Destiny masterfully strips away the sensationalist veneer to deliver a surgical analysis of procedural misconduct under FRCP 37E2. It is a rare example of how digital drama can be weaponized for high-level legal education.
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Jane Doe's Most Disgusting Request YetAdded:
This case was filed on February 18th, 2025. That's one year and three months.
We have 264 docket entries. That's almost one filing every other day for a case that has one screenshot worth of evidence from a person who dodged discovery for 8 months. After months and months and months after Discovery is closed, by the way, we are finally getting a sanction for expoliation. Now, no motion to compel during discovery.
nothing was discovered after discovery closed that would lead him to think that something is a miss. Is what they are trying to do is simply try to make the judge think there's more evidence than there actually is for her to not they're just trying to survive the MSJ I think.
For what reason? I don't know. I guess maybe because they think the trial would be memes. I I truly don't know.
Plaintiff's motion for sanctions under the Federal Rules of Civil Procedure 37E2 for defendants expoliation of evidence. plaintiff moves for sanctions under FRCP 372 for the spoliation ESI central to her Cardi claim. I have a conspiracy theory that I have absolutely no support for. I have not talked to a single lawyer that has heard of submitting everything to some third party vendor for generating discovery or whatever. I don't know if Kafka has.
I've never heard of this in my life. But my conspiracy theory is the reason why they used that third party thing is because I I bet that it let Joanne go through all of the files for her to more easily sort out what she wanted to turn over and what she wanted to hide. That's what I think. That's why she liked because when I provided information to them, it was just full conversation logs from this date to that date. So hundreds or thousands of messages in like a single like in a full conversation log.
Whereas from me to them, it was just single messages. Every single message was its own bait stamp. But I think now it's because she used that third party platform to selectively release stuff to us from them to me. Yes, that's what I think. That's why I think they used it.
Why did you comply with Discovery before they turn anything over? I mean, technically it's your legal obligation to I don't know. I don't know. I just never considered that they would just lie and cheat and hide everything. I I don't know. Maybe I should have, but I mean, I don't have a counter claim. So, after defendants's duty to preserve attached, he deleted his communications with multiple witnesses and destroyed the Google Drive files and Discord attachments he transmitted to them. As to one witness, ABMC defendant filed a sworn true and correct log of 22 outbound media files and produced none of them. You can eat my entire [ __ ] ass. I will rot beneath a prison before I ever give any pornographic videos of mine to you disgusting [ __ ] nasty [ __ ] piece of [ __ ] for you and [ __ ] Lauren and whatever other goggle of disgusting [ __ ] pedto weirdo porno friends you have. I will never ever the fact that you would even suggest this that I need to turn over every that was one of their discovery requests by the way was every single image and video that I'd sent over the past 5 years. You are crazy at Destiny. It's called eiscocovery and it's much more common for patent litigation. Sure. It wouldn't surprise me if like these platforms were used if you have like hundreds of thousands of bait stamps or whatever worth of like or I should say if you like hund like tons and tons and tons of documents to go through like I could understand it but for cell phone messages and [ __ ] The log is demonstrably false. It omits two additional Google Drive links defendant's own chat thread shows him sending. Remarkably, defendants spent time and effort creating his false true and correct log, but no time or effort in getting the video removed from Kiwi Farms or other sites. I guess you can just lie in footnotes, but I mean like the Supreme Court doesn't matter and our federal courts don't matter and literally zero [ __ ] courts matter, I guess, for [ __ ] anything, I guess.
So, I guess I could just lie in every single [ __ ] footnote because it's part of the record that I did go through efforts to DMCA stuff, to contact a registar to take some stuff down that we sent an email to null. Um but I but I guess we can just lie in our footnotes I guess. Okay. Based defendants bulliation strikes at the heart of the case. The destroyed evidence bears directly on the dispositive merits issue in defendants's pending MSJ. Whether defendant transmitted intimate recordings of plaintiff after Card's October 1st, 2022 effective date. Then why wasn't this part of your motion for summary judgement? Why is this a separate motion for sanctions? Like this is a thing that comes during the this is like pre-trial [ __ ] Why why wasn't why wasn't this argument attached to the MSJ response.
