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Case 1:15-cv-07433-LAP Document 1327-17 Filed 01/05/24 Page 2 of 6 From: Meredith Schultz <mschultz@BSFLLP.com> Sent: Wednesday, July 20, 2016 11:24 AM To: Laura Menninger Ce: Sigrid McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell (cassellp@law.utah.edu) Subject: RE: Conferral regarding forensic search Follow Up Flag: Follow Up Flag Status: Flagged Laura, Please see my additions in-line, in black, below to your email sent yesterday. My in-line communication should also be responsive to the email that you just sent. If I have left anything out, please let me know. Thanks, Meredith Meredith L. Schultz BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Phone: 954-356-0011 ext. 4204 Fax: 954-356-0022 http://www.bsfllp.com From: Laura Menninger [mailto:l!menninger@hmflaw.com] Sent: Tuesday, July 19, 2016 1:33 PM To: Meredith Schultz Subject: RE: Giuffre - Conferral regarding search terms Meredith: I 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: 1.1 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. Please advise of the processes you are undertaking to access the account, and the process you undertook to ascertain that the mindspring account no longer exists. 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 Terramar — You have withdrawn that as a standalone search term.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, 1 mu.