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Case 1:15-cv-07433-LAP Document 1327-2 Filed 01/05/24 Page 2 of 13 BOI|IE S, SC AHINCILEER € FLEXNER LEP 40! EAST LAS OLAS BOULEVARD * SUITE |200* FORT LAUDERDALE, FL 3330!-221\* PH. 954.356.0011! * FAX 954.356.0022 Meredith L. Schultz, Esq. E-mail: mschultz@bsfllp.com June 30, 2016 ViA E-MAIL Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Imenninger@hmtlaw.com Re: Guiffre v. Maxwell Case No. 15-cv-07433-RWS Dear Laura, I write pursuant to this Court’s June 20, 2016, Order regarding search and production from Defendant’s electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell’s various email accounts, including but not limited to the following: (1) GMax1@ellmax.com (and any other accounts at ellmax.com); (2) gmax1@mindspring.com (and any other accounts at mindspring.com); (3) any of Ms. Maxwell’s email account associated with The Terramar Project (including any account ending in @theterramarproject.org); and (4) any other email accounts either used in the past, or currently in use. Additionally, please use FileSeek software (or a functional equivalent) to retrieve any data, including electronic documents (such as Word documents; PDFs; Excel sheets; etc.), from Ms. Maxwell’s devices, including personal computers, work computers, any tablets, and any phones. This includes any cloud storage accounts. Please confirm that you have imaged Ms. Maxwell’s hard drives and other devices. Once you have gathered that data onto a platform (such as Summation or its functional equivalent), please run the below search terms. Since the Court ordered us to negotiate the search terms, please let me know if you think additional terms would be appropriate or whether you object to any terms, and your basis thereof. When applying the search terms, the search terms need to “hit” on documents even if the terms are embedded within other words. So, for example, the term “acuity” would yield a hit on the document, even if the word in the document is “acuityreputatoin.” To return a hit on those WWW.BSFLLP.COM