Case 1:15-cv-07433-LAP Document 300-2 Filed 07/22/16 Page 1 of 3 From: Laura Menninger Sent: Thursdi. 14, 2016 2:35 PM To: Meredith Cc: Jeff Pagliuca; Sigrid S. McCawley - Boies, Schiller & Flexner LLP (5mccawleyftsfllo.com); [email protected]' ([email protected]) - Conferral regarding search terms Subject: Meredith — I am writing to you, in compliance with the Court's Order, to negotiate the search terms for the search of our client's electronic devices. While Jeff raised many of these issues orally with Brad last week, I am including them in written form so that there can be no dispute about our position. I do object to the vast number of your 368 search terms. Most are not tied to asy Request for Production served on Ms. Maxwell, nor the Court's Orders limiting those requests. Terramar — Search term 49 is "Terramar." While we are searching our client's terramar email address for otherwise responsive documents, this search term would pull up thousands of documents related to her work for that organization which are (a) non-responsive and (b) irrelevant to this action. We will not agree to this standalone search term. Witness Names With regard to the search terms numbered 124-341, insofar as I 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 1 EXHIBIT 2 EFTA02799406