Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 1 of 35

EXHIBIT K
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 2 of 35

B O ,I E S, S CH I LL ER & F LE X N ER LL P
401 EAST LAS OLAS BOULEVARD• SUITE 1200 • FORT LAUDERDALE. FL 33301- 2211 • PH. 954.356.0011 • FAX 954.356.0022

Sigrid s. Mccawley, Esq.

E-mail: [email protected]

June 10, 2016

VIA E-MAIL

Laura A. Menninger, Esq.

HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
[email protected]

Re: Giuffre v. Maxwell

Case No.15-cv-07433-RWS

Dear Ms. Menninger:

On behalf of the Plaintiff, Virginia Giuffre, documents, Bates-stamped GIUFFRE005607

through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production.
Certain of the documents within this production have been designated as CONFIDENTIAL in
accordance with your proposed Protective Order. Please treat these documents accordingly.

This production consists solely of all data that is responsive to Defendant's various
requests for production from Ms. Giuffre's iCloud account.

Attached to this letter, please also find an updated privilege log.

If you have any questions concerning the foregoing, or if there are any issues with the
media, please do not hesitate to contact me at (954) 356-0011.

Sincerely,

SSM:dk
Enclosures

WWW.BSFLLP.COM
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 3 of 35

From: Richards, Jason R.

To: Robert Giuffre
Subject: RE: Hi There
Date: Wednesday, August 27, 2014 10:44:32 AM

Hi Jenna,

My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from FBI
records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of Ron Eppinger. The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.

Best wishes,

Jason

-----Original Message-----
From: Robert Giuffre [mailto:[email protected]]
Sent: Wednesday, August 27, 2014 9:49 AM
To: Richards, Jason R.
Subject: Hi There

G'day Jason,

I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an
era, just need a couple dates confirmed is all.

If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept upside down looking through records and come up w nada. What was your
acquaintance's name that took my statement about Ron Eppinger? Is it possible that it wasn't Wilton
Manors and maybe it was somewhere else?

I'm really racking my brain about this!! It would be a personal favor to me and I am so very much
appreciative of anything you might know!!

Thanks a lot mate!!

Jenna

Sent from my iPhone

GIUFFRE005607
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 4 of 35

From: Richards, Jason R.

To: "[email protected]"
Subject: Re: Hi There
Date: Wednesday, August 27, 2014 10:50:27 AM

Feel free to reach out to me any time.

Take care.

Jason

----- Original Message -----

From: Robert Giuffre <[email protected]>
To: Richards, Jason R.
Sent: Wed Aug 27 10:46:50 2014
Subject: Re: Hi There

Thank you Jason. I hope all has been well for you and yours!

All the best, I won't bother you again.

Jenna

Sent from my iPhone

> On Aug 27, 2014, at 10:44 AM, "Richards, Jason R." <[email protected]> wrote:
>
> Hi Jenna,
>
> My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the
information you are looking for because I am not able to release information (should there be any) from
FBI records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of Ron Eppinger. The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
>
> Best wishes,
>
> Jason
>
> -----Original Message-----
> From: Robert Giuffre [mailto:[email protected]]
> Sent: Wednesday, August 27, 2014 9:49 AM
> To: Richards, Jason R.
> Subject: Hi There
>
> G'day Jason,
>
> I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an
era, just need a couple dates confirmed is all.
>
> If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept upside down looking through records and come up w nada. What was your
acquaintance's name that took my statement about Ron Eppinger? Is it possible that it wasn't Wilton
Manors and maybe it was somewhere else?
>
> I'm really racking my brain about this!! It would be a personal favor to me and I am so very much
appreciative of anything you might know!!

GIUFFRE005608
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 5 of 35

>
> Thanks a lot mate!!
>
> Jenna
>
> Sent from my iPhone

GIUFFRE005609
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 6 of 35

From: Robert Giuffre

To: [email protected]
Subject: Virginia Roberts(Jane doe 102)
Date: Tuesday, April 15, 2014 9:50:31 AM

Hi Jason,

Long time, no talk. I hope all has been well for you and yours!! I am now back in the USA, not too
many people know about that and I'd like to keep it that way as my case against Jeffrey Epstein has
intensified!! I am here to get this BS non- prosecution agreement thrown out and speaking w Judge
Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI
to assist our case further in proving how much pedophilia occurred by Jeffrey and the many other
monsters he obliged w underage girls. If this is a possibility please let me know so I can give you Brad
Edwards( my attorney) his contact details. Many thanks for your time and I hope we should meet again.

Kindest Regards,
Virginia Roberts
Phone 321-271-4948

Sent from my iPhone

GIUFFRE005610
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 7 of 35

From: Robert Giuffre

To: [email protected]
Subject: Virginia Roberts re: Jeffrey Epstein Case
Date: Wednesday, April 16, 2014 1:52:05 PM

Hi Christina,

I was wondering if you remember me from Sydney Consulate, I am a victim in the investigation from
the Jeffrey Epstein case and was wondering if you could tell me if I would be able to get ahold of any
of the pics and/or videos that the FBI might have confiscated from any of Epstein's residences? Also can
I ask if you might have any of the flight logs that include my name in them to be sent to me as well.
It's all for evidential purposes and would prove a many of things to help my case.

