
Bradley Edwards 
Disseminate 
the 
letter from 
Work 
product; 
attorney/client 
privilege; 
wexner atty 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
15356-15359 
08/26/2009 
Attorneys at RRA 
Bradley Edwards 
Witness info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
14934-14950 
07/22/2009 
Jacquie Johnson 
Bradley Edwards 
Investigator Info 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
13413-13414 
08/06/2009 
Denis Kleinfeld 
Bradley Edwards 
Epstein information 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
13908-13911 
08/24/2009 
Attorneys at RRA 
Mike Fisten 
Meeting info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10595-10597 
09/29/2009 
Bradley Edwards 
Jacquie Johnson 
Subpoena for Adriana Mucinska 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
t 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
IQ 
FROM 
DfStRIPTION 
OBJECTION 
10633-10638 
10/05/2009 
Bradley Edwards 
William Berger 
Trial Prep 
work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10681-10692 
10/07/2009 
Jacquie Johnson 
Mike Fisten 
Depositions 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10777-10786 
10/16/2009 
Bradley Edwards 
Paul Cassell 
New 
Evidence 
of 
Epstein 
work 
product; 
attorney/client 
privilege; 
Fraudulent Transfers 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04094-04100 
04/07/2009 
Bradley Edwards 
Paul Cassell 
Draft Motion to Strike 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02915 
10/03/2009 
Attorneys at RRA 
Mike Fisten 
Finances 
work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02971 
10/14/2009 
Jacquie Johnson 
Bradley Edwards 
Larry Visoski depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02976 
09/09/2009 
Jacquie Johnson 
Bradley Edwards 
Disseminate 
the 
letter from 
work 
product; 
attorney/client 
privilege; 
wexner 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02995 
06/24/2009 
Bradley Edwards 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/c...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
t 
t 
I 
Farmer Jaffe Weissing Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10193 
08/11/2009 
Bradley Edwards 
Jacquie Johnson 
Trump Depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10255 
09/09/2009 
Bradley Edwards 
William Berger 
Depo of Alan Dershowitz 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
10259-10263 
09/09/2009 
Attorneys of RRA 
Jacquie Johnson 
Cooperfield Service 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03876-03877 
10/26/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03879-03884 
07/13/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03886-03891 
07/13/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03905-03920 
09/08/2009 
William Berger 
Bradley Edwards 
E.W., L.M. Doe v. Epstein 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
03937 
08/1...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
C 
I 
Farmer Jaffe Weissin2 Edwards Fistos & Lehrman 
BATES 
M!E 
TO 
FROM 
DESCRIPTION 
OBJEglON 
to the discovery of the admissible evidence; 
protected by privacy rights 
04005-04011 
05/13/2009 
Bradley Edwards 
William Berger 
Discovery 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04070-04093 
04/07/2009 
Bradley Edwards 
Paul Cassell 
Motion to Strike 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03754 
07/08/2009 
Paul Cassell 
Bradley Edwards 
Conference Call 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03848-03858 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
Cooperfield Service 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03642-03643 
09/04/2009 
Paul Cassell 
Bradley Edwards 
1. Accounts/ 2. Motion for IME 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03657-03661 
09/04/2009 
Attorneys at RRA 
Paul Cassell 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02475 
06/15/2009 
Susan Stirling 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02494-02515 
09/20/2009 
Bradley Edwards 
Pat D...

NOT A CERTIFIED COPY
·--- ·;··. ,: ... _, ...... . 
Privilege Log - Dated 2-23-2011 
,. 
I 
I 
I 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
!1ATE5 
QAis 
TO 
FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
02520-02543 
06/06/2009 
Bradley Edwards 
Paul Cassell 
Memo of Assest Transfers 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02548-02553 
08/03/2009 
Seth Williamson 
Bradley Edwards 
Federal Subpoena 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02560-02565 
07/31/2009 
Bradley Edwards 
Jacquie Johnson 
Federal Subpoena 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02568-02570 
10/13/2009 
Jacquie Johnson 
Bradley Edwards 
New Times Article 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02578-02583 
05/28/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02619-02622 
09/09/2009 
Jacquie Johnson 
Bradley Edwards 
New client Retainer 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
02633-02646 
05/01/2009 
Paul cassell 
Bradley Edwards 
Response 
to 
Motion 
to Work 
product; 
attorney/client 
privilege; 
Consolidate + Cassell strategy 
irrelevant and not reasonably calculated to lead 
Memo for Jay 
to the discovery of the admissible evidence; 
protected by priva...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
t 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
~ATES 
Rm 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
07967-07975 
09/22/2009 
Jacquie Johnson 
MikeFisten 
Subpoena on Epstein case 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07979-08000 
08/18/2009 
Bradley Edwards 
Jacquie Johnson 
Subpoenas for Pilots 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07735-07736 
07/24/2009 
Bradley Edwards 
Jacquie Johnson 
Releases for therapist 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07643-07645 
09/09/2009 
Bradley Edwards 
Jacquie Johnson 
New dlent Retainer 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07698-07706 
09/06/2009 
Paul Cassell 
Bradley Edwards 
Answer to the Complaint 
work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07620-07632 
08/14/2009 
Jacquie Johnson 
Bradley Edwards 
Review of "Notice of Taking Depo 
Work 
product; 
attorney/client 
privilege; 
- RC - Bear Sterns" 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07635-07636 
10/15/2009 
Mike Fisten 
Bradley Edwards 
Questions 
from 
forensic 
Work 
product; 
attorney/ client 
privilege; 
accountant 
detecting 
Epstein 
irrelevant and not reasonably calculated to lead 
fraudulent transfers 
to the discovery of the admissible evidence; 
protected by privacy ri...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23·2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
10 
FROM 
DESCRIPTION 
OBJECTION 
Visoski depo 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
0 7595-07604 
05/20/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07616 
07/22/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07530-07549 
06/11/2009 
Bradley Edwards 
Susan Stirling 
Overtime 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07470-07507 
07/09/2009 
Paul Cassell 
Bradley Edwards 
Motion to Compel 
Work 
product; 
attorney/client 
privllege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07447-07469 
10/13/2009 
Attorneys at RRA 
Russell Adler 
New Times Article on epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07444-07446 
05/01/2009 
Bradley Edwards 
Paul Cassell 
Response 
to 
Motion 
to Work 
product; 
attorney/client 
privilege; 
Consolidate + Cassell Strategy 
irrelevant and not reasonably calculated to lead 
Memo for Jay 
to the discovery of the admissible evidence; 
protected by privacy rights 
07440 
10/18/2009 
Attorneys at RRA 
Bradley Edwards 
New Trump Property 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to t...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissinl? Edwards Fistos & Lehrman 
BATES 
DATE 
!Q 
fBQM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
07424-07431 
09/26/2009 
Bradley Edwards 
Paul Cassell 
Need Depo Transcript 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07412-07423 
04/08/2009 
Bradley Edwards 
Paul Cassell 
Draft Motion to Strike 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07403-07411 
04/08/2009 
Paul Cassell 
Bradley Edwards 
Draft Motion to Strike 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07394-07402 
07/10/2009 
Bradley Edwards 
Paul Cassell 
Multiple 2255 Counts 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07386-07392 
05/28/2009 
William Berger 
Bradley Edwards 
Motion to Unseal 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07378-07385 
04/07/2009 
Bradley Edwards 
Paul Cassell 
Motion to Unseal 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07370-07377 
04/07/2009 
Paul Cassell 
Bradley Edwards 
Motion to Unseal 
Work 
product; 
attorney/ die nt 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07354-07369 
10/28/2009 
Beth ...

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Privilege log - Dated 2-23-2011 
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DATE 
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FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
07346 
10/28/2009 
Beth Williamson 
Bradley Edwards 
Motion to protect 2nd depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of • the admissible evidence; 
protected by privacy rights 
07337 
10/28/2009 
Bradley Edwards 
Jacquie Johnson 
Motion to protect 2n° depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07328 
10/28/2009 
Bradley Edwards 
Beth Williamson 
Motion to protect 2nd depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07319 
10/28/2009 
Bradley Edwards 
Jacquie Johnson 
Motion to protect 2nd depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07313-07318 
04/10/2009 
Paul Cassell 
Bradley Edwards 
Motion to Compel - Photograph 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07287-07301 
07/08/2009 
Bradley Edwards 
Paul Cassell 
Motion to Compel -
File this 
Work 
product; 
attorney/client 
privilege; 
week? 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07252-07278 
09/08/2009 
Bradley Edwards 
Paul Cassell 
Motion for IME + Accountant 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07247-072S1 
09/08/2009 
Pau...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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BATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
07230-07233 
06/08/2009 
Paul Cassell 
Bradley Edwards 
Memo on Asset Transfers 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07157-07158 
09/29/2009 
Russell Adler 
Bradley Edwards 
RE: Mark Schwartz 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence~ 
protected by privacy rights 
07128-07141 
07/08/2009 
Paul Cassell 
Bradley Edwards 
Motion for bond asset transfer Work 
product; 
attorney/client 
privilege; 
and memo final 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07094-07098 
09/14/2009 
Paul Cassell 
Bradley Edwards 
Letter to Critton RE: Motions to 
Work 
product; 
attorney /client 
privilege; 
Compel 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07025-07027 
10/29/2009 
Bradley Edwards 
Paul Cassell 
L.M. and E.W. v. Epstein -
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07099-07106 
09/14/2009 
Bradley Edwards 
Paul Cassell 
Letter to Critton RE: Motions to Work 
product; 
attorney/client 
privilege; 
Compel 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07071-07078 
07/23/2009 
Paul Cassell 
Bradley Edwards 
L.M.'s Son's B~day 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07066-07070 
07/23/2009 
Bradley E...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
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TO 
FROM 
DESCRIPTION 
OBJECTION 
and/or liquidations 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07019-07024 
10/29/2009 
Bradley Edwards 
Paul Cassell 
LM. and E.W. v. Epstein - I'm on 
Work 
product; 
attorney/dient 
privilege; 
it 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06837-06839 
04/08/2009 
Beth Williamson 
Bradley Edwards 
Jane Doe change of address 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06826-06836 
04/08/2009 
Bradley Edwards 
Beth Williamson 
Jane Doe change of address 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06823-06825 
04/08/2009 
Bradley Edwards 
Beth Williamson 
Jane Doe change of address 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06813-06816 
07/02/2009 
Paul Cassell 
Bradley Edwards 
Doe 
v. 
Epstein 
Motion 
for Work 
product; 
attorney/client 
privilege; 
Extension 
of 
Time 
to 
File 
irrelevant and not reasonably calculated to lead 
Response/Reply/ Answer 
to the discovery of the admissible evidence; 
protected by privacy rights 
06808-06810 
09/13/2009 
Bradley Edwards 
Paul Cassell 
"Is Jeffrey Epstein the new Work 
product; 
attorney/client 
privilege; 
Madoff - Running a giant Ponzi 
irrelevant and not reasonably calculated to lead 
scheme?" 
to the discovery of the admissible evidence; 
protected by privacy rights 
06804-06805 
09/13/2009 
Paul Cassell 
Bradley Edwards...

NOT A CERTIFIED COPY
Privilege Log-Dated 2-23-2011 
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Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
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DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06800-06803 
09/06/2009 
Paul Cassell 
Bradley Edwards 
RE: 1. Accountants 2. Motion for Work 
product; 
attorney/client 
privilege; 
IME 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06761-06762 
08/19/2009 
Attorneys at RRA 
Paul Cassell 
IME Rules 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
06767-06769 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
IME's 
protected by privacy rights 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06782-06787 
04/10/2009 
Paul Cassell 
Bradley Edwards 
Confidential 
Detailed Strategy 
Work 
product; 
attorney/client 
privilege; 
Memo on Asset Protection Issues 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
06744-06747 
05/01/2009 
Paul Cassell 
Bradley Edwards 
Depa of Jeffrey Epstein 
protected by privacy rights 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
06736-06739 
05/01/2009 
Bradley Edwards 
Paul Cassell 
Asset Protection Issue 
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 
06709-06710 
10/14/2009 
Bradley Edwards 
Mike Fisten 
Igor Zlnoview depo 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discove...

NOT A CERTIFIED COPY
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DATE 
IQ 
FROM 
DESCRIPTION 
QBJEglON 
06691-06696 
07/09/2009 
Bradley Edwards 
Paul Cassell 
How many 2255 claims? 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06683-06686 
07/08/2009 
Paul Cassell 
Bradley Edwards 
Hiding Assets 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06654 
07/24/2009 
Paul Cassell 
Bradley Edwards 
Secretary Contact info 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06599-06600 
07/08/2009 
Bradley Edwards 
Paul Cassell 
Hiding Assets 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06574-06590 
04/07/2009 
Paul Cassell 
Bradley Edwards 
Motion to Unseal 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06567-06570 
07/09/2009 
Bradley Edwards 
Paul Cassell 
Motion to Compel 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06558-06561 
07/09/2009 
Paul Cassell 
Bradley Edwards 
Motion to Compel 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
131 

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BATES 
DATE 
IQ 
.EB.QM 
DESCRIPTION 
OBJECTION 
06554-06557 
05/14/2009 
Bradley Edwards 
Paul Cassell 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06549-06553 
05/14/2009 
Paul Cassell 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06540-06541 
09/21/2009 
Bradley Edwards 
Mike Fisten 
Info on Maxwell 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06537 
10/23/2009 
Bradley Edwards 
Paul Cassell 
Doe v. Jeffrey Epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06529-06530 
10/23/2009 
Paul Cassell 
Bradley Edwards 
Doe v. Epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06496-06505 
10/20/2009 
Bradley Edwards 
Paul Cassell 
Visoski depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06177-06181 
09/25/2009 
William Berger 
Bradley Edwards 
Financial discovery 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06149-06153 
07/10/2009 
Paul Cassell 
Bradley Edwards 
Federal 
First 
Amendment Work 
product; 
attorney/client 
privilege...

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Privilege Log - Dated 2-23-2011 
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Mm 
TO 
FROM 
DESCRIPTION 
OBJECTION 
protected by privacy rights 
06118-06146 
09/15/2009 
Seth Lehrman 
Bradley Edwards 
Farnsworth v. Macys case 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06113-06117 
07/14/2009 
Bradley Edwards 
Richard Wolfe 
Facebook/Myspace 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06106-06112 
05/19/2009 
Amy Swan 
William Berger 
Expert Witness 
Work 
product; 
attorney/dient 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06091 
08/04/2009 
William Berger 
Paul Cassell 
EW and LM v. Epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06001-06011 
07/18/2009 
Paul Cassell 
Bradley Edwards 
Epstein's Address and Position of Work 
product; 
attorney/client 
privilege; 
Critton on Motion 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05996 
04/08/2009 
Bradley Edwards 
Beth Williamson 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05998-06000 
09/17/2009 
Jacquie Johnson 
Bradley Edwards 
Epstein: Forensics/Investigations 
Work 
product; 
attorney/client 
privilege; 
INVOICE 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05992 
04/19/2009 
Bradley Edwards 
Marc Nur...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
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BATES 
QAis 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05968 
10/17/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05944-05947 
05/01/2009 
William Berger 
Bradley Edwards 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05927 
09/18/2009 
Bradley Edwards 
Amy Swan 
Ryan Hall Psychiatrist 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05931-05932 
07/27/2009 
Amy Swan 
Bradley Edwards 
Client's Cell Phone Number 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05919-05920 
07/28/2009 
Bradley Edwards 
AmySwan 
Client's Cell Phone Number 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05915 
04/22/2009 
Bradley Edwards 
Marc Nurik 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05911 
05/28/2009 
Bradley Edwards 
William Berger 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights ...

NOT A CERTIFIED COPY
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Privilege Log - Dated 2-23-2011 
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~ATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05890 
07/27/2009 
Bradley Edwards 
Amy Swan 
litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calcuf ated to lead 
to the 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 
05 87 4-05879 
07/23/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05868 
08/03/2009 
Bradley Edwards 
KenJenne 
Epstein Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05865 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05860-05861 
09/10/2009 
Bradley Edwards 
Maribel Matiska 
Litigation strategy 
Work 
product; 
attorn...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
E 
& 
& 
Farmer Jaffe Weissin2: Edwards Fistos & Lehrman 
[SATES 
Mn 
IQ 
FROM 
DESCRIPTION 
OBJEglON 
to the discovery of the admissible evidence; 
protected by privacy rights 
05845 
07/24/2009 
Bradley Edwards 
Ken Jenne 
Plane Tail Numbers 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05811 
06/09/2009 
Bradley Edwards 
Susan Stirling 
Witness Numbers 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05813 
08/15/2009 
Bradley Edwards 
KenJenne 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05748-05749 
08/11/2009 
Bradley Edwards 
Jacquie Johnson 
Litigation Strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05711 
05/11/2009 
Attorneys at RRA 
Bradley Edwards 
Subpoena Clinton 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05701-05704 
04/20/2009 
Bradley Edwards 
Russell Adler 
Epstein strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05687 
08/21/2009 
Bradley Edwards 
MarcNurik 
Alfredo Rodriguez 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05690-05691 
05/11/2009 
Bradley Edwards 
Susan Stirling 
Motion to Unseal 
Wo...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
& 
I 
I 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
~ 
DATE 
TO 
ERQ.M 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05680-05682 
05/11/2009 
Bradley Edwards 
William Berger 
Subpoena Clinton 
Work 
product; 
attorney /dient 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05676 
08/24/2009 
Attorneys at RRA 
M*e Fisten 
Topics for Meeting 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05648 
07/23/2009 
Attorneys at RRA 
Gary Farmer 
Assemble 
Epstein 
litigation Work 
product; 
attorney/client 
privilege; 
meeting 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05629 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Law Enforcement cannot release 
Work 
product; 
attorney/clien1t 
privilege; 
juvenile reports 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05621-05622 
09/18/2009 
Amy Swan 
Bradley Edwards 
Preparing Motion to take an IME 
Work 
product; 
attorney /client 
privilege; 
of Epstein 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
05610-05612 
04/27/2009 
Susan Stirling 
Bradley Edwards 
Request for Copies 
protected by privacy rights 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05588-05590 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Travel restrictions 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
-
to the di...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
& 
& 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
§ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
QBJECTION 
05575-05576 
08/21/2009 
MarcNurik 
Bradley Edwards 
Alfredo Rodriguez 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05582 
09/11/2009 
Bradley Edwards 
Mike Fisten 
Epstein strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05569-05570 
08/17/2009 
Marc Nurik 
Bradley Edwards 
Legal Opinion 
Work 
product; 
attorney/client 
priVilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05556-05558 
08/14/2009 
Attorneys at RRA 
Bradley Edwards 
Communication with legal expert 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05537 
07/30/2009 
Jacquie Johnson 
Bradley Edwards 
No 
objections 
from 
defense Work 
product; 
attorney/client 
privilege; 
counsel regarding depo for Sarah 
irrelevant and not reasonably calculated to lead 
Kellen 
to the discovery of the admissible evidence; 
protected by privacy rights 
05534 
07/24/2009 
Ken Jenne 
Bradley Edwards 
Flight logs for Epstein 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05518 
07/22/2009 
Attorneys at RRA 
Bradley Edwards 
Assemble 
Epstein 
Litigation 
Work 
product; 
attorney/client 
privilege; 
meeting 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05512-05513 
07/23/2009 
Priscila 
Nora Batian 
Assemble...

NOT A CERTIFIED COPY
····-·-·•·;····l-•:•: ______ _ 
Privilege Log - Dated 2-23-2011 
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I 
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Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJEg:ION 
to the discovery of the admissible evidence; 
protected by privacy rights 
0S502-05507 
07/22/2009 
Jacquie Johnson 
Bradley Edwards 
Wayne Black's email 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05475 
04/21/2009 
Marc Nurik 
Bradley Edwards 
Call with Chris Hanson from 
Work 
product; 
attorney/ client 
privilege; 
dateline 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
0S471-05472 
08/14/2009 
Marc Nurik 
William Berger 
Legal expert regarding legal issue 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05447 
08/14/2009 
Marc Nurik 
William Berger 
Communication with legal expert 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05420-05423 
05/20/2009 
William Berger 
Bradley Edwards 
Research on cases saying a judge 
Work 
product; 
attorney/client 
privilege; 
can postpone one party's depo irrelevant and not reasonably calculated to lead 
until the other is completed 
to the discovery of the admissible evidence; 
protected by privacy rights 
05409-05412 
08/17/2009 
Bradley Edwards 
Marc Nurik 
Legal 
opinion 
regarding 
Work 
product; 
attorney/client 
privilege; 
discovery 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05403-05405 
04/27/2009 
Marc Nurik 
Bradley Edwards 
Jeffrey Epstein Wikipedia page 
Work 
product; 
attorney/client 
privilege...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
l}ATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
05399 
10/17/2009 
William Berger 
Bradley Edwards 
Proposal for settlement 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05399 
10/17/2009 
William Berger 
Bradley Edwards 
Proposal for settlement 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05271-05272 
07/22/2009 
Bradley Edwards 
Jacquie Johnson 
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 
I 
I 
I 
I 
Farmer Jaffe Weissin~ Edwards Flstos & Lehrman 
.§ATES 
DATE 
IQ 
fRQM 
DESCRIPTION 
OBJECTION 
05155-05156 
04/20/2009 
Russell Adler 
Bradley Edwards 
Set Epstein's depo duces tecum 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05159-05160 
05/28/2009 
William Berger 
Bradley Edwards 
Right to move to reconsider all Work 
product; 
attorney/client 
privilege; 
rulings 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05149-05150 
05/27/2009 
Susan Stirling 
Bradley Edwards 
Epstein 
filed 
a 
motion 
to Work 
product; 
attorney/client 
privilege; 
continue the trial 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05153 
08/24/2009 
Bradley Edwards 
Mike Fisten 
Epstein traveling 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05146-05147 
05/26/2009 
Paul Cassell 
Bradley Edwards 
The response to the motion to Work 
product; 
attorney/client 
privilege; 
continue is due 6/8 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05137-05144 
05/20/2009 
Attorneys at RRA 
Russell Adler 
Epstein litigation strategy 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05133-05136 
05/11/2009 
William Berger 
Bradley Edwards 
Subpoena Clinton and others on Work 
product; 
attorney/client 
privilege; 
Sid Garcia's witness list 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
pr...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer Jaffe. Weissin~. Edwards. Fistos & Lehrman 
I 
!}.ATES 
Qfil 
TO 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
05125-05132 
05/05/2009 
William Berger 
Bradley Edwards 
Response to motion to compel all Work 
product; 
attorney/client 
privilege; 
the sex information of his clients 
irrelevant and nQt reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05115-05117 
04/27/2009 
Bradley Edwards 
Susan Stirling 
Epstein depos 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01699 
09/15/2009 
Jacquie Johnson 
Bradley Edwards 
VZdepo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05120-05121 
05/04/2009 
William Berger 
Bradley Edwards 
Reporter asking how the depo of Work 
product; 
attorney/client 
privilege; 
Epstein went 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05095-05098 
07/01/2009 
Bradley Edwards 
Paul Cassell 
Epstein v. State of Florida -
Work 
product; 
attorney/client 
privilege; 
Emergency Petition for Writ of irrelevant and not reasonably calculated to lead 
Certiorari; Emergency Motion to to the discovery of the admissible evidence; 
Review Denial of Stay 
protected by privacy rights 
01694 
10/17/2009 
Jacquie Johnson 
Bradley Edwards 
PFS 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05066-05067 
05/06/2009 
Marc Nurik 
William Berger 
Epstein sealed records and TV 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reaso...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissini? Edwards Fistos & Lehrman 
JIATES 
.ME 
TO 
FROM 
DESCRIPTION 
QBJECTIQN 
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/clien'I: 
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 ca...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
& 
I 
Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
rurr§ 
DATE 
TO 
EB.QM 
DESCRIPTION 
OBJECTION 
04893-04896 
09/10/2009 
Jacquie Johnson 
Bradley ~dwards 
Epstein Discovery 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04890 
09/10/2009 
Jacquie Johnson 
Bradley Edwards 
Epstein Discovery 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04884-04885 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
Epstein Discovery 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01469 
07/17/2009 
Ken Jenne 
Bradley Edwards 
Discussions about the Epstein 
Work 
product; 
attorney/client 
privilege; 
case 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04745-04747 
08/04/2009 
Bradley Edwards 
Jacquie Johnson 
Epstein depo in New York 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04738-04744 
08/25/2009 
Bradley Edwards 
Paul Cassell 
Hearing regarding the Epstein 
Work 
product; 
attorney/client 
privilege; 
computers 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04660 
10/22/2009 
Bradley Edwards 
Marc Nurik 
Epstein AUSA -Attorneys Fees 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04642-04646 
09/11/2009 
Bradley Edwards 
Beth Williamson 
Discussions 
ab...

NOT A CERTIFIED COPY
Privilege Log - Dated 2~23~2011 
& 
& 
I 
Farmer Jaffe Weissin~ Edwards. Fistos & Lehrman 
BATES 
MJ]. 
TO 
FROM 
D~SCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
04607-04617 
09/11/2009 
Jacquie Johnson 
Bradley Edwards 
Holding Fed Subs until we get Work 
product; 
attorney/client 
privilege; 
response on form 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04526-04535 
10/17/2009 
Bradley Edwards 
Paul Cassell 
Two ideas regarding strategy 
Work 
product; 
attorney/client 
priVilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04488-04490 
07/18/2009 
Bradley Edwards 
Paul Cassell 
Taking the 5th 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01362 
09/11/2009 
Elizabeth Villar 
Bradley Edwards 
Getting the forensic aspect off Work 
product; 
attorney/client 
privilege; 
the 
ground 
-epstein's 
asset 
irrelevant and not reasonably calculated to lead 
transfers 
to the discovery of the admissible evidence; 
protected by privacy rights 
04481-04487 
08/18/2009 
Paul Cassell 
Bradley Edwards 
Epstein Subpoena 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05465-05467 
06/26/2009 
Wayne Black 
Bradley Edwards 
Subpoenas for trial 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05470 
07/11/2009 
Bradley Edwards 
Wayne Black 
Flight Logs 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidenc...

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissim~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
ffiQM 
OESCRIPTIQN 
O~JECTION 
Rodriguez 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05501 
07/21/2009 
Wayne Black 
Bradley Edwards 
Litigation strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05524-05533 
07/23/2009 
Wayne Black 
Bradley Edwards 
Addresses for people involved in 
Work 
product; 
attorney /client 
privilege; 
the case 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05541 
07/31/2009 
Carolyn Edwards 
Bradley Edwards 
All depos in jane doe's case 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05635 
10/22/2009 
Pat Diaz 
Bradley Edwards 
New developments that require 
Work 
product; 
attorney/client 
privilege; 
your expertise 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rightsO 
146 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
& 
' 
I 
Farmer Jaffe Weissing Edwards. Fistos & Lehrman 
BATES 
DATE 
TO 
fRQM. 
DESCRIPTION 
OBJECTION 
05640 
10/29/2009 
Pat Diaz 
Bradley Edwards 
New Epstein victim 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05652-05653 
04/01/2009 
Bradley Edwards 
Carolyn Edwards 
personal discussion 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05671 
10/22/2009 
Bradley Edwards 
Pat Diaz 
Litigation strategy 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05696 
05/11/2009 
Bradley Edwards 
Wayne Black 
Phone number for one of the Work 
product; 
attorney/client 
privilege; 
other 
girls 
on 
the 
list 
of irrelevant and not reasonably calculated to lead 
prospective clients 
to the discovery of the admissible evidence; 
protected by privacy rights 
05815-05816 
04/01/2009 
Carolyn Edwards 
Bradley Edwards 
Taking the depos of everyone 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05820-05821 
07/23/2009 
Bradley Edwards 
Wayne Black 
Dates for depos of all witnesses 
Work 
product; 
attorney/client 
privilege; 
in the case 
irrelevant and not reasonably calculated to lead 
147 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
' 
I 
' 
Farmer Jaffe Weissin~ Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
05824-05825 
07/23/2009 
Bradley Edwards 
Wayne Black 
Paula Heil 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05828-05829 
07/23/2009 
Bradley Edwards 
Wayne Black 
Dates for depos of all witnesses 
Work 
product; 
attorney/client 
privilege; 
in the case 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05833-05835 
07/23/2009 
Bradley Edwards 
Wayne Black 
FBI has original flight logs and 
Work 
product; 
attorney/client 
privilege; 
they interviewed pilots 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05839-05841 
07/23/2009 
Bradley Edwards 
Wayne Black 
Copies of the flight logs 
Work 
product; 
attorney/ dient 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05869-05870 
04/01/2009 
Carolyn Edwards 
Bradley Edwards 
Personal convo between Brad 
Work 
product; 
attorney/client 
privilege; 
and Mom 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05913-05914 
04/01/2009 
Carolyn Edwards 
Bradley Edwards 
Personal convo between Brad 
Work 
product; 
attorney/client 
privilege; 
and Mom 
irrelevant and not reasonably calculated to lead 
to the discovery of the_ admissible evidence; 
protected by privacy rights 
148 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
' 
I 
l 
Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
BATES 
Qfil 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
05995 
04/01/2009 
Bradley Edwards 
Carolyn Edwards 
Third 
party 
subpoenas 
for Work 
product; 
attorney /client 
privilege; 
Tatum/Courtney 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06513-06523 
06/15/2009 
Bradley Edwards 
Wayne Black 
Ghisella Maxwell info 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06699-06701 
06/17/2009 
Wayne Black 
Bradley Edwards 
Epstein litigation 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07079-07089 
09/03/2009 
Bradley Edwards 
Pat Diaz 
Discussion about girls involved in 
Work 
product; 
attorney/client 
privilege; 
the case 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07437-07439 
10/19/2009 
Paul Cassell 
Ronald Wise 
New 
evidence 
of 
Epstein 
Work 
product; 
attorney/client 
privilege; 
Fraudulent transfers + Affidavit 
irrelevant and not reasonably calculated to lead 
from you 
to the discovery of the admissible evidence; 
protected by privacy rights 
07936-07958 
04/28/2009 
Earleen Cote 
Bradley Edwards 
Cases against mansion nightclub 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08006-08011 
06/03/2009 
Bradley Edwards 
Wayne Black 
Getting addresses for people for Work 
product; 
attorney/client 
privilege; 
us to serve subpoenas 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
& 
C 
' 
t 
Farmer Jaffe Weissinl! Edwards Fistos & Lehrman 
i,iATES 
Qfil 
TO 
FROM 
DESCRIPTION 
OBJECTION 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
26479-26481 
08/19/2009 
Attorneys at RRA 
KenJenne 
Assistance on the Epstein Case 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
27155-27159 
10/23/2009 
Attorneys at RRA 
Steven Jaffe 
PACER entries 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
26604-26605 
10/27/2009 
Phaedra Xanthos 
KenJenne 
Political 
Work 
product; 
attorney/client 
privilege; 
Contributions/advertisement for irrelevant and not reasonably calculated to lead 
the rental on little St. James to the discovery of the admissible evidence; 
Island 
protected by privacy rights 
26570 
08/13/2009 
Scott Rothstein 
MarcNurik 
Discussions about Epstein 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
04954 
10/28/2009 
Attorneys at RRA 
Jacquie Johnson 
Creation of another Doe file 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06665-06670 
08/12/2009 
Shawn Gilbert 
Bradley Edwards 
Epstein Costs 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
06675-06676 
08/26/2009 
Shawn Gilbert 
Bradley Edwards 
Personal convo in regards to Work 
product; 
attorney/client 
privilege; 
moving offices 
irrelevant and not re...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
& 
& 
I 
Farmer Jaffe WeissinJ? Edwards Fistos & Lehrman 
SATES 
DATE 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
06679-06682 
08/26/2009 
Bradley Edwards 
Shawn Gilbert 
Personal convo in regards to 
Work 
product; 
attorney /client 
privilege; 
moving offices 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
07590-07594 
05/13/2009 
Shawn Gilbert 
Bradley Edwards 
Office information 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08451-08453 
08/17/2009 
Bradley Edwards 
Pat Diaz 
Updated Witness List 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08455-08456 
06/03/2009 
Carla Martinez 
Bradley Edwards 
Vanity Fair 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08466-08479 
08/26/2009 
Attorneys at RRA 
Bradley Edwards 
Witness info that we need to use 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
01767 
07/06/2009 
Wayne Black 
Bradley Edwards 
Info on a guy going to victim's 
Work 
product; 
attorney/client 
privilege; 
boyfriends house 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
08379 
06/06/2009 
Bradley Edwards 
Wayne Black 
Info on Former FHP trooper Work 
product; 
attorney/client 
privilege; 
subcontracted by Riley 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
08399 
07/23/2009 
Bradley Edwards 
Paul Cassell 
Epstein...

NOT A CERTIFIED COPY
: ....... _. 
.· .. 
·····-··-·•.· .... ·-······· 
Privilege Log - Dated 2-23-2011 
! 
I 
' 
I 
Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
@ATES 
gfil 
IQ 
FROM 
DESCRIPTION 
OBJECTION 
to the discovery of the admissible evidence; 
protected by privacy rights 
08406 
10/30/2009 
Attorneys at RRA 
Russell Adler 
Flying epstein rape survivor to St. 
Work 
product; 
attorney/ client 
privilege; 
Louis to see expert 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05697 
08/19/2009 
Bradley Edwards 
Mike Flsten 
Meeting with client 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20330-20334 
08/24/2009 
Bradley Edwards 
Pat Roberts 
Serving Alan Oershowitz 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20327-20329 
10/17/2009 
Attorneys at RRA 
Mike Fisten 
Property purchased by Epstein in 
Work 
product; 
attorney/client 
privilege; 
Palm Beach 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20100-20102 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Epstein's arrival at his building 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20283-20326 
10/14/2009 
Attorneys at RRA 
Mike Fisten 
Research regarding Mr. Visoski 
Work 
product; 
attorney/client 
privilege; 
and questions to consider during irrelevant and not reasonably calculated to lead 
the depo 
to the discovery of the admissible evidence; 
protected by privacy rights 
20092-20099 
08/24/2009 
Attorneys at RRA 
KenJenne 
Epstein travel 
Work 
product; 
attorney/client 
...

NOT A CERTIFIED COPY
:,::,:·:-· 
·-··--···-·····-----·-·-···-·-· 
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OB!ECTIQN 
20085-20091 
10/15/2009 
Bradley Edwards 
Mike Fisten 
Questions from accountant 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
19996-20084 
10/14/2009 
Attorneys at RRA 
Mike Fisten 
Visoski Research and Questions 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20217-20218 
08/04/2009 
Bradley Edwards 
Mike Fisten 
Info on Copperfield 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20213-20216 
08/03/2009 
Attorneys at RRA 
KenJenne 
Info on Copperfield 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20211-20212 
08/03/2009 
Mike Fisten 
Bradley Edwards 
Pilots depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20207-20210 
08/10/2009 
Jacquie Johnson 
Bradley Edwards 
List of witness 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
20201-20204 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Serving Dershowitz 
protected by privacy rights 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
153 

NOT A CERTIFIED COPY
_____ _.:.;-_.,:_,.;-
Privilege Log- Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
MI! 
TO 
FROM 
DESCRIPTION 
OBJECTION 
20193-20200 
08/24/2009 
Attorneys at RRA 
Bradley Edwards 
Proof of him being out of FL -
Work 
product; 
attorney/client 
privilege; 
Violation of the agreement 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
19982-19985 
09/03/2009 
Jacquie Johnson 
Mike Fisten 
Dave Rogers depo 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
19988 
10/07/2009 
Jacquie Johnson 
Mike Fisten 
Depositions 
Work 
product; 
attorney /client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
19971-19981 
08/24/2009 
Attorneys at RRA 
Mike Fisten 
Serving Dershowitz 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
19969-19970 
08/18/2009 
Bradley Edwards 
Mikefisten 
Subpoenas for Pilots 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
19962-19968 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Working with the FBI to get some 
Work 
product; 
attorney/client 
privilege; 
info 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20190-20192 
08/24/2009 
Pat Roberts 
Bradley Edwards 
Personal emails regarding Brad's Work 
product; 
attorney/client 
privilege; 
surgery 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
20187-20189 
08/24/2009 
Attor...

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
' 
& 
' 
I 
Farmer Jaffe Weissinf! Edwards Fistos & Lehrman 
§ATES 
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 reasonabl...

NOT A CERTIFIED COPY
______ ;·:_,::_. ___ . 
_ _. _________ . 
Privilege Log- Dated 2-23-2011 
t 
' 
I 
I 
Farmer Jaffe Weissing Edwards Fistos & Lehrman 
QATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
03129-03130 
06/09/2009 
Josh Roberts 
Bradley Edwards 
Personal conversation 
Work 
product; 
attorney/client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
03119-03121 
06/09/2009 
Bradley Edwards 
Josh Roberts 
Personal conversation 
Work 
product; 
attorney/ client 
privilege; 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05440-05441 
04/01/2009 
Bradley Edwards 
Carolyn 
(Legal 
CW Personal information 
Work 
product; 
attorney/client 
privilege; 
Asst. 
ta 
Jay 
irrelevant and not reasonably calculated to lead 
Howell, 
Ca-
to the discovery of the admissible evidence; 
Counsel) 
protected by privacy rights 
02593-02594 
05/13/2009 
T. Edwards (wife) 
Bradley Edwards 
Regarding personal information. 
Privileged 
document• irrelevant and not 
calculated to lead to discovery of admissible 
evidence, privacy rights of parties involved, 
spouse privilege 
18877-18879 
09/10/209 
Marc Nurik 
Bradley Edwards 
Concerning 
the 
names 
of Work 
product; 
attorney/client 
privilege; 
potential 
witnesses 
and 
the irrelevant and not reasonably calculated to lead 
issuance of subpoena's for them. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18344-18347 
08/24/2009 
Bradley Edwards 
Mike Fisten 
Investigative 
information 
and 
Work 
product; 
attorney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
156 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer. Jaffe. Weissin2. Edwards. Fistos & Lehrman 
BATES 
.QAll 
TO 
fBQM 
DESCRIPTION 
OBJECTION 
18339-18340 
08/24/2009 
KenJenne 
Bradley Edwards 
Investigative 
information 
and 
Work 
product; 
att~rney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18341-18343 
08/24/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
information 
and 
Work 
product; 
attorney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18853-18854 
09/10/2009 
Bradley Edwards 
Jacquie Johnson 
Concerning 
the 
names 
of Work 
product; 
attorney/client 
privilege; 
potential 
witnesses 
and 
the Irrelevant and not reasonably calculated to lead 
issuance of subpoena's for them. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18337-18338 
08/03/2009 
Bradley Edwards 
Mike Fisten 
Investigative 
information 
and 
Work 
product; 
attorney/client 
privilege; 
techniques on the Epstein case 
irrelevant and not reasonably calculated to lead 
are discussed. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18306 
10/16/2009 
Pat Roberts 
Ken Jenne 
List of future depo's in Epstein 
Work 
product; 
attorney/client 
privilege; 
case and names of potential 
irrelevant and not reasonably calculated to lead 
witnesses. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18307 
10/17/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein Assets. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
157 

