Subject: RE: Brunel

Date: Wed, 10 Feb 2021 19:03:52 +0000

I think that's fine, thanks.

**Sent:** Wednesday, February 10, 2021 2:01 PM

Subject: RE: Brunel

Thanks, . Sorry for my delayed response – I somehow missed this email. I’ll plan to respond to as follows – but let me know if this doesn’t get it right.

We can conduct searches with multiple search terms. That said, to the extent we are asked to run several variations to get a sense of the volume of documents, we would ask that those requests be specific and focused. I hope that helps. Happy to discuss if you have any additional questions.

**Sent:** Monday, February 08, 2021 5:11 PM

Subject: RE: Brunel

The short answer is yes, Relativity permits searches with multiple search restrictions. There is a limit to how many variations and connectors we’re willing to test-run for volume, of course. If they asked us to run all the different name constructions as search terms in combination with all of the other terms they gave us, we’d have to run dozens and dozens of searches. So they’d need to send us a narrow universe of very specific requests in order for us to run searches this way.

Feel free to call me if you have any questions about this. And I know you’ve both used relativity, so let me know if you have a different take.







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Subject: Re: Brunel

This list represents unique documents for each term.

On Feb 2, 2021, at 8:22 AM,

Can you remind if this list represents unique documents, or does it instead refer to hits (i.e., potentially reflecting multiple times the same word appears in one document).





Thanks for speaking earlier today. The below chart reflects the search terms we ran in Relativity and the number of results for each term:



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Please let us know if you have any questions.

Thanks,