EFTA00191264

vinovCase 9:08-cv-80736-Kfichillatiksunetltrc2445010enteteticOirefal_Sevemketa01300N2014 Page 13 of 
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EFTA00191364

PRIVILEGE LOG 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-000001 
thru 
P-000039 
File folder entitled "CORR RE GJ 
SUBPOENAS" containing correspondence 
related to various grand jury subpoenas and 
attorney (Villafafia) handwritten notes 
6(e) 
Work Product 
Box #1 
P-000040 
thru 
P-000549 
Operation Leap Year Grand Jury Log 
containing subpoenas OLY-01 through OLY-81, 
correspondence and research related to 
enforcement of same, documents produced in 
response to some subpoenas; and attorney 
(Villafafia) handwritten notes 
6(e) 
Work Product 
Contains documents subject 
to investigative privilege 
Also contains documents 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000550 
thru 
P-000621 
File folder entitled "Ritz Compact Flash SW" 
containing copies of a sealed search warrant 
application, warrant, and supporting documents 
6(e) 
Contains information subject 
to investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000622 
thru 
P-000693 
File folder entitled "PNY Technologies Compact 
Flash SW" containing copies of a sealed search 
warrant application, warrant, and supporting 
documents 
6(e) 
Contains information subject 
to investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000694 
thru 
P-000781 
File folder entitled "JE Corporations" containing 
attorney research on Epstein-owned corporations 
and prior litigation 
Work Product 
Contains information subject 
to investigative privilege 
Box #1 
P-000782 
thru 
P-000803 
File folder entitled "Capital One" 
containing subpoena and correspondence 
6(e) 
Box #1 
P-000804 
thru 
P-000854 
File folder entitled "DTG Operations/Dollar 
Rent-a-Car" containing subpoena and responsive 
documents 
6(e) 
Contains documents and 
information subject to 
investigative privilege 
Also contains documents and 
information subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 1 of 23 
EFTA00191365

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-000855 
thru 
P-000937 
File folder entitled "JP Morgan Chase" 
containing subpoena, correspondence, and 
responsive documents 
6(e) 
Contains documents and 
information subject to 
investigative privilege 
Box #1 
P-000938 
thru 
P-000947 
File folder entitled "Washington Mutual" 
containing subpoena, correspondence, and 
responsive documents 
6(e) 
Contains documents and 
information subject to 
investigative privilege 
Box #1 
P-000948 
tiny 
P-000982 
File folder entitled "Computer Search &" 
containing legal research on computer search and 
handwritten notes on indictment preparation 
Work Product 
Attorney-Client 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000983 
thru 
P-001007 
File folder entitled "Attorney Notes from 
Document Review" containing typed and 
handwritten attorney (Villafafia) notes, target 
letters, correspondence re grand jury subpoena 
Work product 
6(e) 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-001008 
thru 
P-001056 
File folder entitled "Notes from Fed Ex Records" 
containing handwritten and typed attorney 
(Villafana) notes and screen shots of FedEx 
subpoena response electronic file 
Work Product 
6(e) 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-001057 
thru 
P-001959 
File folder entitled "Colonial Bank Records" 
containing records received in response to grand 
jury subpoena 
6(e) 
Contains information subject 
to investigative privilege 
Box #1 
P-001960 
Thru 
P-002089 
File folder entitled "OLY Grand Jury Log Vol 2: 
OLY-5I THROUGH" containing subpoenas 
numbered OLY-51 through OLY-81 with related 
correspondence 
6(e) 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Page 2 of 23 
EFTA00191366

