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Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 6 of 17 c. The EarthLink account The second account, SN, is, as Ms. Maxwell has repeatedly explained to Plaintiff's counsel, an account that she does not recognize, that she does not recall having ever logged onto, and for which she has no password. See DE 320. Ms. Maxwell tried every avenue available online through EarthLink to reset the password or otherwise access the account. In fact, when one attempts to recover a password for that account, the system states “The email address you entered is not an EarthLink email address or ID.” According to Plaintiff, such a message means the account has been permanently deleted by the host company. Plaintiffs counsel, Meredith Shultz, wrote on May 17, 2016, regarding an account of Plaintiff's (that she claims she cannot access but for which relevant and responsive emails were located on her computer): “Regarding her live.com address, it appears that the account has been permanently deleted by the host Company. One method of telling if an account still exists for live.com (and for most web mail systems) is to perform an account password recovery. When you enter the e-mail address and enter the captca code and hit Next, the website states that it does not recognize the email address. This means that the account has been permanently deleted from live.com’s system.” Menninger Decl., Ex. A. Plaintiff does not, and cannot, explain why she thinks that her own live.com email address has been permanently deleted by the host company, yet based on the exact same set of data, she thinks that an email account that Ms. Maxwell does not recall ever using (and from which no documents exist on her devices) from Earthlink still remains on its system. If there is some way to access the account, Plaintiff hasn’t said what it is. Ms. Maxwell simply has no way to access this account and has no information, save Plaintiffs rank speculation.” ? Plaintiff has an account from which actual documents have been produced — proving she did use the account (unlike Ms. Maxwell’s EarthLink account) and it contains relevant information. Yet Plaintiff claims she 4