Like technically the judge could just rule on it before even getting to this and just toss this. But whatever.
Defendant's own productions show that in 2023 he transmitted multiple Google Drive links and other media to ABMC, including a May 5th, 2023 link sent with the message, "Did I ever send you the one for blowing me? The underlying files no longer exist." This was a Google Drive link from 2023 for a person that to this day has no reason to even be involved in this case.
So, ignore the fact that I don't even have an obligation to keep any of this [ __ ] Okay? I still do and I still did have everything, which is why I was able to turn it over cuz I do document and archive all my stuff. Plaintiff's forensic expert, Jesus Pena, has confirmed that defendants preservation and production were forensically unreliable. Again, this word forensic doesn't make any sense. But again, I don't know if they they saw a TV show or the AI told them to do this or whatever, but like forensics don't begin with the accused. It doesn't make any sense to say this. Nothing about that makes any sense. You can edit whatever you want, destroy whatever you want, generate a hash, submit it to eiscocovery. I mean, that's what the plaintiff has done.
She's hidden all of her messages with uh straight raid. She has hidden all of her messages with Lauren, and I don't have any of them. Defendant used non-native third-party tools. There are no native tools to extract Discord logs. So, all of them are going to be third party.
Generated no hash values or metadata.
These are meaningless statements.
Manually reconstructed parts of exhibit E. Everything you see is going to be some manual construction because there is no such thing as an original export or non- third. So, none of this makes sense. rendered the Google Drive files and Discord attachments unreoverable because Discord doesn't save all of those files indefinitely and neither does Google Drive. Defendant never moved to exclude Pena never deposed him and disclosed no rebuttal expert. Yeah, because you don't I don't think you need an expert to rebut a [ __ ] Rule 37E2 applies where ESI that should have been preserved is lost because a party failed to take reasonable steps to preserve it and acted with intent to deprive another party of its use. Scans citing cases here. Defendants own deposition, testimony, productions, sworn statements, and public admissions establish each element. Plaintiff respectfully requests that the court strike defendants's defenses and enter judgment in plaintiff's favor as to liability or alternatively find under rule 37E2 that the defendant intentionally expoliated evidence with the intent to deprive plaintiff of its use in this litigation and presume or instruct the jury that it must or may presume that the destroyed Google Drive files defendant transmitted to Abby in 2023 included one or more of the three intimate recordings of plaintiff The defendant admitted at deposition he made. Plaintiff also requests an award of reasonable attorney's fees and costing curt in bringing this motion.
Defendant testified that he recorded three intimate videos of plaintiff. The video publicly leaked on November 29th, 2024 by an account associated with solotiny leaks depicts plaintiff performing oral sex on defendant.
Defendant has admitted transmitting that video to a non-party witness rose in April of 2022 before Card's effective date. The merits dispute is whether any of the three recordings of plaintiff was transmitted or was still accessible on or after Card's October 1st, 2022 effective date. Nonparty witness ABMC has submitted two sworn declarations attesting to defendants transmission of the video to her after Card's effective date. So two, yes, but both are basically the same thing. But okay.
Yeah, I like how it's I'm recording these like I'm recording these solo or whatever. The defendant's duty to preserve attached no later than November 29th, 2024 when Solo Tiny Leaks publicly posted intimate content of plaintiff and others putting defendant on notice at litigation was reasonably foreseeable.
You're saying here that after another account starts leaking [ __ ] of mine onto the internet that I have a duty to not I'm not allowed to protect myself and delete any other videos across all of my social media. 37 dogs. Thank you for the 10 tier 2 subs. The funny thing is is that plaintiff literally reminded me.