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-002090 
Thru 
P-002169 
File folder entitled "Epstein Corporate Records: 
OLY-51, OLY-52, OLY-53, OLY-54" containing 
subpoenas, records received in response to 
subpoenas, and related correspondence 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-002170 
Thru 
P-002246 
File folder entitled "Colonial Bank" containing 
subpoenas, correspondence related to subpoenas, 
records received in response to subpoenas 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-002247 
Thru 
P-002265 
File folder entitled "JEGE & Hyperion from 
Goldberger OLY-46 & OLY-47" containing 
documents received in response to subpoenas 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-002266 
Thru 
P-002386 
Indictment preparation binder containing: 
Grand jury subpoena log, evidence/activity 
summary chart, wimess/victim names and contact 
list, attorney (Villafada) handwritten notes, 302s, 
portions of state investigative file, attorney 
(Villafada) typed notes, of individuals listed as 
"Additional victims" 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-002387 
Thru 
P-002769 
Indictment preparation binder containing: 
Grand jury subpoena log, evidence/activity 
summary chart, witness/victim names and contact 
list, attorney (Villafaila) handwritten notes, 302s, 
portions of state investigative file, attorney 
(Villafaila) typed notes, relevant pieces of grand 
jury materials, telephone records/flight records 
analysis charts, victim/witness photographs, 
DAVID records, NCICs, and related materials for 
persons identified as Jane Does #15, 16, 17, 18, 
19, Past Employees, Misc. Witnesses 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-002770 
Thru 
P-003211 
Indictment preparation binder containing: 
witness/victim list with identifying information, 
sexual activity summary, telephone call summary 
chart, attorney (Villafaila) handwritten notes, 
302s, portions of state investigative file, attorney 
(Villafalia) typed notes, relevant pieces of grand 
jury materials, telephone records/flight records 
analysis charts, victim/witness photographs, 
DAVID records, NCICs, and related materials for 
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 
8 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page .3 of 2.3 
EFTA00191367

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-003212 
Thru 
P-003545 
Indictment preparation binder containing meta- 
analysis charts of telephone/flight/grand jury 
information for a number of victim/witnesses, 
Nadia Marcinkova, and Adriana Mucinska 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003546 
Thru 
P-003552 
FBI Reports of March 2008 interviews of 
additional witness/victim located in New York 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003553 
Thm 
P-003555B 
Printout of filenames from Federal Express 
subpoena response with Attorney notations 
Work product 
6(e) 
Box #1 
P-003556 
Thru 
P-003562 
Document entitled "Identified Numbers" with 
accompanying handwritten attorney list compiled 
from grand jury materials and attorney analysis of 
records 
Work product 
6(e) 
Contains information subject 
to investigative privilege 
Box #1 
P-003563 
Thru 
P-003629 
Folder entitled "Flight Manifests" containing 
manifests received pursuant to grand jury 
subpoena 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-003630 
Thru 
P-003633 
File folder entitled "Recent Attorney Notes" 
containing handwritten attorney (Villafafia) notes 
regarding document review and case strategy 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Box #1 
P-003634 
Thru 
P-003646 
File folder bearing victim name containing FBI 
interview report from May 2008, telephone 
activity report with attorney (Villafanafia) 
handwritten notes, related grand jury material 
Work product 
Attorney-client privilege 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 4 of 23 
EFTA00191368

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-003647 
Thru 
P-003651 
File folder entitled "Summary of Sexual Activity" 
containing chart bearing handwritten title "Sexual 
Activity — Summary" with meta-analysis of 
information, sorted by name of each 
victim/witness, including name and identifying 
information of each victim/witness 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003652 
Thru 
P-003663 
File folder entitled "Victim Civil Suits" 
Not privileged. 
Produced to counsel for 
Petitioners 
Box #1 
P-003664 
Thru 
P-003678 
File folder entitled "Research re JE Websites" 
containing attorney research 
Work product 
Box #1 
P-003679 
Thru 
P-003680 
File folder entitled "Serene Cano (N.Y. AUSA)" 
containing attorney (Villafana) handwritten notes 
Work product 
Box #1 
P-003681 
Thru 
P-003687 
File folder entitled "Dr. Anna Salter" containing 
attorney (Villafana) memo to expert witness and 
handwritten attorney notes 
Work product 
Investigative privilege 
Box #1 
P-003688 
Thru 
P-003693 
File folder entitled "I[] G[] Interview" containing 
attorney handwritten notes of interview, and 
attorney handwritten notes regarding potential 
charges 
Work product 
Investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-003694 
Thru 
P-0037 1 1 
File folder entitled "Research re Travel for 
Prostitution" containing attorney (Villafana) 
handwritten notes regarding grand jury 
presentation, chart entitled "Brought to Epstein's 
House" with handwritten notes, Message Pad 
meta-analysis chart, summary of evidence related 
to one victim/witness, and relevant grand jury 
information 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003712 
Empty file folder bearing name of victim/witness 
Investigative privilege 
Also contains information 
subject to privacy rights of 
victim who is not a party to 
this litigation 
Page 5 of 23 
EFTA00191369