NOT A CERTIFIED COPY
Privilege Log- Dated 2-23-2011 
Farmer. Jaffe. Weissini?. Edwards. Fistos & Lehrman 
l}ATES 
DATE 
!.Q 
FROM 
DESCRIPTION 
OBJECTION 
18308-18309 
10/18/2006 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein Assets. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
18188-18189 
09/04/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein witnesses and 
irrelevant and not reasonably calculated to lead 
names of potential witnesses. 
to the discovery of the admissible evidence; 
protected by privacy-rights 
18184-18185 
08/26/2009 
Mike Fisten 
Bradley Edwards 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
finding of Epstein witnesses and 
irrelevant and not reasonably calculated to lead 
names of potential witnesses. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18186-18187 
08/31/2009 
Bradley Edwards 
Jacquie Johnson 
Discussion of potential witnesses Work 
product; 
attorney/client 
privilege; 
and the process of subpoena for irrelevant and not reasonably calculated to lead 
depo's. 
to the discovery of the admissible evidence; 
protected by privacy rights 
18180-18183 
08/24/2009 
Bradley Edwards 
Mike Fisten 
Investigative 
Discussion 
re: Work 
product; 
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 
I 
I 
I 
I 
Farmer Jaffe Weissine Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
05253 
08/24/2009 
Bradley Edwards 
Wayne Black 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05279-05280 
08/24/2009 
Bradley Edwards 
Pat Roberts 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05315-05318 
07/26/2009 
Bradley Edwards 
Wayne Black 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
05209-05211 
06/26/2009 
Bradley Edwards 
Wayne Black 
Investigative 
Discussion 
re: 
Work 
product; 
attorney/client 
privilege; 
strategy of case. 
irrelevant and not reasonably calculated to lead 
to the discovery of the admissible evidence; 
protected by privacy rights 
159 

NOT A CERTIFIED COPY
EXHIBIT I 

NOT A CERTIFIED COPY
EXHIBIT I 
DOCUMENTS PRODUCED BY EDWARDS IN MAY 2012 THAT 
ARE ON HIS FEBRUARY 23, 2011, PRIVILEGE LOG 
AND IDENTIFIED ON EPSTEIN'S NOVEMBER 16, 2017 EXHIBIT LIST 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
94 
5/22/09 
E-mail from Bradley J. Edwards to Susan Spencer 
p.52 
12:13 p.m. 
Wendel (01449) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01449 
5/22/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
95 
5/22/09 
E-mail from Susan Spencer Wendell to Bradley J. 
p.55 
12:21 p.m. 
Edwards (05148) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05148 
5/22/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
97 
5/26/09 
E-mail from Timothy Malloy to Bradley J. Edwards 
p.55 
5:33 p.m. 
(05151) 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05151 
5/26/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
98 
5/28/09 
E-mail from Susan Spencer Wendell to Bradley J. 
p.55 
2:13 p.m. 
Edwards (05161) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05161 
5/28/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
99 
5/28/09 
E-mail from Bradley J. Edwards to William J. Berger 
p.46 
2:16 p.m. 
(02241-02242) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02241-
5/28/09 
Confidential 
Bradley 
Other Rape 
W/P Priv.; not reasonably 
02242 
Source 
Edwards 
Victims 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
102 
6/9/09 
E-mail from Bradley J. Edwards to Eric Glasser (06655) 
pp. 54-55 
3:10 p.m. 
2 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06655 
6/9/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
105 
6/23/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.55 
1:13 p.m. 
(05239) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05239 
6/23/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
106 
6/23/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.55 
1:16 p.m. 
(05203) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05203 
6/23/09 
Confidential 
Bradley 
Providing New 
W/P Priv.; not reasonably 
Source 
Edwards 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
107 
6/23/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.55 
1:29 p.m. 
(05277-05278) 
3 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05277-
6/23/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
05278 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
108 
6/23/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.55 
2:31 p.m. 
(05207-05208) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05207-
6/23/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
05208 
Course 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
109 
6/23/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.55 
2:41 p.m. 
( 05324-05325) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05324-
6/23/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
05325 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
110 
6/23/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.47 
2:53 p.m. 
(05212-05213) 
4 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05212-
6/23/09 
Confidential 
Bradley 
Secret Plea Deal 
W/P Priv.; not reasonably 
05213 
Source 
Edwards 
for Epstein 
calculated to lead to 
Providing New 
discovery of admissible 
Witnesses 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
111 
6/23/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.48 
3:08 p.m. 
(05344-05346) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05344-
6/23/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
05346 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
112 
6/23/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.47 
3:12 p.m. 
(05215-05217) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05215-
6/23/09 
Confidential 
Bradley 
Secret Plea Deal of 
W/P Priv.; not reasonably 
05217 
Source 
Edwards 
Epstein providing 
calculated to lead to 
new witnesses 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
113 
6/23/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.55 
4:39 p.m. 
( 05368-05369) 
5 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05368-
6/23/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
05369 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
114 
6/23/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.55 
5:22 p.m. 
(05220-05221) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05220-
6/23/09 
Confidential 
Bradley 
Secret Plea Deal 
W/P Priv.; not reasonably 
05221 
Source 
Edwards 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
115 
6/23/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.55 
5:28 p.m. 
(05387-05388) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05387-
6/23/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
05388 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
116 
6/24/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.55 
9:39 a.m. 
( 05224-05225) 
6 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05224-
6/24/09 
Confidential 
Bradley 
Secret Plea Deal 
W/P Priv.; not reasonably 
05225 
Source 
Edwards 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
119 
7/4/09 
E-mail from Bradley J. Edwards to William J. Berger 
pp. 46-47 
4:37 p.m. 
(02204) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02204 
7/14/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
120 
7/15/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.55 
1:17 p.m. 
(04906) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04906 
7/15/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
121 
7/15/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.55 
1:22 p.m. 
(04905) 
7 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04905 
7/15/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
124 
7/22/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.52 
11:22 a.m. 
(01479) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01479 
7/22/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
125 
7/22/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.49 
11:35 a.m. 
(05803) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05803 
7/22/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
129 
7/28/09 
E-mail from Bradley J. Edwards to Susan Spencer 
p.52 
8:59 a.m. 
Wendel (01483) 
8 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01483 
7/28/09 
Confidential 
Bradley 
Additional 
W/P Priv.; not reasonably 
Source 
Edwards 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
130 
7/28/09 
E-mail from Susan Spencer Wendel to Bradley J. 
p.53 
8:59 a.m. 
Edwards (03070) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
03070 
7/28/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
131 
7/28/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.52 
9:28 a.m. 
(01486) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01486 
7/28/09 
Confidential 
Bradley 
Providing New 
W/P Priv.; not reasonably 
Source 
Edwards 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
132 
7/28/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.50 
10:00 a.m. 
(05848) 
9 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05848 
7/28/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
134 
7/28/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.57 
1:47 p.m. 
(11075-11076) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
11075-
7/29/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
11076 
Edwards 
Source 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
135 
7/29/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.50 
1:49 p.m. 
( 05852-05853) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05852-
7/29/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
05853 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
136 
7/30/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.48 
2:36 p.m. 
( 05535-05536) 
10 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05535-
7/30/09 
Confidential 
Bradley 
Additional 
W/P Priv.; not reasonably 
05536 
Source 
Edwards 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
137 
7/30/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.57 
2:36 p.m. 
(11320-11322) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
11320-
7/30/99 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
11322 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
138 
7/30/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p.48 
6:06 p.m. 
( 05538-05539) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05538-
7/30/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
05539 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
139 
7/31/09 
E-mail from Michele Dargan to Bradley J. Edwards 
p.57 
11:20 a.m. 
(11080-11082) 
11 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
11080-
7/31/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
11082 
Edwards 
Source 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
140 
8/10/09 
E-mail from Bradley J. Edwards to Michael lsikoff 
p.50 
6:59 p.m. 
(06965) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06965 
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
141 
8/10/09 
E-mail from Michael lsikoff to Bradley J. Edwards 
p.50 
7:23 p.m. 
(06967) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06967 
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
142 
8/11/09 
E-mail from Bradley J. Edwards to Michael lsikoff 
p.50 
8:43 a.m. 
(06968-06969) 
12 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06968-
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06969 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
143 
8/11/09 
E-mail from Michael lsikoff to Bradley J. Edwards 
p.50 
9:29 a.m. 
(06963-06964) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06963-
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06964 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
144 
8/11/09 
E-mail from Bradley J. Edwards to Michael lsikoff 
p.50 
10:10 a.m. 
(06970-06971) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06970-
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06971 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
145 
8/11/09 
E-mail from Michael lsikoff to Bradley J. Edwards 
p.50 
12:34 p.m. 
(06959-06960) 
13 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06959-
8/11/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
06960 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
146 
8/14/09 
E-mail from Michael lsikoff to Bradley J. Edwards 
p.50 
4:40 p.m. 
(06975) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06975 
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
148 
8/15/09 
E-mail from Bradley J. Edwards to Michael lsikoff 
p.50 
6:00 p.m. 
(06972-06973) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06972-
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06973 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
149 
8/17/09 
E-mail from Michael lsikoff to Bradley J. Edwards 
p.50 
10:32 a.m. 
(06976-06977) 
14 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06976-
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06977 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
150 
8/17/09 
E-mail from Bradley J. Edwards to Jacquie Johnson 
p.47 
10:42 a.m. 
(02442) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02442 
8/17/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
152 
8/24/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p.52 
7:38 p.m. 
(01506) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01506 
8/24/09 
Confidential 
Bradley 
Other Rape 
W/P Priv.; not reasonably 
Source 
Edwards 
Victims 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
153 
8/25/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.50 
11:03 a.m. 
(05952-05953) 
15 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05952-
8/25/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
05953 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
154 
8/26/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p.53 
9:56 p.m. 
(02269) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02269 
8/26/09 
Confidential 
Bradley 
Other Rape 
W/P Priv.; not reasonably 
Source 
Edwards 
Victims 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
155 
8/31/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.53 
10:58 a.m. 
(02895) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02895 
8/31/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
Edwards 
Source 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
157 
9/7/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
1:39 p.m. 
(07612-07613) 
16 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07612-
9/7/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
07613 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
158 
9/7/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.53 
6:42 p.m. 
( 02595-02596) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02595-
9/7/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
02596 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
159 
9/7/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p. 51 
6:49 p.m. 
(07614-07615) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07614-
9/7/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
07615 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
160 
9/7/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
7:00 p.m. 
(07605-07606) 
17 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07605-
9/7/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
07606 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
161 
9/7/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p. 51 
8:12 p.m. 
(07607-07608) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07607-
9/7/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
07608 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
162 
9/7/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
10:55 p.m. 
(07609-07611) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07609-
9/7/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
07611 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
163 
9/8/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p.54 
11:43 a.m. 
(04015) 
18 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04015 
9/8/09 
Confidential 
Bradley 
Providing New 
W/P Priv.; not reasonably 
Source 
Edwards 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
164 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
11:50 a.m. 
(07646) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07646 
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
165 
9/8/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p. 51 
11:53 a.m. 
(07647) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07647 
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
166 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
12:04 p.m. 
(07676-07677) 
19 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07676-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07677 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
167 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
1:59 p.m. 
(07674-07675) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07674-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07675 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
168 
9/8/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p. 51 
2:04 p.m. 
(07678-07679) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07678-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07679 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
169 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
2:36 p.m. 
(07684-07685) 
20 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07684-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07685 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
171 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
2:49 p.m. 
(07695-07697) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07695-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07697 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
170 
9/8/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p. 51 
2:42 p.m. 
(07682-07683) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07682-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07683 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
172 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
3:25 p.m. 
(07680-07681) 
21 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07680-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07681 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
173 
9/8/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p. 51 
7:51 p.m. 
(07686-07688) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07686-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07688 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
174 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
7:53 p.m. 
(07689-07691) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07689-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07691 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
175 
9/8/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 51 
7:53 p.m. 
(07692-07694) 
22 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
07692-
9/8/09 
Bradley 
Confidential 
Providing New 
W/P Priv.; not reasonably 
07694 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
179 
9/18/09 
E-mail from Bradley J. Edwards to Susan Spencer 
p.48 
1:01 p.m. 
Wendel (05619-05620) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
05619-
9/18/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
05620 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
181 
9/18/09 
E-mail from Bradley J. Edwards to Michele Dargan 
p. 56 
2:55 p.m. 
(01280-01288) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01280-
9/18/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
01288 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
182 
9/21/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.54 
1:37 p.m. 
(03081) 
23 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
03081 
9/21/09 
Bradley 
Confidential 
Providing 
W/P Priv.; not reasonably 
Edwards 
Source 
Witnesses 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
183 
9/23/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.47 
8:42 p.m. 
(04320) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04320 
9/24/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
184 
9/24/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p.47 
6:31 a.m. 
(04321) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04321 
9/24/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
185 
9/24/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.47 
6:53 a.m. 
(04318-04319) 
24 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
04318-
9/24/09 
Confidential 
Bradley 
Litigation Strategy 
W/P Priv.; not reasonably 
04319 
Source 
Edwards 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
186 
9/24/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p. 56 
8:45 p.m. 
( 10586-10589) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
10586-
9/24/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
10589 
Edwards 
Source 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
187 
9/28/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards, cc 
p.54 
8:09 a.m. 
Renee/Carlos Morrison (02913) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02913 
9/28/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
188 
9/28/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p.50 
10:06 a.m. 
(06789) 
25 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06789 
9/28/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
189 
9/28/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.50 
10:20 a.m. 
(06788) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06788 
9/28/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
190 
9/28/09 
E-mail from Mike Fisten to Conchita Sarnoff (19986-
p.55 
11:45 p.m. 
19987) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
19986-
9/28/09 
Confidential 
Bradley 
Additional 
W/P Priv.; not reasonably 
19987 
Source 
Edwards 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
194 
10/2/09 
E-mail from Michael lsikoff to Bradley J. Edwards 
p.50 
4:28 p.m. 
(06979-06980) 
26 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06979-
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06980 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
195 
10/2/09 
E-mail from Bradley J. Edwards to Mike Fisten (02440-
p.47 
4:52 p.m. 
02441) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
02440-
10/2/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
02441 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
196 
10/2/09 
E-mail from Bradley J. Edwards to Michael lsikoff, cc 
p.50 
4:53 p.m. 
Jacquie Johnson (06974) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06974 
8/11/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
197 
10/2/09 
E-mail from Michael lsikoff to Bradley J. Edwards, cc 
p.50 
6:14 p.m. 
Jacquie Johnson (06955-06956) 
27 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06955-
10/2/09 
Bradley 
Confidential 
Litigation Strategy 
W/P Priv.; not reasonably 
06956 
Edwards 
Source 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
198 
10/8/09 
E-mail from Bradley J. Edwards to Richard Johnson 
p.50 
4:11 p.m. 
(06961) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
06961 
8/11/09 
Bradley 
Confidential 
Secret Plea Deal 
W/P Priv.; not reasonably 
Edwards 
Source 
for Epstein 
calculated to lead to 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
202 
10/14/09 
E-mail from Bradley J. Edwards to Conchita Sarnoff 
p.54 
7:39 a.m. 
(03190) 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
03190 
10/14/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
Edwards 
Source 
Information re; 
calculated to lead to 
Epstein Strategies 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
203 
10/14/09 
E-mail from Conchita Sarnoff to Bradley J. Edwards 
p.54 
9:02 a.m. 
(03189) 
28 