She was like, "Hey, make sure you delete everything in your conversation with this guy." And I'm pretty sure even Judge Bera in the very beginning of this case, in the first hearing they had, I think even um even she said, "Hey, uh wouldn't it make sense that somebody would be deleting stuff if their account [ __ ] was getting leaked? [ __ ] you have to buy these on Pacer." What an insane claim that as soon as my [ __ ] gets leaked online, I am completely and totally disallowed from cleaning up any of my DMs to anybody else. I'm not allowed to delete any message. I'm not allowed to do anything because I should just assume that somebody's going to [ __ ] sue me. How much you want to bet that if we look up this case, this is absolutely not even remotely related to this claim. Also, actually, I don't even give a [ __ ] Never mind. I'm not going to waste my time. The duty was reinforced on January 23rd, 2025 by a hand and email served to demand for preservation of evidence which directed defendant to immediately initiate a litigation hold for potentially relevant ESI. The court itself reinforced the duty at the April 4th, 2025 hearing. You can't destroy evidence after you're on notice of the suit and the preservation letter has been sent. It's funny that they quote the judge there. That was the judge rebuking them for trying to get a preliminary injunction against him, saying that, "Well, he's already on notice. Why the [ __ ] would you need a preliminary injunction?" But good one.
Defendant [clears throat] deleted his set of his communication with multiple witnesses after his duty reserve attached. The defendant communicated with at least five women whose communications are relevant. According to who?
Plaintiff, Abmc, Hannah Brookke, witness A, and witness B before and after the November 2024 leaks. each attests that defendant deleted his side ABMC. The defendant admitted a deposition that he deleted his Discord messages with ABMC sometime maybe at the end of 2024. He also admitted on May 13th, 2026 live stream that after the leaks in January or February, I ran like a whole redacted my discord thereby placing the deletion squarely after his preservation duty had attached. The duty is to preserve not that I can't remove content from other platforms. I have preserved everything.
That's why the only evidence in this entire case that we can argue about is the evidence that I've provided. ABMC separately attests that in April of 2025, the defendant deleted all of his direct messages to me on the Discord platform, including the sharing of the video of Pixie. The destruction is critical. Due to defendants's deletions, ABMC cannot produce the video and defendant produced none of the media files that he sent to ABMC. Again, eat my entire ass. Hannah Brooke. Brooke attests that defendant deleted his messages to her on Discord sometime in early February 2025 because Hannah was leaking our DMs and just Discord server, but she also has nothing at all to do with this court case. Defendant admitted communicating with Brooke on Discord and when asked whether he deleted those communications, conceded it's possible.
Plaintiff requested the Brook communications, but defendant produced none. I thought we did. If I had him, I produced them. Witness A. Sometime after January 21st, 2025, defendant deleted the messages between witness A and him on Discord and removed her access to the Google Drive containing the explicit content he had shared. They try to make this weird argument of um like I that I had some massive This was a Kiwi Farms argument that I just had some massive Google Drive folder with every [ __ ] video I'd ever recorded. I think they're like alluding to that here. Defendant produced no communications with witness A. I don't I don't even know who this one is. Witness B. Defendant admitted to witness B that he shared her video with Rose. Witness B sometime after the November 29th, 2024 leaks. Witness B discovered defendant had deleted messages between them. If that's the uh S person, I mean, they deleted their messages with me first. I don't even know what this again, this has no relevance whatsoever to our case. Um, why are they obsessed on getting their entire hands of the actual vids? Can you explain? Because Pixie shares all of the stuff that I've given her in Discovery.
She shared it with Lauren. And I know she has because Lauren has gone around behind the scenes talking about it because they're both disgusting, groy pieces of [ __ ] What was this page seven judge quote? Oh, and I will tell you that even as you've pled it so far, and we'll see what the defense says. But if I got sued for distributing the materials about a woman, and I may have done that with other women, then I might say to myself, maybe I shouldn't do that anymore. Let me delete that. Let me take that back. Let me not do those things I'm being alleged that I'm doing because maybe those things are bad and I shouldn't be doing it. That may be one of the things that's going on. That's not spoliation. I don't know. Some of the stuff that that's in this motion, I'm not finding on its face what the connection is to this case. I assume you will make that argument to judge Torres and connect it up to how it's connected to this case because some of that I don't know is a spoliation issue even, right? At least how you've pled it so far or how you've argued it so far. This was during the when they were arguing for their temporary restraining order. I think the defendant deleted his side of his discord communications with plaintiff from her review, leaving her unable to access his messages. The defendant produced a two-way Discord chat thread with plaintiff. But defendants's transmission of intimate images are not visible in the thread itself. And he produced none of the underlying attachments. They're not I don't know if you need those. I don't know if they're relevant. Like I think um I don't even know why she would think those are real when they're claiming that every single thing I'm producing isn't authenticated anyway. All I know is that if they asked for it, we produced it. But I'm just curious how this works. If you back up the Discord logs and then delete them and pliff wants to back it up as well, she won't be able to. No. How can it be checked if you tampered with the evidence of that point? How is that handled? It's this is civil court, bros. It's like if the evidence is what it purports to be and seems to be the way, then you just accept it as true. Now, I think that also or I think we could have a discussion if they're providing evidence and it's different than mine, then I think that's then maybe we would get more into the arguing that would be a material dispute of fact that the jury would have to decide, right? Well, he's producing logs that show this. Well, our logs say this and now the burden is on the parties to explain why are these different and they would have their argument and I would have my argument.
