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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 3 of 21 IL. DISCUSSION At a minimum, the Court should direct Defendant to run the search terms in the list originally submitted by Ms. Giuffre. More broadly, the Court should grant Ms. Giuffre’s request for an adverse inference based on the incurable prejudice she has suffered as a result of Defendant’s failure to comply with her discovery obligations and this Court’s June 20, 2016, Order. A. Defendant’s Refusal to Even Run Ms. Giuffre’s Name as a Search Term. Defendant has been recalcitrant in running even the most basic searches of electronic data. For example, in a letter sent on June 8, 2016, and in a meet and confer call on July 26, 2016, counsel for Ms. Giuffre asked Defendant to run Ms. Giuffre’s name as a search term to find documents responsive to (for example) Ms. Giuffre’s Request No. 12, which sought Defendant’s documents relating to Ms. Giuffre. That request was refused in writing on Friday, July 29, 2016, at 7:02 p.m. (EST). See McCawley Decl. at Exhibit 1, July 29, 2016, 7:02 p.m., Letter from Ty Gee to Ms. Schultz (refusing to run Ms. Giuffre’s name as a search term as part of effort to identify responsive documents). Specifically, Mr. Gee’s letter said that such a search term was inappropriate because it was “guaranteed” to generate “thousands of hits”: