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Case 1:15-cv-07433-LAP Document 1327-16 Filed 01/05/24 Page 4 of 6 time to discuss the terms or the issues raised regarding overbreadth. As such, we proceeded processing your list with the exceptions set forth. | will reiterate my offer to set a call to discuss the excluded terms to determine if there are agreeable additions. In light of the deposition scheduled for Friday and the time it takes to run searches, any call would need to be set prior to noon MT tomorrow. Please advise, one way or the other, if you are satisfied with the list or if you would like to set a call. -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 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. From: Laura Menninger Sent: Thursday, July 14, 2016 2:35 PM To: Meredith Schultz Cc: Jeff Pagliuca; Sigrid S. McCawley - Boies, Schiller & Flexner LLP (smccawley@bsfllp.com); 'brad@pathtojustice.com' (brad@pathtojustice.com) Subject: Giuffre - Conferral regarding search terms Meredith — lam writing to you, in compliance with the Court’s Order, to negotiate the search terms for the search of our client’s electronic devices. While Jeff raised many of these issues orally with Brad last week, | am including them in written form so that there can be no dispute about our position. | do object to the vast number of your 368 search terms. Most are not tied to any Request for Production served on Ms. Maxwell, nor the Court’s Orders limiting those requests. Terramar — Search term 49 is “Terramar.” While we are searching our client’s terramar email address for otherwise responsive documents, this search term would pull up thousands of documents related to her work for that organization which are (a) non-responsive and (b) irrelevant to this action. We will not agree to this standalone search term. Witness Names