EFTA00086375

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 31 of 51 
2:008777-008808 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:008809-008847 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:008848-008862 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:008863-008890 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009104-009111 
Protected from discovery by opinion work product 
privilege. 
2:009126-008134 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009135-009141 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009141A-00914 
1C 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009142-009152 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009153-009156 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009157-009208 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009209-009213 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009214-009271 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:009272-009354 
Protected from discovery by opinion work product 
privilege. 
2:009355-009403 
Protected from discovery by opinion work product 
privilege. 
2:009404-009536 
Protected from discovery by opinion work product 
privilege. 
2:009537-009574 
Protected from discovery by opinion work product 
privilege. 
2:009575-009603 
Protected from discovery by opinion work product 
privilege. 
2:009604-009711 
Protected from discovery by opinion work product 
privilege. 
31 
EFTA00086475

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 32 of 51 
2:009820-009965 
Protected from discovery by opinion work product 
privilege. 
2:009966-010096 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:010097-010276 
Protected from discovery by opinion work product 
privilege. 
2:010277-010394 
Protected from discovery by opinion work product 
privilege. 
2:010395-010488 
Protected from discovery by opinion work product 
privilege. 
2:010489-010509 
Protected from discovery by opinion work product 
privilege. 
2:010510-010525 
Protected from discovery by opinion work product 
privilege. 
2:010526-010641 
Protected from discovery by opinion work product 
privilege, 
The correspondence between 
the Government and Epstein's 
counsel is not privileged and 
should be produced. The 
Government must certify that it 
has been produced. 
2:010642-010650 
Protected from discovery by opinion work product 
privilege. 
2:010651-010659 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:010660-010757 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
2:010758-010793 
Protected from discovery by opinion work product 
privilege. 
2:010794-010829 
Protected from discovery by opinion work product 
privilege. 
2:010830-010853 
Protected from discovery by opinion work product 
privilege. 
2:010854-010876 
Protected from discovery by opinion work product 
privilege. 
2:010877-010920 
Protected from discovery by opinion work product 
privilege. 
2:010921-011049 
Protected from discovery by opinion work product 
privilege. 
32 
EFTA00086476

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 33 of 51 
2:011050-011212 
Protected from discovery by opinion work product 
privilege. 
2:011213-011237 
Protected from discovery by opinion work product 
privilege. 
2:011238-011319 
Protected from discovery by opinion work product 
privilege. 
2:011320-011361 
Protected from discovery by opinion work product 
privilege. 
2:011362-011374 
Protected from discovery by opinion work product 
privilege. 
2:011375-011456 
Protected from discovery by opinion work product 
privilege. 
2:011457-011626 
Protected from discovery by opinion work product 
privilege. 
3:011627-011662 
Protected from discovery by opinion work product 
privilege. 
3:011663-012361 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
3:011699-011777 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
3:011778-011788 
Produce victim identities. 
Document does not exhibit the 
mental impressions of counsel 
but rather the cumulation of 
facts. Petitioners should be 
provided with the victim 
identities under an appropriate 
protective order. 
3:011789-011879 
Protected from discovery by opinion work product 
privilege. 
3:011880-011922 
Protected from discovery by opinion work product 
privilege. 
3:011923-011966 
Protected from discovery by opinion work product 
privilege. 
The underlying correspondence 
between Government and 
Epstein's counsel should be 
produced without attorney 
annotations. The Government 
must certify that Petitioners 
have this correspondence. 
3:011967-012016 
Protected from discovery by opinion work product 
privilege. 
33 
EFTA00086477

