Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG — WITH VICTIMS’ OBJECTIONS EFTA00208682

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG — WITH VICTIMS’ OBJECTIONS Key to Objections (linking to Victims’ Motion to Compel Production of Docments that Are Not Privileged) Objection General Objections -- Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Government's Fiduciary Duty to Crime Victims Bars Privilege Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections - Privilege Not Properly Invoked Final Decision Exempted from Privilege Qualified Privilege Overridden By the Victims’ Need for the Documents Investigative Privilege - Privilege Not Properly Invoked Qualified Privilege Overridden By the Victims’ Need for the Documents Work Product Doctrine No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Qualified Privilege Overridden By the Victims’ Need for the Documents Work Production Privilege Does No Apply When the Attorney’s Conduct is at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand Jury Materials Page 1 of 69 Abbreviation Inadequate Log No Factual Underpinnings Waiver Fiduciary Duty Crime-Fraud-Misconduct Factual Materials Not in Anticipation of Litigation Ordinary Government Communication No Attorney-Client Relationship Improper Invocation Final Decision Overriding Need Improper Invocation Overriding Need Claims Against Public Prosecutor Overriding Need Attorney Conduct at Issue Court Authorized Under 6(e)(3)(E) Court Inherent Power to Release Proper Victim’s Petition CVRA-authorized release EFTA00208683

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 3 of 70 Grand Jury Materials Can Be Severed from Other Materials The Privacy Rights of Other Victims Government Redaction Can Resolve Privacy Concerns No Assertion of Privacy Rights by Other Victims Privacy Act The Privacy Act Does Not Apply to Court-Compelled Disclosures for Discovery Material Severable Redaction No Assertion by Victims Court-Compelled Disclosure Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “CORR RE GJ 6(e) Inadequate Log; No Factual Underpinnings; P-000001 SUBPOENAS” containing correspondence Work Product Fiduciary Duty; Not in Anticipation of thru related to various grand jury subpoenas and Litigation; Claims Against Public Prosecutor; P-000039 attorney (Villafafia) handwritten notes Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Overriding Need Box #1 Operation Leap Year Grand Jury Log 6(e) Inadequate Log; No Factual Underpinnings: P-000040 containing subpoenas OLY-01 through Work Product Fiduciary Duty; Factual Materials; Not in thru OLY-81, correspondence and research Contains documents Anticipation of Litigation; Improper P-000549 related to enforcement of same, documents | subject to investigative | Invocation; Overriding Need; Claims Against produced in response to some subpoenas; and attorney (Villafaiia) handwritten notes privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims; Overriding Need Page 2 of 69 EFTA00208684

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 4 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “Ritz Compact Flash 6(e) Inadequate Log: No Factual Underpinnings; P-000550 SW” containing copies of a sealed search Contains information Fiduciary Duty; Factual Materials; Not in thru warrant application, warrant, and) subject to investigative | Anticipation of Litigation; — Improper P-000621 supporting documents privilege Invocation; Overriding Need; Factual Also contains information | Materials; Court Authorized Under 6(e)(3)(E): subject to privacy rights of | Court Inherent Power to Release: Proper victims who are not Victim’s Petition; CVRA-authorized release; parties to this litigation | Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “PNY Technologies 6(e) Inadequate Log: No Factual Underpinnings; P-000622 Compact Flash SW” containing copies of a Contains information Fiduciary Duty; Factual Materials; Not in thru sealed search warrant application, warrant, | subject to investigative | Anticipation of Litigation; — Improper P-000693 and supporting documents privilege Invocation; Overriding Need; Factual Also contains information | Materials; Court Authorized Under 6(e)(3)(E): subject to privacy rights of | Court Inherent Power to Release: Proper victims who are not Victim's Petition; CVRA-authorized release; parties to this litigation | Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “JE Corporations” Work Product Inadequate Log: No Factual Underpinnings: P-000694 containing attorney research on Epstein- Contains information Fiduciary Duty; Not in Anticipation of thru owned corporations and prior litigation subject to investigative | Litigation; Improper Invocation; Overriding P-000781 privilege Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Overriding Need Box #1 File folder entitled “Capital One” 6(e) Inadequate Log; No Factual Underpinnings; P-000782 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court thru Authorized Under 6(e)(3)(E); Court Inherent P-000803 Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 3 of 69 EFTA00208685

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections 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 Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E): Court Inherent Power to Release: Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 P-000855 thru P-000937 Box #1 P-000938 thru P-000947 File folder entitled “JP Morgan Chase” containing subpoena, correspondence, and responsive documents File folder entitled “Washington Mutual” containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege 6(e) Contains documents and information subject to investigative privilege Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Inadequate Log: No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Box #1 P-000948 thru 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 Page 4 of 69 Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims EFTA00208686

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 6 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “Attorney Notes from Work product Inadequate Log: No Factual Underpinnings; P-000983 Document Review” containing typed and 6(e) Fiduciary Duty; Factual Materials; Not in thru handwritten attorney (Villafafia) notes, Contains information Anticipation of Litigation; — Improper P-001007 target letters, correspondence re grand jury | subject to investigative | Invocation; Overriding Need; Claims Against subpoena privilege. Also contains | Public Prosecutor; Attorney Conduct at Issue: information subject to Factual Materials; Court Authorized Under privacy rights of victims | 6(e)(3)(E); Court Inherent Power to Release; who are not parties to this | Proper Victim’s Petition; CWRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “Notes from Fed Ex Work Product Inadequate Log; No Factual Underpinnings: P-001008 Records” containing handwritten and typed 6(e) Fiduciary Duty; Factual Materials; Not in thru attorney (Villafafia) notes and screen shots Contains information Anticipation of — Litigation; — Improper P-001056 of FedEx subpoena response electronic file subject to investigative | Invocation; Overriding Need; Claims Against privilege. Also contains | Public Prosecutor; Attorney Conduct at Issue; information subject to Factual Materials; Court Authorized Under privacy rights of victims | 6(e)(3)(E); Court Inherent Power to Release: who are not parties to this | Proper Victim’s Petition; CWRA-authorized litigation release; Material Severable: Redaction; No Assertion by Victims Box #1 File folder entitled “Colonial Bank 6(e) Inadequate Log: No Factual Underpinnings: P-001057 Records” containing records received in Contains information Fiduciary Duty; Not in Anticipation of thru response to grand jury subpoena subject to investigative | Litigation; Improper Invocation; Overriding P-001959 privilege Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Page 5 of 69 EFTA00208687

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 7 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “OLY Grand Jury Log 6(e) Inadequate Log: No Factual Underpinnings; P-001960 Vol 2: OLY-51 THROUGH” containing Contains information Fiduciary Duty; Factual Materials; Not in Thru subpoenas numbered OLY-51 through | subject to investigative | Anticipation of Litigation; — Improper P-002089 OLY-81 with related correspondence privilege. Also contains | Invocation; Overriding Need; Factual information subject to Materials; Court Authorized Under 6(e)(3)(E): privacy rights of victims | Court Inherent Power to Release: Proper who are not parties to this | Victim’s Petition; CVRA-authorized release; litigation Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “Epstein Corporate 6(e) Inadequate Log: No Factual Underpinnings; P-002090 Records: © OLY-51, OLY-52, OLY-53, | Contains information and | Fiduciary Duty; Not in Anticipation of Thru OLY-54” containing subpoenas, records documents subject to Litigation; Improper Invocation; Overriding P-002169 received in response to subpoenas, and | investigative privilege | Need; Factual Materials; Court Authorized related correspondence Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled “Colonial Bank” 6(e) Inadequate Log: No Factual Underpinnings: P-002170 containing subpoenas, correspondence | Contains information and | Fiduciary Duty; Not in Anticipation of Thru related to subpoenas, records received in documents subject to Litigation; Improper Invocation; Overriding P-002246 response to subpoenas investigative privilege | Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled “JEGE & Hyperion 6(e) Inadequate Log; No Factual Underpinnings; P-002247 from Goldberger OLY-46 & OLY-47" | Contains information and | Fiduciary Duty; Not in Anticipation of Thru containing documents received in response documents subject to Litigation; Improper Invocation; Overriding P-002265 to subpoenas investigative privilege | Need; Factual Materials; Court Authorized Page 6 of 69 Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release: Material Severable EFTA00208688

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 8 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections Box #1 P-002266 Thru P-002386 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, attomey —(Villafafia) handwritten notes, 302s, portions of state (Villafafia) listed as investigative file, attorney typed notes, of individuals “Additional victims” Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart, witness/victim names and contact list, attorney (Villafafia) handwritten notes, 302s, portions of state investigative file, attorney (Villafafia) typed notes, relevant pieces of grand jury materials, telephone records/flight records 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 Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release: Proper Victim’s Petition; CWRA-authorized analysis charts, victim/witness | who are not parties to this | release; Material Severable; Redaction; No photographs, DAVID records, NCICs, and litigation Assertion by Victims related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Page 7 of 69 EFTA00208689

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 9 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 Indictment preparation binder containing: Work product Inadequate Log; No Factual Underpinnings: P-002770 witness/victim list with — identifying 6(e) Fiduciary Duty; Factual Materials; Not in Thru information, sexual activity summary, | Contains information and | Anticipation of Litigation; —_ Improper P-003211 telephone call summary chart, attorney documents subject to Invocation; Overriding Need; Claims Against (Villafafia) handwritten notes, 302s,|_ investigative privilege. | Public Prosecutor; Attorney Conduct at Issue; portions of state investigative file, attorney | Also contains information | Redaction; No Assertion by Victims (Villafaiia) typed notes, relevant pieces of | and documents subject to grand = jury materials, telephone | privacy rights of victims records/flight records analysis charts, | who are not parties to this victim/witness photographs, DAVID litigation records, NCICs, and related materials for persons identified as Jane Does #1, 2, 3, 4, 5,6,7,8 | Box #1 Indictment preparation binder containing Work product Inadequate Log; No Factual Underpinnings: P-003212 meta-analysis charts of 6(e) Fiduciary Duty; Factual Materials; Not in Thru telephone/flight/grand jury information for | Contains information and | Anticipation of Litigation; — Improper P-003545 a_number of victim/witnesses. documents subject to Invocation; Overriding Need; Claims Against = investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 8 of 69 EFTA00208690

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 10 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 FBI Reports of March 2008 interviews of Work product Inadequate Log: No Factual Underpinnings; P-003546 additional witness/victim located in New 6(e) Fiduciary Duty; Factual Materials; Not in Thru York Contains information and | Anticipation of Litigation; — Improper P-003552 documents subject to Invocation; Overriding Need; Claims Against investigative privilege. | Public Prosecutor; Attorney Conduct at Issue; Also contains information | Factual Materials; Court Authorized Under and documents subject to | 6(e)(3)(E); Court Inherent Power to Release; privacy rights of victims | Proper Victim’s Petition; CWRA-authorized who are not parties to this | release; Material Severable: Redaction; No litigation Assertion by Victims Box #1 Printout of filenames from Federal Express Work product Inadequate Log; No Factual Underpinnings: P-003553 subpoena response with Attorney notations 6(e) Fiduciary Duty; Not in Anticipation of Thru Litigation; Claims Against Public Prosecutor: P-003555B Overriding Need; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release: Proper Victim’s Petition; CWRA-authorized release; Material Severable Box #1 Document entitled “Identified Numbers” Work product Inadequate Log: No Factual Underpinnings; P-003556 with accompanying handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of Thru list compiled from grand jury materials and Contains information Litigation; Improper Invocation; Overriding P-003562 attorney analysis of records subject to investigative | Need; Claims Against Public Prosecutor; privilege Attorney Conduct at Issue; Factual Materials: Court Authorized Under 6(e)(3)(E): Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release: Material Severable Page 9 of 69 EFTA00208691

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 11 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 Folder entitled = “Flight Manifests” 6(e) Inadequate Log: No Factual Underpinnings; P-003563 containing manifests received pursuant to | Contains information and | Fiduciary Duty; Not in Anticipation of Thru grand jury subpoena documents subject to Litigation; Improper Invocation; Overriding P-003629 investigative privilege | Need; Factual Materials; Court Authorized Under 6(e)(3)(E):; Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled “Recent Attorney Work product Inadequate Log: No Factual Underpinnings; P-003630 Notes” containing handwritten attorney 6(e) Fiduciary Duty; Not in Anticipation of Thru (Villafafia) notes regarding document Investigative privilege | Litigation; Improper Invocation; Overriding P-003633 review and case strategy Deliberative process Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 File folder bearing victim name containing Work product Inadequate Log: No Factual Underpinnings: P-003634 FBI interview report from May 2008,) Attorney-client privilege | Fiduciary Duty; Factual Materials; Not in Thru telephone activity report with attorney 6(e) Anticipation of Litigation; — Ordinary P-003646 (Villafanafia) handwritten notes, related| Investigative privilege | Government Communication; No Attorney- grand jury material Also contains information | Client Relationship; Improper Invocation; and documents subject to | Overriding Need; Claims Against Public privacy rights of victims | Prosecutor; Attorney Conduct at Issue; Factual who are not parties to this | Materials; Court Authorized Under 6(e)(3)(E); litigation Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 10 of 69 EFTA00208692

