Case 9:08-cv-80736-KAM Document

Case PROT25-KAM Document 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, Petitioners, I 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 PROT0 Case PROT26-KAM Document Entered on FLSD Docket 07/19/2013 Page 2 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 19, 2013, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system. Assistant United States Attorney SERVICE LIST Jane Does 1 and 2 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 2 PROT1 Case PROT27-KAM Document M-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 rand jury subpoenas and attorney handwritten notes 6(e) Work Product 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 liti ation 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 ( 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 Also contains information this liti ation 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) 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 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 PROT2 Case PROT28-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 2 of 23 Bates Range Description 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 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 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 to investigative privilege. Box #1 P-000983 thru P-001007 File folder entitled "Attorney Notes from Document Review" containing typed and handwritten attorney ( ) notes, target letters, correspondence re grand jury subpoena Work product 6(e) to investigative privilege. Box #1 P-001008 thru P-001056 File folder entitled "Notes from Fed Ex Records" containing handwritten and typed attorney ) notes and screen shots of FedEx subpoena response electronic file Work Product 6(e) to investigative privilege. Box #1 P-001057 thru P-001959 File folder entitled "Colonial Bank Records" containing records received in response to grand jury subpoena 6(e) 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) to investigative privilege. Page 2 of 23 PROT3 Case PROT29-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23 Bates Range Description 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 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) 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) Box #1 P-002266 Thru P-002386 Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary chart witness/victim names and contact list, attorney ( handwritten notes, 302s, 'lions of state investigative file, attorney ) typed notes, of individuals listed as "Additional victims" Work product 6(e) investigative privilege. Also contains information and documents subject to privacy Box #1 P-002387 Thru P-002769 Indictment preparation binder containing: Grand jury subpoena log, evidence/activity summary charta_witness/victim names and contact list, attorney ( handwritten notes, 302s, as 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) Box #1 P-002770 Thru P-003211 Indictment preparation binder containing: witness/victim list with identifying information, sexual activity summ telephone call summary chart, attorney handwritten notes, 3CSsfions 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) Page 3 of 23 PROT4 Case PROT30-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23 Bates Range Description Box #1 P-003212 Thru P-003545 Indictment preparation binder containing metaanalysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Work product 6(e) 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) Box #1 P-003553 Thru P-003555B Printout of filenames from Federal Express subpoena response with Attorney notations Work product 6(e) Box #1 P-003556 Thru P-003562 Document entitled "Identified Numbers" with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records Work product 6(e) Box #1 P-003563 Thru P-003629 Folder entitled "Flight Manifests" containing manifests received pursuant to grand jury subpoena 6(e) Box #1 P-003630 Thru P-003633 File folder entitled "Recent Attibites" 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 Work product Attorney-client privilege 6(e) Also contains information and interview report from May 2008. telephone activity report with attorney ( ) handwritten notes, related grand jury material Page 4 of 23 PROT5 Case PROT31-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23 Bates Range Description 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) Box #1 P-003652 Thru P-003663 File folder entitled "Victim Civil Suits" Not privileged. Produced to counsel for Petitioners Box #1 P-003664 Thru P-003678 File folder entitled "Research re JE Websites" containing attorney research Work product Box #1 P-003679 Thru P-003680 File folder entitled "Serene Cano (N.Y. AUSA)" containing attorney (IIIIII) handwritten notes Work product Box #1 P-003681 Thru P-003687 File folder entitled "Dr. Anna Salter" containing attorney ( ) memo to expert witness and handwritten attorney notes Work product Box #1 P-003688 Thru