Kindest Regards,
Virginia Roberts
321-271-4948 cell

Sent from my iPhone

GIUFFRE005611
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 8 of 35

From: [email protected] on behalf of Sharon Rikard

To: Virginia Giuffre
Subject: Re: Victims Refuse Silence
Date: Saturday, March 28, 2015 9:49:55 AM

Hi Virginia,
So sorry for the late response. Our organization currently works with survivors of
sex trafficking provided continuing education, life skills and counseling. We will help
with transportation and their basic necessities. Our ultimate goal is a home for
domestic minor sex trafficking survivors.
Our contact information is:
doorstofreedom.com
[email protected]
843-817-0740

I am going to forward your information to our Attorney Generals office as

Marie Sazehn has compiled a list of organizations in our state of people/organizations
and their involvement in helping survivors.

Thanks for all you are doing to help others!

Blessings,
Sharon Rikard

GIUFFRE005612
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 9 of 35

From: Virginia Giuffre

To: [email protected]
Subject: Victims Refuse Silence
Date: Wednesday, March 18, 2015 12:19:06 PM

Hi Sharon,

This is Virginia, we spoke earlier and I just wanted to say thank you for your time and what your doing
to help the victims in your area. The mentality has to be changed!! Good luck!!

Kindest Regards,
Virginia Roberts

Sent from my iPhone

GIUFFRE005613
CONFIDENTIAL
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 10 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards and Cassell re attorney defense/commo
1 2/12/2015 6:14 Virginia Giuffre [email protected] impressions and legal advice relating to deposition testimony n interest Withheld 3 msg
AC Privilege and
Work
[email protected],br Product/joint
[email protected],robie defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work
3 2/16/2015 15:37 Virginia Giuffre [email protected] information provided by client to assist in legal advice product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work
4 2/16/2015 16:15 Sigrid McCawley [email protected] information provided by client to assist in legal advice product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work
5 2/16/2015 16:24 Virginia Giuffre [email protected] information provided by client to assist in legal advice product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work
6 2/16/2015 16:24 Sigrid McCawley [email protected] information provided by client to assist in legal advice product Withheld 2 msg
AC Privilege and
[email protected],bra Work
[email protected],cassell Product/joint
[email protected],robiejenna defense/commo
7 2/21/2015 16:45 Sigrid McCawley [email protected] [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 11 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
defense/commo
8 2/21/2015 16:58 Virginia Giuffre [email protected] Discussion of evidence among client and attorney n interest Withheld 2 msg
AC Privilege and
Work
[email protected],cassellp@l Product/joint
aw.utah.edu,[email protected] defense/commo
9 2/21/2015 17:05 Brad Edwards [email protected] om Discussion of evidence among client and attorneys n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
10 2/21/2015 17:10 Sigrid McCawley [email protected] Discussion of evidence among client and attorney n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
defense/commo
11 2/21/2015 17:16 Virginia Giuffre [email protected] Discussion of evidence among client and attorneys n interest Withheld 3 msg
AC Privilege and
Work
[email protected],brad@pat Product/joint
htojustice.com,[email protected]. defense/commo
12 2/23/2015 14:21 Sigrid McCawley [email protected] edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg
AC Privilege and
Work
Product/joint
[email protected],ro [email protected],cassellp@ defense/commo
13 2/23/2015 14:29 [email protected] [email protected] law.utah.edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg
AC Privilege and
Work
[email protected],brad@pat Product/joint
htojustice.com,[email protected]. defense/commo
14 2/23/2015 16:01 Virginia Giuffre [email protected] edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 12 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
Email chain with McCawley, Giuffre, and Paralegals re seeking defense/commo
15 2/24/2015 17:51 Sigrid McCawley [email protected] information to assist in legal advice, with attachment n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
defense/commo
16 Attached case research n interest Withheld 14 rtf
AC Privilege and
Work
Product/joint
Email chain with Giuffre, McCawley and legal assistant re legal defense/commo
17 2/26/2015 12:59 Virginia Giuffre [email protected] document, with attachment n interest Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
18 Attached draft legal document n interest Withheld 1 jfif
AC Privilege and
Work
Product/joint
Email with Giuffre, McCawley, Edwards and Henderson re defense/commo
19 2/28/2015 17:47 Virginia Giuffre [email protected] discussion of draft statement n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
[email protected],brad@pa Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
20 3/13/2015 17:29 Stan Pottinger [email protected] thtojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley and Pottinger re defense/commo
21 3/13/2015 17:49 Virginia Giuffre [email protected] legal advice on media issues n interest Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 13 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
[email protected],brad@pa Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
22 3/13/2015 17:56 [email protected] [email protected] thtojustice.com Pottinger re legal advice on media issues n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
[email protected],robi Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
23 3/13/2015 18:00 Brad Edwards [email protected] [email protected] Pottinger re legal advice on media issues n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
24 3/13/2015 18:24 Virginia Giuffre [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
25 3/13/2015 18:25 Virginia Giuffre [email protected] Pottinger re legal advice on media issues n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
[email protected],StanPotti Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
26 3/13/2015 21:53 Virginia Giuffre [email protected] [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
27 3/13/2015 23:38 Brad Edwards [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
28 3/13/2015 23:40 Virginia Giuffre [email protected] Pottinger re legal advice on media issues n interest Withheld 4 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 14 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
[email protected],br defense/commo
[email protected],stan Providing information to assist in legal advice re potential legal n interest/work
29 3/17/2015 15:20 Virginia Giuffre [email protected] action, with attachments product Withheld 1 msg

