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Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 5 of 21 sexual abuse. Of course, the facts at issue in this case began in January 2015, when Defendant defamed Ms. Giuffre, leading to this lawsuit, filed in September 2015. Ms. Giuffre also testified that, at one point, she had a dream journal, but never testified that she had her dream journal during the pendency of this litigation or that her dream journal had anything related to this litigation within it. Ms. Giuffre performed a diligent search for all documents even potentially connected to this case. She produced a 141 page manuscript from her electronic files, which was also written in 2011; she produced a huge number of photographs and travel documents from the time Defendant and Epstein abused her; and she produced a copious amount of ESI from various sources. To leave no stone unturned, Ms. Giuffre paid $600 to retrieve storage boxes from a remote location and produced additional photographs found within those boxes. After a diligent search with the assistance of her attorneys, Ms. Giuffre was unable to locate the spiral bound notebook into which she used to record some of her dreams. However, the great number of documents produced by Ms. Giuffre, and those produced by third-parties, unambiguously point to the conclusion that this dream book would not have been useful to Defendant, because if it included anything related to this matter, it would likely have simply contained additional notes about Defendant’s involvement with Epstein in abusing her. From these simple facts, Defendant now seeks to spin a claim of “intentional destruction of evidence.” That the Defendant is asking the Court to somehow penalize Ms. Giuffre for taking a step to heal from Defendant’s sexual abuse is perverse. In any event, it is wholly unsupported in law, as no duty exists to preserve documents before a cause of action accrues. Of course, Ms. Giuffre could not predict in 2013 that Defendant would later defame her in 2015. Therefore, Ms. Giuffre had no duty to preserve anything at that point in time. And, in any event,