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-003713 
Thru 
P-003746 
File folder entitled "T[j MO" containing grand 
jury subpoenas, motion and order to compel 
testimony, and correspondence regarding same 
6(e) 
Documents under seal 
pursuant to court order 
Box #1 
P-003747 
Thru 
P-003751 
File folder entitled "Adriana Ross" containing 
subpoena and correspondence regarding same 
6(e) 
Box #1 
P-003752 
Thru 
P-004295 
File folder entitled "PBPD Investigative File" 
obtained via subpoena 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box NI 
P-004296 
Thm 
P-004350 
File folder bearing name of victim/witness 
containing meta-analysis chart showing telephone 
calls, travel, and grand jury materials relevant to 
possible charges 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this liti ation 
Box #1 
P-004351 
Thru 
P-004381 
File folder entitled "Daniel 
Documents 
Work product 
53909-004" containing attorney research related 
to bias issue 
Box #1 
P-004382 
Thru 
P-004478 
File Folder entitled "FEDEX" containing 
documents obtained via subpoena 
6(e) 
Investigative privilege 
Box #1 
P-004479 
Thru 
P-004551 
File Folder entitled "State of Delaware Records" 
containing documents obtained in preparation for 
indictment 
6(e) 
Investigative privilege 
Work product 
Box #1 
P-004552 
Thru 
P-004555 
File folder entitled "Jet Blue Records" containing 
documents obtained via subpoena 
6(e) 
Work product 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-004556 
Thru 
P-004560 
File folder entitled "FL EMPLOYMENT 
RECORDS" containing FDLE records on targets 
and witnesses obtained at attorney request 
Investigative privilege 
Work product 
Page 6 of 23 
EFTA00191370

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-004561 
Thru 
P-004565 
Filed folder entitled "JANUSZ BANASIAK" 
containing attorney (Villafafta) handwritten notes 
of interview 
Work product 
Investigative privilege 
Box #1 
P-004566 
Thru 
P-004716 
File folder entitled "JANUSZ BANASIAK 
RECORDS 23-0001 THROUGH 23-" containing 
documents obtained via subpoena 
6(e) 
Work product 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-004717 
Thru 
P-004722 
File folder entitled "IGOR ZINOVIEV" 
containing attorney research regarding witness 
Work product 
Investigative privilege 
Box #1 
P-004723 
Thru 
P-004725 
File folder entitled "BEAR STEARNS 
RESEARCH" containing attorney research 
regarding potential witness and subpoena 
recipient 
Work Product 
Investigative privilege 
Box #1 
P-004726 
Thru 
P-004819 
File folder entitled "LAWSUITS INVOLVING 
EPSTEIN CORP'S" containing attorney research 
regarding Epstein's past personal and business 
litigative practices 
Work Product 
Investigative privilege 
Box #1 
P-004820 
Thru 
P-004959 
Filed folder entitled "SEC RECORDS" 
containing attorney research regarding Epstein 
financial relationships 
Work Product 
Investigative privilege 
Box #1 
P-004960 
Thru 
P-005059 
File folder entitled "Message Pads" containing 
selected items from evidence obtained via 
subpoena 
Work Product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005060 
Thru 
P-005081 
File folder bearing name of victim/witness 
containing correspondence with counsel for 
victim/witness, attorney witness outline with 
attorney handwritten notes, attorney handwritten 
notes regarding witness reports and case 
preparation 
Work Product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005082 
Thru 
P-005083 
File folder entitled "New York Trip" containing 
attorney notes re witness interview 
Work product 
Investigative privilege 
Page 7 of 23 
EFTA00191371

