Case 1:15-cv-07433-LAP Document 1202-2 Filed 01/27/21 Page 1 of 10 United States District Court Southern District of New York Plaintiff Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PROPOSED SEARCH TERMS Pursuant to this Court's July 21, 2016, Order. hereby submits proposed search terms and a proposed method of employing them. I. GATHERING DATA To ensure that Defendant captured all her email data, requested that Defendant "please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) GMaxl®ellmax.com (and any other accounts at ellmax.com); (2) [email protected] (and any other accounts at mindspring.com); (3) any of Ms. Maxwell's email account associated with The Terramar Project (including any account ending in @theterramarproject.org); and (4) any other email accounts either used in the past, or currently in use." data from Ms. Maxwell's later requested that account be captured. To ensure that Defendant captured her data from her electronic devices. requested: "please use FileSeek software (or a functional equivalent) to retrieve any data. including electronic documents (such as Word documents; PDFs; Excel sheets; etc.), from Ms. Maxwell's devices, including personal computers, work computers, any tablets, and any phones. This includes any cloud storage 21 EFTA02785692