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 12 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “Summary of Sexual Work product Inadequate Log: No Factual Underpinnings; P-003647 Activity” containing ~—chart___ bearing 6(e) Fiduciary Duty; Factual Materials; Not in Thru handwritten title “Sexual Activity -— | Investigative privilege | Anticipation of Litigation; — Improper P-003651 Summary” with meta-analysis of Deliberative process Invocation; Overriding Need; Claims Against information, sorted by name of each | Also contains information | Public Prosecutor; Attorney Conduct at Issue: victim/witness, including name and) and documents subject to | Factual Materials; Court Authorized Under identifying information of — each} privacy rights of victims | 6(e)(3)(E); Court Inherent Power to Release; victim/witness who are not parties to this | Proper Victim’s Petition; CWRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “Victim Civil Suits” Not privileged. N/A P-003652 Produced to counsel for Thru Petitioners P-003663 Box #1 File folder entitled “Research re JE Work product Inadequate Log; No Factual Underpinnings: P-003664 Websites” containing attorney research Fiduciary Duty; Not in Anticipation of Thru Litigation; Claims Against Public Prosecutor: P-003678 Overriding Need; Attorney Conduct at Issue Box #1 File folder entitled “Serene Cano (N.Y. Work product Inadequate Log; No Factual Underpinnings: P-003679 AUSA)” containing attorney (Villafafa) Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor: P-003680 Overriding Need; Attorney Conduct at Issue Box #1 File folder entitled “Dr. Anna Salter” Work product Inadequate Log: No Factual Underpinnings; P-003681 containing attorney (Villafafia) memo to | Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru expert witness and handwritten attorney Litigation; Improper Invocation; Overriding P-003687 notes Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Page 11 of 69 EFTA00208693

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 13 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections 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 Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Redaction; No Assertion by Victims Box #1 P-003694 Thru P-003711 File folder entitled “Research re Travel for Prostitution” containing attorney (Villafafia) 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 Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Box #1 Empty file folder bearing name of | Investigative privilege | N/A P-003712 victim/witness Also contains information subject to privacy rights of victim who is not a party to this litigation Box #1 File folder entitled “T[] M[]” containing 6(e) Inadequate Log: No Factual Underpinnings; P-003713 grand jury subpoenas, motion and order to Documents under seal Fiduciary Duty; Factual Materials; Court Thru compel testimony, and correspondence pursuant to court order Authorized Under 6(e)(3)(E); Court Inherent P-003746 regarding same Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box#1 | File folder entitled “(ll HF 6(e) Inadequate Log; No Factual Underpinnings; P-003747 containing subpoena and correspondence Fiduciary Duty; Factual Materials; Court Thru regarding same Authorized Under 6(e)(3)(E); Court Inherent P-003751 Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable Page 12 of 69 EFTA00208694

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 14 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “PBPD Investigative 6(e) Inadequate Log: No Factual Underpinnings; P-003752 File” obtained via subpoena Investigative privilege | Fiduciary Duty; Factual Materials; Not in Thru Also contains information | Anticipation of Litigation; — Improper P-004295 and documents subject to | Invocation; Overriding Need; Factual privacy rights of victims | Materials; Court Authorized Under 6(e)(3)(E): who are not parties to this | Court Inherent Power to Release: Proper litigation Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder bearing name of victim/witness Work product Inadequate Log: No Factual Underpinnings; P-004296 containing meta-analysis chart showing 6(e) Fiduciary Duty; Factual Materials; Not in Thru telephone calls, travel, and grand jury | Investigative privilege | Anticipation of Litigation; — Improper P-004350 materials relevant to possible charges Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Box #1 File folder entitled “Daniel Gonzalez Work product Inadequate Log; No Factual Underpinnings: P-004351 Documents 53909-004" containing Fiduciary Duty; Not in Anticipation of Thru attorney research related to bias issue Litigation; Claims Against Public Prosecutor: P-004381 Overriding Need; Attorney Conduct at Issue Box #1 File Folder entitled “FEDEX” containing 6(e) Inadequate Log: No Factual Underpinnings; P-004382 documents obtained via subpoena Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru Litigation; Improper Invocation; Overriding P-004478 Need; Factual Materials; Court Authorized Page 13 of 69 Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release: Material Severable EFTA00208695

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 15 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File Folder entitled “State of Delaware 6(e) Inadequate Log No Factual Underpinnings: P-004479 Records” containing documents obtained | Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru in preparation for indictment Work product Litigation; Improper Invocation; Overriding P-004551 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #1 File folder entitled “Jet Blue Records” 6(e) Inadequate Log: No Factual Underpinnings; P-004552 containing documents obtained — via Work product Fiduciary Duty; Factual Materials; Not in Thru subpoena Investigative privilege | Anticipation of Litigation; — Improper P-004555 Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “FL EMPLOYMENT | _ Investigative privilege | Inadequate Log; No Factual Underpinnings: P-004556 RECORDS” containing FDLE records on Work product Fiduciary Duty; Not in Anticipation of Thru targets and witnesses obtained at attorney Litigation; Improper Invocation; Overriding P-004560 request Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Box #1 Filed folder entitled “JANUSZ Work product Inadequate Log; No Factual Underpinnings: P-004561 BANASIAK” containing attorney | Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru (Villafafia) handwritten notes of interview Litigation; Improper Invocation; Overriding P-004565 Need; Claims Against Public Prosecutor; Page 14 of 69 Attorney Conduct at Issue EFTA00208696

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Bates Range Description Privilege(s) Asserted Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 16 of 70 Victims’ Objections Box #1 P-004566 Thru P-004716 Box #1 P-004717 Thru P-004722 Box #1 P-004723 Thru P-004725 Box #1 P-004726 Thru P-004819 Box #1 P-004820 Thru P-004959 File folder entitled “JANUSZ BANASIAK 6(e) RECORDS 23-0001 THROUGH 23-” Work product containing documents obtained via} Investigative privilege subpoena Also contains information and documents subject to privacy rights of victims who are not parties to this litigation File folder entitled “IGOR ZINOVIEV” Work product containing attorney research regarding | Investigative privilege witness File folder entitled “BEAR STEARNS Work Product RESEARCH” containing attorney research | __ Investigative privilege regarding potential witness and subpoena recipient File folder — entitled == “LAWSUITS Work Product INVOLVING EPSTEIN CORP’S” | __ Investigative privilege containing attorney research regarding Epstein’s past personal and business litigative practices Filed folder entitled “SEC RECORDS” Work Product containing attorney research regarding | Investigative privilege Epstein financial relationships Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of — Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Inadequate Log: No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Page 15 of 69 EFTA00208697

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 17 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “Message Pads” Work Product Inadequate Log: No Factual Underpinnings; P-004960 | containing selected items from evidence 6(e) Fiduciary Duty; Factual Materials; Not in Thru obtained via subpoena Investigative privilege | Anticipation of Litigation; — Improper P-005059 Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder bearing name of victim/witness Work Product Inadequate Log; No Factual Underpinnings: P-005060 | containing correspondence with counsel 6(e) Fiduciary Duty; Factual Materials; Not in Thru for victim/witness, attorney witness outline | Investigative privilege | Anticipation of Litigation; Improper P-005081 with attorney handwritten notes, attorney | Also contains information | Invocation; Overriding Need; Claims Against handwritten notes regarding witness | and documents subject to | Public Prosecutor; Attorney Conduct at Issue: reports and case preparation privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “New York Trip” Work product Inadequate Log: No Factual Underpinnings: P-005082 containing attorney notes re witness| Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru interview Litigation; Improper Invocation; Overriding P-005083 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue P-005084 thru P-005107 are non N/A responsive documents and have been removed Page 16 of 69 EFTA00208698

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 18 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “ANNA SALTER” Work product Inadequate Log; Fiduciary Duty; Factual P-005 108 containing attorney research on select | Investigative privilege | Materials; Not in Anticipation of Litigation; Thru expert, use of experts at trials in child Improper Invocation; Overriding Need; Claims P-005193 exploitation cases, and additional research Against Public Prosecutor; Attorney Conduct materials on offenders and victims at Issue Box #1 File folder entitled “Extra Copies” Work product Inadequate Log: No Factual Underpinnings: P-005194 containing meta-analysis chart and 302’s of 6(e) Fiduciary Duty; Factual Materials; Not in Thru victim/witnesses used in preparing | Investigative privilege | Anticipation of Litigation; Improper P-005300 indictment package Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim's Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Box #1 File folder entitled “JUAN ALESSI 6(e) Inadequate Log; No Factual Underpinnings: P-005301 STATEMENT” containing transcript) Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru obtained via subpoena Litigation; Improper Invocation; Overriding P-005331 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Box #1 File folder entitled “KEN LANNING” Work product Inadequate Log; No Factual Underpinnings: P-005332 containing attorney research on select | Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru expert, including attorney handwritten Litigation; Improper Invocation; Overriding P-005341 notes Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Page 17 of 69 EFTA00208699

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 19 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 File folder entitled “Info re Planes” 6(e) Inadequate Log: No Factual Underpinnings; P-005342 containing correspondence regarding | __ Investigative privilege | Fiduciary Duty; Improper Invocation; Thru subpoenas and documents received in Overriding Need; Factual Materials; Court P-005387 response to subpoenas Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable Box #1 File folder entitled “Police Reports & PC Work product Inadequate Log; No Factual Underpinnings: P-005388 Affidavit” containing portions of police 6(e) Fiduciary Duty; Factual Materials; Not in Thru reports with attorney notes, related phone | Investigative privilege | Anticipation of Litigation; — Improper P-005442 records, a list entitled “Victims” with | Also contains information | Invocation; Overriding Need; Claims Against identifying information and attorney | and documents subject to | Public Prosecutor; Attorney Conduct at Issue; handwritten notes, photographs and privacy rights of victims | Factual Materials; Court Authorized Under DAVID information, and additional | who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release: attorney research regarding Epstein sexual litigation Proper Victim's Petition; CWRA-authorized activity release; Material Severable: Redaction; No Assertion by Victims Box #1 File folder entitled “[Victim name] 6(e) Inadequate Log: No Factual Underpinnings: P-005443 Transcript of Interview & GJ Transcript” Investigative privilege | Fiduciary Duty; Factual Materials; Not in Thru Also contains information | Anticipation of Litigation; — Improper P-005496 and documents subject to | Invocation; Overriding Need; Factual privacy rights of victims | Materials; Court Authorized Under 6(e)(3)(E): who are not parties to this | Court Inherent Power to Release: Proper litigation Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #1 File folder entitled “Bear Stearns Subpoena 6(e) Inadequate Log: No Factual Underpinnings; P-005497 Resp.” containing material received in| Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru response to subpoena Litigation; Improper Invocation; Overriding P-005556 Need; Factual Materials; Court Authorized Page 18 of 69 Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable EFTA00208700

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 20 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #1 U.S. Attorney’s Office Criminal Case File Work product Inadequate Log: No Factual Underpinnings; P-005557 Jacket containing file opening documents, Deliberative process Fiduciary Duty; Not in Anticipation of Thru expert witness payment documents Litigation; Improper Invocation; Overriding P-005576 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Box #1 U.S. Attorney’s Office Asset Forfeiture Work product Inadequate Log: No Factual Underpinnings: P-005578 Case File Jacket containing file opening Deliberative process Fiduciary Duty; Not in Anticipation of Thru and file closing documents Litigation; Improper Invocation; Overriding P-005583 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Box #1 File folder entitled “6001 Immunity 6(e) Inadequate Log; No Factual Underpinnings: P-005584 Request” containing internal memoranda Work product and Fiduciary Duty; Not in Anticipation of Thru seeking witness immunity and | deliberative process (as to | Litigation: Improper Invocation; Overriding P-005606 correspondence with counsel for witness internal memoranda) Need; Claims Against Public Prosecutor: regarding same Investigative privilege | Attorney Conduct at Issue; Factual Materials; Also contains information | Court Authorized Under 6(e)(3)(E); Court and documents subject to | Inherent Power to Release; Proper Victim's privacy rights of victims | Petition; CWRA-authorized release; Material who are not parties to this | Severable; Redaction; No Assertion by litigation Victims Box #2 File folder entitled “MASTER PHONE Work product Inadequate Log; No Factual Underpinnings: P-005607 RECORDS” containing meta-analysis of 6(e) Fiduciary Duty; Factual Materials; Not in Thru all phone, travel, and grand jury data forall | Investigative privilege | Anticipation of Litigation; — Improper P-005914 victim/witnesses for indictment preparation | Also contains information | Invocation; Overriding Need; Claims Against and documents subject to privacy rights of victims who are not parties to this litigation Page 19 of 69 Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release: Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims EFTA00208701

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Bates Range Description Privilege(s) Asserted Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 21 of 70 Victims’ Objections Box #2 P-005915 Thru P-005977 Box #2 P-005978 Thru P-006050 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 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 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 Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Factual Materials; Not in Anticipation of — Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Inadequate Log: No Factual Underpinnings: Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Page 20 of 69 EFTA00208702

