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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 6 of 21 broad discovery requests that sought documents concerning dozens of individuals, including Ms. Giuffre’s close family members. To comply with these extraordinarily broad requests, Ms. Giuffre ran search terms constituting the names of all these individuals. For example, Ms. Giuffre has run the following names as search terms, including Defendant’s name, over her data: e Ghislaine (the defendant) e Maxwell (the defendant) e Jeffrey (Jeffrey Epstein) e Epstein (Jeffrey Epstein) e Sky Roberts (the name Ms. Giuffre’s father and brother) e Lynn, Roberts (the name of Ms. Giuffre’s mother) Indeed, to date Ms. Giuffre has produced 8,321 pages of documents in her possession. Fact discovery has now closed. Ms. Giuffre has requested that Defendant negotiate search terms with her as far back as March 10, 2016. This Court ordered Defendant to run mutually agreed upon search terms and produce relevant documents. Yet Defendant has yet to make any document production pursuant to this Court’s June 20, 2016, Order. B. Defendant’s Other Failures to Produce Documents Defendant’s ignoring the July 11, 2016, court-ordered deadline to produce documents pursuant to mutually agreed upon terms, and Defendant’s recalcitrance in searching for documents related to Ms. Giuffre are not the only examples of Defendant’s failure to make appropriate discovery. Defendant claims to have run a number of Ms. Giuffre’s search terms, yet claims that such a search yielded no responsive documents, save the few added to Defendant’s privilege log. Defendant did not provide any “hit” information to show which terms yielded results, or how many results they yielded. Defendant claims to have reviewed over 10,000