Case 9:08-cv-80736-KAM Document 265-2 Entered on FLSD Docket 10/20/2014 Page 1 of 68 Ncc to Objections PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS (linking to Victims' Motion to Compel Production of Docments that Are Not Privileged) Objection General Objection., -Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections Final Decision Exempted from Privilege Qualified Privilege Overridden By the Victims' Need for the Documents Investigative Privilege Not Within the Scope of the Investigative Privilege Privilege Not Properly Invoked Qualified Privilege Overridden By the Victims' Need for the Documents Work Product Doctrine No Work Product Doctrine in the Context of a Claim Against Public Prosecutors Qualified Privilege Overridden By the Victims' Need for the Documents Work Production Privilege Does No Apply When the Attorney's Conduct is at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(e)(3XE) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand Jury Materials Grand Jury Materials Can Be Severed from Other Materials Abbreviation Inadequate Log No Factual Underpinnings Waiver Crime-Fraud-Misconduct Factual Materials Not in Anticipation of litigation Ordinary Government Communication No Attorney-Client Relationship Final Decision Overriding Need Not Within Investigative Privilege Improper Invocation Overriding Need Claims Against Public Prosecutor Overriding Need Attorney Conduct at Issue Court Authorized Under 6(e)(3)(E) Court Inherent Power to Release Proper Victim's Petitio