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FBI VOL00009
EFTA00185206
310 sivua
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Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 13 of 14 Bates Range Description Privilege(s) Asserted Suppl. Box 3 P413934 Thru P-013936 Draft Letter, marked "Confidential," to corrections from Deliberative Process Privilege Attorney Work Product with handwritten Suppl. Box 3 P-013937 Thru P-013939 Draft Letter, to Professor Paul Deliberative Process Privilege Attorney Work Product G. Cassell, with handwritten corrections Suppl. Box 3 P413940 Thru P-013942 Draft Letter, marked "Confidential: To O ned b Addressee Only," , with handwritten corrections Be to Deliberative Process Privilege Attorney Work Product Suppl. Box 3 P-013943 E-mail, 2011, 11:19 ., RE: for our review with e-mail a to and to ) attached to May 5, to Deliberative Process Privilege Attorney Work Product Re-write of Epstein letters from 5, 2011, 11:08 . and Ma 5, 2011, 11:10 M.), (May 5, 2011, 10:41 Suppl. Box 3 P-013944 E-mail to 11:17 , RE: Re-write our review, with e-mail a 5, to and to attached May 5, 2011, for to .), .), Deliberative Process Privilege of Epstein letters from 2011, 11:08 ay 5, 2011, 11:01 (May 5, 2011, 10:41), Suppl. Box 3 P-013945 E-mail, to . May 4, 2011, 5:01 e- Deliberative Process Privilege p.m., RE: draft letters mail from to 4:57 p.m. attached in Epstein matter, with (May 4, 2011, Suppl. Box 3 P-013946 E-mail, to May 4, Law Enforcement investigatory record, atty work product; deliberative process privilege 2011, 4:08 p.m., RE: FYI on the Florida matter Suppl. Box 3 P-013947 E-mail, to May 3, 2011, for atty work product; law enforcement investigatiory record 12:23 p.m., RE: OPR Inquiry — request information, with post-it note attached with handwritten attorney notes on tele 'hone call between and with and Suppl. Box 3 P-013948 Thru P-013951 E-mail to and atty work-product May 3, 2011, 12:30 p.m., FW: OPR Inquiry — request for information, with attached e-mails. Handwritten attorney notes on margin Page 13 of 14 EFTA00185426
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Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 14 of 14 Bates Range Description Prig ilege(s) Asserted Suppl. Box 3 P-013952 Thru P-013953 E-mail, to March atty work-product; any- client privilege 16, 2011, 10:52 ., RE: Referral of Cassell Wiest for Investi 1 ation, with e-mail from to and (March 15 2011 7:21 p.m. attached Suppl. Box 3 P-013954 Thru P-013955 E-mail, to OPR, December 16, 2010, 10:59 ., FW: OPR Referral — Allegation of Misconduct — U.S. Attome 's Office S.D.Fla., with e-mail from to (December 16, 2010, 10:22 .), attached. Handwritten attorney any work-product, any- client privilege notations. Suppl. Box 3 P-013956 Thru P-013846 Fourteen (14) pages of handwritten attorney notes on case, telephone interviews with DOJ attorneys atty work-product Page 14 of 14 EFTA00185427
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, Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, I. UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Second Supplemental Privilege Log. The index has been marked with Bates Numbers P-013970' thru P-014923. The documents referenced in the Second Supplemental Privilege Log will be delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parse in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 400 West Palm Beach. FL 33401 Telephone: Facsimile: Please note that, while preparing the Second Supplemental Privilege Log, the undersigned discovered an error on the Supplemental Privilege Log, that is, the last entry states that the last document bears Bates Numbers P-013956 thru P-013846. The correct Bates range for that document is P-013956 thru P-013969 [14 pages]. 1 EFTA00185428
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Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 2 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 23, 2015, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system. Assistant United United States Attorney SERVICE LIST Jane Does 1 and 2 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [email protected] 954-524-2820 Fax: 954-524-2822 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: casselp®law.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 2 EFTA00185429
