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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 4 of 21 In your June 8 letter, apparently acknowledging the overbreadth of the RFP, you suggest the defendant could respond by conducting an electronic search for plaintiff’s various names—searching all documents in defendant’s possession. Setting aside that this is not what the RFP asked for, that too would entail an extraordinary and unreasonable amount of time and money, since plaintiffs various names are guaranteed to have thousands of hits, and someone would have to review every hit to determine, e.g., whether the document previously was provided to you, whether the document is not subject to production because of privilege, or whether it was a false hit. What would be the purpose of such an enormous expenditure of time and money? You have not said, but it appears fairly obvious that this is fishing with a drift net. We decline your request to engage in this exercise. Having represented that running Ms. Giuffre’s that name was an “extraordinary and unreasonable” task “guaranteed to have thousands of hits, and someone would have to review every hit ...” (McCawley Decl. at Exhibit 1 at pg. 2 (emphasis added)), a mere three days later, on Monday, August 1, 2016, Defendant seemingly reversed her position, and represented to the Court that she had, in fact, run Ms. Giuffre’s names as search terms. (DE 321-6). But, contrary to the previous claim that it would be enormously burdensome to sort through these “hits,” Defendant now claimed that she had not found any responsive documents. It is possible that Defendant changed her mind over the weekend and reversed course. And, it is possible that Defendant did run those recently-contested terms over the weekend. And, it is possible that Defendant, over the weekend, gathered a team of lawyers to review the “thousands of hits” yielded by those terms. And, it is possible that not a single one of Defendant’s thousands of documents bearing Ms. Giuffre’s name was relevant to this action. All these things are possible, but none is likely. Either way, Defendant’s refusal to even include Ms. Giuffre’s name as a search term (either in reality or in the position she took on Friday) is evidence of Defendant’s continued bad faith and complete avoidance of her discovery obligations. The case centers on Defendant’s