Case 1:15-cv-07433-LAP Document 288-1 Filed 07/15/16 Page 1 of 4 From: Jeff Pagliuca Sent: Thursday, July 14, 2016 11:23 AM To: Laura Menninger Subject: FW: Your motions From: Jeff Pagliuca Sent: Thur.,ly 14, 2016 11:22 AM To: 'Brad Subject: RE: Your motions Brad, I after our conversation last week I thought that you understood that we did not agree with the 344 search terms that Ms. Schultze unilaterally imposed on us and that we needed additional time to complete the exam process because all of us, Laura, me and the client, were out of town over the holiday weekend. I recall telling you that we intended to complete any search in advance of the deposition on the 22nd because I did not want to have a third deposition. My recollection of the discussion was that you were going to confer with your team about this along with the other items we discussed. I apologize if I was not clearer and for my part in any miscommunication. We covered a lot of topics and we both had a number of other things to do. 1 EXHIBIT 1 EFTA02799372