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18 JANE DOE'. UNITED STATES COURT FILE NO. 08-80736-CV-MARRA SECOND SUPPLEMENTAL PRIVILEGE LOG - BOX #4 Bates Range Description Privilege(s) Asserted P-013970 thru P-013971 11/29/2006-12/1/2006 emails between and prison Work Product Investigative Privilege Privacy Act employee regarding attempted contact with potential witness P-013972 5/18/2007 email from to informing him Work Product 6(e) Deliberative Process Investigative Privilege of intent to subpoena Roy Black's private investigator and steps taken to obtain DOJ authorization P-013973 thru P-013976 5/18/2007 emails between and expert witness regarding Work Product 6(e) Investigative Privilege securing pre-indictment consultation contract P-013977 thru P-013979 5/21/2007 email from to (CEOS) re Work Product 6(e) Deliberative Process Investigative Privilege 2423(b) charging question P-013980 5/21/2007 email from to and Work Product 6(e) Deliberative Process regarding guidance on grand jury presentation P-013981 5/22/2007 email from Andy to and Work Product Deliberative Process (cc: ) re letter received from Gerald Lefcourt discussing a meetin to discuss E in invest' ation P-013982 5/23/2007 email from to re extradition Work Product A/C privilege Investigative Privilege research P-013983 thru P-013984 5/23/2007 emails between and Work Product Deliberative Process regarding decision to meet with counsel for Epstein Page 1 of 18 EFTA00185430
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 2 of 18 Bates Range Descri t lion Privilege(s) Asserted P-013985 thru P-013989 6/14/2007-6/21/2007 emails between 6(e) Work Product Deliberative Process Investigative Privilege and regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meetin with counsel for E stein P-013990 thru P-013991 6/26/2007 email from to , Work Product Deliberative Process and addressing arguments regarding interstate nexus for 2422 char es P-013992 thru P-013994 7/3/2007-7/4/2007 emails between and 6(e) Work Product Investigative Privilege Deliberative Process regarding extension of time to respond to subpoenas requested by Lilly Ann Sanchez and possible resolution of case P-013995 thru P-014010 6/12/2007-7/6/2007 series of emails between and Work Product Investigative Privilege Privacy Act AUSAs and re an earlier unrelated investigation of Epstein P-014011 thru P-014025 7/3/2007-7/13/2007 email chain between and 6(e) Work Product Deliberative Process Investigative Privilege regarding disagreement on plea negotiations and written request for meeting between USAO management and victims P414026 thru P-014027 7/16/2007 email from to and 6(e) Work Product Deliberative Process Investigative Privilege regarding correspondence from Roy Black and Motion to Quash P-014028 thru P-014030 7/18/2007 emails from to and 6(e) Work Product Deliberative Process Investigative Privilege regarding Motion to Quash grand jury subpoena and supporting affidavit filed by Roy Black P-014031 thru P414032 7/19/2007 email chain between 6(e) Work Product Deliberative Process Investigative Privilege Attorney-Client Privilege S/A and S/A regarding potential service of target letters Page 2 of 18 EFTA00185431
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 3 of 18 Bates Range Desert • tion Privilege(s) Asserted P-014033 7/19/2007 email from to and Work Product 6(e) Investigative Privilege Deliberative Process regarding planned service of target letters P-014034 7/26/2007 email from to and 6(e) Work Product Deliberative Process Investigative Privilege regarding proposed changes to the indictment P-014035 7/31'2007 email from to Work Product Deliberative Process and summarizing proposed plea terms as per recommendation P-014036 7/31/2007-8/2/2007 email chain between Work Product Deliberative Process Investigative Privilege and regarding plea negotiations P-014037 8/2/2007 email drom to Work Product Deliberative Process Investigative Privilege and with draft response to Epstein counsel regarding ement P-014038 thru P-014041 8/2/2007 emails between , Andy and Work Product Deliberative Process regarding letter received from Lilly Ann Sanchez P-014042 8/3/2007 Email from I to Work Product Deliberative Process Investigative Privilege and regarding draft response to correspondence from Epstein counsel and planned investigative steps if a ment cannot be reached. P-014043 thru P-014044 Emails dated 8/6/2007 from to and regarding correspondencea to his arture. Work Product Deliberative Process P-014045 thru P-014046 8/7/2007 email chain between= , and Work Product Deliberative Process Investigative Privilege Alex Acosta regarding meeting to discuss Epstein matter Page 3 of 18 EFTA00185432
