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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 2 of 21 e Plaintiff's Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20) - Defendant’s Motion to Stay - Denied (DE 28). e Plaintiff's February 26, 2016 Letter Motion to Compel Defendant to Sit for Her Deposition (DE 63) - Granted (DE 106). e Plaintiff's Motion to Compel Documents Subject to Improper Claim of Privilege (DE 33) - Granted in Part (DE 73). e Plaintiff's Motion to Compel Documents Subject to Improper Objections (DE 35) - Granted in part (106). e Plaintiff's Response in Opposition to Defendant’s Motion for a Protective Order Regarding Defendant’s Deposition (DE 70) - Defendant’s Motion Denied (DE 106). e Plaintiffs Motion for Forensic Examination (DE 96) - Granted in part (June 20, 2016 Sealed Order). e Plaintiff's Motion to Compel Defendant to Answer Deposition Questions (DE 143) — Granted (June 20, 2016 Sealed Order). e Plaintiff's Motion for Adverse Inference Instruction (DE 279) - Pending. e Plaintiff's Motion to Enforce the Court's Order and Direct Defendant to Answer Deposition Questions (DE 315) - Pending. On June 20, 2016, this Court Granted in Part Ms. Giuffre’s Motion for Forensic Exam, and directed Defendant to capture her data and run mutually agreed-upon search terms. The Court also ordered Defendant to produce documents to Ms. Giuffre by July 11, 2016. (This part of the Court’s Order is not under seal and can be found at DE 264-1). On June 30, 2016, and on July 8, 2016, counsel for Ms. Giuffre sent letters to Defendant following up on this Order and proposing search terms (attached as exhibits to DE 279). Defendant did not respond. The July 11, 2016, deadline passed without any production from Defendant. On July 13, 2016, Ms. Giuffre moved for an adverse inference instruction (DE 279). Thereafter, the Court denied Defendant’s motion to strike Ms. Giuffre’s motion for an adverse inference instruction, directing the parties to submit search terms to the Court on August 1, 2016, advising that “[a] briefing schedule and the submission date will be set after search terms are determined.” (DE 301). Pursuant to this Court’s July 22, 2016, on Monday, August 1, 2016, Ms. Giuffre filed the list of search terms that Ms. Giuffre believes should be run over Defendant’s data. (DE 323).