DOJ-OGR-00019978.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page119 of 200 56 1 hiding. She is a risk of flight because she changed her e-mail 2 and phone number. That's what we heard in the opening brief. 3 Well, what happened? Something the government, frankly, should 4 know about, because it was certainly public, last year, in a 5 civil litigation, in August of 2019, right around the time of 6 the arrest of Mr. Epstein, the Second Circuit ruled that 7 certain records in one of the civil cases should be unsealed 8 and released to the public. That was done. There was no stay 9 at the moment. The demand was issued, and the documents were 10 released. Certain of those documents were supposed to be 11 redacted and sometimes they were and sometimes they were not, 12 documents including e-mail addresses, Social Security numbers, 13 names, phone numbers, the sorts of things your Honor, I am 14 sure, has to deal with all the time in these kinds of 15 situations. 16 But as it turned out, for whatever reason, some of the 17 documents were not redacted and her e-mail address was 18 revealed. Shortly after that, she starts getting strange 19 e-mails. Her phone is hacked, and she had to change e-mails 20 and change the account. 21 Now she has got a phone that has legal materials on 22 it, correspondence with her counsel in civil litigation that's 23 been hacked, so she keeps it. Why does she keep it? Because 24 she is in civil litigation. Her obligation is to keep 25 evidence, not destroy it, and is advised that a way to keep it SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019978