EFTA00086375

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave, Suite 400. 
West Palm Beach. Florida 3340) 
Facsimile-
FACSIMILE COVER SHEET 
TO: 
JIM EISENBERG 
E_SQ.  
 DATE: 
February 5, 2007 
FAX NO. 
PHONE NO.  
# OP PAGES: 
FROM: 
ASSISTANT U. S . ATTORNEY
PHONE NO. 
COMMENTS: 
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Case No. 08-80736-CV-MARRA 
P-003745 
EFTA00086415

EISENBERG & FOUTS, P.A. 
ATTORNEYS AT LAW 
JAMES L. EISENBERG 
Suitt 704. Oat Cleartake Centre 
250 Australian Avenue So. 
Wen Palm Beach. FL 33401 
BOARD CERTIFIED CRIMINAL TRIAL LAW5'ER 
561-659-2009 
Fax 
Case No. 08-80736-CV-MARRA 
P-003746 
EFTA00086416

EISENBERG & FOUTS, P.A. 
Attorneys At Law 
JAMES L. EISENBERG 
Florida Bar Board Certified Cele°Iasi Trial Lawyer 
National Board Of Trial Advocacy Certified Criminal Trial Advocate 
KAI LI ALOE FOUTS 
One Clearlake Centre, Suite 704, 250 Australian Avenue South, West Palm Bach, FL 33401 
Fax 
September 21, 2006 
, Asst. U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Re: 
Grand Jury Subpoena for 
Dear 
Please allow me to confirm my latest e-mail to you. I did receive your e-mail of last week with 
attachments and passed them on to my client. At this time, I can only say that my client does not 
want to do eit 
of your suggestions. She does not want to give a statement under the immunity 
ed with its Kastigar exception and she does not want to testify before the grand jury 
5" Amendment grounds. With this client, I am sorry, but I must have a formal grant 
e she will say anything. 
I GOVERNMENT
EXHIBIT 
2
Case No. 08-80736-CV-MARRA 
P-000146 
EFTA00086417

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NOR 1HERN (WEST PALM BEACH) DIVISION 
FGJ 07-103(WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
SEALED ORDER 
On Application of the United States Attorney for the Southern District of Florida, and it 
appearing to the satisfaction of the Court: 
1. 
That 
has been called to testify and to provide other information before 
the United States District Court for the Southern District of Florida, including a Grand Jury 
itnpanelled therein; and 
2. 
That in the judgment of the said United States Attorney, 
has refused 
to testify and provide other information on the basis of her privilege against self-incrimination; and 
3. 
That in the judgment of the said United States Attorney, the testimony and other 
information from 
may be necessary to the public interest; and 
4. 
That the aforesaid Application has been made with the approval of the Assistant 
Attorney General in charge of the Criminal Division of the Department of Justice or a duly 
designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, 
United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 
0.132(e). 
NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, 
that 
give testimony and provide other information which she refuses 
G `EXH
QVERNMIENT 
IBTir 
EFTA00086418

provide on the basis of her privilege against self-incrimination, as to all matters about which she may 
be interrogated before said United States District Court, including a Grand Jury impaneled therein, 
as well as any subsequent proceeding or trial. 
However, no testimony or other information compelled under this Order (or any information 
directly or indirectly derived from such testimony or other information) may be used against 
•M in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise 
failing to comply with this Order. 
IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. 
Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United 
States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, 
to counsel for the witness, and to law enforcement officers engaged in the investigation pending 
before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, 
nor may they disclose the existence of the Order to any others. 
DONE and ORDERED this  AC  day of April, 2007t 
Palm Beach, Florida. 
DONALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
cc: 
AUSA 
2 
EFTA00086419

Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Matthewman 
JANE DOES #1 AND #2, 
l'et itioners, 
v . 
UNITED STATES OF AMERICA, 
Respondent. 
UNITED STATES' NOTICE OF FILING PRIVILEGE LOG 
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United 
States of America, by and through the undersigned Assistant United States Attorney, hereby gives 
notice of its filing of its Privilege Log, which is attached hereto. 
The documents referenced in the Privilege Log are being delivered today to the Chambers 
of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's 
Omnibus Order. 
Respectfully submitted, 
WIFREDO A. FERRER 
UNITED STATES ATTORNEY 
By: 
Assistant United States Attorney 
Florida Bar No. 
500 South Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Telephone: 
Facsimile: 
GOVERNMENT 
EXHIBIT 
• 
• 
EFTA00086420

Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 2 of 2 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July 19, 2013,1 electronically filed the foregoing document 
with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties 
are able to receive notice via the CM/ECF system. 
Assistant United States Attorney 
SERVICE LIST 
Jane Does 1 and 2 v. United States, 
Case No. 08-80736-C1V-MARRA/MATTHEWMAN 
United States District Court, Southern District of Florida 
Fort Lauderdale FL 33301-3268 
Fax: 
Paul G. Cassell 
S.J. Quinney College of Law at the 
University of Utah 
332 S. 1400 E. 
Salt Lake Ci 
Utah 84112 
Fax: (801) 585-6833 
E-mail: 
Attorneys for Jane Doe # 1 and Jane Doe # 2 
2 
EFTA00086421

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23 
PRIVILEGE LOG 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-000001 
thru 
P-000039 
File folder entitled "CORR RE GJ 
SUBPOENAS" containing correspondence 
related to various 
d jury subpoenas and 
attorney 
handwritten notes 
6(e) 
Work Product 
Box #1 
P-000040 
thru 
P-000549 
Operation Leap Year Grand Jury Log 
containing subpoenas OLY-01 through OLY-81, 
correspondence and research related to 
enforcement of same, documents produced in 
response to some subpoenas; and attorney 
(la 
handwritten notes 
6(e) 
Work Product 
Contains documents subject 
to investigative privilege 
Also contains documents 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000550 
thru 
P-000621 
File folder entitled "Ritz Compact Flash SW" 
containing copies of a sealed search warrant 
application, warrant, and supporting documents 
6(e) 
Contains information subject 
to investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000622 
thru 
P-000693 
File folder entitled "PNY Technologies Compact 
Flash SW" containing copies of a sealed search 
warrant application, warrant, and supporting 
documents 
6(e) 
Contains information subject 
to investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-000694 
thru 
P-000781 
File folder entitled "JE Corporations" containing 
attorney research on Epstein-owned corporations 
and prior litigation 
Work Product 
Contains information subject 
to investigative privilege 
Box #1 
P-000782 
thru 
P-000803 
File folder entitled "Capital One" 
containing subpoena and correspondence 
6(e) 
Box #1 
P-000804 
thru 
P-000854 
File folder entitled "DTG Operations/Dollar 
Rent-a-Car" containing subpoena and responsive 
documents 
6(e) 
Contains documents and 
information subject to 
investigative privilege 
Also contains documents and 
information subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 1 of 23 
EFTA00086422

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2.013 Page 2 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-000855 
thru 
P-000937 
File folder entitled "JP Morgan Chase" 
containing subpoena, correspondence, and 
responsive documents 
6(e) 
Contains documents and 
information subject to 
investigative privilege 
Box #1 
P-000938 
thru 
P-000947 
File folder entitled "Washington Mutual" 
containing subpoena, correspondence, and 
responsive documents 
6(e) 
Contains documents and 
information subject to 
investigative privilege 
Box #1 
P-000948 
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 
Box #1 
P-000983 
thru 
P-001007 
File folder entitled "Attorney Notes from 
Document Review" containin typed and 
handwritten attorney 
notes, target 
letters, correspondence re grand jury subpoena 
Work product 
6(e) 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-001008 
thru 
P-001056 
"Notes 
Worts Product 
6(e) 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
File folder entitled 
from Fed Ex Records" 
cor.stisin handwritten and typed attorney 
( 
notes and screen shots of FedEx 
subpoena response electronic file 
Box #1 
P-001057 
thru 
P-001959 
File folder entitled "Colonial Bank Records" 
containing records received in response to grand 
jury subpoena 
6(e) 
Contains information subject 
to investigative privilege 
Box #1 
P-001960 
Thru 
P-002089 
File folder entitled "OLY Grand Jury Log Vol 2: 
OLY-51 THROUGH" containing subpoenas 
numbered OLY-51 through OLY-81 with related 
correspondence 
6(e) 
Contains information subject 
to investigative privilege. 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Page 2 of 23 
EFTA00086423

