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Case 1:15-cv-07433-LAP Document 1327-16 Filed 01/05/24 Page 2 of 6 From: Laura Menninger Sent: Tuesday, July 19, 2016 11:33 AM To: "Meredith Schultz’ Subject: RE: Giuffre - Conferral regarding search terms Meredith: | write to confirm our oral conferral. Please let me know if you disagree with the following or if there is some other agreement you think we reached: 1. | will endeavor to have my client gain access to an earthlink account that you believe is hers. Your basis for that belief is a disk you produced last week, obtained pursuant to a FOIA request, that contained at Page 2035 an address book from approximately 2005 which has that earthlink account name next to Ms. Maxwell’s name. 2. Terramar — You have withdrawn that as a standalone search term. | have represented to you that we have searched all Terramar emails for otherwise responsive documents as well as 3. Witness names — You believe that search terms 124-341, which are witness names broken up into first and last names from your Rule 26 list, relate to your RFP number 5 (“All documents relating to massages...”). | represented to you that | have searched for the terms “massage,” “masseur,” “therapy” etc. as you requested, but you would still like me to search a subset of 124-341 surnames names for all communications with certain witnesses that you believe relate to “massages.” | said | would look at your list, when you send it, and evaluate whether we still object to running those more limited names to see if there are any communications that “relate to massages.” | still object that the search terms involving names is too broad and burdensome for me to have to review all communications with those individuals to try to discern what you believe may or may not relate to a “massage.” mu. 4. Lawyer names — You have withdrawn. 5. Common words — You have withdrawn with the exception of “lingerie,” which | will run to see if it relates in some way to RFP 5 (“massages”). 6. Other words — a. You have withdrawn #93 Abernathy and #94 Brillo. b. | maintain my objection to Guggenheim, the name of a museum which you represented to me pertains in some way to allegations made by witnesses Farmer, but for which no documents or other information has been shared (i.e., | have never seen any allegations by witnesses Farmer). Because there is no RFP to which | believe that term relates, and it is the name of a museum, | object to running that search term. c. Gerbil — You have withdrawn. 7. Additionally: a. _ladvised you that | was not able to search for #3 because those letters are the first part of my client’s longstanding email address, and search for that term will yield literally every single email she has sent or received. | believe you have withdrawn that requested search term. b. | advised you that | was not able to search for initials at #16-21 and 75-77. To the extent those initials represent people from whom you have requested all communications (and which the Court has limited to 1999-2002 and post-2002 as they relate to sex trafficking), for example, Jeffrey Epstein, Prince Andrew, | am searching for and producing responsive documents, so there is no need to search for the 1