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 34 of 51 
3:01217-012055 
Protected from discovery by grand jury secrecy. 
3:012056-012088 
Protected from discovery by grand jury secrecy. 
' 3:012089-012129 
Protected from discovery by grand jury secrecy. 
3:012130-012150 
Protected from discovery by grand jury secrecy. 
3:012151-012167 
Protected from discovery by grand jury secrecy. 
3:012168-012170 
Protected from discovery by grand jury secrecy. 
3:012171-012173 
Protected from discovery by grand jury secrecy. 
3:012174-012176 
Protected from discovery by opinion work product 
privilege. 
Final versions of sent 
correspondence should be 
produced. The Government 
must certify whether Petitioners 
have any sent version of this 
correspondence. 
3:012177-012178 
Protected from discovery by opinion work product 
privilege. 
3:012179-012188 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
3:012362-012451 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
3:012451-012452 
Produce victim identities. 
Document does not exhibit the 
mental impressions of counsel 
but rather the cumulation of 
facts. Petitioners' need 
outweighs investigative 
privilege. Petitioners should be 
provided with the victim 
identities under an appropriate 
protective order. 
3:012453-012623 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
3:012624-012653 
Production not necessary; documents are not relevant or 
likely to lead to the discovery of materials relevant to 
this CVRA litigation. 
The Court has reviewed the 
content of the FBI "302's," 
which are forms prepared by 
FBI agents to document 
interviews. These interview 
reports summarize the various 
victims' interactions with 
Epstein, and do not indicate a 
conveyance of information 
from the FBI to the victims 
regarding the likelihood of 
prosecution. 
34 
EFTA00086478

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 35 of 51 
3:012654-012864 
Protected from discovery by opinion work product 
privilege. 
3:012865-013226 
Protected from discovery by grand jury secrecy and 
opinion work product privilege. 
3:013227 
Production not necessary; not relevant or likely to lead 
to the discovery of materials relevant to this CVRA 
litigation. 
Involves OPR investigation 
into Epstein's allegation that 
certain prosecutors had 
conflicts of interest. Not 
relevant to victims' CVRA 
rights. 
3:013228-013230 
Production not necessary; not relevant or likely to lead 
to the discovery of materials relevant to this CVRA 
litigation. 
Involves OPR investigation 
into Epstein's allegation that 
certain prosecutors had 
conflicts of interest. Not 
relevant to victims' CVRA 
rights. 
3:013231-013239 
Production not necessary; not relevant or likely to lead 
to the discovery of materials relevant to this CVRA 
litigation. 
Involves OPR investigation 
into Epstein's allegation that 
certain prosecutors had 
conflicts of interest. Not 
relevant to victims' CVRA 
rights. 
3:013240 -O13247 
Production not necessary; not relevant or likely to lead 
to the discovery of materials relevant to this CVRA 
litigation. 
Involves OPR investigation 
into Epstein's allegation that 
certain prosecutors had 
conflicts of interest. Not 
relevant to victims' CVRA 
rights. 
3:013248-013251 
Protected from disclosure by the attorney-client 
privilege; also not relevant or likely to lead to the 
discovery of materials relevant to this CVRA litigation. 
3:013252-013253 
Protected from disclosure by the attorney—client 
privilege; also not relevant or likely to lead to the 
discovery of materials relevant to this CVRA litigation. 
3:013254-013257 
Protected from disclosure by the attorney—client 
privilege; also not relevant or likely to lead to the 
discovery of materials relevant to this CVRA litigation. 
3:013258-013259 
Protected from disclosure by the attorney-client 
privilege; also not relevant or likely to lead to the 
discovery of materials relevant to this CVRA litigation. 
3:013260-013262 
Protected from disclosure by the attorney-client 
privilege; also not relevant or likely to lead to the 
discovery of materials relevant to this CVRA litigation. 
35 
EFTA00086479

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 36 of 51 
3:013263-013271 
Protected from discovery by attorney-client and opinion 
work product privilege; also not relevant or likely to 
lead to the discovery of materials relevant to this CVRA 
litigation. 
3:013272-013278 
Protected from disclosure by the attorney—client 
privilege; also not relevant or likely to lead to the 
discovery of materials relevant to this CVRA litigation. 
S:013279 013280 
Protected from discovery by opinion work product 
privilege. 
S:013281 
Protected from discovery by opinion work product 
privilege. 
S:013282-013283 
Protected from discovery by opinion work product 
privilege. 
S:013284 
Protected from discovery by opinion work product 
privilege. 
S:013285-013289 
Protected from discovery by opinion work product 
privilege. 
S:013290-013292 
Protected from discovery by opinion work product 
privilege. 
8:013293-013299 
Protected from discovery by opinion work product 
privilege. 
The portions of this 
correspondence between the 
Government and Epstein's 
counsel should be produced. 
The Government must certify 
that Petitioners have been 
provided with these outside 
correspondences. 
S:013300-013303 
Protected from discovery by opinion work product 
privilege. 
5:013304-013325 
Protected from discovery by opinion work product 
privilege. 
8:013326-013329 
Protected from discovery by opinion work product 
privilege. 
S:013330-013333 
Protected from discovery by opinion work product 
privilege. 
S:013334-013337 
Protected from discovery by opinion work product 
privilege. 
36 
EFTA00086480

