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Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 7 of 11 in anticipation of a potential lawsuit in the United Kingdom. See Menninger Decl. at paragraph 8. The documents concerning Mr. Barden have been added to the privilege log. Id. Upon receipt of Plaintiff's Response to the Letter Motion to Strike for Plaintiff's failure to confer, the undersigned reiterated that there were no “secret search terms” and that Plaintiff's own proposed terms were used, as limited. See Menninger Decl., Ex. C. Defense counsel also reiterated the request for Court Ordered conferral, again offering times to confer that would permit any additional terms to be run, documents reviewed and production of non-privileged responsive documents (if any) prior to Ms. Maxwell’s July 22, 2016 second deposition. Id. Plaintiff's Revised List of Search Terms Finally, on July 19, 2016, Plaintiffs counsel agreed to a telephone call with the undersigned to discuss the lack of responsive documents to the 110 search terms already run, as well as the remaining objectionable terms and their purported relevance. During the call, Plaintiff's counsel argued that their proposed search terms numbered 124-341 were relevant because they were witness names “related to massages” (RFP 5). That justification was clearly lacking because the terms included names like “Dore Louis,” who is a lawyer for witness Johana Sjoberg and whose wife works with Ms. McCawley. They also included Plaintiff's treating physician Karen Kutikoff, Plaintiff's literary agent Jarred Weisfeld, Plaintiff's mother Lynn Miller, Detective Joe Recarey, Mr. Edwards’ law partner Scott Rothstein, and countless other people who would have no knowledge of any massages nor otherwise were related to the discovery requests at issue. See Menninger Decl. Ex. A. Moreover, Ms. Maxwell already had 99 66. run the Plaintiff's proposed terms related to massages, including “massage,” “masseuse,” “masseur,” and “therapy.” In effect, Plaintiff proposed search terms sought to expand her discovery requests from communications with a discrete set of individuals to all communications