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 22 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “JANE DOE #4” Work product Inadequate Log: No Factual Underpinnings: P-006066 =| containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that) Investigative privilege | Anticipation of Litigation; — Improper P-006220 victim/witness for indictment preparation Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled ““JANE DOE #12” Work product Inadequate Log; No Factual Underpinnings: P-006221 containing meta-analysis of all phone, 6(e) Fiduciary Duty; Factual Materials; Not in Thru travel, and grand jury data related to that | Investigative privilege | Anticipation of Litigation; Improper P-006222 victim/witness for indictment preparation Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “CORRECTED Work product Inadequate Log: No Factual Underpinnings: P-006223 PHONE RECORDS 5/31/07” containing 6(e) Fiduciary Duty; Factual Materials; Not in Thru meta-analysis of all phone, travel, and| Investigative privilege | Anticipation of Litigation; Improper P-006522 grand jury data related to all | Also contains information | Invocation; Overriding Need; Claims Against victims/witnesses for indictment | and documents subject to | Public Prosecutor; Attorney Conduct at Issue; preparation privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 21 of 69 EFTA00208703

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 23 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “[Victim Name] Phone Work product Inadequate Log: No Factual Underpinnings; P-006523 Records” containing telephone records 6(e) Fiduciary Duty; Factual Materials; Not in Thru received in response to subpoena Investigative privilege | Anticipation of Litigation; — Improper P-006802 Also contains information | Invocation; Overriding Need; Claims Against and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “Lists of Identified Work product Inadequate Log; No Factual Underpinnings: P-006803 Phone Numbers” containing charts of 6(e) Fiduciary Duty; Factual Materials; Not in Thru information culled from grand jury| Investigative privilege | Anticipation of Litigation; Improper P-006860 materials, interviews, and other | Also contains information | Invocation; Overriding Need; Claims Against investigation, with attorney handwritten | and documents subject to | Public Prosecutor; Attorney Conduct at Issue: notes, and information to issue follow-up | privacy rights of victims | Factual Materials; Court Authorized Under grand jury subpoena who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “EPSTEIN/KELLEN Work product Inadequate Log: No Factual Underpinnings;: P-006861 CELL PHONE RECORDS” containing 6(e) Fiduciary Duty; Factual Materials; Not in Thru documents received via subpoena with | Investigative privilege | Anticipation of Litigation; — Improper P-007785 attorney handwritten notes and | Also contains information | Invocation; Overriding Need; Claims Against highlighting and documents subject to | Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 22 of 69 EFTA00208704

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 24 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 Folder entitled “OLY GRAND JURY Work product Inadequate Log: No Factual Underpinnings; P-007786 |LOG: OLY-01 THROUGH OLY-50” 6(e) Fiduciary Duty; Factual Materials; Not in Thru containing subpoenas, correspondence | Investigative privilege | Anticipation of Litigation; — Improper P-008120 regarding same, 6(e) letters, attorney | Also contains information | Invocation; Overriding Need; Claims Against handwritten notes regarding records | and documents subject to | Public Prosecutor; Attorney Conduct at Issue: received in response to subpoenas privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 Handwritten flight logs received in 6(e) Inadequate Log; No Factual Underpinnings: P-008121 response to subpoena Investigative privilege | Fiduciary Duty; Not in Anticipation of Thru Litigation; Improper Invocation; Overriding P-008139 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Box #2 Grand jury presentation folder containing Work product Inadequate Log; No Factual Underpinnings: P-008140 | attorney handwritten notes, typed outline 6(e) Fiduciary Duty; Factual Materials; Not in Thru with additional handwritten notes,|_—_— Investigative privilege | Anticipation of Litigation; Improper P-008298 complete indictment package dated | Also contains information | Invocation; Overriding Need; Claims Against 2/19/2008, victim list with identifying | and documents subject to | Public Prosecutor; Attorney Conduct at Issue: information, photographs, and summary of | privacy rights of victims | Factual Materials; Court Authorized Under activity who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; litigation Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 23 of 69 EFTA00208705

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Bates Range Description Privilege(s) Asserted Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 25 of 70 Victims’ Objections 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 11" Circuit]) N/A 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 Page 24 of 69 Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials: Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable EFTA00208706

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 26 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder containing March 18, 2008 Work product Inadequate Log: No Factual Underpinnings;: P-008383 grand jury presentation materials, including 6(e) Fiduciary Duty; Factual Materials; Not in Thru “Operation Leap Year Revised Indictment | Investigative privilege | Anticipation of Litigation; — Improper P-008516 Summary Chart (by victim),” grand jury Deliberative process Invocation; Overriding Need; Claims Against materials, draft indictments, victim | Also contains information | Public Prosecutor; Attorney Conduct at Issue: reference list, grand jury subpoena log and documents subject to | Factual Materials; Court Authorized Under privacy rights of victims | 6(e)(3)(E); Court Inherent Power to Release; who are not parties to this | Proper Victim’s Petition; CWRA-authorized litigation release; Material Severable; Redaction; No Assertion by Victims Box #2 6/25/2007 Letter from Gerald Lefcourt to P-008517 Jeffrey Sloman and Andrew Lourie Thru [pursuant to Court’s Order, not being P-008535 withheld as privileged — will be produced to opposing counsel upon lift of stay by 11" Circuit Box #2 Handwritten attorney notes to prepare for Work product Inadequate Log: No Factual Underpinnings: P-008536 interview of Jane Doe #2 Investigative Privilege | Fiduciary Duty; Factual Materials; Not in Thru Contains information Anticipation of Litigation; — Improper P-008542 subject to privacy rights of | Invocation; Overriding Need; Claims Against victims who are not Public Prosecutor; Attorney Conduct at Issue: parties to this suit Redaction; No Assertion by Victims Box #2 Handwritten attorney notes regarding May Work product Inadequate Log; No Factual Underpinnings: P-008543 8, 2007 grand jury presentation 6(e) Fiduciary Duty; Factual Materials; Not in Thru Investigative privilege | Anticipation of Litigation; — Improper P-008549 Contains information Invocation; Overriding Need; Claims Against subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue: victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release: Proper Victim's Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Page 25 of 69 EFTA00208707

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 27 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Most Recent Work product Inadequate Log: No Factual Underpinnings;: P-008550 Indictment & Good Cases” containing draft 6(e) Fiduciary Duty; Factual Materials; Not in Thru indictment and legal research Investigative privilege | Anticipation of Litigation; — Improper P-008615 Deliberative process Invocation; Overriding Need; Claims Against Contains information Public Prosecutor; Attorney Conduct at Issue: subject to privacy rights of | Factual Materials; Court Authorized Under victims who are not 6(e)(3)(E); Court Inherent Power to Release; parties to this suit Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “FBI Summary Charts” Work product Inadequate Log; No Factual Underpinnings: P-008616 | containing chart prepared at direction of | Attorney-Client Privilege | Fiduciary Duty; Factual Materials; Not in Thru AUSA, containing ~—s victim» =~—s names, 6(e) Anticipation of Litigation; Ordinary P-008686 identifying information, summary of | Investigative privilege | Government Communication; No Attorney- activity, and other information relevant to Contains information Client Relationship; Improper Invocation; indictment subject to privacy rights of | Overriding Need; Claims Against Public victims who are not Prosecutor; Attorney Conduct at Issue: Factual parties to this suit Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable ; Redaction; No Assertion by Victims Box #2 File folder entitled “[Victim name}]/Jane Work product Inadequate Log; No Factual Underpinnings: P-008687 Doe #4” containing phone records and 6(e) Fiduciary Duty; Factual Materials; Not in Thru meta-analysis of all phone, travel, and) Investigative privilege | Anticipation of Litigation; — Improper P-008776 grand jury data related to that) Contains information and | Invocation; Overriding Need; Claims Against victim/witness for indictment preparation documents subject to Public Prosecutor; Attorney Conduct at Issue; privacy rights of victims | Factual Materials; Court Authorized Under who are not parties to this | 6(e)(3)(E); Court Inherent Power to Release; suit Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 26 of 69 EFTA00208708

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 28 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “[Victim name]/Jane Work product Inadequate Log: No Factual Underpinnings;: P-008777 Doe #5” containing handwritten notes and 6(e) Fiduciary Duty; Factual Materials; Not in Thru meta-analysis of all phone, travel, and) Investigative privilege | Anticipation of Litigation; — Improper P-008808 grand jury data related to that Contains information Invocation; Overriding Need; Claims Against victim/witness for indictment preparation | subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings: P-008809 Doe #6” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; — Improper P-008847 that victim/witness for _ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue: victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release: Proper Victim’s Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Box #2 File folder entitled “[Victim name}]/Jane Work product Inadequate Log: No Factual Underpinnings: P-008848 Doe #7” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to |__ Investigative privilege | Anticipation of Litigation; — Improper P-008862 that victim/witness for _ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 27 of 69 EFTA00208709

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 29 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “[Victim name]/Jane Work product Inadequate Log: No Factual Underpinnings; P-008863 Doe #8” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; Improper P-008890 that victim/witness for _ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “Certified Copy of State P-008891 Case” containing certified copy of Epstein Thru state criminal cases and change of plea P-009103 transcript [not being withheld as privileged — copy provided to opposing counsel] Box #2 File folder entitled “Meeting Timeline” Work product Inadequate Log; No Factual Underpinnings: P-009104 containing Villafafia typed _notes Deliberative process Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru summarizing meetings with opposing in Anticipation of Litigation; Improper P-009111 counsel prepared at request of R. Invocation; Overriding Need; Claims Against Alexander Acosta, with handwritten Public Prosecutor; Attorney Conduct at Issue correction and typed guideline estimate Box #2 11/26/2008 Email from Roy Black to A. P-009112 Marie Villafafiia and Karen Atkinson re N/A Thru Jeffrey Epstein (work release) P-009113 {pursuant to Court’s Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11" Circuit] Page 28 of 69 EFTA00208710

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 30 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 7/3/2008 Email from A. Marie Villafaiia to P-009114 Col. M. Gauger at PBSO re Epstein work N/A Thru release with attachment [not being P-009115 withheld as privileged — produced to opposing counsel] Box #2 12/6/2007 Letter from Jeffrey Sloman to P-009116 Jay P. Lefkowitz re Jeffrey Epstein (victim Thru notification) [pursuant to Court’s Order, P-009125 not being withheld as privileged — will be produced to opposing counsel upon lift of b Box #2 File folder entitled “[Victim name}/Jane Work product Inadequate Log; No Factual Underpinnings; P-009126 Doe #9” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; — Improper P-009134 that victim/witness for —_ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release: Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “[Victim name}]/Jane Work product Inadequate Log: No Factual Underpinnings; P-009135 Doe #13” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to |__ Investigative privilege | Anticipation of Litigation; — Improper P-009141 that victim/witness for —_ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release: Proper Victim's Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Page 29 of 69 EFTA00208711

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 31 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings: P-009141A | Doe #12” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; — Improper P-009141C | that ~—-victim/witness_ for _ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CWRA-authorized release; Material Severable; Redaction; No | | | Assertion by Victims Box #2 File folder entitled i ; Work product Inadequate Log; No Factual Underpinnings; P-009142 | i containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; Improper P-009152 that individual for indictment preparation Contains information Invocation; Overriding Need; Claims Against Box #2 P-009153 Thru P-009156 File folder entitled * containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation subject to privacy rights of victims who are not parties to this suit Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Inadequate Log; No Factual Underpinnings;: Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Page 30 of 69 EFTA00208712

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 32 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “[Victim name}]/Jane Work product Inadequate Log: No Factual Underpinnings: P-009157 Doe #1” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; — Improper P-009208 that victim/witness for —_ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 File folder entitled “[Victim name]/Jane Work product Inadequate Log; No Factual Underpinnings: P-009209 Doe #2” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to | Investigative privilege | Anticipation of Litigation; — Improper P-009213 that victim/witness for _ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue: victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable: Redaction; No Assertion by Victims Box #2 File folder entitled “[Victim name]/Jane Work product Inadequate Log: No Factual Underpinnings; P-009214 Doe #3” containing meta-analysis of all 6(e) Fiduciary Duty; Factual Materials; Not in Thru phone, travel, and grand jury data related to |__ Investigative privilege | Anticipation of Litigation; — Improper P-009271 that victim/witness for —_ indictment Contains information Invocation; Overriding Need; Claims Against preparation subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this suit 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 31 of 69 EFTA00208713