Bates Range 
Description 
Privilege(s) Asserted 
P-005084 thru P-005107 are non responsive 
documents and have been removed 
Box #1 
P-005108 
Thru 
P-005193 
File folder entitled "ANNA SALTER" containing 
attorney research on select expert, use of experts 
at trials in child exploitation cases, and additional 
research materials on offenders and victims 
Work product 
Investigative privilege 
Box #1 
P-005194 
Thru 
P-005300 
File folder entitled "Extra Copies" containing 
meta-analysis chart and 302's of victim/witnesses 
used in preparing indictment package 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box NI 
P-005301 
Thru 
P-005331 
File folder entitled "JUAN ALESSI 
STATEMENT" containing transcript obtained via 
subpoena 
6(e) 
Investigative privilege 
Box #1 
P-005332 
Thru 
P-005341 
File folder entitled "KEN LANNING" containing 
attorney research on select expert, including 
attorney handwritten notes 
Work product 
Investigative privilege 
Box #1 
P-005342 
Thar 
P-005387 
File folder entitled "Info re Planes" containing 
correspondence regarding subpoenas and 
documents received in response to subpoenas 
6(e) 
Investigative privilege 
Box #1 
P-005388 
Thru 
P-005442 
File folder entitled "Police Reports & PC 
Affidavit" containing portions of police reports 
with attorney notes, related phone records, a list 
entitled "Victims" with identifying information 
and attorney handwritten notes, photographs and 
DAVID information, and additional attorney 
research regarding Epstein sexual activity 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005443 
Thru 
P-005496 
File folder entitled "[Victim name] Transcript of 
Interview & GJ Transcript" 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005497 
Thru 
P-005556 
File folder entitled "Bear Stearns Subpoena 
Resp." containing material received in response 
to subpoena 
6(e) 
Investigative privilege 
Page 8 of 23 
EFTA00191372

Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-005557 
Thru 
P-005576 
U.S. Attorney's Office Criminal Case File Jacket 
containing file opening documents, expert 
witness payment documents 
Work product 
Deliberative process 
Box #1 
P-005578 
Thru 
P-005583 
U.S. Attorney's Office Asset Forfeiture Case File 
Jacket containing file opening and file closing 
documents 
Work product 
Deliberative process 
Box #1 
P-005584 
Thru 
P-005606 
File folder entitled "6001 Immunity Request" 
containing internal memoranda seeking witness 
immunity and correspondence with counsel for 
witness regarding same 
6(e) 
Work product and 
deliberative process (as to 
internal memoranda) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-005607 
Thru 
P-005914 
File folder entitled "MASTER PHONE 
RECORDS" containing meta-analysis of all 
phone, travel, and grand jury data for all 
victim/witnesses for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-0059 I5 
Thru 
P-005977 
File folder bearing name of victim/witness 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-005978 
Thru 
P-006050 
File folder bearing name of victim/witness 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006051 
Thru 
P-006065 
File folder bearing name of victim/witness 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 9 of 23 
EFTA00191373

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-006066 
Thru 
P-006220 
File folder entitled "JANE DOE #4" containing 
meta-analysis of all phone, travel, and grand jury 
data related to that victim/witness for indictment 
preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006221 
Thru 
P-006222 
File folder entitled ""JANE DOE #12" containing 
meta-analysis of all phone, travel, and grand jury 
data related to that victim/witness for indictment 
preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006223 
Thru 
P-006522 
File folder entitled "CORRECTED PHONE 
RECORDS 5/31/07" containing meta-analysis of 
all phone, travel, and grand jury data related to all 
victims/witnesses for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006523 
Thru 
P-006802 
File folder entitled "[Victim Name] Phone 
Records" containing telephone records received 
in response to subpoena 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006803 
Thru 
P-006860 
File folder entitled "Lists of Identified Phone 
Numbers" containing charts of information culled 
from grand jury materials, interviews, and other 
investigation, with attorney handwritten notes, 
and information to issue follow-up grand jury 
subpoena 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006861 
Thru 
P-007785 
File folder entitled "EPSTEIN/KELLEN CELL 
PHONE RECORDS" containing documents 
received via subpoena with attorney handwritten 
notes and highlighting 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 10 of 23 
EFTA00191374