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 4 of 18 Bates Range Desert . tion Privilege(s) Asserted P-014047 8/7/2007 email from to Andy regarding deadline Work Product Deliberative Process Investigative Privilege set for Epstein plea and Epstein's plan to demand a meeting with CEOS. P-014048 8/7/2007 email from to regarding Work Product Deliberative Process Investigative Privilege Epstein meeting P-014049 thru P-014050 8/7/2007 email chain from to Work Product Deliberative Process Investigative Privilege and Alex Acosta regarding Epstein meeting P-014051 8/8/2007 emails between and Work Product Deliberative Process Investi ative Privilege (CEOS) regarding case staffing and plea negotiations P-014052 8/8/2007 email chain between Alex Acosta, Work Product Deliberative Process Investigative Privilege and regarding "The meeting on Epstein" P-014053 8/8/2007 email from to regarding Work Product Investigative Privilege Deliberative Process plea negotiations, guideline calculations, and assistance in preparing case for trial P-014054 8/8/2007 email from I to Alex Acosta, Work Product 6(e) Investigative Privilege Deliberative Process and regarding planning meeting with Epstein counsel and service of target letters P-014055 8/10/2007 Electronic correspondence from to expert witness regarc_ljgn: to . ics for expert testimon Work Product P-014056 8/10/2007 email from = to regarding Work Product target letters and sta in motion to com . 1 . roduction of com . uters P-014057 8/30/2007 email from to and regarding press covers • e of meetin with Ken Starr Work Product P-014058 9/4/2007-9/6/2007 emails between and Work Product Deliberative Process regarding planned participation of FBI ASAIC at 9/7/2007 meeting with Epstein defense team Page 4 of 18 EFTA00185433
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 5 of 18 Bates Ran e Description Privil e s Asserted P-014059 thru P-014061 9/6/2007 emails between Work Product Deliberative Process and regarding status of plea negotiations, draft agreements, and need to confer with victims P-014062 thru P-014068 9/10/2007-9/14/2007 emails between I and Alex Acosta regarding final plea negotiations, finalizing details with State Attorney's Office and final revisions to indictment pack: a Work Product Deliberative Process 6(e) Investigative Privilege P-014069 9/10/2007 email from to and = Work Product 6(e) Investigative Privilege regarding Acosta inquiry about FBI investigation into State grand ' roceedin P-014070 thru P-014074 9/11/2007 emails between Work Product Deliberative Process Investigative Privilege Attorney-Client Privilege , and regarding changes to the draft indictment and status of plea negotiations P-014075 thru P-014089 9/10/2007-9/11/2007 emails between Alex Acosta, and Work Product Deliberative Process regarding modifications to the proposed Non-Prosecution A eement P-014090 thru P-014102 9/13/2007 emails from I to Alex Acosta, and regarding plea to federal charges recommending 18 USC 403 or 1512(d), or 47 USC 223(aX1)(3); response that Epstein was only willing to plead to assault on the plane; and rejection of facts supporting assault on the plane charge Work Product Deliberative Process P-014103 thru P-014107 9/13/2007-9/14/2007 emails regarding research Work Product regarding victim trust fund set up in Alaska child exploitation case P-014108 thru P-014134 9/17/2007-9/19/2007 emails between I Alex Acosta, and regarding negotiations of a federal plea and a non-prosecution agreement Work Product Deliberative Process Page 5 of 18 EFTA00185434