Attorney
Client/joint
[email protected],br defense/commo
[email protected],robie Email chain with Giuffre, Edwards, Pottinger and McCawley re n interest/work
30 3/17/2015 18:40 Stan [email protected] legal advice related to VRS product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Pottinger and McCawley re n interest/work
31 3/17/2015 19:42 Virginia Giuffre [email protected] legal advice related to VRS product Withheld 1 msg

Attorney
Client/joint
[email protected],ro defense/commo
[email protected],stan [email protected],brittany@path Email chain with Giuffre, Edwards, Henderson, Pottinger, n interest/work
32 3/20/2015 15:43 Sigrid McCawley [email protected] tojustice.com McCawley and BSF staff re legal advice related to VRS product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
33 3/20/2015 15:57 Sigrid McCawley [email protected] Providing legal advice re potential deposition product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
34 3/24/2015 21:19 Sigrid McCawley [email protected] [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 15 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
35 3/24/2015 21:21 Virginia Giuffre [email protected] [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
[email protected],ro Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
36 3/24/2015 21:36 Andres Ortiz [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
37 3/24/2015 22:21 Virginia Giuffre [email protected] BSF staff re legal advice related to VRS product Withheld 3 msg

Attorney
[email protected],StanPotti Client/joint
[email protected],brad@pathtojustice defense/commo
.com,[email protected],e Email chain with Giuffre, Edwards, Henderson, Pottinger, n interest/work
38 3/26/2015 2:00 Sigrid McCawley [email protected] [email protected] McCawley and BSF staff re legal advice related to VRS product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
39 3/26/2015 2:21 Virginia Giuffre [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
40 3/26/2015 2:22 Sigrid McCawley [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 16 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
41 3/26/2015 3:00 Virginia Giuffre [email protected] BSF staff re legal advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Giuffre conveying information sought by attorney to assist in n interest/work
42 4/1/2015 21:32 Virginia Giuffre [email protected] legal advice with attachments product Withheld 1 msg

Attorney
Client/joint
defense/commo
Providing draft legal document for client review, with n interest/work
43 4/2/2015 7:01 Brittany Henderson [email protected] [email protected] attachment product Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
44 Attached Draft legal document n interest Withheld 15 pdf
AC Privilege and
Work
Product/joint
[email protected],eperez@ Email chain with Giuffre, Henderson, Edwards and legal defense/commo
45 4/3/2015 15:32 Brittany Henderson [email protected] BSFLLP.com assistant re legal document, with attachment n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
46 Attached draft legal document n interest 15 pdf

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 17 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
n interest/work
47 4/8/2015 20:34 Virginia Giuffre [email protected] Seeking legal advice related to VRS product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re advice re legal filings, n interest/work
48 4/9/2015 3:23 Virginia Giuffre [email protected] with attachments product Withheld 2 msg

Attorney
Client/joint
[email protected],bra defense/commo
[email protected],robiej [email protected],sperki Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
49 4/9/2015 7:16 Sigrid McCawley [email protected] [email protected] BSF staff re legal advice re media issues product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, and McCawley re legal advice n interest/work
50 4/9/2015 9:26 Brad Edwards [email protected] [email protected] re media issues product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re legal advice re media n interest/work
51 4/9/2015 9:33 Sigrid McCawley [email protected] issues product Withheld 2 msg
AC Privilege and
Work
Product/joint
Conveying legal advice re draft legal documents to client, with defense/commo
52 4/9/2015 12:46 Sigrid McCawley [email protected] attachments n interest Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 18 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
Conveying legal advice re draft legal documents to client, with defense/commo
53 attachments n interest Withheld 14 docx
AC Privilege and
Work
Product/joint
Conveying legal advice re draft legal documents to client, with defense/commo
54 attachments n interest Withheld 12 docx
AC Privilege and
Work
Product/joint
Conveying legal advice re draft legal documents to client, with defense/commo
55 attachments n interest Withheld 2 docx

Attorney
Client/joint
defense/commo
[email protected],brad@pat n interest/work
56 4/10/2015 14:59 Sigrid McCawley [email protected] htojustice.com Providing legal advice re media issues product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
57 4/10/2015 15:37 Virginia Giuffre [email protected] Regarding legal advice re media issues product Withheld 1 msg
AC Privilege and
Work
[email protected],brad@pat Email chain with Giuffre, McCawley, Henderson, Edwards, Product/joint
htojustice.com,brittany@pathtojus Pottinger and legal assistant re legal documents, with defense/commo
58 4/10/2015 17:31 Sigrid McCawley [email protected] tice.com,[email protected] attachments n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
59 Attached draft legal document n interest Withheld 3 pdf