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-007786 
Thru 
P-008120 
Folder entitled "OLY GRAND JURY LOG: 
OLY-01 THROUGH OLY-50" containing 
subpoenas, correspondence regarding same, 6(e) 
letters, attorney handwritten notes regarding 
records received in response to subpoenas 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-008121 
Thru 
P-008139 
Handwritten flight logs received in response to 
subpoena 
6(e) 
Investigative privilege 
Box #2 
P-008140 
Thru 
P-008298 
Grand jury presentation folder containing 
attorney handwritten notes, typed outline with 
additional handwritten notes, complete indictment 
package dated 2/19/2008, victim list with 
identifying information, photographs, and 
summary of activity 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-008299 
Thru 
P-008363 
File folder entitled "FINAL AGREEMENTS" 
containing subfolder entitled "Agrmts Filed in 
State Court" (P-008300-P-008327 [not being 
withheld as privileged — have been produced to 
opposing counsel]); signed Non-Prosecution 
Agreement, Addendum, and operative portion of 
12/19/2007 Sanchez-Acosta letter (P-008328-P-
008343 [not being withheld as privileged — have 
been produced to opposing counsel]); subfolder 
entitled "12/19/07 Acosta-Sanchez Ltr" 
containing unredacted copies of that letter (P-
008344-P-008363 [pursuant to Court's Order, not 
being withheld as privileged — will be produced 
to opposing counsel upon lift of stay by 1 I1h
Circuit]) 
Box #2 
P-008364 
Thru 
P-008382 
File folder entitled "Lacerda Immunity Request" 
containing internal memoranda, Justice 
Department documentation, and subpoena 
regarding immunity request 
6(e) 
Work Product 
Deliberative Process 
Investigative privilege 
Box #2 
P-008383 
Thru 
P-008516 
File folder containing March 18, 2008 grand jury 
presentation materials, including "Operation Leap 
Year Revised Indictment Summary Chart (by 
victim)," grand jury materials, draft indictments, 
victim reference list, grand jury subpoena log 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 11 of 23 
EFTA00191375

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-008517 
Thru 
P-008535 
6/25/2007 Letter from Gerald Lefcourt to Jeffrey 
Sloman and Andrew Lourie 
[pursuant to Court's Order, not being withheld as 
privileged — will be produced to opposing counsel 
upon lift of stay by I Id' Circuit] 
Box #2 
P-008536 
Thru 
P-008542 
Handwritten attorney notes to prepare for 
interview of Jane Doe #2 
Work product 
Investigative Privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008543 
Thru 
P-008549 
Handwritten attorney notes regarding May 8, 
2007 grand jury presentation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008550 
Thru 
P-008615 
File folder entitled "Most Recent Indictment & 
Good Cases" containing draft indictment and 
legal research 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008616 
Thru 
P-008686 
File folder entitled "FBI Summary Charts" 
containing chart prepared at direction of AUSA, 
containing victim names, identifying information, 
summary of activity, and other information 
relevant to indictment 
Work product 
Attorney-Client Privilege 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008687 
Thru 
P-008776 
File folder entitled "[Victim name]/Jane Doe #4" 
containing phone records and meta-analysis of all 
phone, travel, and grand jury data related to that 
victim/witness for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this suit 
Box #2 
P-008777 
Thru 
P-008808 
File folder entitled "[Victim name]/Jane Doe #5" 
containing handwritten notes and meta-analysis 
of all phone, travel, and grand jury data related to 
that victim/witness for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Page 12 of 23 
EFTA00191376