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 6 of 18 Bates Range Description Privilege(s) Asserted P-014135 thru P-014149 9/19/2007-9/20/2007 emails between , Work Product Deliberative Process and regarding plea negotiations with counsel for E stein P-014150 thru P-014156 9/20/2007 emails between and Work Product Deliberative Process regarding plea agreement to federal charges and factual proffer P-014157 thru P-014160 9/21/2007 emails between I and Work Product Deliberative Process = and regarding revisions to the non- • rosecution agreement P-014161 9/21/2007 email from I to Alex Acosta, Work Product Deliberative Process and regarding review of Epstein indictment c e P-014162 thru P-014170 9/24/2007 series of emails between Alex Acosta, and Work Production Deliberative Process regarding plea negotiations and revisions to non- prosecution agreement P-014171 thru P-014174 9/23/2007-9/24/2007 series of emails between Alex Acosta, Work Product Deliberative Process . and regarding proposed revisions to non-prosecution a reement P-014175 thru P-014203 9/20/2007-9/24/2007 emails between Alex Acosta, nd Work Product Deliberative Process regarding revisions to the non-prosecution agreement P-014204 thru P-014205 9/24/2007 emails between and Work Product Deliberative Process regarding notifying Palm Beach Police Chief and victims about agreement P-014206 thru P-014216 9/24/2007-9/25/2007 emails between Alex Acosta, n --- and Rolando regarding Lefkowitz email about keeping agreement from becoming public and confidentiality provision in agreement Work Product Deliberative Process P-014217 thru P-014238 10/5/2007-10/16/2007 emails between Work Product Deliberative Process and Alex Acosta re selection of Special Master and negotiation of revision/addendum to Non-Prosecution Agreement Page 6 of 18 EFTA00185435
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 7 of 18 Bates Range Descriris Privilege(s) Asserted P-014239 thru P-014242 10/18/2007 emails between and regarding Work Product Deliberative Process Epstein's request to delay his change of plea P-014243 thru P-014251 10/19/2007 emails between and regarding Work Product Deliberative Process Special Master's Selection of Attorney Representative P-014252 thru P-014275 10/22/2007-10/31/2007 emails between Alex Acosta, and Work Product Deliberative Process regarding negotiation of Addendum to Non-Prosecution Agreement and drafting of correspondence regarding scope of Special Master's duties and selection criteria P-014276 10/31/2007 email from to Work Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation regarding attempts to interview additional witnesses/victims P-014277 thru P-014282 11/2/2007-11/5/2007 emails between and Work Product Deliberative Process regarding drafting 11/5/2007 letter from Siouan to Lefkowitz P-014283 thru P-014284 11/5/2007-11/7/2007 emails from to Work Product Deliberative Process inquiring about status of matter and contact by Epstein investigators with victims P-014285 thru P-014298 11/8/2007-11/14/2007 emails between Work Product Deliberative Process Attorney-Client Privilege and regarding response to objections raised by Epstein counsel and efforts to charigt date ea P-014299 thru P-014307 11/14/2007-11/19/2007 emails between MI Alex Acosta, and regarding communications with State Attorney's Office and Sheriff's Office in an attempt to insure that Epstein was ineligible for work release Work Product Deliberative Process Attorney-Client Privilege Page 7 of 18 EFTA00185436
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 8 of 18 Bates Range Desui ,it Privilege(s) Asserted P-014308 thru P-014310 11/19/2007 emails between and Work Product Deliberative Process about efforts by Epstein's counsel to change date for change of plea P-014311 thru P-014329 11/19/2007-11/28/2007 emails between Work Product Deliberative Process Attorney-Client Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation and regarding drafting victim notification letter of upcoming plea P-014330 thru P-014337 11/28/2007 correspondence between and regarding Lefkowitz 11/27/2007 email discussing presentation to DAAG Work Product Deliberative Process P414338 thru P414354 11/29/2007-12/1/2007 emails between Alex Acosta, and regarding draft response to Jay Leflcowitz and victim notification letters Work Product Deliberative Process P414355 thru P-014361 12/3/2007 emails between Villafafia, Alex Acosta, and Work Product Deliberative Process regarding history of plea negotiations and drafting response to correspondence from Jay Lekowitz and Ken Starr P-014362 thru P414402 12/3/2007-12/5/2007 cones • • ndence between Alex Acosta, , and about drafting and sending the 12/4/2007 Acosta letter to Ken Starr Work Product Deliberative Process 6(e) Attorney-Client Privilege P-014403 thru P-014414 12/6/2007 emails between Work Product Deliberative Process , Alex Acosta, and regarding correspondence from Ken Starr, request for a meeting from Epstein counsel, and need to notify victims of upcoming plea P-014415 thru P-014420 12/6/2007-12/7/2007 emails between Work Product Deliberative Process and Alex Acosta regarding draft victim notification letter Page 8 of 18 EFTA00185437
