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Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 15 of 17 Q. That is not my question, my question is, did you ever delete emails in January of 2015? A. In the normal course of my work, there are emails from spam that I delete. That is the type of email I've deleted. Anything that is material to what you want, I have not deleted. . How do you know that? . Well, anybody that's to do with Jeffrey or Alan or women or anything of which I know you were interested in, of which I have anything I would not have done because I don't want to subject myself to... [cut off by Plaintiff's counsel] PO Menninger Decl., Ex. C at 370. This Court permitted the forensic examination of all on Ms. Maxwell’s electronic devices to ensure that there were no deleted emails or files that might contain relevant information. In that forensic examination, the entire devices and accounts were searched, including all deleted emails and files. Again, as stated, no relevant non-privileged documents resulted from this extensive and exhaustive examination. Plaintiff received the relief that she requested — a forensic examination — to ensure that no information had been lost or destroyed. It has not. Plaintiff cannot now claim that the non-existent hypothetical emails she suspected existed can form the basis for the severe and improper sanction of an adverse inference. CONCLUSION Plaintiff has now litigated this issue on four separate occasions, received a complete and exhaustive forensic examination, and the result is exactly what Ms. Maxwell has always contended — there is no relevant non-privileged information that was not originally produced. Having failed to find the smoking gun — because there is none — Plaintiff now weaves a convoluted argument attempting to get an adverse inference instruction because she cannot prove her case based on the actual law and facts. Such an inference is contrary to law, the rules of evidence, and the very notion of a fair trial. It is impermissible and must be denied. WHEREFORE, Defendant Ghislaine Maxwell request that this Court 1) DENY Plaintiff's Motion To Compel Data From Defendant’s Undisclosed Email Account and For an 13