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 37 of 51 
5:013342-013350 
Protected from discovery by opinion work product 
privilege. 
The underlying correspondence 
between Epstein's counsel and 
the Government should be 
produced without attorney 
annotations. The Government 
must certify that Petitioners 
have been provided with these 
outside correspondences. 
S:013351-013361 
Protected from discovery by opinion work product 
privilege. 
The underlying correspondence 
between Epstein's counsel and 
the Government should be 
produced without attorney 
annotations. The Government 
must certify that Petitioners 
have been provided with these 
outside correspondences. 
S:013362-013366 
Protected from discovery by opinion work product 
privilege. 
Any version of the letter 
actually sent to Epstein's 
counsel should be produced. 
Government must certify 
whether it has been produced. 
S:013367-013372 
Protected from discovery by opinion work product 
privilege. 
Any version of the letter 
actually sent to Epstein's 
counsel should be produced. 
Government must certify 
whether it has been produced. 
S:013373-013503 
Protected from discovery by opinion work product 
privilege. 
S:013504-013507 
Protected from discovery by opinion work product 
privilege. 
S:013508-013514 
Partially protected from discovery by opinion work 
product privilege. 
Only the top portion of P-
013509 contains materials 
internal to the Government—a 
one-sentence email between 
two United States Attorneys. 
The Government must certify 
that Petitioners have the 
remainder of P-013509 and P-
013510-013514, as these 
communications are between 
the Government and Epstein's 
counsel. 
37 
EFTA00086481

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 38 of 51 
$:013515-013525 
Protected from discovery by opinion work product 
privilege. 
Any final version of the letter 
actually sent to Epstein's 
counsel should be produced. 
Government must certify 
whether it has been produced. 
S:013526-013527 
Protected from discovery by opinion work product 
privilege. 
S:013528-013530, 
013532-013537 
Protected from discovery by opinion work product 
privilege. 
S:013531 
Protected from discovery by grand jury secrecy. 
S:013538-013553 
Protected from discovery by opinion work product 
privilege. 
S:013554-013608 
Protected from discovery by opinion work product 
privilege. 
S:013609-013615 
Protected from discovery by grand jury secrecy. 
S:013616-013621 
Protected from discovery by opinion work product 
privilege. 
S:013622-013643 
Protected from discovery by opinion work product 
privilege. 
S:013644-013653 
Protected from discovery by opinion work product 
privilege. 
S:013654-013745 
Protected from discovery by opinion work product 
privilege. 
S:013747-013810 
Protected from discovery by opinion work product 
privilege. 
S:013811-013833 
Protected from discovery by opinion work product 
privilege. 
S:013834-013835 
Protected from discovery by opinion work product 
privilege. 
S:013836-013837 
Protected from discovery by opinion work product 
privilege. 
S:013838-013841 
Protected from discovery by opinion work product 
privilege; also not relevant material or likely to lead to 
discovery of material relevant to the instant CVRA 
litigation. 
The underlying correspondence 
between Epstein's counsel and 
the Government should be 
produced without attorney 
annotations. The Government 
must certify that Petitioners 
have been provided with these 
outside correspondences. 
38 
EFTA00086482