But in this entire court case, they've produced absolutely [ __ ] nothing on their side. It's just them endlessly trying to needle my evidence that I produced for not being good enough.
That's it. But also, how was it on my side to preserve evidence for this court case starting on November 24th, 2020 or November, whatever, 2024th, but not on the plaintiff. Also, the only person who's admitted to deleting evidence and not backing it up in this case is Pixie to Steelman. Are there cases where your side actually makes the other side unable to produce evidence? Then then you can't win those cases. What do you mean? You can't sue somebody and say, "I'm suing them for a thing they did wrong and I think they had all the evidence for that wrong and they deleted it and I don't have any evidence of that." That's not justable. What the What's the court supposed to do? Take out a [ __ ] uh magic eightball? The defendant has made three distinct productions concerning his communications with ABMC. Compared against one another, they established both fabrication and destruction.
The two-way Discord Discord chat thread, a 36-page chronological tabular export of Discord of Discord direct messages between defendant and ABMC covering March 7th, 2023 through May 7th, 2025.
I like how even in my deposition where they were deposing me, every baked stamp was an SB.
Everything was stuff that I'd provided.
They couldn't there was nothing that they even had to ask me questions about for stuff that they' produced. I don't know if there was a single exhibit that they had from their side. They didn't have evidence. They have no They have no evidence for this case. They have nothing. Every log is mine. every the bait stamp is just marking stuff that has been made available uh during a discovery. So SB that bait stamp is for Steen Bunnell and then this is a specific document that's being referred to. Didn't they ask you about the ABMC screenshot? Oh, they had they that was theirs. I think they did produce that.
That was theirs. The thread contains four Google Drive URLs defendant transmitted to ABMC in 2023.
April 24th Google Drive URL proceeded by defendants message. I've got a five-minute video of me eating someone out. Do you want it? May 5th, 2023.
Google Drive URL preceded by defendants message. Did I ever send you the one of her blowing me? November 3rd. Two consecutive Google Drive URLs. The thread also references numerous audio recordings, video files, and other media defendant was sending or had sent to ABMC. But the transmissions of those files are not visible in the thread itself. And the underlying files were never produced each [ __ ] Only the transmissions from ABMC to defendant are visible. and only those underlying files were produced.
The one-sided Discord export. Defendant produced a 106 page. Dude, my production compared to these [ __ ] losers is unreal. Defendant produced a 106 page export captioned for the username ICER and rendered in the Discord visual interface. The export covers the same time frame, but contains only ABMC side.
No responses from defendant defendant appear for more than 2 years until May 1st, 2025.
The two productions display different usernames for the same person, confirming they were generated at different times and contradicting defendants sworn statement that he preserved the entirety of his AbbeyMC communications.
Well, depending on when I take uh an export from Discord.
It's going to depend on what her name is probably rendered as. Like it's just so like they're just trying to throw up um they're just trying to throw up a um enough smoke to survive the MSJ because there is no possible way to get other people's messages from Discord. I don't know why I'm explaining this to you guys, but like even if I were to ask for a Discord export of the data package that they have for their GDPR compliance, that only has my messages.
It doesn't have anything from the other person. You have to use a third-party tool. Uh I think I usually use Discord chat exporter. You have to use a third party tool in order to export the other side's conversation.
So, how do they know the May 5th video is Pixie? They don't. But they're just saying maybe it was. It wasn't, by the way, because these two, this this is a this is a set of um Google Drive URLs that is a video of me eating somebody out and then I think them blowing me.