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 19 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
defense/commo
60 Attached draft legal document n interest Withheld 21 pdf

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
61 4/10/2015 17:40 Virginia Giuffre [email protected] advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
62 4/10/2015 19:10 Virginia Giuffre [email protected] advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
63 4/10/2015 19:28 Sigrid McCawley [email protected] advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
64 4/10/2015 19:33 Virginia Giuffre [email protected] advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
65 4/10/2015 20:03 Sigrid McCawley [email protected] advice related to VRS product Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 20 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
66 4/10/2015 20:04 Virginia Giuffre [email protected] advice related to VRS product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
67 4/10/2015 20:04 Sigrid McCawley [email protected] advice related to VRS product Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley legal assistant re seeking Product/joint
and providing information sought by attorney to assist in defense/commo
68 4/10/2015 23:46 Virginia Giuffre [email protected] providing legal advice, with attachments n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
[email protected],brad@pat Email chain with Giuffre, Pottinger, Edwards and McCawley re defense/commo
69 4/13/2015 13:52 Sigrid McCawley [email protected] htojustice.com legal advice regarding potential public statements n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Pottinger, Edwards and McCawley re defense/commo
70 4/13/2015 13:56 Virginia Giuffre [email protected] legal advice regarding media issues n interest Withheld 3 msg

Attorney
[email protected],bri Client/joint
[email protected],ro defense/commo
[email protected],stan n interest/work
71 4/14/2015 23:38 Brad Edwards [email protected] Providing legal advice related to VRS product Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 21 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re legal advice regarding n interest/work
72 4/16/2015 11:14 Virginia Giuffre [email protected] media issues product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re legal advice regarding n interest/work
73 4/16/2015 11:47 Sigrid McCawley [email protected] media issues product Withheld 2 msg

Attorney
Client/joint
defense/commo
n interest/work
74 4/24/2015 19:22 Sigrid McCawley [email protected] Providing legal advice re records retention, with attachments product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
75 Attached letter providing legal advice re document retention product Withheld 2 pdf

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re legal advice regarding n interest/work
76 4/24/2015 19:59 Virginia Giuffre [email protected] potential deposition product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
77 4/27/2015 21:20 Brad Edwards [email protected] [email protected] Seeking information to assist in providing legal advice product Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 22 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
[email protected],brad@pa Product/joint
thtojustice.com,robiejennag@y7m defense/commo
78 4/30/2015 6:42 Brittany Henderson [email protected] ail.com Legal documents provided to assist in providing legal advice n interest Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre, Henderson and paralegal re seeking n interest/work
79 4/30/2015 7:02 Brittany Henderson [email protected] and providing information to assist in providing legal advice product Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, Henderson, Edwards, McCawley and Product/joint
legal assistant re seeking information to assist in providing legal defense/commo
80 4/30/2015 7:05 Virginia Giuffre [email protected] advice n interest Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, Henderson, Edwards, McCawley and Product/joint
legal assistant re seeking information to assist in providing legal defense/commo
81 5/4/2015 20:04 Virginia Giuffre [email protected] advice, with attachment n interest Withheld 2 msg
AC Privilege and
Work
Email chain with McCawley, Giuffre, Edwards, Pottinger, Product/joint
Henderson and Paralegal re seeking and providing information defense/commo
82 5/11/2015 18:20 Sigrid McCawley [email protected] [email protected] to assist in legal advice, with attachments n interest Withheld 1 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, Edwards, Pottinger and Product/joint
Paralegal re seeking information to assist in providing legal defense/commo
83 5/11/2015 18:34 Virginia Giuffre [email protected] advice re potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre and McCawley re case research, with defense/commo
84 5/11/2015 18:40 Sigrid McCawley [email protected] attachment n interest Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 23 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
[email protected],ro Providing and seeking information to assist in legal advice re defense/commo
85 5/11/2015 18:45 Sigrid McCawley [email protected] potential legal action, with attachment n interest Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re seeking information n interest/work
86 5/11/2015 18:47 Virginia Giuffre [email protected] to assist in providing legal advice re potential litigation product Withheld 1 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, Edwards, Pottinger and Product/joint
Paralegal re seeking information to assist in providing legal defense/commo
87 5/11/2015 18:56 Virginia Giuffre [email protected] advice re potential litigation n interest Withheld 2 msg

Attorney
Client/joint
defense/commo
n interest/work
88 5/17/2015 22:37 Sigrid McCawley [email protected] Providing litigation documents to client, with attachments product Withheld 3 msg
AC Privilege and
Work
Product/joint
defense/commo
89 Attached draft legal agreement n interest Withheld 10 pdf

Attorney
Client/joint
defense/commo
n interest/work
90 5/17/2015 22:40 Sigrid McCawley [email protected] Providing legal advice re legal agreement, with attachment product Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
91 5/18/2015 18:40 Virginia Giuffre [email protected] Discussion of confidential agreement, with attachments n interest Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 24 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
n interest/work
92 Attached confidential agreement page product Withheld 1 jfif