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 33 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Purpose of Travel Work product Inadequate Log: No Factual Underpinnings; P-009272 Cases” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009354 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Interstate Commerce Work product Inadequate Log: No Factual Underpinnings: P-009355 Cases” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009403 Overriding Need: Attorney Conduct at Issue Box #2 File folder entitled “Attorney Conflict Work product Inadequate Log; No Factual Underpinnings: P-009404 Research” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor: P-009536 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Mann Act/Travel to Work product Inadequate Log: No Factual Underpinnings: P-009537 Have Sex w/Minor” containing attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-009574 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Travel Act” containing Work Product Inadequate Log: No Factual Underpinnings; P-009575 attorney research and handwritten notes Fiduciary Duty; Not in Anticipation of Thru Litigation; Claims Against Public Prosecutor; P-009603 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Florida Work Product Inadequate Log; No Factual Underpinnings: P-009604 Prostitution/Lewdness Statutes” containing Fiduciary Duty; Not in Anticipation of Thru attorney research and handwritten notes Litigation; Claims Against Public Prosecutor; P-009711 Overriding Need; Attorney Conduct at Issue Box #2 Booklet entitled “Attorney General P-009712 Guidelines for Victim and Witness Thru Assistance” [not being withheld as P-009819 privileged — produced to opposing counsel] Box #2 File folder entitled “Corporate Liability Work Product Inadequate Log: No Factual Underpinnings; P-009820 Rsrch” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-009965 Overriding Need; Attorney Conduct at Issue Page 32 of 69 EFTA00208714

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 34 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Research — re Work Product Inadequate Log: No Factual Underpinnings: P-009966 Knowledge of Age Unnecessary” 6(e) Fiduciary Duty; Not in Anticipation of Thru containing attorney research ~—s and Litigation; Claims Against Public Prosecutor; P-010096 handwritten notes and copy of grand jury Overriding Need; Attorney Conduct at Issue: subpoena Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CWRA-authorized release; Material Severable Box #2 File folder entitled “Money Laundering” Work Product Inadequate Log; No Factual Underpinnings: P-010097 containing attorney research ~— and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor: P-010276 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “1960 & Work Product Inadequate Log; No Factual Underpinnings: P-010277 Aiding/Abetting” containing —_ attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor: P-010394 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “18 USC § 2255 Cases” Work Product Inadequate Log: No Factual Underpinnings; P-010395 containing attorney research — and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010488 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Research re Overt Acts Work Product Inadequate Log; No Factual Underpinnings: P-010489 & Witness Testimony” containing attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-010509 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled = = “Extradition” Work Product Inadequate Log; No Factual Underpinnings: P-010510 containing attorney research ~—s and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor: P-010525 Overriding Need; Attorney Conduct at Issue Page 33 of 69 EFTA00208715

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 35 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Rsrch re Crime Work Product Inadequate Log: No Factual Underpinnings;: P-010526 Victims Rights” containing attorney Deliberative Process Fiduciary Duty; Crime-Fraud-Misconduct; Thru research, handwritten notes, draft victim Crime-Fraud-Misconduct; Factual Materials; P-010641 notification letter, and draft Not in Anticipation of Litigation: Improper correspondence to Jay Lefkowitz Invocation; Overriding Need; Claims Against (Also contains a November 28, 2007 letter Public Prosecutor; Attorney Conduct at Issue 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 11" Circuit) Box #2 File folder entitled “Immunity” containing Work Product Inadequate Log; No Factual Underpinnings: P-010642 attorney research on granting immunity to Fiduciary Duty; Not in Anticipation of Thru witnesses Litigation; Claims Against Public Prosecutor; P-01650 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Research re GJ. Work Product Inadequate Log; No Factual Underpinnings: P-010651 Transcript” containing attorney research 6(e) Fiduciary Duty; Not in Anticipation of Thru and draft pleadings re compelling Deliberative process Litigation; Improper Invocation; Overriding P-010659 production of grand jury transcript with Need; Claims Against Public Prosecutor; subpoena Attorney Conduct at Issue; Factual Materials: Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release: Material Severable Page 34 of 69 EFTA00208716

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 36 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Research re GJ Work Product Inadequate Log: No Factual Underpinnings: P-010660 Transcript” containing = grand ~—jury 6(e) Fiduciary Duty; Not in Anticipation of Thru subpoena, 6(e) letters, attorney research Litigation; Claims Against Public Prosecutor; P-010757 and correspondence related to subpoena Overriding Need; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CWRA-authorized release; Material Severable Box #2 File folder entitled “Original Proposed Work Product Inadequate Log; No Factual Underpinnings: P-010758 Ind.” containing draft indictment 6(e) Fiduciary Duty; Not in Anticipation of Thru Deliberative process Litigation; Improper Invocation; Overriding P-010793 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials: Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release: Material Severable Box #2 File folder entitled “Epstein” containing Work Product Inadequate Log; No Factual Underpinnings: P-010794 sample indictments and attorney research Fiduciary Duty; Not in Anticipation of Thru Te potential charges with attorney notes Litigation; Claims Against Public Prosecutor: P-010829 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “1591 & Money Work Product Inadequate Log: No Factual Underpinnings; P-010830 Laundering” containing attorney research Fiduciary Duty; Not in Anticipation of Thru and handwritten notes Litigation; Claims Against Public Prosecutor: P-010853 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “18 USC 2425” Work Product Inadequate Log: No Factual Underpinnings; P-010854 containing attorney research ~— and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010876 Overriding Need; Attorney Conduct at Issue Page 35 of 69 EFTA00208717

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 37 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Knowledge of Age” Work Product Inadequate Log: No Factual Underpinnings; P-010877 containing attorney research ~— and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-010920 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “2423(b) Work Product Inadequate Log; No Factual Underpinnings: P-010921 Constitutionality and Purpose of Travel” Fiduciary Duty; Not in Anticipation of Thru containing attorney research ~— and Litigation; Claims Against Public Prosecutor; P-011049 handwritten notes Overriding Need: Attorney Conduct at Issue Box #2 File folder entitled “Mistake not a Work Product Inadequate Log; No Factual Underpinnings: P-011050 Defense” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor: P-011212 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Research — re Work Product Inadequate Log: No Factual Underpinnings: P-011213 ‘Pandering’” containing attorney research Fiduciary Duty; Not in Anticipation of Thru and handwritten notes Litigation; Claims Against Public Prosecutor; P-011237 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Research re Grand Work Product Inadequate Log: No Factual Underpinnings;: P-011238 Jury Instructions” containing attorney 6(e) Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor; P-011319 Overriding Need; Attorney Conduct at Issue: Factual Materials: Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release: Proper Victim’s Petition; CWRA-authorized release; Material Severable Box #2 File folder entitled “Telephone = Facility Work Product Inadequate Log; No Factual Underpinnings: P-011320 of Commerce” containing —_ attorney Fiduciary Duty; Not in Anticipation of Thru research and handwritten notes Litigation; Claims Against Public Prosecutor: P-011361 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Def of Prostitution” Work Product Inadequate Log; No Factual Underpinnings; P-011362 containing attorney —sresearch ~— and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011374 Overriding Need; Attorney Conduct at Issue Page 36 of 69 EFTA00208718

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 38 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #2 File folder entitled “Relevant Florida Work Product Inadequate Log: No Factual Underpinnings; P-011375 Statutes” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011456 Overriding Need; Attorney Conduct at Issue Box #2 File folder entitled “Unit of Prosecution Work Product Inadequate Log: No Factual Underpinnings: P-011457 Research” containing attorney research and Fiduciary Duty; Not in Anticipation of Thru handwritten notes Litigation; Claims Against Public Prosecutor; P-011626 Overriding Need: Attorney Conduct at Issue Box #3 File folder entitled “Attorney Notes” Work Product Inadequate Log; No Factual Underpinnings: P-011627 containing attorney handwritten and typed Fiduciary Duty; Not in Anticipation of Thru notes Litigation; Claims Against Public Prosecutor: P-011662 Overriding Need; Attorney Conduct at Issue Box #3 File folder entitled “Drafts” containing 6(e) Inadequate Log: No Factual Underpinnings; P-011663 draft indictments with attorney handwritten Work Product Fiduciary Duty; Factual Materials; Not in Thru notes, draft internal memoranda, relevant Deliberative Process Anticipation of Litigation; — Improper P-011698 and | witness interview reports and grand jury | Investigative Privilege | Invocation; Overriding Need; Claims Against P-012189 thru | material and attorney handwritten notes Contains information Public Prosecutor; Attorney Conduct at Issue: P-012361 subject to privacy rights of | Factual Materials; Court Authorized Under (gap was victims who are not 6(e)(3)(E); Court Inherent Power to Release: scanning parties to this Proper Victim's Petition; CWRA-authorized error) release; Material Severable: Redaction; No Assertion by Victims Box #3 File folder entitled “6/9/09 Signed 6(e) Inadequate Log; No Factual Underpinnings: P-011699 Indictment” containing signed indictment Work product Fiduciary Duty; Not in Anticipation of Thru package dated 6/9/2009 with corrections Deliberative process Litigation; Improper Invocation; Overriding P-011777 Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Factual Materials: Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 37 of 69 EFTA00208719

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 39 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 File folder entitled “6/12/09 Victim Notif. Work product Inadequate Log: No Factual Underpinnings; P-011778 Log” containing chart with victim contact Fiduciary Duty; Crime-Fraud-Misconduct; Thru information and attorney notes regarding Factual Materials; Not in Anticipation of P-011788 dates and type of contacts Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Box #3 File folder entitled “Breach Memo” Work product Inadequate Log: No Factual Underpinnings: P-011789 containing memorandum analyzing breach Deliberative process Fiduciary Duty; Not in Anticipation of Thru of Non-Prosecution Agreement with Litigation; Improper Invocation; Overriding P-011879 attachments Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Factual Materials Box #3 File folder entitled “Overt Act Lists” Work product Inadequate Log; No Factual Underpinnings: P-011880 containing handwritten notes cross- | Attorney-client privilege | Fiduciary Duty; Factual Materials; Not in Thru checking all overt acts alleged in draft Deliberative process Anticipation of Litigation; Ordinary P-011922 indictment by victim and typed overt act 6(e) Government Communication; No Attorney- summary charts for indictment preparation Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Page 38 of 69 EFTA00208720

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 40 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 Folder entitled “Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel” containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru @ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in Anticipation of Litigation; P-011966 Sanchez to Andrew Lourie with | Attorney-Client Privilege | Ordinary Government Communication; No handwritten attorney (Lourie) Attorney-Client — Relationship; Improper notes: Invocation; Overriding Need: Claims Against @ 6/25/2007 letter from Gerald Public Prosecutor; Attorney Conduct at Issue: Lefcourt to Jeffrey Sloman, Matt Factual Materials; Court Authorized Under Menchal, Andrew Lourie, and 6(e)(3)(E); Court Inherent Power to Release: Marie Villafaiia with handwritten Proper Victim’s Petition; CWRA-authorized attorney (Villafafia) notes; release; Material Severable @ 6/25/2007 email from Andrew Lourie to Matt Menchel and Marie Villafaiia entitled “Thoughts on Lefcourt’s letter” Handwritten and typed attorney (Villafafia) notes regarding main themes raised by Epstein counsel Box #3 Composition book entitled “Operation Work product Inadequate Log: No Factual Underpinnings;: P-011967 Leap Year” containing attorney | Investigative privilege | Fiduciary Duty; Factual Materials; Not in Thru handwritten notes regarding investigation 6(e) Anticipation of Litigation; — Improper P-012016 and case strategy Contains information Invocation; Overriding Need: Claims Against subject to privacy rights of victims who are not parties to this litigation Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Page 39 of 69 EFTA00208721

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 41 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 Motion of Jeffrey Epstein to Intervene and 6(e) Inadequate Log: No Factual Underpinnings; P-012017 to Quash Grand Jury Subpoenas and Fiduciary Duty; Factual Materials; Court Thru Incorporated Memorandum of Law Authorized Under 6(e)(3)(E); Court Inherent P-012055 Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 Affidavit of Roy Black, Esq. in Support of Inadequate Log: No Factual Underpinnings: P-012056 Motion of Jeffrey Epstein to Intervene and Fiduciary Duty; Factual Materials; Court Thru to Quash Grand Jury Subpoenas Authorized Under 6(e)(3)(E); Court Inherent P-012088 Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable Box #3 United States’ Response to Motion of Inadequate Log; No Factual Underpinnings: P-012089 Jeffrey Epstein to Intervene and to Quash Fiduciary Duty; Factual Materials; Court Thru Grand Jury Subpoenas and Cross-Motion Authorized Under 6(e)(3)(E); Court Inherent P-012129 to Compel Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable Box #3 Declaration of Joseph Recarey Inadequate Log; No Factual Underpinnings: P-012130 Fiduciary Duty Thru P-012150 Box #3 Ex Parte Declaration Number One in 6(e) Inadequate Log; No Factual Underpinnings: P-012151 Support of United States’ Response to| Investigative Privilege | Fiduciary Duty; Factual Materials; Not in Thru Motion to Quash Subpoenas Also contains information | Anticipation of Litigation; — Improper P-012167 subject to privacy rights of | Invocation; | Overriding Need; — Factual victims who are not parties to this litigation Materials; Court Authorized Under 6(e)(3)(E): Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release: Material Severable; Redaction; No Assertion by Victims Page 40 of 69 EFTA00208722