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-002090 
Thru 
P-002169 
File folder entitled "Epstein Corporate Records: 
OLY-51, OLY-52, OLY-53, OLY-54" containing 
subpoenas, records received in response to 
subpoenas, and related correspondence 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-002170 
Thru 
P-002246 
File folder entitled "Colonial Bank" containing 
subpoenas, correspondence related to subpoenas, 
records received in response to subpoenas 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-002247 
Thru 
P-002265 
File folder entitled "JEGE & Hyperion from 
Goldberger OLY-46 & OLY-47" containing 
documents received in response to subpoenas 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-002266 
Thru 
P-002386 
Indictment preparation binder containing: 
Grand jury subpoena log, evidence/activity 
summary ch 
witness/victim names and contact 
list, attorney 
handwritten notes, 302s, 
ail
s of state investigative file, attorney 
typed notes, of individuals listed as 
"Additional victims" 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-002387 
Thm 
P-002769 
Indictment preparation binder containing: 
Grand jury subpoena log, evidence/activity 
summary ch 
witness/victim names and contact 
list, attorney 
handwritten notes, 302s, 
in
Rion of state investigative file, attorney 
typed notes, relevant pieces of grand 
jury materials, telephone records/flight records 
analysis charts, victim/witness photographs, 
DAVID records, NCICs, and related materials for 
persons identified as Jane Does #15, 16, 17, 18, 
19, Past Employees, Misc. Witnesses 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P4)02770 
Thru 
P-003211 
Indictment preparation binder containing: 
witness/victim list with identifying information, 
sexual activity sumselephone call summary 
chart, attorney 
handwritten notes, 
3fats.
ions of state investigative file, attorney 
( 
typed notes, relevant pieces of grand 
jury materials, telephone records/flight records 
analysis charts, victim/witness photographs, 
DAVID records, NCICs, and related materials for 
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7, 
8 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 3 of 23 
EFTA00086424

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-003212 
Thru 
P-003545 
Indictment preparation binder containing meta- 
analysis charts of telephone/flight/grand jury 
information for a number of victim/witne 
s, 
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 
and 
Box #1 
P-003546 
Thru 
P-003552 
FBI Reports of March 2008 interviews of 
additional witness/victim located in New York 
Work product 
6(e) 
Contains information and 
documents subject to 
investigative privilege. Also 
contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003553 
Thru 
P-0035558 
Printout of filenames from Federal Express 
subpoena response with Attorney notations 
Work product 
6(e) 
Box #1 
P-003556 
Thru 
P-003562 
Document entitled "Identified Numbers" with 
accompanying handwritten attorney list compiled 
from grand jury materials and attorney analysis of 
records 
Work product 
6(e) 
Contains information subject 
to investigative privilege 
Box #1 
P-003563 
Thru 
P-003629 
Folder entitled "Flight Manifests" containing 
manifests received pursuant to grand jury 
subpoena 
6(e) 
Contains information and 
documents subject to 
investigative privilege 
Box #1 
P-003630 
Thru 
P-003633 
File folder entitled "Recent AttonStes" 
containing handwritten attorney 
) notes 
regarding document review and case strategy 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Box #1 
P-003634 
Thru 
P-003646 
File folder bearing victim name containing FBI 
interview report from May 2008 tele one 
activity report with attorney 
) 
handwritten notes, related grand jury material 
Work product 
Attorney-client privilege 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 4 of 23 
EFTA00086425

