Giuffre_Maxwell_Batch7_p00041.png

Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 40 of 42 attached hereto at Schultz Dec. at Exhibit 4.) Sadly, Defendant’s innuendo is not confined to her most recent response, as throughout this litigation, Defendant has repeatedly made deliberately misleading statements to the Court® and some explicitly false claims.’ For present purposes, the key point is that Ms. Giuffre fully fulfilled her conferral obligation. IV. CONCLUSION For the foregoing reasons, the Court should direct Defendant to disclose both the local part and the domain name of all her email accounts, including those from 1999-2009, and allow a neutral third-party expert to recover responsive data from those accounts (based upon the search terms this Court previously ordered) and allow a forensic review of all of Defendant’s electronic data to ensure compliance with this Court’s Order. In addition, in view of the pattern of obstructive behavior, the Court should give to the jury an adverse inference instruction. October 28, 2016 * For example, Defendant intimated to the court that she wanted to depose Judith Lightfoot, complaining that there was not sufficient time to arrange the deposition, in attempt to appear to be prejudiced before this Court, when, really, Defendant had absolutely no interest in taking Judith Lightfoot’s deposition and could not be prejudiced. (DE 257). For another example, Defendant represented to the Court that Dr. Olson’s records were not produced until after Ms. Giuffre was deposed - that was a distortion as Defendant already had those documents from Dr. Olsen himself, and they were re-issued by Ms. Giuffre after the deposition with Bates labels. See Plaintiff's Response in Opposition to Defendant’s Motion to Reopen Deposition (DE 259). For another example, Defendant represented to the Court that Ms. Giuffre’s rape (where the presence of blood and semen was noted by the police report) was a “simulated sex act” (DE 335). For another example, Defendant put forth to the Court a misleading tally of questions posed to Defendant that included all of the times questions were repeated due to Defendant’s refusal to answer, including questions that were asked 15 times without eliciting a response. (DE 368, Plaintiff's Reply in Support of Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions). For another example, Defendant represented to the Court that Ms. Giuffre’s privilege log contained un-identified third parties, when it did not. (DE 155). ° Defendant clearly and falsely told the Court that Ms. Giuffre has an “opioid addiction” (Reply ISO Motion for Sanctions DE 303), when there is no evidence - documentary or testimonial- that even remotely supports that false and calumnious claim. 10