NOT A CERTIFIED COPY
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
03189 
10/14/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
Edwards 
Source 
Information Re: 
calculated to lead to 
Epstein Strategies 
discovery of admissible 
evidence 
EPSTEIN'S NOVEMBER 16, 2017, EXHIBIT LIST 
No. 
Date 
Document 
Privilege 
Log 
208 
10/20/09 
E-mail from George Rush to Bradley J. Edwards (01433) 
p.52 
1:01 p.m. 
FARMER JAFFE'S FEBRUARY 23, 2011 PRIVILEGE LOG 
Bates 
Date 
To 
From 
Description 
Objection 
01433 
10/20/09 
Bradley 
Confidential 
Additional 
W/P Priv.; not reasonably 
Edwards 
Source 
Information Re: 
calculated to lead to 
Epstein 
discovery of admissible 
Molestations 
evidence 
29 

NOT A CERTIFIED COPY
EXHIBIT J 

NOT A CERTIFIED COPY
IU THE CIRCUIT COURT OF THE 
FfFrtENTH JU.DfC:I.AL CIRCUIT, _TN 
AND FOR PALM BEACH COUNTY; FLORIDA 
~-
.. 
case No~ 5 02 o 6 9,CAO 4 b so 0XXXXMB 
JEFFREY EPSTEIN, 
Piainti'ff /coun:ter-,Defendant, 
SCOTT RO'I'HS_TEJN, in,diviciua,lly; 
'BRADLEY EDWARDS, ind:ividually, 
Qe:Eendants/Counter-Plaintiffs. 
I 
-----------------
TRANSCRIPT OF PROCEEDINGS 
.DATE TAKEN: 
TIME: 
·.PLACE 
BEFORE: 
_TfiursdaJ-1f March 18th; 2018 
:1:30 p. m~ -
4 :50 :p .m. 
2·05 N •. Dixie Highwayi, Room. 10D 
West Palm Beach, Florida 
·oonald Ha._fele, Pres:Lciing Judge 
This cause :Came on. to_ be heard at .the time and 
v1ac§ aforesaid, when and where the ;fo'llowing 
proceedings were reported by: 
Elaine v. Williams 
Palm Beach .~ep9rting S~rvice, Inc. 
'1665 Palm 'Beach Lakes Boulevard, 9uite iodi 
West J?alm Beach, :FL. 33401 
(561) 471-2;)9-5 
·Palm. Beach Reporting service; Inc. 
_561.-471-2995 
.1 

NOT A CERTIFIED COPY
1·· 
.' I 
w ... , 
\ ., 
., 
1 
2 
3 
4 
5 
6 
7 
8 
Q 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
.APPEARANCES.:. 
For Plaintiff/Qounter,-Defendant: 
ttNK &; ;ROCKENBACH, ·p . A. 
1555 ;Palm Beach Lakes Boulevard, Suite. 301 
West 'Palm Beach, 'FL 33401 
By KA.RA BERARD R,OCKEtU3A.CH, ESQQIRE 
By SCOTT J~ LINK, ESQUIRE, 
For Defendarit/Cc:iunter-Plaintiff: 
SEA!lCY,. DENNEY, SCAROLA, BARNHART & 
SHIPLEY, P.A. 
2139 Palm Be~dh L~kes Boulevard, 
West Palm Beach, 'FI, 33409 
By JACK SCAROLA, ESQUIRE 
By DAVID P. VITALE JR., ESQUIRE 
By KAREN TERRY., ESQUIRE' 
For Non-Parties L.M . ., E.W. & ,Jahe: Doe 
HATCH,. JAMES & DODGE, P~ .C'. 
'10 'West Broadway; Suite 400 
Salt Lake City, UT 84101 
By PAUL G. ·CASSELL, ESQUIRE 
_For Je:ftrey Epstein:.: 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Austral:i.an,Ayi3~ Soui:h, Suite 1400 
West Palm Beach,. FL 
33401 
By JACK A. GQLDBERGER, ESQUIRE 
Palm .Beach Reporting Servic:e, \Inc. 
561,-,471:-2995 
2 

NOT A CERTIFIED COPY
\ :· 
·, \, 
') 
•i 
1 
:'2 
:3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
1,3 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
2!{ 
MR. SCl\ROLl\.: 
That is correct. 
The Conrad 
' 
-
9cherer firm was involved in that litigation, a.hd 
the, Conrad Scherer firrn wa.s also interested. ln 
getting to t:ake a. 10:ok .at whatever rel~vant e-:-mai1s 
might have been. in the hands of tlJ.e bankruptcy 
trustee, and then got turned over :to us. 
Well; ther~ were, direct ,negotiations in which 
I was a personal participant with, the lawyers for 
Conrad Scherer, a.rid ari agreement was. reached with. 
the• lawyers for CO:nra.d Scherer. because, as We haye 
told. every judge before whom we have appearecl ~1th 
regard to these matters, ·we' re not attempting to 
h:Lde anything. (You want to conduct. an in:-carner~ 
Clii§pection) (we want you to conduct an iri-carner~ 
Ciri..§.Rection because it will confirm tha.t we're notj 
(attem12tin·g to hide anything. 
We will turn ayer anythir1g tpat you consider 
,af)propria.te for us to turn. over. 
_But we have. no 
ability to waivE:! our client''s ,attorney-client 
privilege, your Honor, and some of these e"""'.:fuails 
clearly •,contain .inforrna.tioh that originated with 
clients. 
And we a.re :L-n: the midst at this point ·Of 
still-peric:i.ing iitiga.:tion, and .it: :Ls important for 
us to ·protect our work product privilE!ge as well. 
Some of t:ha't 1.itigatioµ is stilL ongoing right now. 
.Palm. Beach Reporting Service, ;Inc. 
561,-c47i"°2995 
' • 
-
15 

NOT A CERTIFIED COPY
,. 
•d 
''i 
,, 
1 
2 
3 
4 
5 
6 
7 
8 
9 
·10 
11 
12 
13 
14 
151 
16 
17 
18 
19 
20. 
2i 
22 
23 
24 
25 
'i, 
_that was not in the, hands of Mr~ ~pstein'' s lawyers 
since 2009, whenever this all came .to fruition, 
then I .would .say we'd have to: take a different 
approach. 
'But the very nature bf' the documents 
that we're talking ;about -- again, right:Iy or 
wrongiy held -- were in, fact ]1eld, by Fowler White, 
Epstein:i s: c9,unseJ.,, ,at an Jncredib:Le crucial time in 
this px-oce_ss; and· that being in and around 2010, 
when the Rothstein firm imploded, wheri ·these 
e-mails• were apparently confiscated, when sorri.ebpdy 
inade the decision that instead of Farmer paying for 
the .copy costs, they ':be handed over to Fowler 
Whi;te; 
}i.nd if I have a btt of an incredulous tone 
to that .statern,er1t, it's probably purposeful. 
But the fact remains, Mr. Lirik, that these 
materials were in the hands of Epstein.is attorneys 
from the; inception of the :Ls sue. itself. 
And to now, 
.come to 'the Court with. not fiye pages of doc.urnents 
to look at, b_ut. :21, ()00, or wh_atever that number 
,is ;,.;,_;. it ~scapes me 1::>eca,use of its shear •mass. -- is 
impossible and is not going to be cburitenariced 
:here. 
(And ~· (understand what you' re g~ to tell me) 
(because I've gotten -~ (flayor for some of these) 
(documeht$ that have been provi:a~d). 
Palm, .Beach Reporting Service,, Ind·• 
~61:-471:--2995 
51 

NOT A CERTIFIED COPY
,. 
'r 
;1 
'2: 
3 
4 
5 
6 
7 
8, 
9 
1a 
11 
:·12 
'13 
i4 
is 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25. 
MR~ LINK: 
'Y~s, sir~ 
'l'JIE COURT:. (Aoo--=tfiat is tfiat tliey are 
(detrimental to the position taken by_Jg} (Edward~ 
( and tnat tliey are .. helpful 'to the position taken l5y 
.The issue,. though, is one of wh~ther ·the 
protocol and the orderly _administration of. justice 
is. going to be forsaken notwithstanding also the 
aspect of privilege and the sanctity of priv:i..leged, 
communications, whether all of those considerations 
are g6irig to be thrown out whenpalanced 'against 
material that has be~n in. the hands of 
Mr. Epstein' s lawyers fr.om day one. 
And I, for 
one, .a,m not going to .sacrifice protocol over. what 
may or 'may :not be, nuinber ohe, privileged/ ,and :if 
nOt privileged,. certainly late disclosed 
d6cumehtati6h of a mass:i.ve nature. 
i 
Should the amount qf documentation be a 
determinative f 9ct:or i.ri a court's analysis in this 
context, l:>a.sed upon :.35 years of: compound 
experience, bench and bar, and, a little bit more 
now ·than half on the bench, I do not believe that 
the order;Ly administratfon _of justice should. be 
colinten·anced and should be disrupt:,i ve.~ 
Should be 
disruptive. 
Palm Beath. Reporting Service, Inc. 
561"-'471:-'2995' 
52 

NOT A CERTIFIED COPY
EXHIBIT K 

NOT A CERTIFIED COPY
INRE: 
Case 09-34791-RBR 
Doc 6323 
Filed 03/19/18 
Page 1 of 23 
UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
www.flsb.uscourts.gov 
ROTHSTEIN ROSENFELDT ADLER, P.A., 
CASE NO.: 09-34791-RBR 
CHAPTER 11 
Debtor. 
I 
----------------
MOTION FOR ISSUANCE OF AN ORDER TO SHOW CAUSE WHY FOWLER 
WHITE AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF 
COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR 
OTHER APPROPRIATE RELIEF 
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through 
counsel, hereby moves this honorable Court for an Order to Show Cause Why Fowler White and 
Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to Assess 
Sanctions and Costs, and for Other Appropriate Relief, and as grounds therefore states as follows: 
INTRODUCTION 
As the Court will recall from previous litigation in this matter, Jeffrey Epstein is a convicted 
sex offender who has been sued by dozens of victims for sexual abuse of children. In the course 
of the above-captioned bankruptcy proceedings, in 2010, Epstein served a broad subpoena 
attempting to secure thousands of attorney communications by Farmer Jaffe attorney Bradley J. 
Edwards, Esq., who while previously employed as an attorney at Rothstein Rosenfeldt Adler 
("RRA") had represented a number of Epstein's victims in their civil suits against Epstein. Farmer 
Jaffe sought to have Epstein bear the costs of copying and Bates stamping these thousands of 
documents [DE 1120], ultimately resulting in an order from this Court that Epstein's counsel-
attorneys at the law firm of Fowler White Burnett, P.A. ("Fowler White")-would make a copy 
of the materials and return them to Farmer Jaffe. Because of Farmer Jaffe's obvious concern that 
1 

NOT A CERTIFIED COPY
Case 09-34791-RBR 
Doc 6323 
Filed 03/19/18 
Page 2 of 23 
Epstein or his legal counsel might misappropriate these documents while in their physical 
possession for the limited purpose of copying and Bates numbering them, this Court specifically 
ordered that "Fowler White will not retain any copies of the documents contained on the discs 
provided to it, nor shall any images or copies of said documents be retained in the memory of 
Fowler White's copiers." 
[DE 1194]. 
To ensure compliance with its order involving the 
transmission of highly sensitive materials, this Court specifically added an enforcement provision: 
"Should it be determined that Fowler White or Epstein retained images or copies of the subject 
documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor 
of Farmer, Brad Edwards or his client." [DE 1194]. 
Remarkably, in clear and intentional defiance of this Court's order, Farmer Jaffe recently 
discovered that Fowler White indeed retained a copy of the confidential materials at issue-and 
those materials have now been passed along to Epstein's current set of lawyers, as well as to 
Epstein personally. Not to put too fine a point on it, Epstein and his lawyers at Fowler White 
appear to have misappropriated a set of confidential documents, which include sensitive and 
attorney-client protected communications about Epstein's sex abuse victims, and those documents 
to this day remain in the possession of the victims' sexual abuser, Epstein. 
Farmer Jaffe asks this Court to enter an order to show cause, to allow appropriate discovery 
into the apparent misconduct, and to ultimately enter sanctions and costs as may be appropriate. 
HISTORICAL BACKGROUND 
While information surrounding the apparent misappropriation of privileged documents is 
continuing to be revealed, it appears that the following facts cannot be reasonably contested by 
Fowler White or Epstein and, should any of them be conte...