Attorney
Client/joint
defense/commo
n interest/work
93 Attached confidential agreement page product Withheld 1 jfif

Attorney
Client/joint
defense/commo
n interest/work
94 6/5/2015 19:16 Sigrid McCawley [email protected] Conveying attorney mental impression regarding hearing product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re attorney mental n interest/work
95 6/6/2015 17:20 Virginia Giuffre [email protected] impression regarding hearing product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
96 6/25/2015 2:26 Sigrid McCawley [email protected] Providing advice re status and strategy of ongoing legal matters product Withheld 6 msg

Attorney
Client/joint
defense/commo
Discussion with S. McCawley regarding file related to n interest/work
97 7/17/2015 14:19 Sigrid McCawley [email protected] [email protected] representation by B. Josefsberg product Withheld 4 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 25 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
Providing information to assist in legal advice re potential n interest/work
98 7/27/2015 21:53 Virginia Giuffre [email protected] litigation product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
99 7/29/2015 19:45 Sigrid McCawley [email protected] [email protected] Conveying legal advice on media issues product Withheld 1 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, McCawley and paralegals re defense/commo
100 8/5/2015 19:51 Sigrid McCawley [email protected] information sought to assist in providing legal advice n interest Withheld 1 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, legal intern and paralegal Product/joint
re seeking information to assist in providing legal advice re defense/commo
101 8/6/2015 2:14 Sigrid McCawley [email protected] potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, legal intern, Edwards and Product/joint
paralegal re seeking information to assist in providing legal defense/commo
102 8/6/2015 2:45 Sigrid McCawley [email protected] [email protected] advice re potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, legal intern and paralegal Product/joint
re seeking information to assist in providing legal advice re defense/commo
103 8/6/2015 2:55 Virginia Giuffre [email protected] potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
[email protected],brad@pa Email chain with McCawley, Giuffre, and Paralegals re seeking defense/commo
104 8/6/2015 3:48 Sigrid McCawley [email protected] thtojustice.com information to assist in legal advice, with attachments n interest Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 26 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Email chain with Giuffre, McCawley, legal intern and paralegal Product/joint
re seeking information to assist in providing legal advice re defense/commo
105 8/6/2015 3:51 Virginia Giuffre [email protected] potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
[email protected],brittany@ Providing and seeking information to assist in legal advice re defense/commo
106 9/1/2015 18:54 Sigrid McCawley [email protected] pathtojustice.com potential legal action, with attachment n interest Withheld 2 msg

Attorney
Client/joint
[email protected],sm defense/commo
[email protected],stanpot Providing information sought by attorneys to provide legal n interest/work
107 9/7/2015 18:24 Virginia Giuffre [email protected] advice, with attachment product Withheld 1 msg
AC Privilege and
Work
Product/joint
Attached Information sought by attorneys to provide legal defense/commo
108 advice n interest Withheld 4 docx

Attorney
Client/joint
[email protected],ro Email chain with Giuffre, Edwards, Pottinger and McCawley re defense/commo
[email protected],stan collection of information to assist in providing legal advice re n interest/work
109 9/7/2015 18:58 Sigrid McCawley [email protected] potential litigation product Withheld 1 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re draft legal document n interest/work
110 9/15/2015 21:58 Virginia Giuffre [email protected] relating to litigation product Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 27 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re draft legal document n interest/work
111 9/15/2015 22:04 Sigrid McCawley [email protected] relating to litigation product Withheld 2 msg

Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re draft legal document n interest/work
112 9/15/2015 22:07 Virginia Giuffre [email protected] relating to litigation product Withheld 2 msg

Attorney
Client/joint
defense/commo
n interest/work
113 9/20/2015 12:15 Sigrid McCawley [email protected] [email protected] Conveying information about potential legal action. product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
114 9/20/2015 14:47 Virginia Giuffre [email protected] Email chain with Giuffre and McCawley re potential legal action. product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
115 9/20/2015 19:16 Virginia Giuffre [email protected] Email chain with Giuffre and McCawley re potential legal action. product Withheld 1 msg

Attorney
Client/joint
defense/commo
n interest/work
116 9/20/2015 19:29 Sigrid McCawley [email protected] Email chain with Giuffre and McCawley re potential legal action. product Withheld 2 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 28 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
n interest/work
117 9/20/2015 19:30 Virginia Giuffre [email protected] Email chain with Giuffre and McCawley re potential legal action. product Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
118 9/21/2015 14:48 Sigrid McCawley [email protected] Communication re initiation of lawsuit, with attachments n interest Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
119 Attached draft legal document relating to litigation n interest Withheld 12 pdf

Attorney
Client/joint
defense/commo
n interest/work
120 Attached draft legal document relating to litigation product Withheld 2 pdf

Attorney
Client/joint
defense/commo
n interest/work
121 Attached draft legal document relating to litigation product Withheld 2 pdf

Attorney
Client/joint
defense/commo
n interest/work
122 Attached draft legal document relating to litigation product Withheld 3 pdf