But they know for a fact, they know 100% that this can't possibly be the Pixie video because in the messages that follow this that I have produced to them, they've seen um I'm pretty sure I talk about busting into this chick's mouth, which Pixie is not able to happen there. So, they know that this video can't possibly be that, right? And then me and Pixie didn't record any videos whatsoever relating to me eating out at all. Not that I'm aware of unless she's secretly. So this also can't possibly be her video. So they know for a fact. They know 100 million% that neither of these videos could possibly be what they're looking for. They know that. Confirming they're generated at different times. Blah blah blah. The thread in exhibit D also references numerous audio recordings.
Blah blah blah.
Wow. God hates protos. Thank you for the five tier one subbers.
Defendant self-prepared exhibit E. On January 30th, 2026, defendant filed in support of his MSJ a declaration of varying. Attached here to his exhibit E is a true and correct log of every media file and Google Drive link that I ever sent to AbbyMC. And I have preserved the entirety of my communication logs with ABMC, including all media files. Exhibit E lists 22 entries between March and November of 2023. Only two are Google Drive links, both November 3rd, 2023.
Exhibit E, it's I don't know how the [ __ ] this would have happened. I guess it's possible that I didn't copy two links here onto that um onto the exhibit list here. I would have to go back and check how I could have how that could have even happened. But the only reason they even know this is because I gave them my full conversation history with ABMC. So like on one hand my conversation history with her is doctorred and unreliable but on the other hand it's so reliable that they are trusting to use my own doctor evidence to impeach me about a like a spreadsheet that I made of all the files that I had sent to her. Like also by the way when did I make this production? Is that date listed anywhere? I'm pretty sure we produced these files back in [ __ ] 2025.
Like, why not ask for an explanation or ask for a different compilation or whatever you feel like something like nothing here was discovered after my deposition.
Nothing here was discovered, you know, in the past few weeks. You you were sitting on this stuff for months, maybe for a year. So, what why why did we wait so [ __ ] long to file this? And defendant has produced none of the 22 items exhibit E identifies as having uh been sent. The underlying Google Drive files are not existing anymore. Again, I'm sorry, you disgusting piece of like [ __ ] sand, whatever the [ __ ] The idea that you think you can sue me and then start naming random [ __ ] witnesses that have nothing to do with this case and then ask for dozens of videos of jerkoff material of me, you are out of your [ __ ] mind. I cannot One of the most disgusting requests I've ever seen is that is that nasty [ __ ] e whatever begging me for [ __ ] porn videos of myself and other people literally eat [ __ ] How [ __ ] gross. The defendant has thus in a single filing sworn that 22 specific items of responsive ESI existed within his control and failed to produce any of them. The destruction is conclusively established by defendants's own admissions. There is nothing about any of this that says that I have to every single underlying media file.
Chances are the underlying media files of these Google Drive links were probably deleted years ago, but okay. Defendant's deposition testimony confirms that he possessed the very record his productions lack.
But how do you even know that I'm missing something unless it's because you see it in my productions? How does that make sense?
How does that make sense?
To create exhibit E, defendant sorted all the sent messages to ABMC's Discord account. And then he deleted every message that didn't contain a media file and put into a spreadsheet the timestamps to which he sent any media files. The source he used was therefore a complete chat thread containing every outbound message defendant sent ABMC with each attachment identifiable by name and timestamp.
No. What?
No, it's just the same [ __ ] log that I produced up here. Does she think there's some other like they're pretending like there's some more?
Aren't they saying there's a discrepancy? Yeah, I don't know how the [ __ ] this happened. I would have to go back and check. Maybe something in my workflow explained this. But basically, I provided like it was what did they say? 106 pages of my chat logs with Abby. And then from here to try to show that like I've never sent Abby the any [ __ ] videos related to [ __ ] Pixie ever. Um from this 106 pages uh I created a spreadsheet that showed here's every single media file link attachment or whatever that I've ever sent to Abby and like you know I can source I through other conversations like here's where all of these things are. Here's what they link to. Like none of these had to do with um none of these had to do with uh Pixie or the plaintiff. But they're saying that if you go through all 106 pages up here, there's actually 24 links. There's two Google Drive links that I didn't include down here. Um, which I'd have to go back and check. I I don't think that's true. Maybe maybe I [ __ ] up my transfer from here to here.
