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Case 1:15-cv-07433-LAP Document 1327-16 Filed 01/05/24 Page 5 of 6 With regard to the search terms numbered 124-341, insofar as | can tell, you have simply broken apart the first and last names of every witness included within your Rule 26 disclosures. However, you never submitted a RFP seeking all communications between our client and your witnesses. There are some RFPs which identify individual witnesses whose communications with our client you sought (e.g., 1 — Epstein, 2, -Plaintiff, 3-Prince Andrew || Kellen, Dubins, Brunel and Marcincova, 17-Gow, 37-Clintons) and | will include those names within our searches. As to other names included on the list, many are incredibly common names (e.g., Bill, Mark, Phil, Pete, Bob, Mike, Todd) which you are asking to search as standalone terms, i.e., divorced from the accompanying surnames or first names. You have included the name “max*” well aware that our client’s surname, and that of all of her paternal family members, will begin with those three letters together. Your search terms thus are likely to yield every single email sent or received by our client, or her family members, or any other document in her possession with her own name on the document or in the metadata, in other words hundreds of thousands of non-responsive documents. Your search terms include “bill” and thus are likely to include every bill that our client has received or sent or discussed. Your search terms include Philip Barden who the court has already ruled maintains an attorney-client relationship with our client (and to the extent others are copied on his emails, those would be captured by searches for the other people’s names). You included my client’s boyfriend of many years, though he is not on any witness list or in any RFP. In sum, | will not agree to the search terms regarding witness names numbered 124-341 unless you (a) provide me with an actual RFP to which they each relate, and (b) make some effort to match them to actual people who have some relationship to this case (like first name /3 last name or some parts thereof). Lawyer Names What is your basis for search terms numbered 366-368: McCawley, Schultz and Boies? Likewise to the extent Mr. Edwards and Cassell are also included in the witness list, what is your basis for searching for documents referencing them? These search terms seemed designed to pull privileged attorney-client communications and do not correspond to any RFP. We will not agree to these terms. Common Words You have included a number of words that relate to common items and place names. Please explain which RFP allows for a search of the following terms: 50 — Southern District (which will pull up every attorney-client communication that refers to our case and includes any pleading) 51 - Palm Beach (a place our client lived for many years) 64 — New Mexico 66-72 — USVI by various names 113 — hospital 114 - 116 — hotel, suite, villa (every single travel record related to our client’s travel which the Court has not ordered) 119 — 120 — Paris, France 121-122 -Zoro, Ranch 360 — Bed 361 -Bath 365 - Lingerie Other Words Many other words have no relationship to this case. Please advise me as to (a) which RFP they correspond to and (b) your good faith basis for seeking these search terms in relation to any such RFP: 93 — Abernathy 94 - Brillo 355 — Guggenheim 358 - Gerbil