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Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 3 of 42 Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account to communicate those years.! For example, according to United States Department of Commerce, “eighty-eight percent of adult Internet users sent or received e-mail” in 2000. See Eric C. Newburger, “Home Computers and Internet Use in the United States: August 2000,” U.S. DEPARTMENT OF COMMERCE, ECONOMICS AND STATISTICS ADMINISTRATION, U.S. CENSUS BUREAU, September 2001. Additionally, the Pew Research Center published findings that certain demographics have higher internet usage, including many demographics to which Defendant belongs. For example, higher rates of internet usage are found among younger adults (Defendant was 38 in 1999); those with college educations (Defendant has a master’s degree); those in households earning more than $75,000 (Defendant was in a household headed by a billionaire during that time, and that household had its own private email server and account); whites or English-speaking Asian- Americans (Defendant is white); and those who live in urban areas (Defendant lived in Palm Beach and Manhattan). See Andres Perrin and Maeve Duggan, ‘Americans’ Internet Access: 2000-2015,” PEW RESEARCH CENTER, June 26, 2015. Additionally, her boyfriend, Jeffrey Epstein, with whom she shared a household from 1999-2002 (and other years), implemented an entire, private email system to communicate with his household and employees, including Defendant. Accordingly, given Defendant’s extraordinary economic resources, her high-level social connections, and her elaborate residential email/internet configuration she had during that time, it is extraordinarily unlikely that she would not employ an almost ubiquitous communication tool, nor has she denied it. ' On Friday, September 23, 2016, counsel for Ms. Giuffre sent a letter to Defendant inquiring about the undisclosed account. As of the date of this motion, Defendant has made no response. 2