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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 11 of 21 A. Because you know, I know Jeffrey. Maxwell Dep. Tr. at 271:18-22 (April 22, 2016) (McCawley Decl. at Exhibit 2). Yet, Maxwell now wants this court to believe that she has no responsive communications with J relevant to this case. C. Defendant’s Failures to Search All Email Accounts Perhaps part of the reason that Defendant has failed to produce responsive document is that still refusing to collect data from all of her email accounts. In particular, Defendant has not collected data from hel 5 account nor produced relevant documents from hel account. Both email accounts are listed as part of Defendant’s contact information gathered by the police from Epstein’s home, and turned over to the Palm Beach County State Attorney as part of the investigation and prosecution of Epstein: Ms, Ghislaine Maxwell Email See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16- 268, Disc 7 at p. 2305 (GIUFFRE007843). i. The mindspring.com Account As evidenced from the police collection above 3% , was an email address Defendant used while she was with Epstein. Jd. In her filing with this Court, Defendant represented that this was merely a “spam” account “to use when registering for retail sales notifications and the like,” and that it contains no relevant documents. Br. at pg. 8. Of course, if she wasn’t using the yy or the i, what email address was Defendant using while she was with Epstein, and why hasn’t that account been disclosed and searched? This Court should order Defendant to disclose all email accounts she has used from 1999 to the present. 11