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Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 4 of 42 A The II 4 ccount Ms. Giuffre has knowledge of the Ee 2<count because it was listed as part of Defendant’s contact information (including phone number) on documents 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). Despite the fact that this account was listed as her contact information in the home she shared with Epstein, and despite the fact that the username bears her initials, Defendant claims she does not recognize the account, and has no access to it. The mindspring account is also listed as part of Defendant’s contact information gathered by the police. In her filing with this Court, Defendant represented that this was merely a “spam” account “to use when registering for retail sales notifications and the like,” and that it contains no relevant documents. (DE 345 at pg. 8). However, it appears that Jeffrey Epstein created the mindspring.org accounts to communicate with his household and with his employees, and did, in fact, communicate with them this way. As previously recounted, Jeffrey Epstein’s house manager, Juan Alessi testified that MindSpring account was in daily use by the Epstein household to send and receive messages, a household to which Defendant belonged: Q. So when there would be a message from one of them while they were out of town, they would call you, call you on the telephone? A. I haven't spoken to Ghislaine in 12 years.