P-003693 File folder entitled "In G[] Interview" containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges Work product Box #1 P-003694 Thru P-003711 File folder entitled "Research re Travel for Prostitution" containing attorney ( ) 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) Box #1 P-003712 Empty file folder bearing name of victim/witness victim who is not a party to Page 5 of 23 PROT6 Case PROT32-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23 Bates Range Description Box #1 P-003713 Thru P-003746 File folder entitled "T[] M[]" containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same 6(e) Documents under seal pursuant to court order Box #1 P-003747 Thru P-003751 File folder entitled ' ' 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) 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) arties to this liti ation Box #1 P-004351 Thru 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) Box #1 P-004479 Thru P-004551 File Folder entitled "State of Delaware Records" containing documents obtained in preparation for indictment 6(e) Work product Box #1 P-004552 Thru P-004555 File folder entitled "Jet Blue Records" containing documents obtained via subpoena 6(e) Work product Box #1 P-004556 Thru P-004560 File folder entitled "FL EMPLOYMENT RECORDS" containing FDLE records on targets and witnesses obtained at attorney request Work product Page 6 of 23 PROT7 Case PROT33-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23 Bates Range Description Box #1 P-004561 Thru P-004565 Filed folder entitled "JANUSZ BANASIAK" containing attorney ( ) handwritten notes of interview Work product Box #1 P-004566 Thru P-004716 File folder entitled "JANUSZ BANASIAK RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena 6(e) Work product Box #1 P-004717 Thru P-004722 File folder entitled "IGOR ZINOVIEV" containing attorney research regarding witness Work product Box #1 P-004723 Thru P-004725 File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient Work Product Box #1 P-004726 Thru P-004819 File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business litigative practices Work Product Box #1 P-004820 Thru P-004959 Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships Work Product Box #1 P-004960 Thru P-005059 File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena Work Product 6(e) Box #1 P-005060 Thru P-005081 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) Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview Work product Page 7 of 23 PROT8 Case PROT34-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23 Bates Range Description P-005084 thru P-005107 are non responsive documents and have been removed Box #1 P-005108 Thru P-005193 File folder entitled "ANNA SALTER" containing attorney research on select expert, use of experts at trials in child exploitation cases, and additional research materials on offenders and victims Work product 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) Box #1 P-005301 Thru P-005331 File folder entitled "JUAN ALESSI STATEMENT' containing transcript obtained via subpoena 6(e) Box #1 P-005332 Thru P-005341 File folder entitled "KEN LANNING" containing attorney research on select expert, including attorney handwritten notes Work product Box #1 P-005342 Thru P-005387 File folder entitled "Info re Planes" containing correspondence regarding subpoenas and documents received in response to subpoenas 6(e) 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) Box #1 P-005443 Thru P-005496 File folder entitled "[Victim name] Transcript of Interview & GJ Transcript" 6(e) Box #1 P-005497 Thru P-005556 File folder entitled "Bear Stearns Subpoena Resp." containing material received in response to subpoena 6(e) Page 8 of 23 PROT9 Case PROT35-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23 Bates Range Description 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 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 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) 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) Box #2 P-005915 Thru P-005977 containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) Box #2 P-005978 Thru P-006050 Work product 6(e) Box #2 P-006051 Thru P-006065 Work product 6(e) Page 9 of 23 PROT10 Case PROT36-KAM Document IMI-1 Entered on FLSD Docket 07/19/2013 Page 10 of 23 Bates Range Description 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) 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) 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) 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) arties to this liti ation Box #2 P-006803 Thru P-006860 File folder entitled "Lists of Identified Phone Numbers" containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena Work product 6(e) Box #2 P-006861 Thru P-007785 File folder entitled "EPSTEIN, CELL Work product 6(e) PHONE RECORDS" containing documents received via subpoena with attorney handwritten notes and highlighting