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-003647 
Thru 
P-003651 
File folder entitled "Summary of Sexual Activity" 
containing chart bearing handwritten title "Sexual 
Activity — Summary" with meta-analysis of 
information, sorted by name of each 
victim/witness, including name and identifying 
information of each victim/witness 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003652 
Thru 
P-003663 
File folder entitled "Victim Civil Suits" 
Not privileged. 
Produced to counsel for 
Petitioners 
Box #1 
P-003664 
Thru 
P-003678 
File folder entitled "Research re JE Websites" 
containing attorney research 
Work product 
Box #1 
P-003679 
Thru 
P-003680 
File folder entitled 
(N.Y. AUSA)" 
containing attorney I 
I handwritten notes 
Work product 
Box #1 
P-003681 
Thru 
P-003687 
File folder entitled "Dr. 
" containing 
Work product 
Investigative privilege 
attorney a) 
memo to expert witness and 
handwritten attorney notes 
Box #1 
P-003688 
Thru 
P-003693 
File folder entitled "I[j GO Interview" containing 
attorney handwritten notes of interview, and 
attorney handwritten notes regarding potential 
charges 
Work product 
Investigative privilege 
Also contains information 
subject to privacy rights of 
victims who are not parties to 
this litigation 
Box #1 
P-003694 
Thru 
P-003711 
File folder entitled "Research re Travel for 
Prostitution" containing attorney a 
handwritten notes regarding grand jury 
presentation, chart entitled "Brought to Epstein's 
House" with handwritten notes, Message Pad 
meta-analysis chart, summary of evidence related 
to one victim/witness, and relevant grand jury 
information 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-003712 
Empty file folder bearing name of victim/witness 
Investigative privilege 
Also contains information 
subject to privacy rights of 
victim who is not a party to 
this litilation 
Page 5 of 23 
EFTA00086426

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-003713 
Thru 
P-003746 
File folder entitled "TO MO" containing grand 
jury subpoenas, motion and order to compel 
testimony, and correspondence regarding same 
6(e) 
Documents under seal 
pursuant to court order 
Box #1 
P-003747 
Thru 
PM03751 
File folder entitled' 
'containing 
6(e) 
subpoena and correspondence regarding same 
Box #1 
P-003752 
Thru 
P-004295 
File folder entitled "PBPD Investigative File" 
obtained via subpoena 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-004296 
Thru 
P-004350 
File folder bearing name of victim/witness 
containing meta-analysis chart showing telephone 
calls, travel, and grand jury materials relevant to 
possible charges 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
es to this liti ation 
Box #1 
P-004351 
Iliru 
P-004381 
File folder entitled 
Documents 
Work product 
53909-004" containing attorney research related 
to bias issue 
Box #1 
P-004382 
Thru 
P-004478 
File Folder entitled "FEDEX" containing 
documents obtained via subpoena 
6(e) 
Investigative privilege 
Box #1 
P-004479 
Thru 
P-004551 
File Folder entitled "State of Delaware Records" 
containing documents obtained in preparation for 
indictment 
6(e) 
Investigative privilege 
Work product 
Box #1 
P-004552 
Thru 
P-004555 
File folder entitled "Jet Blue Records" containing 
documents obtained via subpoena 
6(e) 
Work product 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-004556 
Thru 
P-004560 
File folder entitled "FL EMPLOYMENT 
RECORDS" containing FDLE records on targets 
and witnesses obtained at attorney request 
Investigative privilege 
Work product 
Page 6 of 23 
EFTA00086427

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23 
Bates Ran e 
Descri don 
Privil 
s Asserted 
Box #1 
P-004561 
Thru 
P-004565 
Filed folder entitled " 
containing attorney 
handwritten notes 
of interview 
Work product 
Investigative privilege 
Box #1 
P-004566 
Thru 
P-004716 
File folder entitled 
6(e) 
Work product 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
ies to this liti tion 
RECORDS 23-0001 THROUGH 23-" containing 
documents obtained via subpoena 
Box #1 
P-004717 
Thru 
P-004722 
File folder entitled " 
Work product 
Investigative privilege 
containing attorney research regarding witness 
Box #1 
P-004723 
Thru 
P-004725 
File folder entitled "BEAR STEARNS 
RESEARCH" containing attorney research 
regarding potential witness and subpoena 
recipient 
Work Product 
Investigative privilege 
Box #1 
P-004726 
Thru 
P-004819 
File folder entitled "LAWSUITS INVOLVING 
EPSTEIN CORP'S" containing attorney research 
regarding Epstein's past personal and business 
liti ative practices 
Work Product 
Investigative privilege 
Box #1 
P-004820 
Thru 
P-004959 
Filed folder entitled "SEC RECORDS" 
containing attorney research regarding Epstein 
financial relationships 
Work Product 
Investigative privilege 
Box #1 
P-004960 
Thru 
P-005059 
File folder entitled "Message Pads" containing 
selected items from evidence obtained via 
subpoena 
Work Product 
6(e) 
investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005060 
Thru 
P-005081 
File folder bearing name of victim/witness 
containing correspondence with counsel for 
victim/witness, attorney witness outline with 
attorney handwritten notes, attorney handwritten 
notes regarding witness reports and case 
preparation 
Work Product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005082 
Thru 
P-005083 
File folder entitled "New York Trip" containing 
attorney notes re witness interview 
Work product 
Investigative privilege 
Page 7 of 23 
EFTA00086428

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
P-005084 thru P-005107 are non responsive 
documents and have been removed 
Box #1 
P-005108 
Thru 
P-005193 
File folder entitled " 
containing 
Work product 
Investigative privilege 
attorney research on select expert, use of experts 
at trials in child exploitation cases, and additional 
research materials on offenders and victims 
Box #1 
P-005194 
Thru 
P-005300 
File folder entitled "Extra Copies" containing 
meta-analysis chart and 302's of victim/witnesses 
used in preparing indictment package 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
rties to this liti ation 
Box #1 
P-005301 
Thru 
P-005331 
File folder entitled 
6(e) 
Investigative privilege 
STATEMENT" containing transcript obtained via 
subpoena 
Box #1 
P-005332 
Thru 
P-005341 
File folder entitled' 
containing 
Work product 
Investigative privilege 
attorney research on select expert, including 
attorney handwritten notes 
Box #1 
P-005342 
mm 
P-005387 
File folder entitled "Info re Planes" containing 
correspondence regarding subpoenas and 
documents received in response to subpoenas 
6(e) 
Investigative privilege 
Box #1 
P-005388 
Thru 
P-005442 
File folder entitled "Police Reports & PC 
Affidavit" containing portions of police reports 
with attorney notes, related phone records, a list 
entitled "Victims" with identifying information 
and attorney handwritten notes, photographs and 
DAVID information, and additional attorney 
research regarding Epstein sexual activity 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005443 
Thru 
P-005496 
File folder entitled "[Victim name] Transcript of 
Interview & GJ Transcript" 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #1 
P-005497 
Thru 
P-005556 
File folder entitled "Bear Steams Subpoena 
Resp." containing material received in response 
to subpoena 
. 
6(e) 
Investigative privilege 
Page 8 of 23 
EFTA00086429

