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Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 4 of 11 Search Terms On June 20, 2016, this Court Ordered Defendant is ordered to collect all ESI by imaging her computers and collecting all email and text messages on any devices in Defendant's possession or to which she has access that Defendant used between the period of 2002 to present. Defendant is further directed to run mutually- agreed upon search terms related to Plaintiff's requests for production over the aforementioned ESI and produce responsive documents within 21 days of distribution of this opinion. On June 30, 2016, Plaintiffs counsel provided a list of 368 search terms. See Menninger Decl. Ex. A. Plaintiff's proposal included astoundingly broad terms, to wit: e “Terramar” -- both the name of Ms. Maxwell’s non-profit and e “max*” — part of Ms. Maxwell’s last name, as well as all of her paternal relatives’ names. e “GM” -- Ms. Maxwell’s initials. e common words such as “hotel,” suite, villa, “bed,” “bath,” and “lingerie.” Plaintiffs originally proposed search terms would literally hit on every single email from either Ms. Maxwell’s personal or her business email addresses, as well as every document related to the non-profit, The Terramar Project, that Ms. Maxwell founded and runs. Plaintiffs originally proposed terms also failed to relate to the actual discovery requests upon which they were to be based. For search terms 124-341, Plaintiff took her own Rule 26 disclosures, separated the first and last names of each witness she had identified, and asked that they be searched individually (along with “wild card character searches’’), even though, as described above there were only 13 specific witnesses for whom Plaintiff had actually sought all communications. For example, Plaintiff wanted the names Bill, Mark, Phil, Bob, Mike and Todd