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 29 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Attorney
Client/joint
defense/commo
n interest/work
123 9/21/2015 14:51 Virginia Giuffre [email protected] Email chain with Giuffre and McCawley re potential legal action. product Withheld 1 msg

Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly burdensome.
Plaintiff contends that requests targeting such privileged
information are not reasonably calculated to lead to the
discovery of admissible evidence, are not important to resolving
the issues, are not relevant to any party’s claim or defense, are
not proportional to the needs of the case, and creates a heavy
burden on Plaintiff that outweighs its benefit. Therefore,
Plaintiff has employed categorical logging pursuant to Local Civil
Rule 26.2(c). Correspondence re: Jane Doe #1 and Jane Doe #2
Virginia Giuffre, Brad
v. United States ("CVRA case"), Case no. 08-80736-CIV-Marra,
Edwards, Paul Cassell,
pending in the Southern District of Florida. Documents withheld
Brittany Henderson (and Virginia Giuffre, Brad
pursuant to the privileges asserted included communications
other , Sigrid McCawley, Edwards, Paul Cassell,
from Ms. Giuffre to the attorneys listed seeking legal advice
Meredith Schultz, David Brittany Henderson, Sigrid
related to the CVRA case, communications from the attorneys
Boies, Jack Scarola, Stan McCawley, Meredith
to Ms. Giuffre giving legal advice or giving attorney mental
Pottinger, Ellen Schultz, David Boies, Jack
impressions related to the CVRA case, communications sending
Brockman, Legal Scarola, Stan Pottinger, Ellen
or attaching attorney work product related to the CVRA case,
Assistants, Professionals Brockman, Legal Assistants, AC Privilege and Approx. 1.3K
and/or communications sending or attaching client revisions to
retained by attorneys to Professionals retained by Work docs
attorney work product related to the CVRA case, and
Emails, letters, and aid in the rendition of attorneys to aid in the Product/joint overlapping
communications re evidence.
other communications legal advice and rendition of legal advice and defense/commo with other
125 from 2011 - Present representation representation n interest Withheld cases

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 30 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly burdensome.
Plaintiff contends that requests targeting such privileged
information are not reasonably calculated to lead to the
discovery of admissible evidence, are not important to resolving
the issues, are not relevant to any party’s claim or defense, are
not proportional to the needs of the case, and creates a heavy
burden on Plaintiff that outweighs its benefit. Therefore,
Plaintiff has employed categorical logging pursuant to Local Civil
Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Giuffre v. Maxwell (“Maxwell
Edwards, Paul Cassell, case”), 15-cv-07433-RWS, pending in the Southern District of
Brittany Henderson, Virginia Giuffre, Brad New York, since the date of filing, September 21, 2015.
Sigrid McCawley, Edwards, Paul Cassell, Documents withheld pursuant to the privileges asserted
Meredith Schultz, David Brittany Henderson, Sigrid included communications from Ms. Giuffre to the attorneys
Boies, Stephen Zach, McCawley, Meredith listed seeking legal advice related to the Maxwell case,
Stan Pottinger, Ellen Schultz, David Boies, communications from the attorneys to Ms. Giuffre giving legal
Brockman, Legal Stephen Zach, Stan advice or giving attorney mental impressions related to the
Assistants, Professionals Pottinger, Ellen Brockman, Maxwell case, communications sending or attaching attorney AC Privilege and Approx. 1.3K
retained by attorneys to Legal Assistants, work product related to the Maxwell case, and/or Work docs
Emails, letters, and aid in the rendition of Professionals retained by communications sending or attaching client revisions to Product/joint overlapping
other communications legal advice and attorneys to aid in the attorney work product related to the Maxwell case, and defense/commo with other
126 from 9/21/15 - Present representation rendition of legal advice and communications re evidence. n interest Withheld cases

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 31 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly burdensome.
Plaintiff contends that requests targeting such privileged
information are not reasonably calculated to lead to the
discovery of admissible evidence, are not important to resolving
the issues, are not relevant to any party’s claim or defense, are
not proportional to the needs of the case, and creates a heavy
burden on Plaintiff that outweighs its benefit. Therefore,
Plaintiff has employed categorical logging pursuant to Local Civil
Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Bradley Edwards and Paul
Edwards, Paul Cassell, Cassell v. Alan Dershowitz (“Dershowitz case”), Case no. 15-
Brittany Henderson, Virginia Giuffre, Brad 000072, pending in the Seventeenth Judicial Circuit, Broward
Sigrid McCawley, Edwards, Paul Cassell, County, Florida. Documents withheld pursuant to the privileges
Meredith Schultz, David Brittany Henderson, Sigrid asserted included communications from Ms. Giuffre to the
Boies, Stephen Zach, McCawley, Meredith attorneys listed seeking legal advice related to the Dershowitz
Stan Pottinger, Ellen Schultz, David Boies, case, communications from the attorneys to Ms. Giuffre giving
Brockman, Legal Stephen Zach, Stan legal advice or giving attorney mental impressions related to the
Assistants, Professionals Pottinger, Ellen Brockman, Dershowitz case, communications sending or attaching attorney AC Privilege and Approx. 1.3K
Emails, letters, and retained by attorneys to Legal Assistants, work product related to the Dershowitz case, and/or Work docs
other communications aid in the rendition of Professionals retained by communications sending or attaching client revisions to Product/joint overlapping
from January 2015 - legal advice and attorneys to aid in the attorney work product related to the Dershowitz case, and defense/commo with other
127 Present representation rendition of legal advice and communications re evidence. n interest Withheld cases