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 42 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 Ex Parte Declaration Number Two in 6(e) Inadequate Log: No Factual Underpinnings: P-012168 Support of United States’ Response to | Investigative Privilege | Fiduciary Duty; Not in Anticipation of Thru Motion to Quash Subpoenas Litigation; Improper Invocation; Overriding P-012170 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Box #3 Supplement to Ex Parte Declaration 6(e) Inadequate Log: No Factual Underpinnings; P-012171 Number One in Support of United States’ | Investigative Privilege | Fiduciary Duty; Factual Materials; Not in Thru Response to Motion to Quash Subpoenas Also contains information | Anticipation of Litigation; — Improper P-012173 subject to privacy rights of | Invocation; Overriding Need; Factual victims who are not Materials; Court Authorized Under 6(e)(3)(E): parties to this litigation | Court Inherent Power to Release: Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 Draft of September 2009 letter from Marie Work Product Inadequate Log: No Factual Underpinnings; P-012174 Villafaiia to Roy Black regarding breach of | Attorney-Client Privilege | Fiduciary Duty; Not in Anticipation of Thru Non Prosecution Agreement — with Deliberative Process Litigation; Ordinary Government P-012176 handwritten attorney (Villafafia) notes Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Box #3 Undated handwritten attorney (Villafafia) Work Product Inadequate Log: No Factual Underpinnings; P-012177 notes regarding negotiations and) Attorney-Client Privilege | Fiduciary Duty; Not in Anticipation of Thru allegations Deliberative Process Litigation; Ordinary Government P-012178 Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Page 41 of 69 EFTA00208723

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 43 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 File Folder entitled “FBI GJ. Log” 6(e) Inadequate Log: No Factual Underpinnings; P-012179 containing copy of FBI grand jury Work Product Fiduciary Duty; Factual Materials; Not in Thru subpoena log with attorney (Villafafia)| Investigative Privilege | Anticipation of Litigation; — Improper P-012188 handwritten notes Also contains information | Invocation; Overriding Need; Claims Against subject to privacy rights of | Public Prosecutor; Attorney Conduct at Issue; victims who are not Factual Materials; Court Authorized Under parties to this litigation | 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CWRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 File folder entitled “Key Documents” 6(e) Inadequate Log; No Factual Underpinnings: P-012362 containing correspondence between AUSA Work Product Fiduciary Duty; Factual Materials; Not in Thru and case agent regarding indictment prep | Attorney-Client privilege | Anticipation of Litigation; | Ordinary P-012451 questions, victim identification | Investigative Privilege | Government Communication; No Attorney- information, corrections to — draft | Also contains information | Client Relationship; Improper Invocation: indictment, indictment preparation | subject to privacy rights of | Overriding Need; Claims Against Public timeline, key grand jury material victims who are not Prosecutor; Attorney Conduct at Issue; Factual parties to this litigation | Materials; Court Authorized Under 6(e)(3)(E): Court Inherent Power to Release; Proper Victim’s Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Box #3 File folder entitled “Victim List” Work Product Inadequate Log; No Factual Underpinnings: P-012451 containing list of victims with dates of | Investigative Privilege | Fiduciary Duty; Factual Materials; Not in Thru birth and age information Also contains information | Anticipation of Litigation; — Improper P-012452 subject to privacy rights of | Invocation; Overriding Need; Claims Against victims who are not Public Prosecutor; Attorney Conduct at Issue: parties to this litigation | Redaction; No Assertion by Victims Page 42 of 69 EFTA00208724

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 44 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 Complete indictment package marked Work-product Inadequate Log: No Factual Underpinnings;: P-012453 “Originals 12/12/07" Deliberative process Fiduciary Duty; Factual Materials; Not in Thru 6(e) Anticipation of Litigation; — Improper P-012623 Also contains documents | Invocation; Overriding Need; Factual subject to investigative Materials; Court Authorized Under 6(e)(3)(E): privilege Court Inherent Power to Release: Proper Also contains documents | Victim’s Petition; CWRA-authorized release; subject to privacy rights of | Material Severable; Redaction; No Assertion victims who are not by Victims parties to this litigation Box #3 Folder entitled “(Victims) Additional | Investigative Privilege | Inadequate Log; No Factual Underpinnings: P-012624 302’s” containing reports of interviews | Also contains documents | Fiduciary Duty; Factual Materials; Not in Thru conducted in June 2007, October 2007, and | subject to privacy rights of | Anticipation of Litigation; — Improper P-012653 March 2008. victims who are not Invocation; Overriding Need; Redaction; No parties to this litigation _| Assertion by Victims Box #3 3-ring binder entitled “Child Molesters: A Work-product Inadequate Log; No Factual Underpinnings: P-012654 Behavioral Analysis” with attorney Fiduciary Duty; Overriding Need Thru (Villafafia) handwritten notes P-012864 Box #3 Indictment preparation binder containing: Work Product Inadequate Log: No Factual Underpinnings: P-012865 witness/victim list with — identifying Deliberative Process Fiduciary Duty; Factual Materials; Not in Thru information, sexual activity summary, 6(e) Anticipation of Litigation; — Improper P-013226 telephone call summary chart, attorney | Also contains documents | Invocation; Overriding Need; Claims Against (Villafaia) handwritten notes, 302s,| subject to investigative | Public Prosecutor; Attorney Conduct at Issue: portions of state investigative file, attorney privilege Factual Materials; Court Authorized Under (Villafafia) typed notes, relevant pieces of | Also contains documents | 6(e)(3)(E); Court Inherent Power to Release; grand = jury materials, telephone | subject to privacy rights of | Proper Victim’s Petition; CWRA-authorized records/flight records analysis charts, victims who are not release; Material Severable; Redaction; No victim/witness photographs, DAVID | parties to this litigation | Assertion by Victims records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 Page 43 of 69 EFTA00208725

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 45 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 April 23, 2008 Memo from Jeffrey Sloman Privacy Act Inadequate Log: No Factual Underpinnings; P-013227 to Office of Professional Responsibility re Fiduciary Duty; Crime-Fraud-Misconduct; Self Reporting, Corrected Version of the Factual Materials; Court Compelled previously submitted April 21, 2008 Letter Disclosure; Waiver to OPR Box #3 April 21, 2008 Letter from Jeffrey Sloman Privacy Act Inadequate Log: No Factual Underpinnings: P-013226 to Office of Professional Responsibility re Fiduciary Duty; Court Compelled Disclosure: Thru Self Reporting Factual Materials; Waiver P-013230 Box #3 April 22, 2008 Letter from A. Marie Privacy Act Inadequate Log: No Factual Underpinnings: P-013231 Villafaia to Office of Professional Factual Materials; Fiduciary Duty; Court Thru Responsibility re Self-Report of Allegation Compelled Disclosure; Waiver P-013239 of Conflict of Interest Box #3 April 21, 2008 Letter from Jeffrey Sloman Privacy Act Inadequate Log; No Factual Underpinnings: P-013240 to Office of Professional Responsibility re Fiduciary Duty; Court Compelled Disclosure; Thru Self Reporting with attachments Factual Materials; Waiver P-013247 Box #3 Emails between Richard Sudder, Assistant | Attorney-Client Privilege | No Factual Underpinnings; Fiduciary Duty; P-013248 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013251 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Box #3 Emails between Richard Sudder, Assistant | Attorney-Client Privilege | No Factual Underpinnings; Fiduciary Duty; P-013252 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013253 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24, 2011 Page 44 of 69 EFTA00208726

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 46 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Box #3 Emails between Richard Sudder, Assistant | Attorney-Client Privilege | No Factual Underpinnings; Fiduciary Duty; P-013254 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013257 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24 and August 29, 2011 Box #3 Emails between Richard Sudder, Assistant | Attorney-Client Privilege | No Factual Underpinnings; Fiduciary Duty: P-013258 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, and Benjamin Attorney-Client Relationship; Waiver P-013259 Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July 28 and August 3, 2011 Box #3 Email from Richard Sudder, Assistant | Attorney-Client Privilege | No Factual Underpinnings; Fiduciary Duty; P-013260 General Counsel, Executive Office for Ordinary Government Communication; No Thru United States Attorneys, to Wifredo Ferrer Attorney-Client Relationship; Waiver P-013262 (U.S. Attorney, SDFL), Robert O’Neill (U.S. Attorney, MDFL), Benjamin Greenberg, (FAUSA, SDFL), and Lee Bentley (FAUSA, MODFL) _ regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated August 24, 2011. CC’s David Margolis (ODAG), Jay Macklin (USAEO), Thomas Anderson (USAEO), Michelle Tapken (USAEO), James Read (USAEO) Page 45 of 69 EFTA00208727

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 47 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections Box #3 P-013263 Thru P-013271 Box #3 P-013272 Thru P-013278 Suppl. Box #3 P-013279 Thru P-013280 Emails between Richard Sudder, Assistant General Counsel, Executive Office for United States Attorneys, and Benjamin Greenberg, First Assistant U.S. Attorney, Southern District of Florida, regarding recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey Epstein Investigation Emails between Peter Mason, Executive Office for United States Attorneys, and Dexter Lee, Southern District of Florida, seeking advice regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 8/15/08 Emails between A. Acosta and A. Marie Villafafia, R. Senior, D. Lee and K. Atkinson’ re __ proposed correspondence to Jay Lefkowitz Attorney-Client Privilege Deliberative Process Work Product Attorney-Client Privilege Attorney-Client Privilege Work Product No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver No Factual Underpinnings; Fiduciary Duty: Ordinary Government Communication; No Attorney-Client Relationship: Factual Materials; Waiver Inadequate Log: No Factual Underpinnings: Fiduciary Duty: Crime-Fraud-Misconduct: Crime-Fraud-Misconduct; Not in Anticipation of Litigation; © Ordinary Government Communication: No Attorney-Client Relationship; Claims Against — Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 Handwritten note re Epstein investigation Attorney-Client Privilege Work Product Investigative privilege Also contains information subject to privacy rights of victims who are not Page 46 of 69 Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public EFTA00208728

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 48 of 70 Bates Range Privilege(s) Asserted Victims’ Objections P-013281 Suppl. Box #3 P-013282 Thru P-013283 7/9/08 Email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger letter re victim notification parties to this litigation Attorney-Client Privilege Work product Deliberative Process Prosecutor; Attorney Conduct at Issue: Redaction; No Assertion by Victims No Factual Underpinnings; Fiduciary Duty: Crime-Fraud-Misconduct; Crime-Fraud- Misconduct; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client — Relationship; —_ Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Waiver Suppl. Box #3 P-013284 7/10/08 Emails between J. Sloman and A. Marie Villafafia, K. Atkinson, and FBI re proposed response to Goldberger’s letter e victim notification Attorney-Client Privilege Work Product Deliberative Process No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013285 Thru P-013289 File folder entitled “8/5/08 AMCV e- mail re correct agrmt” containing 8/5/08 email from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson re “Jeffrey Epstein Agreement” discussing 6/24/08 email from A. Marie Villafaiia to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege Work Product Deliberative Process Page 47 of 69 No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Crime-Fraud- Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client — Relationship; —_ Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue EFTA00208729

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 49 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections Suppl. Box #3 P-013290 Thru P-013292 File folder entitled “8/14/08 E-mail from Lefk to AMCV” containing (undated) emails from A. Marie Villafafia to R. Senior, J. Sloman, A. Acosta, K. Atkinson, D. Lee re draft response to 8/14/08 email from J. Lefkowitz regarding “the December 2007 proposal” Attorney-Client Privilege Work Product Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013293 Thru P-013299 File folder entitled “8/15/08 AMCV e- mail re Agrmt” containing 8/15/08 e- mails from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re follow up on Agreement and from A. Acosta to Ann Marie Villafana on issue of Special Master with attached 8/15/08 emails from A. Marie Villafafia to A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreement; 8/15/08 email from J. Lefkowitz to A. Marie Villafana, K. Atkinson, R. Black, M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafafia to J. Lefkowitz, K. Atkinson, R. Black re interpretation of Agreement; email from J. Lefkowitz to A. Marie Villafafia, K. Atkinson re questions re Agreement; email from A. Marie Villafafia to J. Lefkowitz, K. Atkinson re production of Agreement to victims Attorney-Client Privilege Work Product Deliberative Process Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation: Ordinary Government Communication; No Attorney-Client Relationship: Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013300 Thru File folder entitled “8/18/08 Lefkowitz Ltr | Attorney-Client Privilege A. Marie Villafafia’s handwritten draft notes for to AMCV” containing Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Page 48 of 69 EFTA00208730