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1. 
From the 1990s through the 2000s, billionaire Jeffrey Epstein sexually abused 
dozens of then-minor girls in his Palm Beach mansion in the Southern District of Florida and 
elsewhere. Several of these victims, including L.M., E.W., and "Jane Doe," were represented by 
Farmer Jaffe attorney Bradley J. Edwards in their civil suits against Epstein. [DE 1120]. 
2. 
Edwards filed the three sexual abuse lawsuits against Epstein in 2008 while a sole 
practitioner before taking the cases with him while Edwards was employed at RRA from April 
2009 through the firm's implosion in November 2009. 
3. 
In late 2009, Epstein sued Edwards for purportedly improperly representing his 
clients who were Epstein's sex abuse victims. Jeffrey Epstein v. Scott Rothstein, Bradley J. 
Edwards, and L.M, Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 
50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). 
4. 
On April 17, 2010, Epstein served a subpoena in the Epstein lawsuit upon Rothstein 
Rosenfeldt Adler, PA ("RRA") Bankruptcy Trustee Howard Stettin, seeking to obtain documents 
from the Trustee, which included documents from attorney Edwards related to Edwards' 
representation of the sex abuse victims while at RRA. [DE 807]. 
5. 
On May 18, 2010, this Court entered an Order approving a proposed Document 
Production Protocol delineating the process that the RRA Bankruptcy Trustee would use to 
identify documents responsive to (among other requests) Epstein's subpoena. [DE 672]. The 
Order provided this Court with jurisdiction over all discovery sought from the RRA Trustee. 
6. 
On August 13, 2010, this Court appointed former Broward County Circuit Judge 
Robert Camey as Special Master, who was directed to work with counsel for the Trustee to obtain 
documents responsive to the subpoena served upon the Trustee by Jeffrey Epstein. Specifically, 
the Special Master was t...

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documents in the Trustee's possession, including Qtask1 data for purposes of determining the 
applicability of the attorney/client and work product privileges that may inure to the benefit of 
L.M., and Brad Edwards, and other current or former clients of Farmer, Jaffe; (ii) segregate any 
such privileged documents; and (iii) prepare a privilege log in accordance with standard practice 
and law." [DE 888]. 
7. 
On September 20, 2010, Special Master Camey moved for clarification of this 
Court's order, suggesting that Farmer Jaffe be permitted the opportunity to review the documents 
themselves in order to determine the applicability of privileges. [DE 1013]. 
8. 
On October 15, 2010, this Court amended [DE 888] to require the RRA Trustee to 
provide the emails at issue to Farmer Jaffe and requesting that Farmer Jaffe prepare the privilege 
log. [DE1068]. 
9. 
On November 2, 2010, L.M. and Edwards filed a Motion requesting that Epstein, 
the party seeking the discovery, bear the printing expense and other reasonable costs and attorney's 
fees associated with his discovery request. [DE 1120]. 
10. 
On November 30, 2010, this Court entered an Agreed Order directing the law firm 
of Fowler White Burnett, P.A. to print a hard copy of all of the documents contained on the discs 
with Bates numbers added, and provide a set of copied, stamped documents to the Special Master 
and an identical set to Farmer Jaffe Weissing Edwards Fistos & Lehrman ("Farmer Jaffe"). The 
Farmer Jaffe attorneys were to then use their set to create its privilege log. [DE 1194]. 
11. 
The Court, recognizing the trust Farmer Jaffe was being forced to place in the 
adversary lawyers to perform the copying and Bates numbering without stealing the materials, 
specifically ordered, "Fowler White will not retain any copies of the documents contained on 
1 Qtask was an internal firm electronic communication platform. 
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the discs provided to it, nor shall any images or copies of said documents be retained in the 
memory of Fowler White's copiers. Should it be determined that Fowler White or Epstein 
retained images or copies of the subject documents on its computer or otherwise, the Court 
retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards or his client." [DE 
1194]. 
12. 
On December 13, 2010, 27,542 bates stamped documents were provided to Farmer 
Jaffe. 
13. 
On January 25, 2011, Farmer Jaffe provided Epstein with 8,408 pages of non-
privileged emails. 
14. 
On January 26, 2011, Farmer Jaffe served Epstein with a privilege log governing 
the remainder of the documents. 
15. 
On February 15, 2011, Epstein challenged the privilege log as insufficient before 
this Court. [DE 1442]. 
16. 
On February 23, 2011, Farmer Jaffe provided Epstein with an additional 12,711 
pages of emails, 2 and an Amended Privilege Log containing 159 pages identifying the remaining 
6,471 pages of emails containing privileged information that were not being produced. 
17. 
On March 25, 2011, Special Master Camey filed his Interim Report before this 
Court confirming that of the more than 27,000 pages of emails, all documents had been released 
to Epstein subject to confidentiality provisions, with the exception of the documents identified on 
2 The 12,711 pages of documents were divided into two separate categories respectively labeled 
"attorneys eyes only" and "Farmer Jaffe Irrelevant E-Mails." Two boxes of "attorneys eyes only" 
documents were produced containing 1,829 pages of documents in the first box and 3,198 pages 
of documents in the second box, totaling 5,027 pages. Two 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, totaling 7,684 pages. 
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Farmer Jaffe's 159-page privilege log of February 23, 2011, which documents were not subject to 
discovery. [DE 1570]. 
18. 
In 2012, additional litigation ensued regarding some of the documents in state court 
in the Epstein lawsuit against Edwards. 3 
19. 
To date, 21,282 pages of emails have been permissibly and lawfully provided to 
Epstein. Consequently, 6,471 pages of emails have never been provided to be retained by Epstein 
and his lawyers as they are protected by various privileges including attorney client privilege and 
work product privilege and remain on the privilege log. 
RECENT EVENTS 
20. 
On November 1, 2017, the law firm of Link & Rockenbach, P.A. entered a Notice 
of Appearance in the Epstein lawsuit, pending before Judge Donald Hafele (the successor to Judge 
Crow). As it has evolved, Epstein's lawsuit against Edwards was dismissed and the lawsuit now 
3 Specifically, on April 10, 2012, Judge David F. Crow (presiding over the Epstein lawsuit) entered 
an Order requiring Edwards to produce any non-privileged documents identified in paragraph 13 
of Epstein's Motion to Compel and Amend Protective Order, which specifically only included 
emails relating to news reporters or the media. On May 7, 2012, Judge Crow entered an Order on 
Plaintiff Jeffrey Epstein's Motion to Compel Production of Documents from Defendant Bradley 
Edwards and for Sanctions stating, "Bradley Edwards shall within 30 days of the date of this order 
file a more complete privilege log. The Court finds the privilege log is insufficient on its face and 
does not comply with the requirements ofF.R.C.P. 1.280(b)(5) and TJG Ins. Corp. v. Johnson, 799 
So. 2d 339 (Fla. 4th DCA 2001). In all other respects the Motion is denied at this time." 
On May 8, 2012, Edwards provided Epstein with 163 pages of emails pursuant to Judge 
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involves a malicious prosecution claim brought by Bradley Edwards against Jeffrey Epstein. 
Edwards alleges that Epstein sued him, with malice and without probable cause, for representing 
then-minor girls sexually abused by Epstein, including L.M. 
21. 
On March 2, 2018, Epstein, through counsel Scott Link and Kara Rockenbach, 
Epstein filed Plaintiff/Counter-Defendant Jeffrey Epstein's Notice of Filing of Redacted Appendix 
in Support of Response in Opposition to Defendant/Counter-Plaintiff Bradley J. Edwards' Second 
Supplement to Motion in Limine Addressing Scope of Admissible Evidence. Included in Epstein's 
353-page filing were at least 49 privileged emails spanning over 100 pages, that are subject to 
various privileges pursuant to the privilege log and that were never lawfully permitted to be 
provided to Epstein or retained by his lawyers. Epstein attached not only actual copies of various 
emails, but also provided a purported "summary" of the emails, which included specific quotations 
from communications over which attorney-client privilege and other protections had been 
repeatedly asserted, by Farmer Jaffe, Edwards, and L.M. Epstein also provided a wholly out-of-
context and substantially misleading summary of what he believed the emails demonstrated. In 
subsequent filings in court proceedings, he has continued to reference the content of privileged 
documents and mischaracterize their significance in the pending state court malicious prosecution 
case. 
22. 
On March 5, 2018, Edwards filed his Motion to Strike Epstein's Untimely 
Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing 
Privileged Materials Listed on Farmer Jaffe's Privilege Log. 
23. 
On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, 
E.W. and Jane Doe, filed an emergency motion to intervene and an emergency motion to join 
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Edwards' motion to strike. The three victims alleged that Epstein's recent filing disclosed their 
protected attorney-client communications. 
24. 
On March 7, 2018, counsel for Epstein delivered a flash drive to counsel for 
Edwards, "which duplicates the disc we located in Fowler White's files." Letter of transmittal 
attached hereto as Exhibit A. The subject flash drive contained three separate PDF files 
respectively titled: (1) "Bradley Edwards.pdf' containing 8,507 pages of emails; (2) "Epstein 
Searches.pdf' containing 17,348 pages of emails; and (3) "Scott Rothstein.pdf' containing 1,687 
pages of emails ("subject documents"). Notably, the flash drive indicated that the three PDF files 
had been last "modified" on December 8, 2010, a mere nine days after this Court ordered Fowler 
White to take very limited possession of the subject documents to print and Bates stamp them, and 
then not to retain any copies. This was also a short five days before the Bates stamped documents 
were delivered to Farmer Jaffe on December 13, 2010. 
25. 
On March 7, 2018, counsel for Epstein also provided a sworn affidavit from 
certified paralegal Tina L. Campbell that she had obtained these materials from Fowler White's 
files. Specifically, Ms. Campbell attested under oath that on January 10, 2018, she had reviewed 
approximately 36 boxes of Fowler White's Epstein files at Fowler White's Miami, Florida offices. 
During that review, electronic discs found in the Fowler White files were marked for review, but 
the contents were not reviewed. Affidavit attached hereto as Exhibit B. On February 1, 2018, 
Link & Rockenbach, P.A. received three boxes from the Fowler White firm containing copies of 
the items that had been marked for reproduction including a disc labeled "Epstein Bate Stamp" 
handwritten in black sharpie. The disc marked "Epstein Bate Stamp" was not reviewed until 
February 25, 2018. 
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26. 
It is thus undisputed that a disk containing the privileged emails in question was in 
the possession of Fowler White in early January 2018-a disc showing that it had last been 
modified on December 8, 2010. 
27. 
On March 8, 2018, Judge Hafele held a hearing regarding the privileged 
communications. Counsel for Epstein, Edwards, and the three victims at issue (L.M., E.W., and 
Jane Doe) all appeared. Counsel for Edwards began the hearing by explaining the relevant 
background as well as how Fowler White had made and retained a copy of the privileged 
communications in violation of this Court's order. Counsel for Epstein then responded, arguing 
that they (i.e., Link & Rockenbach) had not improperly taken any documents from Fowler White. 
This argument led Judge Hafele to ask, "[t]he critical question, though, is why did Fowler White 
have these documents, why were they continued to be held, and was it in violation either expressly 
or constructively as it relates to Judge Ray's order?" Hearing Trans. at 32:10-14 (all portions of 
the March 8, 2018 hearing transcript cited herein are attached hereto as Exhibit C). 
28. 
Without offering any real explanation in response to the Court's inquiry, counsel 
for Epstein simply stated, "[s]o let's talk about Fowler White because it is as clear as mud." 
Hearing Trans. at 35:6-7. Counsel for Epstein further explained that"[ w ]hen these issues came up, 
we asked Fowler White to please give us the original boxes. We got the original boxes and found 
the disc in a folder that says J. Camey printing on it. That's it. That's all that's on this folder." 
Hearing Trans. at 45: 11-15. Epstein's counsel then conjectured certain speculative scenarios, 4 but 
4 Epstein's current legal counsel speculated that after a copy of the materials were provided to the 
Special Master, Judge Camey, that Judge Camey somehow turned around, contacted Fowler White 
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ultimately admitted "I wasn't there. I can't tell you what [Fowler White] did .... " Hearing Trans. 
at 45:23-24. 
29. 
During the hearing, counsel for Epstein revealed that Epstein personally had 
retained copies of the confidential materials, in contravention of the November 30, 2011 Order. 
Hearing Trans. at 64:7-8 (counsel for Epstein admits that copies of the documents have been 
provided "within my law firm, and my client."). When further asked, "Has Mr. Epstein been 
provided with copies of the documents or the contents of these privileged documents?," counsel 
for Epstein replied, "I just said my client. My law firm and my client. And I can say legal counsel, 
Mr. Goldberger. So that's it." Hearing Trans. 64:14-19. 
30. 
During the hearing, counsel for Epstein (Link and Rockenbach) also revealed that 
Fowler White was disclaiming any memory of the circumstances surrounding the creation and 
retention of the disc: "We have reached out to lawyers for Fowler White. They have no memory 
of it." Hearing Trans. at 35:15-21. 
31. 
Epstein's claim that Fowler White had "no memory" of the surrounding 
circumstances led counsel for Edwards to respond that it was difficult to believe Fowler White had 
no records regarding the disc: "Your Honor knows very well that Fowler White is a very large law 
firm that keeps meticulous time records with regard to the services they render. And the concept 
that it is impossible to reconstruct through those time records what was received, when it was 
received, when it was reviewed, what happened with it, who was informed of what was happening 
with it, quite frankly, is inconceivable to me." Hearing Trans. at 60:8-19. 
32. 
Judge Hafele responded in agreement by noting his surprise that Fowler White was 
not explaining what had happened: "And that's a good point. What I was going to point out earlier 
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Fowler White that someone from Fowler White would have had the ability to weigh in somehow 
as to these critical issues. Perhaps I'm being a bit naive when I say that having served Mr. Epstein 
in their capacity as counsel, it's my respectful belief that they owed an obligation to Mr. Epstein, 
if not this Court, to explain how and why they had access and kept these records in their possession 
in light of that [bankruptcy] court order and in light of this ongoing litigation. And as a matter of 
respect to Mr. Epstein and his ongoing legal team, to have made some type of affirmative steps to 
have dealt with this issue head on because of the apparent implications of same." Hearing Trans. 
at 60:20-61: 14. 
33. 
Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order 
Fowler White to explain who they had distributed the confidential materials to. Judge Hafele 
indicated that, in light of Fowler White's withdrawal from the case in front of him, he did not have 
"that ability" to enter such an order directed against them. Hearing Trans. at 79:25-80: 1. 
34. 
Based on the foregoing facts, over the past seven years, Fowler White has been in 
possession of a disc containing over 27,000 pages of documents-6,741 pages of which were 
privileged materials never lawfully received by them-that they were specifically ordered not to 
retain in any format. The retained disc in question had the exact number of documents copied to 
it that Fowler White copied at the direction of this Court on November 30, 2010. And, the subject 
disc was last modified a mere nine days after this Court ordered Fowler White to copy, Bates 
stamp, tum over, and permanently destroy the materials from their internal system. This was also 
a short five days before the final Bates stamped documents were delivered in hard copy to Farmer 
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MEMORANDUM OF LAW 
Based on the egregious conduct of Epstein and his attorneys, the exact fear contemplated 
by the parties, the Special Master, and this Court when the November 30, 2010 order was entered, 
has alarmingly come to fruition. 
Despite obligations as officers of this Court to follow a 
specifically delineated procedure designed to protect highly confidential and privileged materials, 
Fowler White has apparently deliberately copied and retained highly sensitive confidential and 
privileged materials for over seven years. Recently, these materials have been disclosed to 
additional counsel for Epstein and these materials remain in the possession of Epstein personally. 
The misappropriation of this information has caused irreparable harm. Epstein's current counsel, 
Link & Rockenbach have also now filed privileged information in the public court file in the 
Edwards v. Epstein matter ( although that filing has since been placed under seal) and have 
repeatedly referenced the privileged content of the misappropriated documents in other filings. 
Specifically foreseeing the need to ensure that its earlier order was complied with in full, this Court 
expressly retained jurisdiction to award sanctions in the event of any breach. This Court should 
take steps to ensure that its order is complied with in the future and to punish and remedy violations 
in the past. 
Farmer Jaffe believes that the true extent of its damages can only be determined through a 
thorough inquiry into the entire chain of custody detailing the whereabouts of the subject 
documents since inception and including any person who has seen or been informed of the content 
of said documents. To that extent, an evidentiary hearing and corresponding discovery are 
essential, as complete determination of the breadth and degree of complicity by Fowler White and 
Jeffrey Epstein, both jointly and severally, is imperati...