Page 10 of 23 PROT11 Case PROT37-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 11 of 23 Bates Range Description 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) Box #2 P-008121 Thru P-008139 Handwritten flight logs received in response to subpoena 6(e) 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) 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 11ih Circuit Box #2 P-008364 Thru P-008382 File folder entitled ' Immunity Request" 6(e) Work Product Deliberative Process containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request Box #2 P-008383 Thru P-008516 File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Work product 6(e) Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log Page 11 of 23 PROT12 Case PROT38-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 12 of 23 Bates Range Description Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt . [pursuant to Court's Order, not being withheld as privileged - will be produced to opposing counsel upon lift of stay by 11'" Circuit] Box #2 P-008536 Thru P-008542 Handwritten attorney notes to prepare for interview of Jane Doe #2 Work product Investigative Privilege 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, Work product 6(e) 2007 grand jury presentation Box #2 P-008550 Thru P-008615 File folder entitled "Most Recent Indictment & Good Cases" containing draft indictment and legal research Work product 6(e) 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) 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) 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) Page 12 of 23 PROT13 Case PROT39-KAM Document IMI-1 Entered on FLSD Docket 07/19/2013 Page 13 of 23 Bates Range Description Box #2 P-008809 Thru P-008847 File folder entitled "[Victim name]/Jane Doe #6" Work product 6(e) Box #2 P-008848 Thru P-008862 File folder entitled "[Victim name]/Jane Doe #7" Work product 6(e) Box #2 P-008863 Thru P-008890 File folder entitled "[Victim name]/Jane Doe #8" Work product 6(e) 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 Box #2 P-009112 Thru P-009113 11/26/2008 Email from Roy Black to and Karen Atkinson re Jeffrey Epstein (work release) [pursuant to Court's Order, not being withheld as privileged - will be produced to opposing counsel u on lift of sta b 1 1 th Circuit Box #2 P-009114 Thru P-009115 7/3/2008 Email from Epstein work release with attachment [not being withheld as privileged roduced to o osin 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 1 l th Circuit]) Page 13 of 23 PROT14 Case PROT40-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 14 of 23 Bates Range Description Box #2 P-009126 Thru P-009134 File folder entitled "[Victim name]/Jane Doe #9" Work product 6(e) Box #2 P-009135 Thru P-009141 File folder entitled "[Victim name]/Jane Doe #13" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) i Box #2 P-009141A Thru P-009141C File folder entitled "[Victim name]/Jane Doe #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6(e) who are not arties to this suit Box #2 P-009142 Thru P-009152 File folder entitled Work product 6(e) who are not arties to this suit grand jury data related to that individual for Box #2 P-009153 Thru P-009156 File folder entitled' Work product 6(e) grand jury data related to that individual for Box #2 P-009157 Thru P-009208 File folder entitled "[Victim name]/Jane Doe #1" Work product 6(e) Box #2 P-009209 Thru P-009213 File folder entitled "[Victim name]/Jane Doe #2" Work product 6(e) Page 14 of 23 PROT15 Case PROT41-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 15 of 23 Bates Range Description Box #2 P-009214 Thru P-009271 File folder entitled "[Victim name]/Jane Doe #3" Work product 6(e) Box #2 P-009272 Thru P-009354 File folder entitled "Purpose of Travel Cases" containing attorney research and handwritten notes Work product Box #2 P-009355 Thru P-009403 File folder entitled "Interstate Commerce Cases" notes Work product Box #2 P-009404 Thru P-009536 File folder entitled "Attorney Conflict Research" notes Work product Box #2 P-009537 Thru P-009574 File folder entitled "Mann Act/Travel to Have Sex w/Minor" containing attorney research and Work product Box #2 P-009575 Thru P-009603 File folder entitled "Travel Act" containing attorney research and handwritten notes Work Product Box #2 P-009604 Thru P-009711 File folder entitled "Florida Prostitution/Lewdness Statutes" containing attorney research and handwritten notes Work Product Box #2 P-009712 Thru P-009819 Booklet entitled "Attorney General Guidelines for Victim and Witness Assistance" [not being withheld as privileged - produced to opposing counsel] Box #2 P-009820 Thru P-009965 File folder entitled "Corporate Liability Rsrch" notes Work Product Box #2 P-009966 Thru P-010096 File folder entitled "Research re Knowledge of Age Unnecessary" containing attorney research and handwritten notes and copy of grand jury subpoena Work Product 6(e) Page 15 of 23 PROT16 Case PROT42-KAM Document IM-1 