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 9 of 18 Bates Range Description Privilege(s) Asserted P-014421 thru P-014428 12/6/2007-12/7/2007 emails between and regarding request from State Attorney's Office for draft plea proffer Work Product Deliberative Process 6(e) Attorney-Client Privilege Investigative Privilege P-014429 thru P-014439 12/9/2007-12/12/2007 emails between 4 and regarding drafting response to personal attacks and Work Product Deliberative Process upcoming meet.irt with Ken Starr P-014440 12/11/2007 email from to and Alex Acosta Work Product Deliberative Process regarding call with lawyer for Jane Doe #2 (T.M.) P-014441 12/12/2007 emails between and Work Product Deliberative Process 6(e) regarding planning indictment review P-014442 12/14/2007 email from to Alex Acosta, Work Product Deliberative Process and regarding state cases mentioned by Epstein's counsel P-014443 12/14/2007 email from Villafafia to Alex Acosta, , and with draft letters to State Attome 's Office and victims Work Product Deliberative Process P-014444 12/17/2007 email from to inquiring about Work Product Deliberative Process case status and informing Sloman regarding agent concern about victim notifications P-014445 thru P-014447 12/19/2007 email from to Alex Acosta and Work Product Deliberative Process 6(e) summarizing research into other cases where individuals were charged with violating 2422(b) based u m iShe use of a telephone P-014448 thru P-014454 12/19/2007 emails between Alex Acosta, and Work Product Deliberative Process regarding drafting response to concerns raised durin: December 14, 2007 meeting between Epstein counsel Alex Acosta, , the FBI SAIC, and Page 9 of 18 EFTA00185438
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 10 of 18 Bates Range Desert don Privilege(s) Asserted P-014455 thru P-014456 12/19/2007 email from to Alex Acosta, Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation and regarding challenge to state charge raised by Epstein counsel during 12/14/2007 meeting P-014457 thru P-014464 12/20/2007 emails between and regarding Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation inquiries from State Attorney's Office regarding Epstein plea to state charge and facts supporting state plea P-014465 thru P-014485 12/18/2007-12/21/2007 emails between and other Work Product 6(e) AUSAs regarding other instances of charging 2422(b) based on the use of a telephone as a "fa.ilf interstate commerce" P-014486 12/21/2007 email from to with thoughts on Work Product Deliberative Process recent correspondence from Jay Lefkowitz raising concerns about interpretation of the .1 folrosecution Agreement P-014487 12/27/2007 email from to Alex Acosta and Work Product Deliberative Process regarding proposed approach to providing potential notice of breach of non- rosecution agreement P-014488 thru P-014499 12/27/2007 emails between Alex Acos regarding Jay Lefkowitz letter of 12/26/2007 Work Product Deliberative Process P-014500 1/2/2008 email from to Alex Acosta and Work Product Deliberative Process regarding telephone conversation with State Attorney's Office about delay in Epstein state plea. P-014501 thru P-014506 1/2/2008 emails between Alex Acosta, and Work Product Deliberative Process regarding requests from Alex Acosta to for information related to the handling of the investigation by the State Attorney's Office Page 10 of 18 EFTA00185439
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 11 of 18 Bates Range lion Privilege(s) Asserted P-014507 thru P-014508 1/2/2008 emails from to Alex Acosta and roil Work Product Deliberative Process 6(e) regarding renewed plea negotiations for federal plea agreement P-014509 thru P-014519 1/3/2008 emails between Alex Acosta, and Work Product Deliberative Process regarding Alex Acosta telephone conference with Jay Lefkowitz where Lefkowitz admitted that he never intended to have Epstein plead guilty to an offense that required sex offender re istration. P-014520 1/ from to and ME Attorney client privilege Deliberative Process Investigative Privilege (Small regarding renewed plea negotiations and press coverage o E stein matter. P414521 