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Bates Range Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 50 of 70 Description Privilege(s) Asserted Victims’ Objections P-0133303 proposed letter to J. Lefkowitz; 5/22/07 e- mail from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafaiia re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Suppl. Box #3 | File folder entitled “6/25/07 Lefcourt to P-013304 Thru P-013325 Sloman & Lourie containing 6/25/07 letter (with handwritten notes by A. Marie Villafafia) from G. Lefcourt to J. Sloman, M. Menchel, A. Lourie, A. Marie Villafafia addressing reasons for not prosecuting Epstein; handwritten outline by A. Marie Villafafia of possible response to letter Work Product Attorney-Client Privilege Work Product Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship Suppl. Box #3 | File folder entitled “9/17/07 Villafafia P-013326 Thru P-013329 Lefkowitz containing 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Lourie and from R. Garcia to A. Marie Villafaiia concerning status of plea negotiations Suppl. Box #3 | File folder entitled “11/8/07 Lefkowitz P-013330 Thru P-013333 Sloman” containing 11/8/07 letter from J. Lefkowitz re issues arising during pendency of matter with attorney handwritten notes Attorney-Client Privilege Work Product Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need: Attorney Conduct at Issue Inadequate Log: No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 | File folder entitled “11/13/07 Sloman to P-013334 Thru Lefkowitz (was this sent?)” containing draft 11/13/07 letter from J. Sloman Attorney-Client Privilege Inadequate Log: No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Page 49 of 69 EFTA00208731

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 51 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections P-013337 Suppl. Box #3 P-013338 Thru 013341 responding to J. Lefkowitz’s letter File folder entitled “12/6/07 Sloman to Lefkowitz” containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta Work Product [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013342 Thru P-013350 File folder entitled “12/05/07 Starr to Acosta” containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Lefkowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafania Attorney-Client Privilege Work Product Deliberative Process Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct: Factual Materials; Not in Anticipation of Litigation: Ordinary Government Communication; No Attorney-Client Relationship: Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box #3 P-13351 Thru P-013361 Suppl. Box #3 File folder entitled “12/21/07 Lefkowitz Acosta” containing handwritten notes by A. Marie Villafaiia, 12/21/07 letter from J. Lefkowitz to A. Acosta re performance of NPA and appeal to Washington with attorney handwritten notes File folder labeled “12/26/07 Lefkowitz Attorney-Client Privilege Work Product Attorney-Client Privilege Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Claims Against Public Prosecutor; Overriding Need: Factual Materials; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings: P-013362 to Acosta” containing 2 copies of draft Work Product Fiduciary Duty; Crime-Fraud-Misconduct; Not Thru letter from A. Acosta to J. Lefkowitz Deliberative Process in Anticipation of Litigation; Ordinary P-013366 (with 12/28/07 fax header) Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Suppl. Box #3 | File folder labeled “Draft Itr_ from _| Attorney-Client Privilege | Inadequate Log; No Factual Underpinnings; Page 50 of 69 EFTA00208732

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 52 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections P-013367 Thru P-013372 Suppl. Box #3 P-013373 Thru P-013503 Sloman to Lefkowitz re termination” containing draft letter dated “April , 2008” from J. Sloman to J. Lefkowitz concerning the compliance with the Agreement File folder labeled “6/3/08 Sloman Submission to the DAG” containing 6/3/08 letter from J. Sloman to Mark Filip, Office of the DAG, cc’d to R. Senior, A. Marie Villafaiia, K. Atkinson, re Jeffrey Epstein, detailing events concerning the Agreement and thereafter and with relevant attachments Work Product Attorney-Client Privilege Deliberative Process Work Product Investigative privilege Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against — Public Prosecutor; Overriding Need; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship: Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue: Waiver Suppl. Box #3 P-013504 Thru P-013507 File folder labeled “Mtg w/ Ken Starr, RAA, JS, Drew” containing handwritten notes by A. Marie Villafafia Attorney-Client Privilege Work Product Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against — Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013508 Thru P-013514 Suppl. Box #3 P-013515 Thru File folder labeled “Internal Corr.” containing 11/28/07 e-mails from J. Sloman to A. Marie Villafafia re responding to 11/28/07 e-mail from J. Lefkowitz to J. Sloman regarding victim notification with attachments Draft 11/30/07 letter from A. Acosta to K. Starr ce’d to J. Sloman and A. Marie Villafafia re compliance with Agreement Attorney-Client Privilege Work Product Attorney-Client Privilege Work Product Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against — Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Factual Materials; Waiver Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Page 51 of 69 EFTA00208733

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 53 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections P-013525 and internal emails from J. Sloman, A. Deliberative Process Government Communication; No Attorney- Acosta, and A. Lourie re items to Client Relationship; Improper Invocation; address in letter Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Waiver; Factual Materials Suppl. Box #3 | 5/23/07 e-mail from A. Marie Villafafia | Attorney-Client Privilege | Inadequate Log: No Factual Underpinnings: P-013526 to K. Atkinson re draft proposed internal Work Product Fiduciary Duty; Not in Anticipation of Thru e-mail about handling of case and Deliberative Process Litigation; Ordinary Government P-013527 attached email correspondence between Communication; No Attorney-Client Andrew Lourie and G. Lefcourt Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Factual Materials Suppl. Box #3 | Handwritten notes by A. Marie Villafana Work Product Inadequate Log: No Factual Underpinnings: P-013528 dated 9/21 re telephone conference with Fiduciary Duty; Factual Materials; Not in Thru possible victim representative, conflict Anticipation of Litigation; Claims Against P-013530 check with names and email listed, list of Public Prosecutor; Overriding Need; Attorney names of potential victim representatives, Conduct at Issue P-013532 payment discussion, and guideline Thru calculation, email containing contact info P-013537 for potential victim representative, draft Non Prosecution Agreement dated 9/10/07 4:17 Suppl. Box #3 | Typed note addressed to “Dear David” re 6(e) Inadequate Log; No Factual Underpinnings: P-013531 response to grand jury subpoena Investigative privilege | Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim’s Petition; CVRA- authorized release; Material Severable Suppl. Box #3 | File folder labeled “Notes Re Post- Work Product Inadequate Log; No Factual Underpinnings: P-013538 Agreement Communications” containing Fiduciary Duty; Not in Anticipation of Thru Litigation; Improper Invocation; Overriding Page 52 of 69 EFTA00208734

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 54 of 70 Bates Range | Description P-013553 handwritten notes by A. Marie Villafaiia Privilege(s) Asserted Deliberative Process Victims’ Objections Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Factual Materials Suppl. Box #3 | File folder labeled “E-mails Re Plea P-013554 Negotiations” containing: Thru No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; —§ Ordinary |= Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Waiver; Final Decision Attorney-Client Privilege Work Product Deliberative Process Investigative Privilege @ 11/28/07 e-mail from A. Lourie to A. Marie Villafafia, A. Oosterbaan, R. Garcia re non-prosecution agreement, with attached correspondence; @ 9/19/07 e-mail from <A. Marie Villafafia to A. Lourie, R. Garcia, K. Atkinson re negotiating strategy, with attached correspondence; @ 9/18/07 e-mail from A. Marie Villafafia to A. Acosta, A. Lourie, R.Gar @ 9/17/07 e-mail from A. Marie Villafafia to A. Acosta re negotiation; @ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Acosta, A. Lourie, K. Atkinson, J. McMillan re negotiations: @ 9/17/07 e-mail from A. Marie Villafafia to R. Garcia, A. Lourie re negotiation strategy; @ 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, R. Garcia, A Lourie, K. Atkinson, S. Ball re proposed plea agreement and Information Page 53 of 69 EFTA00208735

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 55 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, A Lourie, R Garcia, K. Atkinson, J. McMillan, S. Ball re plea negotiations 9/13/07 e-mail from A. Marie Villafafia to J. Atkinson, S. Ball, J. McMillan re indictment package: 9/13/07 e-mail from A. Marie Villafafiia to A. Oosterbaan re trust agreement with attached correspondence 9/13/07 e-mail from A. Marie Villafafia to A. Oosterbaan re trust agreement 9/13/07 e-mail from A. Marie Villafafia to R. Garcia, J. Sloman re conference call with J. Lefkowitz: 9/13/07 e-mail from A. Marie Villafaia to A. Lourie re plea negotiations with attached correspondence; 9/13/07 e-mail from A. Marie Villafaiia to A. Lourie re charging strategy with attached correspondence; 9/13/07 e-mail from A. Marie Villafafia to K. Atkinson, S. Ball, J. McMillan re indictment package: 9/13/07 e-mail from A. Marie Villafafia to A. Acosta, J. Sloman, R. Garcia, K. Atkinson, A. Lourie re plea negotiations; Page 54 of 69 EFTA00208736

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 56 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections 9/11/07 e-mail from A. Marie Villafafia to A. Lourie re meeting w/ G. Lefcourt with attached correspondence; 9/11/07 e-mail from A. Marie Villafaia to A. Lourie re revised Agreement with attached correspondence; 9/11/07 e-mail from A. Marie Villafaia to J. Sloman re non- prosecution agreement edits with attached correspondence; 9/11/07 e-mail from <A. Marie Villafafia to A. Oosterbaan re status of negotiations with attached correspondence; 9/10/07 e-mail from A. Marie Villafafia to J. Sloman re negotiations; 9/10/07 e-mail from A. Marie Villafafia to J. Sloman, J. McMillan re state grand jury proceedings; 9/17/07 e-mail from A. Acosta to A. Marie Villafafia, R. Garcia, A. Lourie, K. Atkinson, J. McMillan re draft Agreement with attached correspondence; 9/14/07 e-mail from J. Sloman to A. Marie Villafafia, A. Acosta, R. Garcia, A. Lourie, K. Atkinson, S. Ball, re finalizing documents; 9/14/07 e-mail from A. Lourie to A. Marie Villafafia re charging strateg Page 55 of 69 EFTA00208737

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Bates Range | Description Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 57 of 70 Privilege(s) Asserted Victims’ Objections with attached correspondence; @ 9/13/07 e-mail from A. Oosterbaan to A. Marie Villafaiia re setting up trust fund; @ 9/13/07 e-mail from A. Lourie to A. Marie Villafafia re final negotiations with attached correspondence; @ 9/11/07 e-mail from A. Lourie to A. Marie Villafafia re scheduling a meeting regarding finalizing the agreement with attached correspondence; @ 9/11/07 e-mail from J. Sloman to A. Marie Villafaa re non-prosecution agree @ 9/11/07 e-mail from J. Sloman to A. MarieVillafafia re non-prosecution agree @ 9/11/07 e-mail from A. Oosterbaan to A. Marie Villafafia re negotiations with attached correspondence; @ 9/17/07 e-mail from <A. Marie Villafafia to R. Garcia A. Lourie re negotiation strategy Suppl. Box #3 File folder entitled “{] Target Letter” 6(e) Inadequate Log: No Factual Underpinnings: P-013609 | containing copy of signed letter and Investigative Privilege | Fiduciary Duty; Not in Anticipation of Thru contact info for counsel for target Litigation; Improper Invocation; Overriding P-013615 Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA- authorized release; Material Severable Suppl. Box #3 P-013616 File folder entitled “Atty Notes re Revised Indictment” containing Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Attorney-Client Privilege Deliberative Process Page 56 of 69 EFTA00208738

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 58 of 70 Bates Range Description Privilege(s) Asserted Victims’ Objections Thru P-013621 Suppl. Box #3 handwritten notes by A. Marie Villafaiia File folder entitled “Research Re Possible Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Work product Anticipation of Litigation; Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings: P-013622 Misdemeanors” containing _—_ attorney Fiduciary Duty; Not in Anticipation of Thru research Litigation; Claims Against Public Prosecutor: P-013643 Overriding Need; Attorney Conduct at Issue Suppl. Box #3 | File folder entitled “Notes Re Plea) Attorney-Client Privilege | Inadequate Log: No Factual Underpinnings: P-013644 Thru P-013653 Negotiations” containing 9/17/07 e-mail from A. Marie Villafaiia to J. Richards, N. Kuyrkendall re status update; undated and typed handwritten notes by A. Marie Villafafia re items to be completed on case, strength of case, victim interviews, summary of evidence, guidelines calculations Work Product Deliberative Process Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; — Ordinary Government Communication; No Attorney- Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Suppl. Box #3 P-013654 Thru P-013745 File folder entitled “Plea Agreement Drafts” containing several draft plea agreements some with handwritten notes by A. Marie Villafafia; copies of draft non-prosecution agreement some with handwritten notes by A. Marie Villafafia: copy of a draft Information Attorney-Client Privilege Work Product Deliberative Process Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation: Ordinary Government Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Suppl. Box #3.) File folder entitled = “Draft Non-| Attorney-Client Privilege | Inadequate Log; No Factual Underpinnings: P-0013747 Prosecution _ Agreements” _ containing Work Product Fiduciary Duty; Not in Anticipation of Page 57 of 69 EFTA00208739

