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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 15 of 21 A. Yes. 56:13-17; 5:2-14; 58:1-7; 60:21-61:7 (February 16, 2010) (Emphasis added) (McCawley Decl. at Exhibit 8). Defendant (i email account was part of Epstein’s iy account through which he communicated with his employees and other members of his household, including his co-conspirators Sarah Kellen, Nadia Marcinkova, and the Defendant. This email account likely has (or had) myriad of communications between and among Defendant and Jeffrey Epstein, Defendant and Sarah Kellen, Defendant and Nadia Marcinkova, and others. This email account is the one most likely to have the most relevant documents in this case, as it was used by Jeffrey Epstein and his sex trafficking organization. The fact that this account - an account created for the sole purpose of enabling Defendant and others to communicate with Jeffrey Epstein - has no communications with Epstein or the other co-conspirators, is extremely strong indicia that someone destroyed those email communications. Their destruction warrants an adverse inference instruction. And, at the very least, the Court should direct Defendant to retrieve her data from the Citrix server or any other applicable server upon which the mindspring.com account was hosted. il. The 3 Account The account bears Defendant’s initials, and, again, listed as part of her 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: 15 Ms, Ghislaine Maxwell Email