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Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 33 of 42 account still exists. Consider what the Defendant could have said in her response — but did not say. Defendant could have said that she used an email account from 1999-2002 and could have provided the identity of the account. She did not say that. Though implausible, she could have said that she did not use any email account whatsoever from 1999-2002. She did not say that either. She could have disclosed the domain name of that account. She did not. She could have explained that she deleted her account; that her account had been destroyed by the provider; or that she can no longer access her account for various other reasons. She did not say any of those things. As a result, Defendant offers no accounting whatsoever for her email communications from 1999- 2002. Defendant spills a lot of ink in subsection (d), describing what she refers to as Jeffrey «ce Epstein’s “messaging system’ on a private server” (Resp. Br. at 5). Defendant does not forthrightly state that the Epstein Server Account is distinct from the Mindspring account, which she discusses in a different section, but the language she uses - “there is a big difference between having a private email account (gmail, aol, yahoo, etc.) and communicating through a private messaging system on an employer’s sever” - suggests that she is describing a different, undisclosed email account on Epstein’s private server. If the Epstein Server Account is, indeed, a different account from the Mindspring email account, and she did use it to communicate from 1999- July 18, 2009,! she should have disclosed this account. Yet, even in her latest response, Defendant does not disclose what the email address is. She fails even to disclose the “local part” or the name of the mailbox that comes before the “(@” symbol, as well as the domain name, which follows. Further, she fails to ' July 18, 2009 is the earliest-dated email Defendant has produced in this litigation. (GM_00069) 3