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Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 11 of 13 about privacy. (This Court quashed those subpoenas, see June 23, 2016, Minute Entry). Defendant cannot argue to the Court in June that it is appropriate for her to receive unfettered access to every email Ms. Giuffre ever sent or received from two accounts, and then, in August, argue to the Court that it is inappropriate for a neutral third-party to review Defendant’s electronic documents for deleted (or unproduced) responsive documents - a process through which, importantly, neither Ms. Giuffre nor the Court gets access to all of Defendant’s data (unlike Defendant’s subpoenas which would give all data directly to her). To the contrary, neither Ms. Giuffre nor the Court would ever see or know about Defendant’s personal data unless it is non-privileged, and directly responsive to the requests for production that this Court has already, specifically allowed. Finally, Defendant denies using her gmax1@mindspring.com account for anything other than spam, despite the fact that the account was set up by Jeffrey Epstein for the purpose of sending electronic communications to members of his household. See DE 338; Alessi Dep. Tr. at 223:5-225:17. (June 1, 2016) (McCawley Decl. at Exhibit 4); Banasiak Dep. Tr. at 56:13-17; 5:2-14; 58:1-7; 60:21-61:7 (February 16, 2010) (Emphasis added) (McCawley Decl. at Exhibit 5). Defendant denies knowledge of her i. and has not pursued access to that account, despite the fact that the account name bears her initials and was 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. See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16-268, Disc 7 at p. 2305 (GIUFFRE007843). Yet, Defendant has not disclosed what email account she did use while she abused Ms. Giuffre, and has never searched that account nor produced documents from it. Accordingly, a forensic exam is called for at this time. 10