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 59 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Thru several draft non- prosecution agreements Deliberative Process Litigation; Ordinary Government P-013810 some with handwritten notes by A. Marie Communication; No Attorney-Client Villafaiia; plea sheet State Circuit Court; Relationship; Improper Invocation; Overriding copies of draft Information; draft plea Need; Claims Against Public Prosecutor: proffer; draft motion and order to seal; Attorney Conduct at Issue; Factual Materials draft penalty sheet; draft plea agreement Suppl. Box 3 | File folder entitled “Information Packet | Attorney-Client Privilege | Inadequate Log: No Factual Underpinnings: P-013811 Drafts” containing several drafts of Work Product Fiduciary Duty; Not in Anticipation of Thru Informations, and complete draft Deliberative Process Litigation; Ordinary Government P-013833 Information packet Communication; No Attorney-Client Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue suppl. Box 3 P- | Two pages of filed document, D.E. 62, Atty work-product Inadequate Log; No Factual Underpinnings: 013834 page 2 of 54 and page 6 of 54, Fiduciary Duty; Claims Against Public Through P- containing handwritten attorney notes Prosecutor; Overriding Need; Attorney 013835 Conduct at Issue Suppl. Box3 | Palm Beach Daily News Article, Atty work-product Inadequate Log; No Factual Underpinnings: P-013836 “Attorneys want Jeffrey Epstein Fiduciary Duty; Claims Against Public Thru Agreement Thrown Out.” ~~ with Prosecutor; Overriding Need; Attorney P-013837 attorney's notes written on margin Conduct at Issue Suppl. Box 3 | Letter from Paul Cassell to Wifredo A. Atty work-product Inadequate Log: No Factual Underpinnings;: P-013838 Ferrer, December 10, 2010, Subject: Fiduciary Duty; Claims Against Public Thru Request for Investigation of Jeffrey Epstein Prosecutor; Overriding Need; Attorney P-013841 Prosecution, with underlines, written notes, Conduct at Issue and comments by DOJ attorney Suppl. Box3 | Email from Dexterr Lee to Ruth Atty work-product Inadequate Log; No Factual Underpinnings: P-013842 Plagenhoef (OPR), February 25, 2011, Atty-client privilege Fiduciary Duty; Crime-Fraud-Misconduct; 4:31 p.m. Re: request for OPR Factual Materials; Ordinary Government Investigation — Jeffrey Epstein Non- Communication; No Attorney-Client Prosecution Agreement Relationship; Claims Against — Public Prosecutor; Overriding Need; _ Attorney Page 58 of 69 EFTA00208740

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 60 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Conduct at Issue Suppl. Box 3 | E-mail, Marie Villafana to Andrew Lourie, Atty work-product Inadequate Log; No Factual Underpinnings: P-013843 Rolando Garcia, and Karen Atkinson, atty-client privilege Fiduciary Duty; Ordinary Government Thru September 19, 2007, 4:33 p.m., RE: Plea Communication; No Attorney-Client P-013844 Agreement Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 | E-mail, Andrew Lourie to Marie Villafana, Atty work-product Inadequate Log; No Factual Underpinnings; P-013845 September 19, 2007, 4:21 p.m., RE: Fiduciary Duty; Claims Against Public Thru Epstein, with internal U.S. Attorney's Prosecutor; Overriding Need; Attorney P-013846 _| Office e-mails attached Conduct at Issue Suppl. Box 3 | E-mail, Marie Villafana to Andrew Lourie, Atty work-product Inadequate Log; No Factual Underpinnings: P-013847 Rolando Garcia, and Karen Atkinson, Fiduciary Duty; Claims Against Public Thru September 18, 2007, 11:43 a.m., RE: Draft Prosecutor; Overriding Need; Attorney P-013849 Agreements?, with e-mail from Jay Conduct at Issue Waiver Lefkowitz (September 18, 2007, 11:09 a.m.) attached Suppl. Box 3 | E-mail, Marie Villafana to Alex Acosta, Atty work-product No Factual Underpinnings; Fiduciary Duty: P-013850 Andrew Lourie, Rolando Garcia, Karen Crime-Fraud-Misconduct; Crime-Fraud- Atkinson, and = John McMillan, Misconduct; Waiver: Claims Against Public September 18, 2007, 9:31 a.m., RE: Prosecutor; Overriding Need; Attorney Epstein Negotiations Conduct at Issue Suppl. Box 3. | E-mail, Marie Villafana to Rolando Atty work-product Inadequate Log; No Factual Underpinnings: P-013851 Garcia and Andrew Lourie, September Fiduciary Duty; Claims Against Public Thru 17, 2007, 10:35 am., RE: Epstein Prosecutor; Overriding Need; Attorney P-013853 [providing update re plea negotiations] Conduct at Issue Suppl. Box 3 | E-mail, Marie Villafana to Andrew Atty work-product No Factual Underpinnings; Fiduciary Duty: P-013854 Oosterbaan, September 13, 2007, 8:10 Claims Against Public Prosecutor; Overriding p-m., RE: Epstein, with e-mail from Need; Attorney Conduct at Issue Andrew Oosterbaan (September 13, 2007, 7:54 p.m.), attached Suppl. Box 3 | E-mail, Marie Villafana to Jeff Sloman Inadequate Log: No Factual Underpinnings; Page 59 of 69 EFTA00208741

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 61 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections P-013855 and Andrew Lourie, September 10, Atty-client privilege Fiduciary Duty; Ordinary Government : 2007, 5:24 p.m., RE: FBI Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Communication; No Attorney-Client Relationship Suppl. Box 3 | E-mail, Marie Villafana to Jeff Sloman, Atty work-product No Factual Underpinnings; Fiduciary Duty: P-013856 September 6, 2007, 5:47 p.m., RE: Epstein, Atty-client privilege Ordinary Government Communication; No Thru with e-mail from Jeff Sloman (September Attorney-Client Relationship; Claims Against P-013857 6, 2007, 5:35 p.m.), attached Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 | Email, Marie Villafana to Jeff Sloman, atty work-product No Factual Underpinnings; Fiduciary Duty; P-013858 September 6, 2007, 9:29 a.m., Re: Meeting Claims Against Public Prosecutor; Overriding on Frida’ Need; Attorney Conduct at Issue Suppl. Box | Email, Gerald Lefcourt to Marie [Not considered 3 Villafana, Lilly Ann Sanchez, Roy privileged. Will be P-013859 Black, re: Jeffrey Epstein produced to opposing Through counsel upon lifting of P-013860 stay] Suppl. Box 3. | E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log: No Factual Underpinnings: P-013861 Menchel, July 13, 2007, 3:14 p.m., RE: atty-client privilege Fiduciary Duty; Crime-Fraud-Misconduct; Thru Epstein, with e- mail from Menchel (July Ordinary Government Communication; No P-013865 5, 2007, 3:30 p.m.), Villafana to Attorney-Client Relationship; Waiver; Claims Menchel (July 4, 2007, 5:16 p.m.), and Against Public Prosecutor; Overriding Need; Sloman to Villafana (July 3, 2007, 1:47 Attorney Conduct at Issue p.m.), attached Suppl. Box 3. | E-mail, Marie Villafana to Jeff Sloman, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013866 Matthew Menchel, Andrew Lourie, Crime-Fraud-Misconduct; Waiver; Claims Karen Atkinson, and Shawn Ball, July 3, Against Public Prosecutor; Overriding Need; 2007, 6:26 a.m., RE: Epstein Attorney Conduct at Issue Suppl. Box 3 | E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings: P-013867 Menchel, June 21, 2007, 3:24 p.m., RE: Fiduciary Duty; Crime-Fraud-Misconduct; Thru Meeting Next Week, with e-mails from Waiver; Claims Against Public Prosecutor; Page 60 of 69 EFTA00208742

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Bates Range Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 62 of 70 Description Privilege(s) Asserted Victims’ Objections P-013868 Menchel to Villafana (June 21, 2007, 2:58 p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Overriding Need: Attorney Conduct at Issue Suppl. Box 3 P-013869 E-mail, Marie Villafana to Matthew Menchel, Jeff Sloman, Andrew Lourie, and Karen Atkinson, June 18, 2007, 5:04 p.m., Atty work-product Inadequate Log; No Factual Underpinnings: Fiduciary Duty; Crime-Fraud-Misconduct; Waiver: Claims Against Public Prosecutor; RE: Epstein Overriding Need; Attorney Conduct at Issue Suppl. Box 3. | E-mail, Andrew Lourie to Marie Atty work-product Inadequate Log: No Factual Underpinnings; P-013870 Villafana, May 24, 2007, 9:25 a.m., FW: Fiduciary Duty; Claims Against Public Thru Jeffrey Epstein, with e-mail from Gerald Prosecutor; Overriding Need; Attorney P-013871 Lefcourt to Andrew Lourie (May 23, Conduct at Issue 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 | E-mail, Andrew Lourie to Matthew Atty work-product Inadequate Log; No Factual Underpinnings: P-013872 Menchel, Jeff Sloman, and Marie Fiduciary Duty; Crime-Fraud-Misconduct; Villafana, May 22, 2007, 3:11 p.m., FW: Waiver: Claims Against Public Prosecutor; Jeffrey Epstein, with e-mail from Overriding Need; Attorney Conduct at Issue Lefcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3 | E-mail Menchel to Villafana and Lourie, Atty work-product Inadequate Log; No Factual Underpinnings: P-013873 May 14, 2007, 10:52 am., RE: Fiduciary Duty; Crime-Fraud-Misconduct;: Operation Leap Year, with e-mail from Waiver; Claims Against Public Prosecutor; Villafana to Lourie and Menchel (May Overriding Need; Attorney Conduct at Issue 14, 2007, 10:38 a.m.), attached Suppl. Box | Inadvertently marked as privileged, will N/A 3 P- be produced 013874 Page 61 of 69 EFTA00208743

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Bates Range | Description Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 63 of 70 Through P-013875 Suppl. Box 3 P-013876 Thru P-013877 Suppl. Box 3 P-013878 Thru P-013879 Suppl. Box 3 P-013880 Thru P-013882 E-mail, Villafana to Lourie,Garcia, — and Atkinson, September 19, 2007, 4:33 p.m., RE: Draft Plea Agreement, with e-mail from Lefkowitz to Villafana (September 19, 2007, 3:44 p.m.), and Lefkowitz to Villafana (September 19, 2007, 3:35 p.m.) attached E-mail, Lourie to Villafana, September 19, 2007, 4:21 p.m., RE: Epstein, with e-mails from Villafana to Lourie and Garcia (September 19, 2007, 4:13. p.m), Villafana to Lourie and Garcia (September 19, 2007, 4:05 p.m.), and Lourie to Villafana and Garcia (September 19, 2007, 3:50 p.m.), Villafana to Lourie (September 19 2007, 2:36 p.m.), Lourie to Villafana (September 19, 2007, 2:33 p.m.), and Villafana to Lourie and Garcia (September 19, 2007, 2:31 p.m.), attached E-mail, Villafana to Lourie,Garcia, — and Atkinson, September 18, 2007, 11:43 a.m., RE: Draft Agreements?, with e-mails from Villafana to Lourie, Garcia and Atkinson (September 18, 2007, 11:18a.m.), Atty work-product Atty work-product Atty work-product ee _ ae Inadequate Log: No Factual Underpinnings: Fiduciary Duty; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Inadequate Log: No Factual Underpinnings; Fiduciary Duty; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue No Factual Underpinnings; Fiduciary Duty: Waiver; Claims Against Public Prosecutor; Overriding Need: Attorney Conduct at Issue Page 62 of 69 EFTA00208744

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 64 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Suppl. Box 3 | E-mail, Villafana to Acosta, Lourie, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013883 Garcia, Atkinson, and McMillan, Crime-Fraud-Misconduct; Waiver; Claims September 18, 2007, 9:31 am., RE: Against Public Prosecutor; Overriding Need; Epstein Negotiations Attorney Conduct at Issue Suppl. Box 3 | E-mail, Villafana to Garcia and Lourie, Atty work-product Inadequate Log; No Factual Underpinnings; P-013884 September 17, 2007 10:35 am., RE: Fiduciary Duty; Waiver: Claims Against Thru Epstein, with e-mail from Garcia Public Prosecutor; Overriding Need: Attorney P-013886 (September 17, 2007, 10:26 a.m.), Conduct at Issue attached Suppl. Box 3 | E-mail, Marie Villafana to Andrew Atty work-product Inadequate Log: No Factual Underpinnings: P-013887 Oosterbaan, September 13, 2007, 8:10 Fiduciary Duty; Waiver; Claims Against p-m., RE: Epstein, with e-mail from Public Prosecutor; Overriding Need; Attorney Andrew Oosterbaan (September 13, 2007, Conduct at Issue 7:54 p.m.), attached Suppl. Box 3 | E-mail, Marie Villafana to Jeff Sloman Atty work-product Inadequate Log: No Factual Underpinnings; P-013888 and Andrew Lourie, September 10, Atty-client privilege Fiduciary Duty; Ordinary Government 2007, 5:24 p.m., RE: FBI Communication; No Attorney-Client Relationship; Waiver; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 | E-mail, Marie Villafana to Jeff Sloman, Atty work-product Inadequate Log: No Factual Underpinnings;: P-013889 | September 6, 2007, 5:47 p.m., RE: Epstein, Atty-client privilege Fiduciary Duty; Ordinary Government Thru with e-mail from Jeff Sloman (September Communication; No Attorney-Client P-013890 | 6, 2007, 5:35 p.m.), attached Relationship; Claims Against — Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 | Email, Marie Villafana to Jeff Sloman, atty work-product Inadequate Log; No Factual Underpinnings: P-013891 September 6, 2007, 9:29 a.m., Re: Meeting Fiduciary Duty; Claims Against Public on Friday Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box | Email, Gerald Lefcourt to Marie [Not considered N/A 3 Villafana, Lilly Ann Sanchez, Roy privileged. Will be Page 63 of 69 EFTA00208745