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #1 
P-005557 
Thru 
P-005576 
U.S. Attorney's Office Criminal Case File Jacket 
containing file opening documents, expert 
witness payment documents 
Work product 
Deliberative process 
Box #1 
P-005578 
Thru 
P-005583 
U.S. Attorney's Office Asset Forfeiture Case File 
Jacket containing file opening and file closing 
documents 
Work product 
Deliberative process 
Box #1 
P-005584 
Thru 
P-005606 
File folder entitled "6001 Immunity Request" 
containing internal memoranda seeking witness 
immunity and correspondence with counsel for 
witness regarding same 
6(e) 
Work product and 
deliberative process (as to 
internal memoranda) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-005607 
Thru 
P-005914 
File folder entitled "MASTER PHONE 
RECORDS" containing meta-analysis of all 
phone, travel, and grand jury data for all 
victim/witnesses for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-005915 
Thru 
P-005977 
File folder bearing name of victim/witness 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-005978 
Thru 
P-006050 
File folder bearing name of victim/witness 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006051 
Thru 
P-006065 
File folder bearing name of victim/witness 
containing meta-analysis of all phone, travel, and 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
grand jury data related to that victim/witness for 
indictment preparation 
Page 9 of 23 
EFTA00086430

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 10 of 
23 
Bates Range 
Description 
Privilege® Asserted 
Box #2 
P-006066 
Thru 
P-006220 
File folder entitled "JANE DOE #4" containing 
meta-analysis of all phone, travel, and grand jury 
data related to that victim/witness for indictment 
preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006221 
Thru 
P-006222 
File folder entitled ""JANE DOE #12" containing 
meta-analysis of all phone, travel, and grand jury 
data related to that victim/witness for indictment 
preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006223 
Thru 
P-006522 
File folder entitled "CORRECTED PHONE 
RECORDS 5/31/07" containing meta-analysis of 
all phone, travel, and grand jury data related to all 
victims/witnesses for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006523 
Thru 
P-006802 
File folder entitled "[Victim Name] Phone 
Records" containing telephone records received 
in response to subpoena 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006803 
Thu 
P-006860 
File folder entitled "Lists of Identified Phone 
Numbers" containing charts of information culled 
from grand jury materials, interviews, and other 
investigation, with attorney handwritten notes, 
and information to issue follow-up grand jury 
subpoena 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-006861 
Thru 
P-007785 
File folder entitled "EPSTEIN. 
CELL 
PHONE RECORDS" containing documents 
received via subpoena with attorney handwritten 
notes and highlighting 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Page 10 of 23 
EFTA00086431

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 11 of 
23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-007786 
Thru 
P-008120 
Folder entitled "OLY GRAND JURY LOG: 
OLY-01 THROUGH OLY-50" containing 
subpoenas, correspondence regarding same, 6(e) 
letters, attorney handwritten notes regarding 
records received in response to subpoenas 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-008121 
Thru 
P-008139 
Handwritten flight logs received in response to 
subpoena 
6(e) 
Investigative privilege 
Box #2 
P-008140 
Thru 
P-008298 
Grand jury presentation folder containing 
attorney handwritten notes, typed outline with 
additional handwritten notes, complete indictment 
package dated 2/19/2008, victim list with 
identifying information, photographs, and 
summary of activity 
Work product 
6(e) 
Investigative privilege 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this litigation 
Box #2 
P-008299 
Thru 
P-008363 
File folder entitled "FINAL AGREEMENTS" 
containing subfolder entitled "Agrints 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 nAcosta 
letter (P-008328-P-
008343 [not being withheld as privileged — have 
been produced to opposing counsagiubfolder 
entitled "12/19/07 Acosta- 
Ltr" 
containing unredacted copies of that letter (11-
008344-P-008363 [pursuant to Court's Order, not 
being withheld as privileged — will be produced 
to opposing counsel upon lift of stay by 11d' 
Circuit 
Box #2 
P-008364 
Thru 
P-008382 
File folder entitled 
Immunity Request" 
containing internal memoranda, Justice 
Department documentation, and subpoena 
regarding immunity request 
6(e) 
Work Product 
Deliberative Process 
Investigative privilege 
Box #2 
P-008383 
Thru 
P-008516 
File folder containing March 18, 2008 grand jury 
presentation materials, including "Operation Leap 
Year Revised Indictment Summary Chart (by 
victim)," grand jury materials, draft indictments, 
victim reference list, grand jury subpoena log 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Also contains information and 
documents subject to privacy 
rights of victims who are not 
esti:
g
liislitiation 
Page 11 of 23 
EFTA00086432