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-008809 
Thai 
P-008847 
File folder entitled "[Victim name]/Jane Doe #6" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008848 
Thru 
P-008862 
File folder entitled "[Victim name]/Jane Doe #7" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008863 
Thru 
P-008890 
File folder entitled "[Victim name]/Jane Doe #8" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008891 
Thru 
P-009103 
File folder entitled "Certified Copy of State Case" 
containing certified copy of Epstein state criminal 
cases and change of plea transcript [not being 
withheld as privileged — copy provided to 
opposing counsel 
Box #2 
P-009104 
Thru 
P-009111 
File folder entitled "Meeting Timeline" 
containing Villafafia typed notes summarizing 
meetings with opposing counsel prepared at 
request of R. Alexander Acosta, with handwritten 
correction and typed guideline estimate 
Work product 
Deliberative process 
Box #2 
P-009112 
Thru 
P-009113 
11/26/2008 Email from Roy Black to A. Marie 
Villafafia and Karen Atkinson re Jeffrey Epstein 
(work release) 
[pursuant to Court's Order, not being withheld as 
privileged — will be produced to opposing counsel 
upon lift of stay by 11'" Circuit] 
Box #2 
P-009114 
Thru 
P-009115 
7/3/2008 Email from A. Marie Villafafia to Col. 
M. Gauger at PBSO re Epstein work release with 
attachment [not being withheld as privileged —
produced to opposing counsel] 
Box #2 
P-009116 
Thru 
P-009125 
12/6/2007 Letter from Jeffrey Sloman to Jay P. 
Lefkowitz re Jeffrey Epstein (victim notification) 
[pursuant to Court's Order, not being withheld as 
privileged — will be produced to opposing counsel 
upon lift of stay by 11'" Circuit]) 
Page 13 of 23 
EFTA00191377

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-009126 
Thru 
P-009134 
File folder entitled "[Victim name]/Jane Doe #9" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-009135 
Thru 
P-009141 
File folder entitled "[Victim name]/Jane Doe 
#13" containing meta-analysis of all phone, 
travel, and grand jury data related to that 
victim/witness for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-00914 IA 
Thru 
P-00914 IC 
File folder entitled "[Victim name]/Jane Doe 
#12" containing meta-analysis of all phone, 
travel, and grand jury data related to that 
victim/witness for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-009142 
Thru 
P-009152 
File folder entitled "Adrian `Mucinka' Ross" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that individual for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-009153 
Thru 
P-009156 
File folder entitled "Nadia Marcinkova" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that individual for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-009157 
Thru 
P-009208 
File folder entitled "[Victim name]/Jane Doe #1" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-009209 
Thru 
P-009213 
File folder entitled "[Victim name]/Jane Doe #2" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Page 14 of 23 
EFTA00191378

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-009214 
Thru 
P-009271 
File folder entitled "[Victim name]/Jane Doe #3" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/wimess for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-009272 
Thru 
P-009354 
File folder entitled "Purpose of Travel Cases" 
containing attorney research and handwritten 
notes 
Work product 
Box #2 
P-009355 
Thru 
P-009403 
File folder entitled "Interstate Commerce Cases" 
containing attorney research and handwritten 
notes 
Work product 
Box #2 
P-009404 
Thru 
P-009536 
File folder entitled "Attorney Conflict Research" 
containing attorney research and handwritten 
notes 
Work product 
Box #2 
P-009537 
Thru 
P-009574 
File folder entitled "Mann Act/Travel to Have 
Sex w/Minor" containing attorney research and 
handwritten notes 
Work product 
Box #2 
P-009575 
Thru 
P-009603 
File folder entitled "Travel Act" containing 
attorney research and handwritten notes 
Work Product 
Box #2 
P-009604 
Thru 
P-009711 
File folder entitled "Florida 
Prostitution/Lewdness Statutes" containing 
attorney research and handwritten notes 
Work Product 
Box #2 
P-009712 
Thru 
P-009819 
Booklet entitled "Attorney General Guidelines for 
Victim and Witness Assistance" [not being 
withheld as privileged — produced to opposing 
counsel] 
Box #2 
P-009820 
Thru 
P-009965 
File folder entitled "Corporate Liability Rsrch" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-009966 
Thru 
P-010096 
File folder entitled "Research re Knowledge of 
Age Unnecessary" containing attorney research 
and handwritten notes and copy of grand jury 
subpoena 
Work Product 
6(e) 
Page 15 of 23 
EFTA00191379

