Giuffre_Maxwell_Batch3_p00256.png

Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 13 of 21 A. Yes, typed-out messages. Q. Just explain one example of how it would work. Let's say that Ghislaine wanted to send him a message on MindSpring. How would that work? A. An example? Q. Sure. A. It got so ridiculous at the end of my stay, okay? That Mr. Epstein, instead of talking to me that he wants a cup of coffee, he will call the office; the office would type it; they would send it to me, Jeffrey wants a cup of coffee, or Jeffrey wants an orange juice out by the pool. Q. He would call the office in New York. They would then type it in MindSpring? A. Send it to me. Q. How would you know to check for it? How would you know to look for this MindSpring? A. Because I was in the office. I was there. I was there. And we have a signal when it come on and says, Hey, you've got mail. Q. Okay. A. Every day. Every day it was new things put in. That's why I left, too. Q. Do you know who set up the mind spring system? A. It was a computer guy. It was a computer guy who worked only for Jeffrey. Mark. Mark Lumber. Q. Was he local to Palm Beach? A. No. He was in New York. Everything was set up from New York. And Mark Lumber, I remember he came to Palm Beach to set up the system at the house. Alessi Dep. Tr. at 223:5-225:17. (June 1, 2016) (McCawley Decl. at Exhibit 7). Accordingly, mindspring was a server set up for Jeffrey Epstein and his household to use to communicate to one another, and was, in fact, used in this manner. 13