Case 9:08-cv-80736-KAM Document 330 Entered on PLSD Docket 07/06/2015 Page 39 of 51 
S:013842 
Protected from discovery by opinion work product 
privilege; also not relevant material or likely to lead to 
discovery of material relevant to the instant CVRA 
litigation. 
S:013843-013844 
Protected from discovery by opinion work product 
privilege. 
3:013845-013846 
Protected from discovery by opinion work product 
privilege. 
S:013847-013849 
Protected from discovery by opinion work product 
privilege. 
S:013850 
Protected from discovery by opinion work product 
privilege. 
S:013851-013853 
Protected from discovery by opinion work product 
privilege. 
S:013854 
Protected from discovery by opinion work product 
privilege. 
S:013855 
Protected from discovery by opinion work product 
privilege. 
S:013856-013857 
Protected from discovery by opinion work product 
privilege. 
S:013858 
Protected from discovery by opinion work product 
privilege. 
3:013861-013865 
Protected from discovery by opinion work product 
privilege. 
S:013866 
Protected from discovery by opinion work product 
privilege. 
5:013867-O13868 
Protected from discovery by opinion work product 
privilege. 
S:013869 
Protected from discovery by opinion work product 
privilege. 
S:013870-013871 
Produce; not protected from discovery by any privilege. 
Only the top portion of the 
email chain contains 
correspondence internal to the 
Government, and this does not 
divulge any mental impressions 
or legal theories. The rest of 
the email chain is between the 
Government and Epstein's 
counsel. It should be produced. 
39 
EFTA00086483

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 40 of 51 
S:013872 
Protected from discovery by opinion work product 
privilege. 
Besides internal Government 
correspondence, contains one 
email correspondence between 
the Government and Epstein's 
counsel, which will be 
produced at P-013870-013871. 
S:013873 
Protected from discovery by opinion work product 
privilege. 
S:013876-013877 
Partially protected from discovery by opinion work 
product privilege. 
The email correspondence at 
P—013877 is between the 
Government and Epstein's 
counsel, and not privileged. 
The Government must certify 
that Petitioners have been 
provided with these outside 
correspondences. 
S:013878-013879 
Protected from discovery by opinion work product 
privilege. 
S:013880-013882 
Partially protected from discovery by opinion work 
product privilege. 
Only the top two email 
correspondences are internal to 
the Government. The 
remaining emails, starting at 
the bottom of P-013880 and 
running through P-013882, are 
between the Government and 
Epstein's counsel, and should 
be produced. The Government 
must certify that Petitioners 
have been provided with these 
outside correspondences. 
S:013883 
Protected from discovery by opinion work product 
privilege. 
S:013884-013886 
Protected from discovery by opinion work product 
privilege. 
5:013887 
Protected from discovery by opinion work product 
privilege. 
S:013888 
Protected from discovery by opinion work product 
privilege. 
S:013889-013890 
Protected from discovery by opinion work product 
privilege. 
S:013891 
Protected from discovery by opinion work product 
privilege. 
40 
EFTA00086484

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 41 of 51 
S:013894-013898 
Protected from discovery by opinion work product 
privilege. 
S:013899 
Protected from discovery by opinion work product 
privilege. 
5:013900-013901 
Protected from discovery by opinion work product 
privilege. 
S:013902 
Protected from discovery by opinion work product 
privilege. 
S:013903-013904 
Identical to the email chain at S:013870-013871, and 
should likewise be disclosed. 
S:013905 
Partially protected from discovery by opinion work 
product privilege. 
Email correspondence at 
bottom of page between 
Government and Epstein's 
counsel should be produced. 
The Government must certify 
that Petitioners have been 
provided with these outside 
correspondences. 
5:013906 
Protected from discovery by opinion work product 
privilege. 
S:013909-013911 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
5:013912-013914 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013915-013918 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013919-013921 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013922-013924 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013925-013927 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
The final version of this letter, 
which is addressed to 
Petitioners' counsel, should be 
available to Petitioners. 
S:013928-013930 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
The final version of this letter, 
which is addressed to 
Petitioners' counsel, should be 
available to Petitioners. 
41 
EFTA00086485