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were downloaded into the Fowler White system, whether they were disseminated to third parties, 
and ultimately when and how they ended up in the hands of Jeffrey Epstein. Stated more 
succinctly, the sanctions here must be commensurate with the misconduct. 
Specific Relief Sought 
This Court previously entered an order directing that both Fowler White and Epstein were 
not to "retain[] images or copies of the subject documents on [their] computer[s] or otherwise." 
[DE 1194]. In light of the clear violation of that order, Farmer Jaffe5 now asks this Court to enter 
an additional order as follows: 
1. Fowler White and Epstein are directed within seven days of the entry of this order to 
show cause as to why they should not be held in contempt of the Court's order, DE 1194. 
2. Fowler White and Epstein (including all of Epstein's past and present legal counsel) are 
directed, within seven days of the entry of this order, to provide to counsel for Farmer Jaffe all 
physical, electronic, and other information in their possession concerning the copying, retention, 
and dissemination of the documents covered by DE 1194 (and any materials disclosing the 
contents of those documents), including (but not limited to) all information regarding the making, 
retention, and dissemination of these materials on and after December 8, 2010. This information 
shall include, but is not limited to, any electronic or other information showing the date on which 
copies were made, the authors of any such copies, emails or transmission of such copies, and any 
discussion or reference to such copies. Epstein (and all of his past and present legal counsel) shall 
also provide all correspondence and billing records related to the copying, retention, review, 
discussion, and dissemination of the subject documents, the Bates stamping of the subject 
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documents, or any other activity related to the November 30, 2011 Order from the day that the 
Epstein subpoena was issued on April 17, 2010 through the present. 
3. Fowler White and Epstein (including all of Epstein's past and present legal counsel) 
will provide to Farmer Jaffe within seven days of the entry of this order a listing of all persons or 
entities to whom the subject documents ( or any information derived from the contents of the 
subject materials) have been viewed and distributed, as well as a certification that they have asked 
for return of the subject materials. 
4. Fowler White and Epstein and any other persons know to have ever possessed these 
materials, including Epstein's current counsel, shall allow neutral IT specialists appointed by this 
Court to search all computer servers, including back-up servers and hard-drives, for designated 
search terms especially found within these privileged materials. While mandatory anyway, under 
the circumstances Epstein and all past and current counsel, as well as anyone else known or 
believed to have ever possessed the materials should be strictly ordered to maintain all possible 
platforms that may contain such privileged information to ensure there is no spoliation of the 
evidence of the improper retention, review, dissemination or other use of these materials by any 
person or entity. 
5. Counsel for Farmer Jaffe is permitted to obtain deposition testimony of all persons 
reasonably believed to have knowledge of the circumstances surrounding the copying, retention, 
or dissemination of the documents at issue in DE 1194. 
6. An evidentiary show cause hearing will be held wherein Farmer Jaffe is afforded the 
opportunity to inquire into the facts and circumstances surrounding the wrongful retention and 
resulting dissemination of the subject privileged materials, in order for the aggrieved parties and 
the Court to learn o...

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limited to, testimony from Special Master Robert Camey, Jeffrey Epstein, Fowler White Attorney 
Joseph L. Ackerman, Fowler White Attorney Lilly Ann Sanchez, Jack Goldberger, Tina Campbell, 
Scott Link, Kara Rockenbach, and the currently unidentified attorneys that Mr. Link has 
represented are also working on this case on behalf of Epstein from the Gunster law firm. 
7. Epstein will pay Farmer Jaffe reasonable attorneys' fees and expenses connected with 
Farmer Jaffe's efforts to determine the circumstances surrounding the retention and release of the 
materials and to remedy any damage caused to Farner Jaffe or its clients from the retention, use or 
release of the materials. 
8. Farmer Jaffe is permitted to seek further relief and sanctions after the discovery 
described above is completed. 
Authority to Enter an Additional Order 
This Court's November 30, 2010 Order specifically noted that the Court was retaining 
jurisdiction to enforce compliance: "Should it be determined that Fowler White or Epstein retained 
images or copies of the subject documents on its compute or otherwise, the Court retains 
jurisdiction to award sanctions in favor of Farmer, Brad Edwards or his client." [DE 1194 at 2] 
( emphasis added). The Court clearly has power to now award sanctions and take all other steps 
necessary to secure compliance. 
Of course, all federal courts have the power, by statute, by rule, and by common law, to 
impose sanctions against recalcitrant lawyers and parties litigant. Carlucci v. Piper Aircraft Corp., 
775 F.2d 1440, 1446 (11th Cir. 1985). Even absent explicit legislative enactment, deeply rooted 
in the common law tradition is the power of any court to "manage its affairs [which] necessarily 
includes the authority to impose reasonable and appropriate sanctions upon errant lawyers 
practicing before it." Id. at 1447. Federal courts have the inherent power to enforce complia...

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with their lawful orders through civil contempt remedies. Citronelle-Mobile Gathering, Inc. v. 
Watkins, 943 F.3d 1297. 1301 (11th Cir. 1991). Courts also have the inherent power to sanction a 
party for misconduct. Chambers v. Nasca, 501 U.S. 32, 42 (1991). As the Supreme Court stated 
in Chambers, "[i]t has long been understood that certain implied powers must necessarily result to 
our courts of justice from the nature of their institution, powers which cannot be dispensed with in 
a Court, because they are necessary to the exercise of all others". Id. 
Before the Court uses its inherent contempt power, "[a] petitioner 'must [first] establish by 
clear and convincing evidence that the alleged contemnor violated [a] court's earlier order." Chairs 
v. Burgess, 143 F.3d 1432. 1436 (11th Cir. 1998) (quoting United States v. Roberts, 858 F.2d 698. 
700 (11th Cir. 1988)). Once such a prima facie showing of civil contempt has been made, the 
burden shifts to the contemnor to produce evidence at a show cause hearing that the underlying 
order was not violated or that the violation was excused by an inability to comply. Chairs, 143F.3d 
at 1436.The violation need not be willful to support a finding of civil contempt. McComb, 336 
U.S. 187. 191 (1949) ("Since the purpose [of civil contempt] is remedial, it matters not with what 
intent the defendant did the prohibited act."). Even inadvertent or partial non-compliance with 
orders of the Court constitutes civil contempt if the party has not in good faith made all reasonable 
efforts to comply. U.S. v. Hayes. 722 F.2d 723, 725 (11th Cir. 1984). 
However, "if the court finds the defendant acted willfully or maliciously in disregarding 
the injunction, then the court may cite the defendant for criminal contempt." Mercer v. 
Mitchell, 908 F.2d 763, 769 (11th Cir. 1990) (citing 18 U.S.C. § 401(3) (stating, "[a] court of the 
United States shall hav...

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their official transactions; (3) Disobedience or resistance to its lawful writ, process, order, rule, 
decree, or command)). 6 
The fundamental purpose behind contempt sanctions are twofold, (1) sanctions can coerce 
the contemnor into complying in the future with the Court's orders or (2) they can compensate the 
complainant for losses resulting from the contemnor's past noncompliance. Citronelle-Mobile, 943 
F.2d at 1304. See also McComb v. Jacksonville Paper Co., 336 U.S. 187, 191 (1949); EEOC v. 
Guardian Pools, Inc., 828 F.2d 1507 (11th Cir. 1987); Perfect Fit Industries, Inc. v. Acme Quilting 
Co., 673 F.2d 53, 56-57 (2d Cir. 1982), cert. denied, 103 S.Ct. 73 (1983). In fact, the Court has 
"wide discretion to fashion an equitable remedy for contempt that is appropriate to the 
circumstances." Guardian Pools, 828 F.2d at 1515. Accord United States v. City of Miami, 195 
F.3d 1292, 1298 (11th Cir. 1999). Such options include a coercive daily fine, a compensatory fine, 
attorney's fees, expenses to the aggrieved party, and coercive incarceration. Citronelle-Mobile, 
943 F.2d 1297.Courts have broad power to fashion an appropriate sanction, including anything 
from entry of monetary sanctions to entry of a final judgment on the merits against a party 
demonstrated to have committed a fraud upon the court. See Vargas v. Peltz, 901 F.Supp. 1572 
(S.D. Fla. 1995). 
Compensatory sanctions generally include a fine payable to the petitioner the amount of 
which "is determined by the extent of the actual loss." Id. ( citing United States v. United Mine 
Workers, 330 U.S. 258, 303-04 (1947)). Compensatory sanctions also frequently include the 
payment of the complainant's attorney's fees in seeking the redress. Hutto v. Finney, 437 U.S. 678, 
689 n. 14 (1978) ("[a]n equity court has the unquestioned power to award attorney's fees against a 
6See Federal Rule of Criminal Procedure 42, requirin...

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party who shows bad faith by delaying or disrupting the litigation or by hampering enforcement 
of a court order" and "[ o ]f course, fees can also be awarded as part of a civil contempt penalty"); 
Watkins, 943 F.2d at 1301, 1304 1301;Jaeger v. Massis, No. 00-7390. 2000 U.S. App. LEXIS 
27908 (2d Cir. Nov. 3, 2000). Courts within the Eleventh Circuit have not hesitated to impose 
severe sanctions pursuant to their inherent powers, including cases where a party has acted in bad 
faith. See, e.g., In re Mroz, 65 F.3d 1567 (11th Cir. 1995). 
In light of the Court's sweeping powers to secure compliance with orders, this Court should 
grant the relief sought by Farmer Jaffe above. There can be no doubt that a prima facie showing 
of contempt has been made by clear and convincing evidence. Fowler White and Epstein were 
directed not to retain copies of privileged documents. The events cited above show that Fowler 
White apparently made-and indisputably retained-a copy of the privileged documents. 
Sometime thereafter, Epstein also obtained and retained a copy of the privileged documents and 
now numerous unauthorized people have these documents and knowledge of their privileged 
content. 
At the hearing surrounding the confidential materials, Judge Hafele indicated his 
"respectful belief that [Fowler White] owed an obligation to Mr. Epstein, if not this Court, to 
explain how and why they had access and kept these records in their possession in light of that 
[bankruptcy] court order and in light of this ongoing litigation." Hearing Trans. at 61:5-9. Fowler 
White, however, has failed to come forward voluntarily. Accordingly, this Court should enter an 
order to show cause as to why they have not violated this Court's order. In light of Epstein's 
possession of the materials, he should be directed to show cause as well. 
In addition, it is already clear that efforts to avoid responsibility ...