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 32 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly burdensome.
Plaintiff contends that requests targeting such privileged
information are not reasonably calculated to lead to the
discovery of admissible evidence, are not important to resolving
the issues, are not relevant to any party’s claim or defense, are
not proportional to the needs of the case, and creates a heavy
burden on Plaintiff that outweighs its benefit. Therefore,
Plaintiff has employed categorical logging pursuant to Local Civil
Rule 26.2(c). Correspondence re: Jane Doe No. 102 v. Jeffrey
Epstein (“Epstein case”), Case No. 09-80656-CIV-Marra/Johnson
(Southern District of Florida). Documents withheld pursuant to
the privileges asserted included communications from Ms.
Virginia Giuffre, Bob Virginia Giuffre, Bob Giuffre to the attorneys listed seeking legal advice related to the
Josefsberg, Katherine W. Josefsberg, Katherine W. Epstein case, communications from the attorneys to Ms. Giuffre
Ezell, Amy Ederi, other Ezell, Amy Ederi, other giving legal advice or giving attorney mental impressions related
Podhurst attorneys, Podhurst attorneys, Legal to the Epstein case, communications sending or attaching AC Privilege and Approx. 1.3K
Legal Assistants, and Assistants, and Professionals attorney work product related to the Epstein case, and/or Work docs
Emails, letters, and Professionals retained by retained by attorneys to aid communications sending or attaching client revisions to Product/joint overlapping
other communications attorneys to aid in the in the rendition of legal attorney work product related to the Epstein case, and defense/commo with other
128 from 2009 - Present rendition of legal advice advice communications re evidence. n interest Withheld cases
Email chain with Giuffre and McCawley seeking information to
129 6/10/2015 Virginia Giuffre [email protected] assist with attorney advice. Attorney Client Withheld 2 msg

Letter from Virginia Giuffre to David Boies conveying requested AC Privilege and
130 information to assist in providing legal advice. Work Product Withheld 26 pdf
[email protected],brad@pa
thtojustice.com,robiejennag@y7m AC Privilege and
131 4/30/2015 Brittany Henderson [email protected] ail.com Communication re VRS registrations Work Product Withheld 1 msg
[email protected],brad@pa
thtojustice.com,[email protected], Email chain with McCawley, Edwards, Garvin, Henderson, AC Privilege and
132 4/29/2015 Andres Ortiz [email protected] [email protected] Giuffre and BSF staff re legal advice re VRS communications. Work Product Withheld 1 msg
[email protected],brad@pa
thtojustice.com,[email protected], AC Privilege and
133 4/29/2015 brittany henderson [email protected] [email protected] Communication re legal advice re VRS communications. Work Product Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 33 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

[email protected],brittany Email chain with Cassell, McCawley, Edwards, Garvin, Beloof,

@pathtojustice.com,eperez@BSFLL Henderson, Giuffre and BSF staff re legal advice re VRS AC Privilege and
134 4/17/2015 Paul Cassell [email protected] P.com,[email protected] registrations. Work Product Withheld 5 msg
[email protected],eperez Email chain with Cassell, McCawley, Edwards, Garvin, Beloof,
[email protected],cas @BSFLLP.com,robiejennag@y7mail Henderson, Giuffre and BSF staff re legal advice re VRS AC Privilege and
135 4/17/2015 Sigrid McCawley [email protected] .com registrations. Work Product Withheld 4 msg

[email protected],brittany Email chain with Cassell, McCawley, Edwards, Garvin, Beloof,

@pathtojustice.com,eperez@BSFLL Henderson, Giuffre and BSF staff re legal advice re VRS AC Privilege and
136 4/17/2015 Brad Edwards [email protected] P.com,[email protected] registrations. Work Product Withheld 4 msg

137 2/26/2015 Sigrid McCawley [email protected] Email chain with Giuffre and McCawley re non-testifying expert. Attorney Client Withheld 1 msg
138 2/26/2015 Sigrid McCawley [email protected] Communication re non-testifying expert. Attorney Client Withheld 1 msg
Email chain with Giuffre, McCawley, Edwards, Pottinger and BSF
139 2/11/2016 Sigrid McCawley [email protected] staff re media communications. Attorney Client Redacted 3 msg
[email protected],robi [email protected],brad@patht Email chain with Giuffre, McCawley, Edwards, Pottinger and BSF
140 2/11/2016 Sigrid McCawley [email protected] ojustice.com staff re media communications. Attorney Client Redacted 3 msg
[email protected],Smccawley
@BSFLLP.com,brad@pathtojustice. Email chain with Giuffre, McCawley, Edwards, Pottinger and BSF
141 2/11/2016 [email protected] [email protected] com staff re media communications. Attorney Client Redacted 3 msg
Email chain with Giuffre and Pottinger re media
142 2/9/2016 [email protected] [email protected] communications. Attorney Client Redacted 2 msg