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 12 of 
23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-008517 
Thru 
P-008535 
6/25/2007 Letter from Gerald Lef urt to 
and 
[pursuant to Court's Order, not being withheld as 
privileged — will be produced to opposing counsel 
upon lift of stay by I Ith Circuit] 
Box #2 
P-008536 
Thru 
P-008542 
Handwritten attorney notes to prepare for 
interview of Jane Doe #2 
Work product 
Investigative Privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008543 
Thru 
P-008549 
Handwritten attorney notes regarding May 8, 
2007 grand jury presentation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008550 
Thru 
P408615 
File folder entitled "Most Recent Indictment & 
Good Cases" containing draft indictment and 
legal research 
Work product 
6(e) 
Investigative privilege 
Deliberative process 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008616 
Thru 
P-008686 
File folder entitled "FBI Summary Charts" 
containing chart prepared at direction of AUSA, 
containing victim names, identifying information, 
summary of activity, and other information 
relevant to indictment 
Work product 
Attorney-Client Privilege 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008687 
Thru 
P-008776 
File folder entitled "[Victim name]/Jane Doe #4" 
containing phone records and meta-analysis of all 
phone, travel, and grand jury data related to that 
victim/witness for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information and 
documents subject to privacy 
rights of victims who are not 
parties to this suit 
Box #2 
P-008777 
Thru 
P-008808 
File folder entitled "[Victim name]/Jane Doe #5" 
containing handwritten notes and meta-analysis 
of all phone, travel, and grand jury data related to 
that victim/witness for indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Page 12 of 23 
EFTA00086433

Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 13 of 
23 
Bates Range 
Description 
Privilege(s) Asserted 
Box #2 
P-008809 
Thru 
P-008847 
File folder entitled "[Victim name]/Jane Doe #6" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008848 
Thru 
P-008862 
File folder entitled "[Victim name]/Jane Doe #7" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008863 
Thru 
P-008890 
File folder entitled "[Victim name]/Jane Doe #8" 
containing meta-analysis of all phone, travel, and 
grand jury data related to that victim/witness for 
indictment preparation 
Work product 
6(e) 
Investigative privilege 
Contains information subject 
to privacy rights of victims 
who are not parties to this suit 
Box #2 
P-008891 
Thru 
P-009103 
File folder entitled "Certified Copy of State Case" 
containing certified copy of Epstein state criminal 
cases and change of plea transcript [not being 
withheld as privileged — copy provided to 
opposing counsel] 
Box #2 
P-009104 
Thru 
P-009111 
File folder entitled "Meeting Timeline" 
containing 
typed notes summarizing 
meetings with opposing counsel prepared at 
request of R. Alexander Acosta, with handwritten 
correction and typed guideline estimate 
Work product 
Deliberative process 
Box #2 
P-009112 
Thru 
P-009113 
11/26/2008 Email from Ro Black to 
and 
m Jeffrey Epstein 
(work release) 
[pursuant to Court's Order, not being withheld as 
privileged — will be produced to opposing counsel 
upon lift of stab 11th Circuit 
Box #2 
P-009114 
Thru 
P-009115 
7/3/2008 Email from 
to
at PBSO re Epstein work release with 
attachment [not being withheld as privileged —
produced too 
sin counsel 
Box #2 
P-009116 
Thru 
P-009125 
12/6/2007 Letter from 
to Jay P. 
Lefkowitz re Jeffrey Epstein (victim notification) 
[pursuant to Court's Order, not being withheld as 
privileged — will be produced to opposing counsel 
upon lift of stay by 11th Circuit]) 
Page 13 of 23 
EFTA00086434