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Case 1:15-cv-07433-LAP Document 1327-17 Filed 01/05/24 Page 5 of 6 5. Common words — You have withdrawn with the exception of “lingerie,” which | will run to see if it relates in some way to RFP 5 (“massages”). 6. Other words — a. You have withdrawn #93 Abernathy and #94 Brillo. b. | maintain my objection to Guggenheim, the name of a museum which you represented to me pertains in some way to allegations made by witnesses Farmer, but for which no documents or other information has been shared (i.e., | have never seen any allegations by witnesses Farmer). Because there is no RFP to which | believe that term relates, and it is the name of a museum, | object to running that search term. c. Gerbil — You have withdrawn. 7. Additionally: a.| advised you that | was not able to search for EEN because those letters are the first part of my client’s longstanding email address, and search for that term will yield literally every single email she has sent or received. | believe you have withdrawn that requested search term. b. | advised you that | was not able to search for initials at #16-21 and 75-77. To the extent those initials represent people from whom you have requested all communications (and which the Court has limited to 1999-2002 and post-2002 as they relate to sex trafficking), for example, Jeffrey Epstein, Prince Andrew, | am searching for and producing responsive documents, so there is no need to search for the initials. With regards tof, you told me that is ‘MJ and there is no standalone request for communications with her. -Laura Additionally, please inform me what steps you have taken to ascertain that the is no longer in existence. Similarly, please keep me informed of your steps to access the Please pursue all available avenues to access those accounts, as Ms. Giuffre did with regard to her email accounts. Finally, Ms. Maxwell’s produced documents that indicate that she has an iPad, etc. Please confirm that you have imaged her iPad as well as her phone in order to obtain the data from both (text messages, etc.). One last thing - it occurred to me that in our discussion of terms that were run/not run and to be run/and not to be run, I don’t believe we discussed the terms containing individuals’ email account addresses, specifically Mr. Epstein and Mr. Dershowitz. (If we did discuss that, apologies for my lack of memory). Please confirm that you have run the terms associated with their email addresses. Specifically, these were the terms: 1) jeevacation* 2)j* w/2 *jep* )j* w/2 *jeep* ) ) Ww 4) dersh* 5) law.harvard.edu* 6) alandersh* Please let me know if you have any questions. Please treat this email as confidential under the Protective Order as it contains the names of underage victims of sexual abuse. Thank you,