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 65 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Karen Atkinson, and Shawn Ball, July 3, 2007, 6:26 a.m., RE: Epstein P-013892 Black, re: Jeffrey Epstein produced to opposing Through counsel upon lifting of P-013893 stay] Suppl. Box 3 | E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings: P-013894 Menchel, July 13, 2007, 3:14 p.m., RE: atty-client privilege Fiduciary Duty; | Crime-Fraud-Misconduct; Thru Epstein, with e- mail from Menchel (July Ordinary Government Communication; No P-013898 5, 2007, 3:30 p.m.), Villafana to Attorney-Client Relationship; Claims Against Menchel (July 4, 2007, 5:16 p.m.), and Public Prosecutor; Overriding Need; Attorney Sloman to Villafana (July 3, 2007, 1:47 Conduct at Issue p.m.), attached Suppl. Box 3 | E-mail, Marie Villafana to Jeff Sloman, Atty work-product Inadequate Log; No Factual Underpinnings: P-013899 Matthew Menchel, Andrew Lourie, Fiduciary Duty; Crime-Fraud-Misconduct: Waiver: Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue E-mail, Marie Villafana to Matthew Menchel, June 21, 2007, 3:24 p.m., RE: Suppl. Box 3 P-013900 Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct;: 2007, 5:00 p.m.), Andrew Lourie to Gerald Lefcourt (May 22, 2007, 6:32 p.m.), and Gerald Lefcourt to Andrew Lourie Marie Villafana, and Lilly Ann Thru Meeting Next Week, with e-mails from Claims Against Public Prosecutor; Overriding P-013901 Menchel to Villafana (June 21, 2007, 2:58 Need; Attorney Conduct at Issue p.m.), and Villafana to Menchel (June 21, 2007, 1:37 p.m.), attached Suppl. Box 3 | E-mail, Marie Villafana to Matthew Atty work-product Inadequate Log; No Factual Underpinnings: P-013902 Menchel, Jeff Sloman, Andrew Lourie, and Fiduciary Duty; Crime-Fraud-Misconduct; Karen Atkinson, June 18, 2007, 5:04 p.m., Waiver; Claims Against Public Prosecutor; RE: Epstein Overriding Need; Attorney Conduct at Issue Suppl. Box 3 | E-mail, Andrew Lourie to Marie Atty work-product Inadequate Log; No Factual Underpinnings: P-013903 Villafana, May 24, 2007, 9:25 a.m., FW: Fiduciary Duty; Waiver: Against Thru Jeffrey Epstein, with e-mail from Gerald Public Prosecutor; Overriding Need; Attorney P-013904 Lefcourt to Andrew Lourie (May 23, Conduct at Issue Page 64 of 69 EFTA00208746

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 66 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3. | E-mail, Andrew Lourie to Matthew Atty work-product Inadequate Log: No Factual Underpinnings; P-013905 Menchel, Jeff Sloman, and Marie Fiduciary Duty; Crime-Fraud-Misconduct: Villafana, May 22, 2007, 3:11 p.m., FW: Claims Against Public Prosecutor; Overriding Jeffrey Epstein, with e-mail from Need; Attorney Conduct at Issue Lefcourt to Lourie, Villafana, and Lilly Ann Sanchez (May 22, 2007, 2:05 p.m.), attached Suppl. Box 3. | E-mail Menchel to Villafana and Lourie, Atty work-product No Factual Underpinnings; Fiduciary Duty; P-013906 May 14, 2007, 10:52 am., RE: Crime-Fraud-Misconduct; Claims Against Operation Leap Year, with e-mail from Public Prosecutor; Overriding Need; Attorney Villafana to Lourie and Menchel (May Conduct at Issue 14, 2007, 10:38 a.m.), attached Suppl. Box | Inadvertently marked as privileged, will 3 P- be produced N/A 013907 Through P-013908 Suppl. Box 3 | Memorandum, Lisa Howard, Assistant Deliberative Process Inadequate Log: No Factual Underpinnings: P-013909 Counsel, U.S. Department of Justice, Privilege: atty work- Fiduciary Duty; Crime-Fraud-Misconduct; Thru Office of Professional Responsibility product Factual Materials; Improper Invocation; Final P-013911 (OPR), to Ruth Plagenhoef, Acting Decision; Waiver; Claims Against Public Associate Counsel, OPR, undated, Prosecutor; Overriding Need; Attorney Subject: Recommendation Conduct at Issue Suppl. Box 3. | Memorandum, Lisa Howard, Assistant Deliberative Process Inadequate Log: No Factual Underpinnings; P-013912 Counsel, OPR, to Ruth Plagenhoef, Privilege, atty work- Fiduciary Duty: Crime-Fraud-Misconduct: Thru Acting Associate Counsel, OPR, Subject: product Factual Materials; Improper Invocation: P-013914 Recommendation, with handwritten note Waiver: Final Decision: Claims Against Public dated 5/4/11 Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 | Memorandum, Lisa Howard, Assistant Deliberative Process Inadequate Log: No Factual Underpinnings: Page 65 of 69 EFTA00208747

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 67 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections P-013915 Counsel, OPR, to Ruth Plagenhoef, Privilege: atty work- Fiduciary Duty: Crime-Fraud-Misconduct: Thru Acting Associate Counsel, OPR, Subject: product Factual Materials; Improper Invocation: P-013918 Recommendation, with two post-it notes Waiver; Final Decision; Claims Against Public attached with handwritten attorney Prosecutor; Overriding Need; Attorney notations, and handwritten notations, Conduct at Issue underlines, and circled text throughout the body of the two page memorandum Suppl. Box 3 | Draft letter, marked “Confidential”, from Deliberative Process Inadequate Log: No Factual Underpinnings; P-013919 Robin C. Ashton, Counsel, Office of Privilege Fiduciary Duty; Not in Anticipation of Thru Professional Responsibility to Wifredo A. | Attorney Work Product | Litigation; Improper Invocation; Overriding P-013921 Ferrer, United States Attorney, with Need; Claims Against Public Prosecutor: handwritten corrections, strikethroughs, Attorney Conduct at Issue; Waiver; Final and added text Decision Suppl. Box 3 | Draft Letter, marked “Confidential”, from Deliberative Process Inadequate Log; No Factual Underpinnings: P-013922 Robin C. Ashton, to Wifredo A. Ferrer, Privilege Fiduciary Duty; Not in Anticipation of Thru with handwritten corrections Attorney Work Product | Litigation; Improper Invocation; Overriding P-013924 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Suppl. Box 3 | Draft Letter, from Robin C. Ashton to Deliberative Process Inadequate Log: No Factual Underpinnings;: P-013925 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten correction Attorney Work Product | Litigation; Improper Invocation; Overriding P-013927 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Suppl. Box 3 | Draft Letter, from Robin C. Ashton to Deliberative Process Inadequate Log: No Factual Underpinnings; P-013928 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten corrections Attorney Work Product | Litigation; Improper Invocation; Overriding P-013930 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Suppl. Box 3 | Draft Letter, from Robin C. Ashton to Deliberative Process Inadequate Log: No Factual Underpinnings; P-013931 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten corrections, circled text, Attorney Work Product | Litigation; Improper Invocation; Overriding P-013933 Need; Claims Against Public Prosecutor: Page 66 of 69 EFTA00208748

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 68 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections strikethroughs, and additional text Attorney Conduct at Issue Suppl. Box 3 | Draft Letter, marked “Confidential,” Deliberative Process Inadequate Log: No Factual Underpinnings: P-013934 from Robin C. Ashton to Wifredo A. Privilege Fiduciary Duty; Not in Anticipation of Thru Ferrer, with handwritten corrections Attorney Work Product | Litigation; Improper Invocation; Overriding P-013936 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue Suppl. Box 3 | Draft Letter, Robin C. Ashton to Deliberative Process Inadequate Log: No Factual Underpinnings: P-013937 Professor Paul G. Cassell, with Privilege Fiduciary Duty; Not in Anticipation of Thru handwritten corrections Attorney Work Product | Litigation; Improper Invocation; Overriding P-013939 Need; Claims Against Public Prosecutor: Attorney Conduct at Issue; Waiver Suppl. Box 3 | Draft Letter, marked “Confidential: To Be Deliberative Process Inadequate Log: No Factual Underpinnings; P-013940 Opened by Addressee Only,” Robin C. Privilege Fiduciary Duty; Not in Anticipation of Thru Ashton to Wifredo A. Ferrer, with | Attorney Work Product | Litigation; Improper Invocation; Crime-Fraud- P-013942 handwritten corrections Misconduct; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Waiver; Final Decision; Factual Materials Suppl. Box 3 | E-mail, Ruth Plagenhoef to Lisa Deliberative Process No Factual Underpinnings; Fiduciary Duty: P-013943 Howard, May 5, 2011, 11:19 am., RE: Privilege Not in Anticipation of Litigation: Improper Re-write of Epstein letters for your Attorney Work Product | Invocation; Overriding Need; Claims Against review, with e-mail from Lisa Howard to Public Prosecutor; Attorney Conduct at Issue; Ruth Plagenhoef (May 5, 2011, 11:08 Final Decision; Waiver a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Suppl. Box 3. | E-mail, Plagenhoef to Howard, May 5, Deliberative Process No Factual Underpinnings; Fiduciary Duty; P-013944 2011, Privilege Improper Invocation; Overriding Need; Final 11:17 a.m., RE: your review, with e-mail from Howard to Plagenhoef (May 5, 2011, — 11:08 Re-write of Epstein lett Decision; Waiver Page 67 of 69 EFTA00208749

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Bates Range Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 69 of 70 Description Privilege(s) Asserted Victims’ Objections Plagenhoef to Howard (May 5, 2011, 11:01 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41), attached Suppl. Box 3 P-013945 E-mail, Plagenhoef to Howard, May 4, 2011, 5:01 p.m., RE: draft letters in Epstein matter, with e-mail from Howard to Plagenhoef (May 4, 2011, 4:57 p.m.), attached Deliberative Process Privilege No Factual Underpinnings; Fiduciary Duty: Improper Invocation; Overriding Need Suppl. Box 3 P-013946 E-mail, Plagenhoef to Robin C. Ashton, May 4, 2011, 4:08 p.m., RE: FYI on the Florida matter Law Enforcement investigatory record, atty work product; deliberative process privilege No Factual Underpinnings; Fiduciary Duty: Not in Anticipation of Litigation; Improper Invocation; Overriding Need: Claims Against Public Prosecutor; Attorney Conduct at Issue: Final Decision; Waiver Suppl. Box 3 P-013947 Suppl. Box 3 P-013948 Thru P-013951 E-mail, Paul Cassell to Plagenhoef, May 3, 2011,12:23 p.m., RE: OPR Inquiry — request for information, with post-it note attached with handwritten attorney notes on telephone call between Plagenhoef and Howard with Dexter Lee and Marie Villafana E-mail, Plagenhoef to Howard and Robin C. Ashton, May 3, 2011, 12:30 p.m., FW: OPR Inquiry — request for information, with attached e-mails. | Handwritten attorney notes on margin atty work product; law enforcement investigatiory record atty work-product No Factual Underpinnings; Fiduciary Duty: Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue: Factual Materials; Final Decision No Factual Underpinnings; Fiduciary Duty: Crime-Fraud-Misconduct; Factual Materials; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013952 Thru P-013953 Suppl. Box 3 E-mail, Dexter Lee to Ruth Plagenhoef, March 16, 2011, 10:52 a.m., RE: Referral of Cassell Request for Investigation, with e-mail from Paul Cassell to Dexter Lee and Marie Villafana (March 15, 2011, 7:21 p.m.), attached E-mail, Plagenhoef to Neil Hurley, OPR, atty work-product; atty- client privilege Page 68 of 69 No Factual Underpinnings; Fiduciary Duty; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; EFTA00208750

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Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 70 of 70 Bates Range | Description Privilege(s) Asserted Victims’ Objections P-013954 December 16, 2010, 10:59 a.m., FW: OPR client privilege Fiduciary Duty: Crime-Fraud-Misconduct: Thru Referral — Allegation of Misconduct — Factual Materials; Ordinary Government P-013955 U.S. Attorney’s Office, S.D.Fla., with e- Communication; No Attorney-Client mail from Dexter Lee to Plagenhoef Relationship; Waiver; Claims Against Public (December 16, 2010, 10:22 am), Prosecutor; Overriding Need; Attorney attached. Handwritten attorney notations. Conduct at Issue Suppl. Box 3 | Fourteen (14) pages of handwritten atty work-product Inadequate Log; No Factual Underpinnings: P-013956 attorney notes on case, telephone Fiduciary Duty; Material Severable: Crime- Thru interviews with DOJ attorneys Fraud-Misconduct; Factual Materials; Claims P-013846 Against Public Prosecutor; Overriding Need; Attorney Conduct At Issue. Page 69 of 69 EFTA00208751