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 42 of 51 
S:013931-013933 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
The final version of this letter, 
which is addressed to 
Petitioners' counsel, should be 
available to Petitioners. 
S:013934-013936 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013937-013939 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
The final version of this letter, 
which is addressed to 
Petitioners' counsel, should be 
available to Petitioners. 
S:013940-013942 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013943 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013944 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013945 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013946 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
5:013947 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013948-013951 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013952-013953 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013954-013955 
Not relevant or likely to lead to material relevant to the 
instant CVRA litigation. 
S:013956-013969 
Protected from discovery by opinion work product 
privilege. 
S:'13970-13971 
Protected from discovery by opinion work product 
privilege; also, not relevant or likely to lead to material 
relevant to this CVRA litigation. 
S:13972 
Protected from discovery by opinion work product 
privilege. 
S:13973-13976 
Protected from discovery by opinion work product 
privilege. 
The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 
42 
EFTA00086486

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 
S:13977-13979 
Protected from discovery by opinion work product 
privilege. 
S:13980 
Protected from discovery by opinion work product 
privilege. 
S:I3981 
Protected from discovery by opinion work product 
privilege. 
S:13982 
Protected from discovery by opinion work product 
privilege. 
S:I3983-13984 
Protected from discovery by opinion work product 
privilege. 
S:13985-13989 
Protected from discovery by opinion work product 
privilege. 
S:13990-I 3991 
Protected from discovery by opinion work product 
privilege. 
S:13992-13994 
Protected from discovery by opinion work product 
privilege. 
S:13995-14010 
Protected from discovery by opinion work product 
privilege; also, not relevant or likely to lead to material 
relevant to this CVRA litigation. 
S:S:14011-14025 
Protected from discovery by opinion work product 
privilege. 
S:14026-14027 
Protected from discovery by opinion work product 
privilege. 
S:14028-14030 
Protected from discovery by opinion work product 
privilege. 
S:14031-01432 
Protected from discovery by opinion work product 
privilege. 
S:14033 
Protected from discovery by opinion work product 
privilege. 
S: 14034 
Protected from discovery by opinion work product 
privilege. 
S: 14035 
Protected from discovery by opinion work product 
privilege. 
S: 14036 
Protected from discovery by opinion work product 
privilege. 
S:14037 
Protected from discovery by opinion work product 
privilege. 
43 
EFTA00086487

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 44 of 51 
S:14038-14041 
Protected from discovery by opinion work product 
privilege. 
5:14042 
Protected from discovery by opinion work product 
privilege. 
S:14043-14044 
Protected from discovery by opinion work product 
privilege. 
5:14045-14046 
Protected from discovery by opinion work product 
privilege. 
5:14047 
Protected from discovery by opinion work product 
privilege. 
5:14048 
Protected from discovery by opinion work product 
privilege. 
5:14049-14050 
Protected from discovery by opinion work product 
privilege. 
5:14051 
Protected from discovery by opinion work product 
privilege. 
5:14052 
Protected from discovery by opinion work product 
privilege. 
5:14053 
Protected from discovery by opinion work product 
privilege. 
S:14054 
Protected from discovery by opinion work product 
privilege. 
5:14055 
Protected from discovery by opinion work product 
privilege. 
5:14056 
Protected from discovery by opinion work product 
privilege. 
S:14057 
Protected from discovery by opinion work product 
privilege. 
5:14058 
Protected from discovery by opinion work product 
privilege. 
S:14059-1406I 
Protected from discovery by opinion work product 
privilege. 
S:14062-14068 
Protected from discovery by opinion work product 
privilege. 
S:14069 
Protected from discovery by opinion work product 
privilege. 
S:I4070-14074 
Protected from discovery by opinion work product 
privilege. 
44 
EFTA00086488

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 45 of 51 
S:14075-14089 
Protected from discovery by opinion work product 
privilege. 
S:14090-14102 
Protected from discovery by opinion work product 
privilege. 
S:14103-14107 . 
Protected from discovery by opinion work product 
privilege. 
S:14108-14134 
Protected from discovery by opinion work product 
privilege. 
S:14135-14149 
Protected from discovery by opinion work product 
privilege. 
S:14150-14156 
Protected from discovery by opinion work product 
privilege. 
5:14157-15160 
Protected from discovery by opinion work product 
privilege. 
5:14161 
Protected from discovery by opinion work product 
privilege. 
S:14162-14170 
Protected from discovery by opinion work product 
privilege. 
S:14171-14174 
Protected from discovery by opinion work product 
privilege. 
S:14175-14203 
Protected from discovery by opinion work product 
privilege. 
S:14204-14205 
Protected from discovery by opinion work product 
privilege. 
8:14206-14216 
Partially protected from discovery by opinion work 
product privilege. 
The portions of the email chain 
from Epstein's counsel are not 
privileged. The Government 
mast certify that this outside 
correspondence has been 
produced. 
S:I4217-14238 
Partially protected from discovery by opinion work 
product privilege. 
The portions of the email chain 
from Epstein's counsel are not 
privileged. The Government 
must certify that this outside 
correspondence has been 
produced. 
5:14239-14242 
Protected from discovery by opinion work product 
privilege. 
S:14243.14251 
Protected from discovery by opinion work product 
privilege. 
45 
EFTA00086489

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 46 of 51 
S:14252-14275 
Partially protected from discovery by opinion work 
product privilege. 
The portions of the email chain 
from Epstein's counsel are not 
privileged. The Government 
must certify that this outside 
correspondence has been 
produced. 
5:14276 
Protected from discovery by opinion work product 
privilege. 
S:I4277-14282 
Protected from discovery by opinion work product 
privilege. 
S:14283-14284 
Protected from discovery by opinion work product 
privilege. 
S:I4285-14298 
Protected from discovery by opinion work product 
privilege. 
S:14299-14307 
Protected from discovery by opinion work product 
privilege. 
S:14308-14310 
Protected from discovery by opinion work product 
privilege. 
S:14311-14329 
L 
Partially protected from discovery by opinion work 
product privilege; outside correspondence and P- 
014315-014316 must be produced. 
The Government must certify 
that the outside correspondence 
has been produced. The 
correspondence at P-014315-
014316 must be produced; this 
fact-based material is not 
opinion work product as it does 
not reveal the mental 
impressions of counsel, and the 
court finds that Petitioners have 
a compelling need for the 
information contained therein. 
This need also outweighs any 
deliberative-process privilege 
that may apply. It not 
protected by the attorney-client 
privilege, as the Government 
has not demonstrated that FBI 
agen 
provided 
this information in an attempt 
to secure legal advice or a legal 
opinion from the United States 
Attorney's Office. The 
correspondence must be 
produced pursuant to an 
appropriate protective order. 
46 
EFTA00086490

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 47 of 51 
S:14330-14337 
Partially protected from discovery by opinion work 
product privilege. 
The portions of the email chain 
from Epstein's counsel are not 
privileged. The Government 
must certify that this outside 
correspondence has been 
produced. 
S:14338-14354 
Protected from discovery by opinion work product 
privilege. 
S:14355-14361 
Protected from discovery by opinion work product 
privilege. 
S:I4362-14402 
Protected from discovery by opinion work product 
privilege. 
S:14403-14414 
Protected from discovery by opinion work product 
privilege. 
5:14415-14420 
Protected from discovery by opinion work product 
privilege. 
5:14421- 14428 
Protected from discovery by opinion work product 
privilege. 
5:14429-14439 
Protected from discovery by opinion work product 
privilege. 
S: 14440 
Protected from discovery by opinion work product 
privilege. 
S:14441 
Protected from discovery by opinion work product 
privilege. 
S:14442 
Protected from discovery by opinion work product 
privilege. 
5:14443 
Protected from discovery by opinion work product 
privilege. 
5:14444 
Protected from discovery by opinion work product 
privilege. 
S:14445.14447 
Protected from discovery by opinion work product 
privilege. 
S:I4448-14454 
Protected from discovery by opinion work product 
privilege. 
S:14455-14456 
Protected from discovery by opinion work product 
privilege. 
S:I4457-14464 
Protected from discovery by opinion work product 
privilege. 
47 
EFTA00086491

