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Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 32 of 42 A. The Defendant had a Duty to Search from and Produce All Accounts In her continued refusal to disclose the email account she used from 1999-2002, Defendant offers a red herring argument, stating: “notably absent from the Motion is a single interrogatory, request for admission, or deposition question in which Ms. Maxwell was asked to provide all email addresses she has ever used.” Resp. Br. at 5. Defendant did not need a specific instruction to search within and produce from all of her accounts - such a request is presumed by the use of the terms “all” or “any,” in the interrogatories and the requests for production. It is also presumed by the absence of any limiting language, or restrictions to certain accounts. For example, Ms. Giuffre’s first Request sought “[a]ll documents relating to communications with Jeffrey Epstein from 1999 — present.” More important, however, it was this Court’s own Order that required Defendant to search for, and produce from, all accounts from 1999 through the present. See Schultz Dec. at Exhibit 1, August 9, 2016, DE 352 at p. 1-2, Order directing Defendant to “capture all of the sent/received emails from Defendant’s multiple email accounts, including . . . any other email accounts Defendant has used in the past or currently uses.” (Emphasis added). There can be no excuse for failure to do so and no excuse for continuing to refuse to disclose all of her email accounts. B. Substantial Data is Missing from the Defendant. Significant data is missing from the Defendant. Tellingly, Defendant still does not deny that she had a personal email account before 2002 that she used to communicate. And, tellingly, she still does not disclose what it is. Instead, Defendant has produced a miniscule amount of emails in this case and has not produced any e-mail dated prior to July 18, 2009. The Court should direct Defendant to disclose the e-mail account she was using and disclose whether the