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-010097 
Thru 
P-010276 
File folder entitled "Money Laundering" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-010277 
Thru 
P-010394 
File folder entitled "1960 & Aiding/Abetting" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-010395 
Thru 
P-010488 
File folder entitled "18 USC § 2255 Cases" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-010489 
Thru 
P410509 
File folder entitled "Research re Overt Acts & 
Witness Testimony" containing attorney research 
and handwritten notes 
Work Product 
Box #2 
P-010510 
Thru 
P-010525 
File folder entitled "Extradition" containing 
attorney research and handwritten notes 
Work Product 
Box #2 
P-010526 
Thru 
P-010641 
File folder entitled "Rsrch re Crime Victims 
Rights" containing attorney research, handwritten 
notes, draft victim notification letter, and draft 
correspondence to Jay Lefkowitz 
(Also contains a November 28, 2007 letter from 
Kenneth Starr to Alice S. Fisher; and a November 
29, 2007 letter from Jay Lefkowitz to R. 
Alexander Acosta (P-010528 thru P-010530 and 
P-010556 thru P-010559). Pursuant to the 
Court's Order, these will be produced to opposing 
counsel upon lift of stay by 11th Circuit) 
Work Product 
Deliberative Process 
Box #2 
P-010642 
Thru 
P-01650 
File folder entitled "Immunity" containing 
attorney research on granting immunity to 
witnesses 
Work Product 
Box #2 
P-010651 
Thru 
P-010659 
File folder entitled "Research re G.J. Transcript" 
containing attorney research and draft pleadings 
re compelling production of grand jury transcript 
with subpoena 
Work Product 
6(e) 
Deliberative process 
Box #2 
P-010660 
Thru 
P-010757 
File folder entitled "Research re GJ Transcript" 
containing grand jury subpoena, 6(e) letters, 
attorney research and correspondence related to 
subpoena 
Work Product 
6(e) 
Page 16 of 23 
EFTA00191380

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-010758 
Thru 
P-010793 
File folder entitled "Original Proposed Ind." 
containing draft indictment 
Work Product 
6(e) 
Deliberative process 
Box #2 
P-010794 
Thru 
P-010829 
File folder entitled "Epstein" containing sample 
indictments and attorney research re potential 
charges with attorney notes 
Work Product 
Box #2 
P-010830 
Thru 
P-010853 
File folder entitled "1591 & Money Laundering" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-010854 
Thru 
P-010876 
File folder entitled "18 USC 2425" containing 
attorney research and handwritten notes 
Work Product 
Box #2 
P-010877 
Thru 
P-010920 
File folder entitled "Knowledge of Age" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-010921 
Thm 
P-011049 
File folder entitled "2423(b) Constitutionality and 
Purpose of Travel" containing attorney research 
and handwritten notes 
Work Product 
Box #2 
P-011050 
Thru 
P-011212 
File folder entitled "Mistake not a 
Defense" containing attorney research and 
handwritten notes 
Work Product 
Box #2 
P-011213 
Thru 
P-011237 
File folder entitled "Research re 'Pandering' 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-011238 
Thru 
P-011319 
File folder entitled "Research re Grand Any 
Instructions" containing attorney research and 
handwritten notes 
Work Product 
6(e) 
Box #2 
P-011320 
Thru 
P-011361 
File folder entitled "Telephone = Facility of 
Commerce" containing attorney research and 
handwritten notes 
Work Product 
Box #2 
P-011362 
Thru 
P-011374 
File folder entitled "Def of Prostitution" 
containing attorney research and handwritten 
notes 
Work Product 
Page 17 of 23 
EFTA00191381

Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-011375 
Thru 
P-011456 
File folder entitled "Relevant Florida Statutes" 
containing attorney research and handwritten 
notes 
Work Product 
Box #2 
P-011457 
Thru 
P-011626 
File folder entitled "Unit of Prosecution 
Research" containing attorney research and 
handwritten notes 
Work Product 
Box #3 
P-011627 
Thru 
P-011662 
File folder entitled "Attorney Notes" containing 
attorney handwritten and typed notes 
Work Product 
Box #3 
P-011663 
Thru 
P-011698 and 
P-012189 thru 
P-012361 
(gap was 
scanning error) 
File folder entitled "Drafts" containing draft 
indictments with attorney handwritten notes, draft 
internal memoranda, relevant witness interview 
reports and grand jury material and attorney 
handwritten notes 
6(e) 
Work Product 
Deliberative Process 
Investigative Privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this 
Box #3 
P-011699 
Thru 
P-011777 
File folder entitled "6/9/09 Signed Indictment" 
containing signed indictment package dated 
6/9/2009 with corrections 
6(e) 
Work product 
Deliberative process 
Box #3 
P-011778 
Thru 
P-011788 
File folder entitled "6/12/09 Victim Noti£ Log" 
containing chart with victim contact information 
and attorney notes regarding dates and type of 
contacts 
Work product 
Box #3 
P-011789 
Thru 
P-011879 
File folder entitled "Breach Memo" containing 
memorandum analyzing breach of Non- 
Prosecution Agreement with attachments 
Work product 
Deliberative process 
Box #3 
P-011880 
Thru 
P-011922 
File folder entitled "Overt Act Lists" containing 
handwritten notes cross-checking all overt acts 
alleged in draft indictment by victim and typed 
overt act summary charts for indictment 
preparation 
Work product 
Attorney-client privilege 
Deliberative process 
6(e) 
Page 18 of 23 
EFTA00191382

Bates Range 
Description 
Privilege(s) Asserted 
Box #3 
P-011923 
Thru 
P-011966 
Folder entitled "Responses to Arguments from JE 
Counsel" containing: 
■ 7/13/2007 letter from Lilly Ann Sanchez 
to Andrew Lourie with handwritten 
attorney (Lourie) notes; 
■ 6/25/2007 letter from Gerald Lefcourt to 
Jeffrey Sloman, Matt Menchal, Andrew 
Lourie, 
and 
Marie 
Villafafla 
with 
handwritten attorney (Villafttfla) notes; 
■ 6/25/2007 email from Andrew Lourie to 
Matt Menchel 
and Marie Villafana 
entitled "Thoughts on Lefcourt's letter" 
Handwritten and typed attorney (Villafafia) notes 
regarding main themes raised by Epstein counsel 
Work product 
Deliberative process 
6(e) 
Attorney-Client Privilege 
Box #3 
P-011967 
Thru 
P-012016 
Composition book entitled "Operation Leap 
Year" containing attorney handwritten notes 
regarding investigation and case strategy 
Work product 
Investigative privilege 
6(e) 
Contains information subject 
to privacy rights of victims 
who are not parties to this 
litigation 
Box #3 
P-012017 
Thru 
P-012055 
Motion of Jeffrey Epstein to Intervene and to 
Quash Grand Jury Subpoenas and Incorporated 
Memorandum of Law 
6(e) 
Box #3 
P-012056 
Thru 
P-012088 
Affidavit of Roy Black, Esq. in Support of 
Motion of Jeffrey Epstein to Intervene and to 
Quash Grand Jury Subpoenas 
6(e) 
Box #3 
P-012089 
Thru 
P-012129 
United States' Response to Motion of Jeffrey 
Epstein to Intervene and to Quash Grand Jury 
Subpoenas and Cross-Motion to Compel 
6(e) 
Box #3 
P-012130 
"Him 
P-012150 
Declaration of Joseph Recarey 
6(e) 
Box #3 
P-012151 
Thru 
P-012167 
Ex Pane Declaration Number One in Support of 
United States' Response to Motion to Quash 
Subpoenas 
6(e) 
Investigative Privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Page 19 of 23 
EFTA00191383