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 48 of 51 
S:14486 
Protected from discovery by opinion work product 
privilege. 
S:14487 
Protected from discovery by opinion work product 
privilege. 
S:I4488-14499 
Protected from discovery by opinion work product 
privilege. 
S:14500 
Protected from discovery by opinion work product 
privilege. 
8:14501-14506 
Protected from discovery by opinion work product 
privilege. 
8:14507-14508 
Protected from discovery by opinion work product 
privilege. 
S:14509-14519 
Protected from discovery by opinion work product 
privilege. 
S:14520 
Produce. 
The Government has not 
supported its assertion of 
attorney-client privilege: the 
email does not, in and of itself, 
demonstrate that it was a 
communication between an 
attorney and clients regarding 
the provision of legal services 
or legal advice. Petitioners' 
need for this material 
outweighs any deliberative 
process or investigative 
privilege that may apply. 
5:14521.14522 
Protected from discovery by opinion work product 
privilege. 
8:14523 
Protected from discovery by opinion work product 
privilege. 
S:14524-14550 
Protected from discovery by opinion work product 
privilege. 
48 
EFTA00086492

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 49 of 51 
S:1455I 
Produce. 
The Government has not 
supported its assertion of 
attorney-client privilege: the 
email, authored by an FBI 
agent, does not indicate that it 
is a client communication 
seeking legal services or advice 
from an attorney, the United 
States Attorney's Office. 
Petitioners' need for this 
material outweighs any 
investigative privilege that may 
apply. This must be produced 
pursuant to an appropriate 
protective order. 
S:I4552 
Protected from discovery by opinion work product 
privilege. 
5:14553-14556 
Protected from discovery by opinion work product 
privilege. 
S:14557 
Production not necessary as not relevant or likely to lead 
to material relevant to this CVRA litigation. 
S:14558 
Protected from discovery by opinion work product 
privilege. 
S:I4559-14562 
Protected from discovery by opinion work product 
privilege. 
S:I4563-14565 
Protected from discovery by opinion work product 
privilege. 
5:14566-14568 
Protected from discovery by opinion work product 
privilege. 
5:14569-14573 
Protected from discovery by opinion work product 
privilege. 
5:14574-14583 
Protected from discovery by opinion work product 
privilege. 
5:14584-14622 
Protected from discovery by opinion work product 
privilege. 
S:14623-14627 
Protected from discovery by opinion work product 
privilege. 
5:14628 
Protected from discovery by opinion work product 
privilege. 
5:14629 
Protected from discovery by opinion work product 
privilege. 
49 
EFTA00086493

Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 50 of 51 
S:14630-14631 
Protected from discovery by opinion work product 
privilege. 
S:I4632-14646 
Protected from discovery by opinion work product 
privilege. 
S:I4647-14649 
Protected from discovery by opinion work product 
privilege. 
S:14650-14653 
Protected from discovery by opinion work product 
privilege. 
S:I4654-14655 
Protected from discovery by opinion work product 
privilege. 
S:I4656-14665 
Protected from discovery by opinion work product 
privilege. 
S:14666-14693 
Protected from discovery by opinion work product 
privilege. 
S:I4694-14706 
Protected from discovery by opinion work product 
privilege. 
S:14707-14711 
Protected from discovery by opinion work product 
privilege. 
S:14712-14716 
Protected from discovery by opinion work product 
privilege. 
5:14717-14721 
Protected from discovery by opinion work product 
privilege. 
5:14722-14727 
Protected from discovery by opinion work product 
privilege. 
S:14728-14742 
Protected from discovery by opinion work product 
privilege. 
S:14743-14780 
Protected from discovery by opinion work product 
privilege. 
S:14781-14800 
Protected from discovery by opinion work product 
privilege. 
S:14801-14810 
Protected from discovery by opinion work product 
privilege. 
S:14811-14829 
Protected from discovery by opinion work product 
privilege. 
S:14830-14837 
Protected from discovery by opinion work product 
privilege. 
S:14838-14843 
Protected from discovery by opinion work product 
privilege. 
50 
EFTA00086494