Giuffre_Maxwell_Batch5_p00235.png

Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 5 of 17 IL. MS. MAXWELL HAS DISCLOSED AND SEARCHED ALL EMAIL ACCOUNTS a. All Devices Have Been Forensically Searched for Responsive Emails As requested by Plaintiff and Ordered by the Court, Ms. Maxwell’s computer and all of her electronic devices have been forensically imaged, searched for the search terms requested by Plaintiff, and all responsive documents produced. This expensive, costly and time consuming exercise in futility simply confirmed that all responsive documents, including all responsive emails, were produced in March and April 2016. Most significantly, the devices were searched for all emails—whether saved or deleted — and irrespective of which account they came from; not a single responsive email was located from any Mindspring account and no emails were located from Earthlink or any other secret, hidden, “undisclosed” email account, as Plaintiff speculates must exist. b. The MindSpring account The first two accounts discussed in the Motion have already been fully discussed in prior briefings and at length in conferral conferences.’ See DE 320. In addition to the search of Ms. Maxwell’s computer and devices, the first account, iy was forensically searched on its server using the search terms proposed by Defendants and as required by the Court. The search uncovered no responsive documents from any time period. See DE 320. This included both emails in the account, deleted emails, and any other information relating to the account retained on the MindSpring server. There can simply be no claim for an adverse inference where Plaintiff has already received exactly what she requested — a forensic search of the account for her own defined terms. It resulted in nothing. ' Plaintiff conveniently omits the fact that the EarthLink and MindSpring accounts were in an address book purportedly recovered from Mr. Epstein’s home by the Palm Beach Police in 2005. Thus, there is no indication or inference that either of these accounts were created or used in the 2000 to 2002 time frame as Plaintiff claims. 3