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cataloguing, and filing under seal all improperly acquired and retained privileged materials, it has 
directed their destruction, thereby impeding further investigation of the origin of those materials. 
Accordingly, Fowler White and Epstein (including his legal counsel, past and present) should be 
ordered to provide all relevant discovery about how the violation occurred. To get to the bottom 
of this violation and be permitted to identify the necessary witnesses to be examined at the 
anticipated evidentiary hearing before this Court, Farmer Jaffe also seeks to depose those persons 
who appear to be in the chain of custody of the improperly copied and retained materials. 
Because it is clear that Farmer Jaffe is going to have to bear additional burdens, in terms 
of time and effort in responding to Fowler White and Epstein's improper copying, retention, and 
distribution of privileged materials, the Court should award attorneys' fees and expenses. Epstein 
and his legal counsel have caused these problems; innocent third parties should not bear the 
financial consequences. Finally, because the violation of this Court's order appears to be evolving 
and on-going, Farmer Jaffe requests leave to seek supplemental sanctions and remedies after 
discovery on the violation has been completed. 
CONCLUSION 
WHEREFORE, Farmer Jaffe respectfully requests that this Court enter an order to Fowler 
White and Epstein to show cause why they should not be held in contempt of court, allowing 
discovery and an evidentiary hearing on the circumstances surrounding the improper copying, 
retention, and distribution of privileged materials, and allowing Farmer Jaffe to seek such other 
sanctions and remedies as may be appropriate following discovery on these matters. A proposed 
order to this effect is attached. 
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I HEREBY CERTIFY that, pursuant to L.R. 9073-l(D), Movant's counsel has contacted 
Fowler White in a good faith attempt to resolve the matter without a hearing before bringing this 
motion. Fowler White has failed to respond. 
I HERBY CERTIFY that a true and correct copy of the foregoing was served electronically 
to the examinee, the debtor, the attorney for the debtor, the trustee, all CMIECF subscribers, and 
by email or U.S. Mail on those parties listed on the attached service list this 19th day of March, 
2018. 
I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for 
the Southern District of Florida and I am in compliance with the additional qualifications to 
practice in this court set forth in Local Rule 2090-l(A). 
EDWARDS POTTINGER LLC 
By: 
Isl Bradley Edwards 
Bradley J. Edwards FLBN 542075 
BrittanyN. Henderson FLBN 118247 
Edwards Pottinger LLC 
425 N Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301 
Phone: (954)-524-2820 
Fax: (954)-524-2822 
Attorneys for Farmer, Jaffe, Weissing, 
Edwards, Fistos & Lehrman, P.L. 
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CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on March 19, 2018, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. I also certified that the foregoing document 
is being served this day on all counsel of record or pro se parties identified on the on the attached 
Service List in the manner specified, either via transmission of Notices of Electronic Filing 
generated by CMIECF or in some other authorized manner for those counsel or parties who are 
not authorized to receive electronically Notices of Electronic Filing. 
21 
Isl Bradley Edwards 
Bradley Edwards 

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Joseph L. Ackerman, Jr., Esq. 
Fowler White Burnett, P.A. 
901 Phillips Point West 
777 South Flagler Drive 
West Palm Beach, Florida 33401-6170 
Phone: (561) 802-9044 
Fax: (561) 802-9976 
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 
SERVICE LIST 
Jack A. Goldberger, Esq. 
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 
Jack Scarola, Esq. 
Florida Bar No.: 169440 
David P. Vitale, Jr., Esq. 
Florida Bar No.: 115179 
Attorney 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 
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Phil Burlington, Esq. 
Nichole J. Segal, Esq. 
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 
Jay Howell, Esq. 
Jay Howell & Associates 
Florida Bar No.: 225657 
Attorney E-Mail(s): jay@jayhowell.com 
644 Cesery Blvd. #250 
Jacksonville, FL 32211 
(904) 680-1234 
Paul G. Cassell, Esq. 
S.J. Quinney College of Law at the University of Utah 
332 S. University St. 
Salt Lake City, UT 84112 
(above for address purposes only) 
Attorney E-Mail: cassellp@law.utah.edu 
Attorneys for L.M., E.W., and Jane Doe 
Judge Robert Camey 
2281 Saratoga Ln 
West Palm Beach, FL 33409 
954-258-9573 
rbcamey3@gmail.com 
Special Master 
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UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
~l'". •:.it•,ie~,a-::irrri '1241 IJ.SBCSDF-FTL ~ 
!" 
ii l•._q ~.t...1 
7,f 
INRE: 
ROTHSTEIN ROSENFELDT ADLER, P.A. 
CASE NO. 09-34791-RBR 
CHAPTER 11 
I 
---------------
JOINDER IN MOTION FOR ISSUANCE OF AN ORDER TO SHOW CA SE 
Bradley Edwards, by and through his undersigned counsel, hereby gives no ice of his 
joinder in the motion filed on behalf of Farmer, Jaffe for issuance of an order to show ~use why 
Jeffrey Epstein and Fowler White should not be held in contempt of court. Edwards\adopts all 
arguments and requests for relief asserted in the referenced motion 
\ 
I HEREBY CERTIFY that a true and correct copy of the foregoing Jas served 
electronically to the examinee, the debtor, the attorney for the debtor, the trustee, all ME/ECF 
subscribers, this 
/ ~ay of March, 20 .----
No.: 169440 
tto ey E-Mail(s): jsx@searcylaw.com; and 
ccann@searcylaw.com 
rimary 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 

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UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
www.flsb.uscourts.gov 
ROTHSTEIN ROSENFELDT ADLER, P.A., 
CASE NO.: 09-34791-RBR 
CHAPTER 11 
Debtor. 
I 
----------------
L.M., E.W., AND JANE DOE'S JOINDER IN MOTION FOR ORDER TO SHOW 
CAUSE AND MOTION FOR DISCOVERY, TO ASSESS SANCTIONS AND COSTS 
FOR OTHER APPROPRIATE RELIEF 
Sexual assault victims L.M., E.W., and "Jane Doe" (hereinafter "the Victims"), proceeding 
pseudonymously and through undersigned counsel, having previously moved to intervene in this 
action, now file this j oinder in Farmer Jaffe' s Motion for Issuance of an Order to Show Cause Why 
Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, 
to Assess Sanctions and Costs, and for Other Appropriate Relief [DE 6323]. 
In addition, the Victims seek additional remedies as follows. 
FACTUAL BACKGROUND 
To avoid duplicative pleadings, the Victims simply adopt, as if set forth in full herein, the 
factual recitations made by Farmer Jaffe's earlier motion for an order to show cause. [DE 6323 at 
1-11.] The Victims would also direct the Court to their contemporaneously filed motion to 
intervene, which establishes that they have a direct, substantial, and protectable interest in their 
attorney-client protected materials. These pleadings demonstrate that Fowler While and Epstein 
have directly violated an order of this Court [DE 1194], which prohibited them from retaining and 
distributing copies of attorney-client protected materials of the three victims. 
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RELIEF REQUESTED 
The Victims join in and seek, on their own behalves, all of the relief previously requested 
by Farmer Jaffee. [DE 6323 at 13-15]. 
In addition, the victims seek the following relief, not specifically sought by Farmer Jaffe. 
1. A letter written and signed by both Fowler White and Jeffrey Epstein, and provided to 
the VZictims, to the following effect: "To Whom It May Concern: The documents listed on the 
attached list [insert attachment] were impermissibly retained by the undersigned in violation of an 
order from U.S. Bankruptcy Judge Raymond B. Ray of the Bankruptcy Court for the Southern 
District of Florida. See DE 1194, In Re: Rothstein Rosenfeldt Adler, P.A., No. 09-34791-RBR. If 
you are in possession of any of the attached documents as a consequence of a violation of the 
order, you are requested to promptly return it to the attorney who has provided a copy of this letter 
to you." 
2. Discovery regarding the distribution of the impermissible retained materials, in the form 
of twenty interrogatories, twenty requests for production, and twenty requests for admission, to be 
answered by: (1) Jeffrey Epstein; (2) any attorney, paralegal, other law firm employee or 
consultant, or expert witness who has been involved in the representation of Epstein in the above-
captioned matter or in Epstein v. Edwards, No. 502009CA040800:XXXXMBAG (Cir. Ct. of the 
15th Jud. Cir. for Palm Beach County, Fla.). 
3. Separate letters of apology for each of the three victims, written by Epstein and all 
attorneys and staff found to have played a responsible role in the unauthorized retention and release 
of their privileged materials. 
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4. 
A referral from this Court to appropriate disciplinary authorities, including bar 
authorities, for any attorney found to have apparently violated ethical obligations in connection 
with the improper retention and subsequent distribution of the materials at issue. 
5. Monetary sanctions, payable directly to each of the Victims by Epstein, in the amount 
of $25,000 for each of the three victims (a total of $75,000). After making payment, Epstein is 
permitted to seek reimbursement from any of his attorneys who may have been responsible. 
6. An evidentiary hearing on the circumstances surrounding the violation of the Victims' 
right of confidentiality, and a finding of civil or criminal contempt as may be appropriate, along 
with such additional sanctions as the Court may then find to be appropriate. 
7. Reasonable attorneys' fees for the Victims for all attorney time, costs, and expenses 
incurred as a result of the improper retention and subsequent distribution of the materials at issue. 
AUTHORITY FOR THE COURT TO AW ARD RELIEF 
This Court's previous order [DE 1194] specifically indicated that the Court was 
"retain[ing] jurisdiction" to impose sanctions. In addition, the Court has authority to award 
sanctions, for all the reasons explained by Farmer Jaffe in its memorandum [DE6323 at 15-19], 
which authority the Victims also specifically rely upon here. 
CONCLUSION 
For the foregoing reasons, the Court should grant the three Victims' the relief requested 
above, includingjoinder in Farmer Jaffe's motion for sanctions and their own sanctions and other 
relief as described above. 
I HEREBY CERTIFY that, pursuant to L.R. 9073-l(D), Movant's counsel has contacted 
Farmer Jaffe and Fowler White in a good faith attempt to resolve the matter without a hearing 
before bringing this motion. Farmer Jaffe supports the Victims' motion. Fowler White has been 
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contacted via email on March 19, 2018, about the Victims' motion and has thus far failed to 
respond. 
I HEREY CERTIFY that a true and correct copy of the foregoing was served electronically 
to the examinee, the debtor, the attorney for the debtor, the trustee, all CM/ECF subscribers, and 
by email or U.S. Mail on those parties listed on the attached service list this 30th day of March, 
2018. 
I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for 
the Southern District of Florida and I am in compliance with the additional qualifications to 
practice in this court set forth in Local Rule 2090-l(A). 
SHAPIRO LAW 
8551 West Sunrise Boulevard 
Suite 300 
Plantation, Florida 33322 
Telephone: (954) 315-1157 
By: Isl Peter E. Shapiro 
Peter E. Shapiro 
Florida Bar No. 615551 
pshapiro@shapirolawpa.com 
and 
Paul G. Cassell, Esq. 
S.J. Quinney College of Law at the University of 
Utah 
332 S. University St. 
Salt Lake City, UT 84112 
( above for address purposes only) 
Attorney E-Mail: cassellp@law.utah.edu 
Pro Hae Vice Motion Filed Contemporaneously 
Attorneys for Intervenors L.M, E.W., and Jane Doe 
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CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on March 30, 2018, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. I also certified that the foregoing document 
is being served this day on all counsel of record or pro se parties identified on the on the attached 
Service List in the manner specified, either via transmission of Notices of Electronic Filing 
generated by CM/ECF or in some other authorized manner for those counsel or parties who are 
not authorized to receive electronically Notices of Electronic Filing. 
5 
Isl Peter E. Shapiro 
Peter E. Shapiro 

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Bradley J. Edwards 
Brittany N. Henderson 
Edwards Pottinger LLC 
425 N Andrews Avenue, Suite 2 
SERVICE LIST 
Fort Lauderdale, FL 33301 Phone: (954)-524-2820 
Fax: (954)-524-2822 
brad@epllc.com 
brittany@epll.com 
Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 
Joseph L. Ackerman, Jr., Esq. 
Fowler White Burnett, P.A. 
901 Phillips Point West 
777 South Flagler Drive 
West Palm Beach, Florida 33401-6170 
Phone: (561) 802-9044 
Fax: (561) 802-9976 
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 
Jack A. Goldberger, Esq. 
jgoldberger@agwpa.com; smahoney@agwpa.com 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue S, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-659-8300 
Fax: (561)-835-8691 
Attorneys for Jeffrey Epstein 
Jack Scarola, Esq. 
Florida Bar No.: 169440 
David P. Vitale, Jr., Esq. 
Florida Bar No.: 115179 
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Attorney 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 
Judge Robert Camey 
2281 Saratoga Ln 
West Palm Beach, FL 33409 
954-258-9573 
rbcamey3@gmail.com 
Special Master 
CARLTON FIELDS JORDEN BURT, P.A. 
Niall T. McLachlan, Esq. 
100 SE 2nd Street, Suite 4200 
Miami, FL 33131 
Telephone: 305-530-0050 
Facsimile: 305-530-0055 
Primary Email: 
nmclachlan@cfjblaw.com 
Secondary Email: 
cguzman@cfjblaw.com 
miaecf@cfdom.net 
Counsel for Fowler White Burnett, PA 
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