Entered on FLSD Docket 07/19/2013 Page 16 of 23 Bates Range Description Box #2 P-010097 Thru P-010276 File folder entitled "Money Laundering" notes Work Product Box #2 P-010277 Thru P-010394 File folder entitled "1960 & Aiding/Abetting" notes Work Product Box #2 P-010395 Thru P-010488 File folder entitled "18 PROT50 § 2255 Cases" notes Work Product Box #2 P-010489 Thru P-010509 File folder entitled "Research re Overt Acts & Witness Testimony" containing attorney research and handwritten notes Work Product Box #2 P-010510 Thru P-010525 File folder entitled "Extradition" containing attorney research and handwritten notes Work Product Box #2 P-010526 Thru P-010641 File folder entitled "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28, 2007 letter from Kenneth Starr to Alice S. Fisher; and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010528 thru P-010530 and P-010556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by 11th Circuit) Work Product Box #2 P-010642 Thru P-01650 File folder entitled "Immunity" containing attorney research on granting immunity to witnesses Work Product Box #2 P-010651 Thru P-010659 File folder entitled "Research re G.J. Transcript" containing attorney research and draft pleadings re compelling production of grand jury transcript with sub na Work Product 6(e) Box #2 P-010660 Thru P-010757 File folder entitled "Research re GJ Transcript" containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to subpoena Work Product 6(e) Page 16 of 23 PROT17 Case PROT43-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 17 of 23 Bates Range Description Box #2 P-010758 Thru P-010793 File folder entitled "Original Proposed Ind." containing draft indictment Work Product 6(e) Box #2 P-010794 Thru P-010829 File folder entitled "Epstein" containing sample indictments and attorney research re potential charges with attorney notes Work Product Box #2 P-010830 Thru P-010853 File folder entitled "1591 & Money Laundering" notes Work Product Box #2 P-010854 Thru P-010876 File folder entitled "18 PROT51 2425" containing attorney research and handwritten notes Work Product Box #2 P-010877 Thru P-010920 File folder entitled "Knowledge of Age" notes Work Product Box #2 P-010921 Thru P-011049 File folder entitled "2423(b) Constitutionality and Purpose of Travel" containing attorney research and handwritten notes Work Product Box #2 P-011050 Thru P-011212 File folder entitled "Mistake not a Defense" containing attorney research and Work Product Box #2 P-011213 Thru P-011237 File folder entitled "Research re `Pandering - notes Work Product Box #2 P-011238 Thru P-011319 File folder entitled "Research re Grand Jury Instructions" containing attorney research and Work Product 6(e) Box #2 P-011320 Thru P-011361 File folder entitled "Telephone = Facility of Commerce" containing attorney research and Work Product Box #2 P-011362 Thru P-011374 File folder entitled "Def of Prostitution" notes Work Product Page 17 of 23 PROT18 Case PROT44-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 18 of 23 Bates Range Description Box #2 P-011375 Thru P-011456 File folder entitled "Relevant Florida Statutes" notes Work Product Box #2 P-011457 Thru P-011626 File folder entitled "Unit of Prosecution Research" containing attorney research and Work Product Box #3 P-011627 Thru P-011662 File folder entitled "Attorney Notes" containing attorney handwritten and typed notes Work Product Box #3 P-011663 Thru P-011698 and P-012189 thru P-012361 (gap was scanning error) File folder entitled "Drafts" containing draft indictments with attorney handwritten notes, draft internal memoranda, relevant witness interview reports and grand jury material and attorney 6(e) Work Product who are not parties to this Box #3 P-011699 Thru P-011777 File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections 6(e) Work product Box #3 P-011778 Thru P-011788 File folder entitled "6/12/09 Victim Notif. Log" containing chart with victim contact information and attorney notes regarding dates and type of contacts Work product Box #3 P-011789 Thru P-011879 File folder entitled "Breach Memo" containing memorandum analyzing breach of Non- Prosecution Agreement with attachments Work product Box #3 P-011880 Thru P-011922 File folder entitled "Overt Act Lists" containing handwritten notes cross-checking all overt acts alleged in draft indictment by victim and typed overt act summary charts for indictment preparation Work product Attorney-client privilege 6(e) Page 18 of 23 PROT19 Case PROT45-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 19 of 23 Bates Range Description Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: 7/13/2007 letter from Lilly Ann Sanchez to with handwritten attorney ( 1 notes; 6/25/2007 letter from Gerald Lefcourt to and with handwritten attorney 6/25/2007 email from to and entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney ( ) notes regarding main themes raised by Epstein counsel Work product 6(e) Box #3 