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Case 1:15-cv-07433-LAP Document 1327-13 Filed 01/05/24 Page 3 of 13 Laura A. Menninger, Esq. June 30, 2016 Page 2 of 12 embedded terms, [ request that you use “wildcards” to ensure that embedded terms are located. (Wildcard characters are used to expand word searches into pattern searches by “replacing” single or multiple characters.) Where there are a specific number of characters needed to be included, a single wildcard will achieve that purpose. For example, in some programs, ! is used for single character wildcards, and * is used for multiple character wildcards. For instance: (a) Single character wildcard example: a search for L!n! will return “long,” “link,” “lane,” “lone,” etc. (b) Multiple character wildcard example: a search for chil* will return “children,” “chill,” “chilling,” etc. (c) Mixed use of wildcards: a search for L!n* will return “lines,” “lining,” “linty,” etc. Accordingly, the below search terms are submitted with wildcard characters to be applied in the manner of the examples above. Please apply them as such with whatever characters is required by the software/platform that you will be using. Similarly, regarding how the terms are combined (AND or OR). OR should expand your results while AND will restrict result to only those which include all the terms. Additionally, I want to clarify that I would like all of the metadata to be searched in addition to the text of the documents. For example, if the search term is “acuity,” “hits” should include all the document that include the word “acuity” in their text OR in their metadata (this includes words in items such as email subjects, filenames, as well as any documents which include that word somewhere within their text). I also wanted to point out another special syntax with regard to proximity searching. This is a search that finds words within a specified distance from one another. On some software, this is represented as w/#, so a search for “meet w/2 greet” will return “meet and greet,” “greet and meet” and “meet and nicely greet.” Please apply accordingly. Additionally, for searches for people’s initials in the search terms, please use “exact matches,” “stand alone,” or “literal” terms (see, e.g., PA, AD, JE, GM). Finally, the search terms are not to be treated as case-sensitive, meaning that the terms should be searched according to their letters, regardless of whether they are represented in the list as containing upper case or lower case letters. The following are the applicable search terms. 1) jef* 2) geof*