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Case 1:15-cv-07433-LAP Document 1327-17 Filed 01/05/24 Page 6 of 6 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:Imenninger@hmflaw.com] Sent: Wednesday, July 20, 2016 1:01 PM To: Meredith Schultz Ce: Sigrid McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell (cassellp@law.utah.edu) Subject: Conferral regarding forensic search Meredith — Apart from (i) the list of witness names you believe might be associated with the term “massage” (“massage” and related terms that you requested have been searched), (ii) the word “lingerie”, and (iii) we have completed the forensic copy, search, retrieval and review of all hits on our client’s devices and email accounts as directed by the Court based on agreed to search terms, including those agreed to in our conferral yesterday. After review of more than 9,000 documents and files containing your search terms, the only documents located not previously produced are 6 privileged documents which we will add to our log. We also located a number of privileged communications between our client and myself following the onset of litigation in this case which will not be logged consistent with both parties' agreed to practice. As predicted, no responsive non-privileged documents resulted from the exercise. I will keep you apprised of the results of the “lingerie” and status of ability to access the account. If you want me to consider running additional witness names because you believe those people may relate to RFP 5 regarding “massages”, please forward those names to me and your basis. -Laura The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v. 1]