P-011967 Thru P-012016 Composition book entitled "Operation Leap Year containing attorney handwritten notes regarding investigation and case strategy Work product 6(e) who are not parties to this litigation Box #3 P-012017 Thru P-012055 Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of Law 6(e) Box #3 P-012056 Thru P-012088 Affidavit of Roy Black, Esq. in Support of Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Page 19 of 23 PROT20 Case PROT46-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 20 of 23 Bates Range Description Box #3 P-012168 Thru P-012170 Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas 6(e) Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Box #3 P-012174 Thru P-012176 Draft of September 2009 letter from Work Product to Roy Black regarding breach of Non Prosecution Agreement with handwritten attorney notes Box #3 P-012177 Thru P-012178 Undated handwritten attorney notes Work Product regarding negotiations and allegations Box #3 P-012179 Thru P-012188 File Folder entitled "FBI G.J. Log" containing copy of FBI rand jury subpoena log with attorney ( 6(e) Work Product Box #3 P-012362 Thru P-012451 File folder entitled "Key Documents" containing correspondence between AUSA and case agent regarding indictment prep questions, victim identification information, corrections to draft indictment, indictment preparation timeline, key grand jury material 6(e) Work Product Attorney-Client privilege Box #3 P-012451 Thru P-012452 File folder entitled "Victim List" containing list of victims with dates of birth and age information Work Product Page 20 of 23 PROT21 Case PROT47-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 21 of 23 Bates Range Description Box #3 P-012453 Thm P-012623 Complete indictment package marked "Originals 12/12/07" Work-product 6(e) subject to investigative privilege Box #3 P-012624 Thru P-012653 Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008. Box #3 P-012654 Thru P-012864 3-ring binder entitled "Child Molesters: A Behavioral Analysis" with attorney I Work-product Box #3 P-012865 Thru P-013226 Indictment preparation binder containing: witness/victim list with identifying information, sexual activity suburphone call summary chart, attorney handwritten notes, 3,: tions of state investigative file, attorney ( D 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 #9, 10, 11, 12, 13, 14 Work Product 6(e) subject to investigative privilege Box #3 P-013227 April Office Reporting, submitted 23, 2008 Memo from to Privacy Act of Professional Responsibility re Self Corrected Version of the previously April 21, 2008 Letter to OPR Box #3 P-013226 Thru P-013230 April Office Reporting 21, 2008 Letter from to Privacy Act of Professional Responsibility re Self Box #3 P-013231 Thru P-013239 April Office Report 22, 2008 Letter from to Privacy Act of Professional Responsibility re Selfof Allegation of Conflict of Interest Page 21 of 23 PROT22 Case PROT48-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 22 of 23 Bates Range Description Box #3 P-013240 Thru P-013247 April 21, 2008 Letter from to Privacy Act Office of Professional Responsibility re Self Reporting with attachments Box #3 P-013248 Thru P-013251 Emails between , Assistant General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated `Au • ust 24 and Au• ust 29.2011 Box #3 P-013252 Thru P-013253 Emails between , Assistant General Counsel, Executive Office for United States Attorneys, and First, Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, August 3, and August 24.2011 Box #3 P-013254 Thru P-013257 Emails between , Assistant General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated Auoust 24 and Auaust 29 2011 Box #3 P-013258 Thru P-013259 iEmails between , Assistant ,General Counsel, Executive Office for United I States Attorneys, and First IAssistant 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 P-013260 Thru P-013262 (Email from , Assistant General Counsel, Executive Office for United States Attorneys, to Wifredo Ferrer (U.S. Attorney, SDFL • Robert O'Neill (U.S. Attorney, MDFL , (FAUSA, SDFL), and El (FAUSA, MDFL) regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated Au • ust 24 2011. Page 22 of 23 PROT23 Case PROT49-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 23 of 23 Bates Ran e Descri lion Privile s Asserted Box #3 Emails between Assistant P-013263 General Counsel, Executive Office for United Thru States Attorneys, and First Work Product P-013271 Assistant U.S. Attorney, Southern District of Florida, regarding recusal of Southern District of Florida. dated July 29. 2011 with attached memorandum from to summarizing Jeffrey Epstein Investigation Box #3 Emails between Executive Office P-013272 for United States Attorneys, and Thru Southern District of Florida, seeking advice P-013278 regarding office-wide recusal, dated December 16 and 17, 2010, with attached letter from Paul Cassell to Wifredo A. Ferrer, dated December 10, 2010 Page 23 of 23 PROT24