thru P-014522 to Alex Acosta, , Work Product Deliberative Process 6(e) Privacy Act and regarding proposed additional investigative steps in Epstein case. P-014523 1/9/ to Alex Acosta, and Work Product Deliberative Process regarding informing Jay Lefkowitz that a CEOS attorney would join the SDFL team regarding the Epstein case and would review the rosecution and defense materials. P-014524 thru P-014550 1/ /2 8-1/14/2008 emails between , and regarding assigning a CEOS attorney to the investigation, meeting with the CEOS attorney and victims in Florida, the results of the meetings and planned additional meetings, and revisions to the indictment in light of the meetin s. Work Product Deliberative Process Attorney-client privilege Investigative Privilege 6(e) P-014551 1/17/2008 email from to regarding Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation 6(e) updated summary charts for indictment preparation, meetings with victims, and victim notification letters from FBI P-014552 1/23/2008 email from to and Alex Acosta Work Product Deliberative Process regarding FBI involvement in meeting in DC Page 11 of 18 EFTA00185440
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 12 of 18 Bates Range Descri Lion Privilege(s) Asserted P-014553 thru P-014556 1/25/2008 emails between d Work Product 6(e) Deliberative Process Inveitigative Privilege Also contains information subject to privacy rights of victims who are not parties to this) litigation regarding press coverage of case and strategic decism i .sigegar g revisions to initial indictment P-014557 1/25/2008 email from to and 6(e Attorney-client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation regarding research for purposes oli lluin.l i Jury subpoenas. P-014558 1/29/2008 email from to and regarding status o meeting in DC and concerns regarding la Work Product Deliberative Process 6(e) Investigative Privilege P-014559 thru P414562 1/28/2008-1/29/2008 emails between 1 a MillRlird IF Work Product 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation regarding scheduling victim interviews on 1 31/2008- 1 8 P-014563 thru P-014565 1/30/2008 emails between MI Alex Acosta, and . Work Product Deliberative Process 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation regarding Lefkowitz email about lawsuit filed against Epstem by one of the victims identified during the state investigation. Page 12 of 18 EFTA00185441
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 13 of 18 Bates Range Desert, Privilege(s) Asserted P-014566 thru P-014568 1/31/2008 emails between and Work Product Investigative Privilege Attorney-client privilege Also contains information subject to privacy rights of victims who are not es to this litigation regarding interviews with victims. P-014569 thru P-014573 1/31/2008-2/1/2008 emails between Alex Work Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Investigative Privilege Acosta, and Alan Santiago regarding results of additional victim-witness interviews and requesting intervention with CEOS to move review process along P-014574 thru 2/20/2008-2/21/2008 emails between Work Product Deliberative Process 6(e) Si al Mandelker P-014583 Alex Acosta, and regarding status of CEOS plans to meet with counsel for Epstein and status of indictment review P-014584 that P-014622 2/12/2008-2/22/2008 emails between Work Product Attorney-Client Privilege Investigative Privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation , and analyzing facts gathered from grand jury investigation and discussing strategy for drafting revised indictment P-014623 thru P-014627 2/25/2008 emails between and Caroline Heck Work Product Deliberative Process 6(e) regarding ethical issue about whether or not to present proposed revised indictment to new grand 'u P-014628 2/25/2008 email from Villafafta to Work Product Deliberative Process 6(e) and regarding result lc .msult, with Caroline Heck about grand jury question Page 13 of 18 EFTA00185442
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 14 of 18 Bates Range Descri • tion Privilege(s) Asserted P-014629 2/26/2008 email from to regarding Work Product Deliberative Process CEOS review and draft indictment package P-014630 thru P-014631 2/26/2008 email from to regarding Work Product Deliberative Process Investigative Privilege 6(e) 2/25/2008 correspondence to Jay Lefkowitz further extending the plea deadline for Epstein P-014632 thru P-014646 2/21/2008-2/27/2008 emails between Work Product Deliberative Process 6(e) Investigative Privilege and regarding notifying DOJ's Civil Rights Division regarding the status of the case and the planned indictmen and the draft written notification P-014647 thru P-014649 2/28/2008 emails between and Susan Roe regarding Work Product Investigative Privilege 6(e) related investigation, potential investigatory leads, and CEOS review P-014650 thru P-014653 2/27/2008-2/28/2008 emails between Work Product Investigative Privilege Attorney-client privilege 6(e) Also contains information subject to privacy rights of victims who are not parties to this litigation and regarding review of evidence received pursuant to subpoenas and planned interviews of additional potential victim-witnesses P-014654 thru P-014655 2/29/2008 emails between , a , Work Product Deliberative Process Investigative Privilege 6e and regarding continuing investigation and status of CEOS review P-014656 thru P-014665 3/4/2008-3/5/2008 emails between and Work Product Attorney-client privilege 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation regarding search warrant and victim contact with attorneys Page 14 of 18 EFTA00185443
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 15 of 18 Bates Range - Descri ti Privilege(s) Asserted P-014666 thru P-014693 3/5/2 Work Product Deliberative Process 6(e) Investigative Privilege an regarding meeting in DC, additional information to prepare for meeting, and new information from ongoing investi • P-014694 thru P-014706 3/10/2 - / 008 emails be Work Product Deliberative Process Attorney-client privilege , Krishna Patel, , E.J. Yera, and about Epstein attempts to contact victims and finding c m... sel f P-014707 thru P-014711 3/12/2 8 emails betwee o and n= il , regarding CEOS meeting with Epstein counsel Work Product P414712 thru P-014716 3/14/2008 emails between regarding complete indictment package for e Work Product Deliberative Process 6(e) P-014717 thru P-014721 1St an -3/d17E1210.0Y8ereamreaigsarbedintwg search eent t application and execution of search warrant Work Product Attorney client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation P-014722 thru P-014727 I cli tilialiails , and regarding corrections Work Product Deliberative Process 6(e) Attorney-Client Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation to indictment package and proposed grand jury presentation Page 15 of 18 EFTA00185444
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Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 16 of 18 Bates Range Description Privilege(s) Asserted P-014728 thru P-014742 3/14/2008-3/19/2008 emails between Nesibtt S.mkendall , and about Epstein attempts to contact victims and finding counsel for victims Work Product Deliberative Process Attorney-client privilege Also contains information subject to privacy rights of victims who are not parties to this litigation P-014743 thru P-014780 3/19/2008-3/21/2008 emails between (CEOS), Alexandra Gelber (CEOS), and about meeting between Esptein counsel and CEOS and follow-up uestions Work Product 6(e) Deliberative Process Investi alive Privilege P-014781 thru P-014800 3/111- // 00 n , ails between and regarding waiting for DC's decision regarding Epstein's challenges to NPA; status of ongoing investigation; problems with Epstein's counsel contacting victims in the guise of deposing them for the state criminal action; and securing pro bono counsel for those victims to represent them in connection with the depositions Work Product Deliberative Process Investigative Privilege 6(e) P-014801 thru P-014810 3/28/2008 emails between , Work Product 6(e) Investigative Privilege Deliberative Process and regarding status of DC review of case and preparing for grand jury presentation P-014811 thru P-014829 3/31/2008 emails between 6(e) Work Product Deliberative Process Investigative Privilege and regarding status of ongoing investigation, planned presentation to grand jury, continued delay in awaiting decision from Washington, DC, and • roblems with victims bein harassed P-014830 thru P-014837 4/2/2008 emails between Alex Acosta, and regarding efforts by Jay Lefkowitz and Ken Stan.. with Alex Acosta and instructions to direct • uestion to and Deliberative Process Work Product Attorney-Client Privilege Page 16 of 18 EFTA00185445