Giuffre_Maxwell_Batch3_p00225.png

Case 1:15-cv-07433-LAP Document 1327-15 Filed 01/05/24 Page 4 of5 What is your basis for search terms numbered 366-368: McCawley, Schultz and Boies? Likewise to the extent Mr. Edwards and Cassell are also included in the witness list, what is your basis for searching for documents referencing them? These search terms seemed designed to pull privileged attorney-client communications and do not correspond to any RFP. We will not agree to these terms. Common Words You have included a number of words that relate to common items and place names. Please explain which RFP allows for a search of the following terms: 50 — Southern District (which will pull up every attorney-client communication that refers to our case and includes any pleading) 51 - Palm Beach (a place our client lived for many years) 64 — New Mexico 66-72 — USVI by various names 113 — hospital 114 - 116 — hotel, suite, villa (every single travel record related to our client’s travel which the Court has not ordered) 119 — 120 — Paris, France 121-122 -Zoro, Ranch 360 — Bed 361 -— Bath 365 - Lingerie Other Words Many other words have no relationship to this case. Please advise me as to (a) which RFP they correspond to and (b) your good faith basis for seeking these search terms in relation to any such RFP: 93 — Abernathy 94 - Brillo 355 — Guggenheim 358 - Gerbil Conferral Although many of your other search terms are a tremendous stretch, | can agree to them in the interest of getting the search done on a timely basis. According to our forensic expert, running a search on Ms. Maxwell’s devices of all 368 terms will take more than a week. | am available by telephone today and tomorrow to discuss the issues raised herein. If | do not hear from you, | will presume that you are in agreement to the remainder of the terms being run on the devices. That should allow a production of documents in time for Ms. Maxwell’s continued deposition next week. | am intentionally not taking a position regarding the other demands you provided in your letter of June 30 at pages 1-2. The searches will be conducted in accordance with standard practices in the industry and the Court ordered us to negotiate search terms only. -Laura Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 Imenninger@hmflaw.com