Letter from Virginia Giuffre to David Boies conveying requested AC Privilege and
143 information to assist in providing legal advice. Work Product Withheld 26 pdf

Letter from Virginia Giuffre to David Boies conveying requested AC Privilege and
144 information to assist in providing legal advice. Work Product Withheld 23 docx

145 6/10/2015 Virginia Giuffre [email protected] Email chain with Giuffre and McCawley re ongoing litigation. Attorney Client Withheld 2 msg
[email protected],bh699@n
ova.edu,[email protected],g Email chain with Henderson, McCawey, Edwards, Garvin and
146 4/29/2015 Virginia Giuffre [email protected] [email protected] BSF staff re VRS communications. Attorney Client Withheld 2 msg
Email chain with Boylan, Giuffre, McCawley, and BSF staff re
147 4/10/2015 Virginia Giuffre [email protected] legal advice re VRS registrations. Attorney Client Withheld 2 msg
148 2/26/2015 Virginia Giuffre [email protected] Email confirming legal advice re non-testifying expert. Attorney Client Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 34 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
Email chain with Giuffre and Pottinger re media
149 2/11/2015 Virginia Giuffre [email protected] communications Attorney Client Redacted 3 msg
Email chain with Giuffre, McCawley, Pottinger and BSF staff re
150 2/11/2015 Virginia Giuffre [email protected] media communications. Attorney Client Redacted 3 msg

AC Privilege and
151 1/13/2015 Virginia Giuffre [email protected] Email chain with Pottinger and Giuffre re anticipated litigation. Work Product Withheld 1 msg

Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly
burdensome. Plaintiff contends that requests targeting
such privileged information are not reasonably calculated
to lead to the discovery of admissible evidence, are not
important to resolving the issues, are not relevant to any
party’s claim or defense, are not proportional to the
needs of the case, and creates a heavy burden on Plaintiff
that outweighs its benefit. Therefore, Plaintiff has
employed categorical logging pursuant to Local Civil Rule
26.2(c). This categorical entry is regarding correspondence
re potential legal action against entities and individuals.
Virginia Giuffre, Brad Documents withheld pursuant to the privileges asserted
Edwards, Paul Cassell, Virginia Giuffre, Brad included communications from Ms. Giuffre to the
Brittany Henderson, Edwards, Paul Cassell, attorneys listed seeking legal advice related to potential
Sigrid McCawley, Brittany Henderson, Sigrid law suits, communications from the attorneys to Ms.
Meredith Schultz, David McCawley, Meredith
Giuffre giving legal advice or giving attorney mental
Boies, Stephen Zach, Schultz, David Boies,
impressions related to the law suits, communications
Stan Pottinger, Ellen Stephen Zach, Stan
Brockman, Legal Pottinger, Ellen Brockman, sending or attaching attorney work product related to AC Privilege and
Emails, letters, and Assistants, Professionals Legal Assistants, potential lawsuits, and/or communications sending or Work Approx. 1.3K
other communications retained by attorneys to Professionals retained by attaching client revisions to attorney work product related Product/joint overlapping
from January 2015 - aid in the rendition of attorneys to aid in the to potential lawsuits, and communications re evidence. defense/commo with other
152 Present legal advice rendition of legal advice n interest Withheld cases

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
 Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 35 of 35

Log Privilege Doc

ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type

Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly
burdensome. Plaintiff contends that requests targeting
such privileged information are not reasonably calculated
to lead to the discovery of admissible evidence, are not
important to resolving the issues, are not relevant to any
party’s claim or defense, are not proportional to the
needs of the case, and creates a heavy burden on Plaintiff
The law enforcement that outweighs its benefit. Therefore, Plaintiff has
entity, Virginia Giuffre, The law enforcement entity, employed categorical logging pursuant to Local Civil Rule
David Boies, Stan Virginia Giuffre, David Boies, 26.2(c). This categorical entry is regarding correspondence
Pottinger, Sigrid Stan Pottinger, Sigrid
re the currently ongoing criminal investigation of
Email and letter McCawley, Paul Cassell, McCawley, Paul Cassell, Brad approx. 57
Defendant and others.
153 communications Brad Edwards Edwards Public Interest Withheld documents

Email chain discussing efforts to obtain assistance from FBI AC Privilege and
154 8/27/2014 Virginia Giuffre Brad Edwards agent in obtaining information to assist in providing legal advice. Work Product Withheld 1 msg

Email chain discussing efforts to obtain assistance from FBI AC Privilege and
155 8/27/2014 Virginia Giuffre Brad Edwards agent in obtaining information to assist in providing legal advice. Work Product Withheld 1 msg

Email chain discussing efforts to obtain assistance from FBI AC Privilege and
156 8/27/2014 Virginia Giuffre Brad Edwards agent in obtaining information to assist in providing legal advice. Work Product Withheld 1 msg

Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016