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Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 8 of 11 with anyone that Plaintiff believed was or might be a witness, although no discovery requests called for such communications. Consequently, during the conferral call, Plaintiffs counsel agreed to withdraw the vast majority of objectionable terms. She also agreed to supply a list of witnesses who she believes truly might in some way relate to “massages” and submit that to defense counsel. See Menninger Decl., Ex. D. Plaintiff thereafter provided an additional 66 terms, all names, which Plaintiff claims she has some reason to believe are “related to massages.” Menninger Decl. Ex. E. Ms. Maxwell does not believe that searching these terms is appropriate, because, for example, the names include a journalist (Vicky Ward), Mr. Epstein’s elderly secretary, and various business people that form part of Plaintiff's false narrative regarding her “sex trafficking,” and searching for names in the absence of a topic (i.e., massages) is well-beyond the actual requests for production. Nevertheless, Ms. Maxwell did in fact run all of the names proposed by Plaintiff against the forensic images of Ms. Maxwell’s computers and her email accounts. The second search yielded 284 additional documents, each of which were reviewed individually by counsel for Ms. Maxwell. Menninger Decl. paragraph 8 and 9. Again, not a single responsive, non-privileged document was located; the vast majority of documents were pleadings from this case. The complete list of terms run against Ms. Maxwell’s electronic devices and email accounts as agreed to by the parties is attached. Menninger Decl., Ex. F. Compliance with the Court’s Order to run agreed to terms was completed by July 21, 2016, prior to Ms. Maxwell’s second deposition.