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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 1 of 21 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. / PLAINTIFF’S SUPPLEMENT TO MOTION FOR ADVERSE INFERENCE INSTRUCTION BASED ON NEW INFORMATION Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement to her motion for an adverse inference instruction based on new information, follows. Most notably, Defendant claims to have run search terms and reviewed over 10,000 documents, but, remarkably, claims that not a single document - not one - is relevant to this litigation, and therefore produced nothing with respect to the search. L FACTUAL BACKGROUND On October 27, 2015, Ms. Giuffre submitted her first set of Requests for Production. Defendant failed to make a reasonable search or production of her documents, and Ms. Giuffre sought relief from the Court numerous times: