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Case 1:15-cv-07433-LAP Document 1327-15 Filed 01/05/24 Page 3 of 5 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 — | am 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 With regard to the search terms numbered 124-341, insofar as | can tell, you have simply broken apart the first and last names of every witness included within your Rule 26 disclosures. However, you never submitted a RFP seeking all communications between our client and your witnesses. There are some RFPs which identify individual witnesses whose communications with our client you sought (e.g., 1 — Epstein, 2, -Plaintiff, 3-Prince Andrew Zz Kellen, Dubins, Brunel and Marcincova, 17-Gow, 37-Clintons) and | will include those names within our searches. As to other names included on the list, many are incredibly common names (e.g., Bill, Mark, Phil, Pete, Bob, Mike, Todd) which you are asking to search as standalone terms, i.e., divorced from the accompanying surnames or first names. You have included the name “max*” well aware that our client’s surname, and that of all of her paternal family members, will begin with those three letters together. Your search terms thus are likely to yield every single email sent or received by our client, or her family members, or any other document in her possession with her own name on the document or in the metadata, in other words hundreds of thousands of non-responsive documents. Your search terms include “bill” and thus are likely to include every bill that our client has received or sent or discussed. Your search terms include Philip Barden who the court has already ruled maintains an attorney-client relationship with our client (and to the extent others are copied on his emails, those would be captured by searches for the other people’s names). You included my client’s boyfriend of many years, though he is not on any witness list or in any RFP. In sum, | will not agree to the search terms regarding witness names numbered 124-341 unless you (a) provide me with an actual RFP to which they each relate, and (b) make some effort to match them to actual people who have some relationship to this case (like first name /3 last name or some parts thereof). Lawyer Names