But regardless, first of all, it's not like I'm hiding it. Like the most obvious explanation here, keep in mind for expoliation that they're looking for for this adversary reading, you have to show that I'm intending to doctor and destroy evidence. Why the [ __ ] would I Why would I give you the links up here and then try to hide them down here?
Um, so it's just so stupid. Also, I know the text because I remember reading these books many times. I know which videos he's referring to and they know that these videos aren't of the plaintiff.
They know it. They know that 100% guaranteed.
Yeah. What you're really looking for though, what should have happened was after they realized this, they should have filed a motion to compel to for me to produce the stuff that they claimed I was not producing. And then my failure to comply or to comport with the motion to compel and then more naturally leads during discovery, by the way, I think more naturally leads to the expoliation claims. But how are you going to claim spoliation when you didn't even ask us for this?
And you even had some of these. It's just like so [ __ ] so stupid. I don't even know where they got this theory from. I don't know if this was a kiwi. I haven't read my kiwi friends in a while, but I don't know if this came from um um if this came from I don't even know what I just said. Oh, where this theory came from. I have no clue.
The defendants produced at separate bait stamp numbers the attachment files IBMC sent to him but produced no attachment files that he sent to her because her because she hasn't deleted any of her Discord messages. But there there's no way to back up. Even if you ask for Discord to send you a backup, Discord doesn't send you an attachment. It only sends you the link to Discord CDN but produce no attachment files he sent to her in any form under any Bates number.
Either he still possesses them and has withheld them. Where's the motion to compel? Or he destroyed them after January 30th, 2026. Or he modified the source to strip the his outbound transmissions prior to production.
Excuse me. evidence. Hello.
What the [ __ ] Each scenario is destruction or non-production of ESI defendant himself confirmed under oath having had in his possession.
Defendant also admitted that exhibit E was manually fabricated.
on a public food shop live stream broadcast on September 8th, 2025, one week before he filed exhibit E. The defendant told his audience, "Information is lost. There is no original file. I'm trying to reconstruct a file. I'm artificially creating a file by reconstructing a log." At deposition, he testified that he was merging files with different timestamps. Unix code versus universal time code to make it line up. How does that support your How does that support your statement up here? By the way, there is no original file. That's just true. There is no native non- third party Discord logs.
That's there's that's just a fact. I'm sorry, but there's nothing she submitted to compare to. I feel like a comparison with what she submitted would be the strongest argument. That's cuz you're [ __ ] [ __ ] and you're thinking like this is a real court case with real claims.
No, there is nothing. There is nothing to compare this to. That's why there hasn't been a single time in this entire court case where the plaintiff has said, "We are seeing this on our side, but the defendant hasn't produced anything that seems to line up with what we're seeing or what they produced was in contrast to what we have." Like they have nothing about that. Nothing. Nothing.
May 5th, 2023. omission is independently dispositive.
Also, keep in mind that AbbyMC, and I know why she said this, by the way, is because she was just looking back at her own [ __ ] um messages to try to make up whatever sounded believable. Abby in her two sworn declarations, she said that I sent her the videos in November.
So, why would this May 3rd thing or May 5th thing, why would this have anything to do with anything?
But okay, I guess we're just changing the date on that.
At 23252 59, defendant sent ABMC the message. Did I ever send you the one for blowing me? He sent the Google Drive URL. The URL is now dead. The underlying file is destroyed. The link does not appear on defendant sworn true and collect log. Like the log, this is an artificially constructed thing. Why don't they bring that up? The log is just me copying every single thing from the 106 pages of discovery for her conversation. And it's just me producing like, well, here's a log of every link I sent.
[clears throat] If the link depicted plaintiff, defendant made a postcardy transmission of intimate content of her, establishing the very transmission his MSJ denies.
Oh, so if you just bring in every single person and then you have them say that I can't reproduce every single underlying file for every single Google Drive link I've ever sent in my entire life. Every single one of those could be Pixie's video.
If it depicted any other individual, defendants sworn completeness statement is independently disproven. Either scenario establishes intentional expoliation.
ABMC's October 12th, 2023 message in the produced thread, I still watch the BJ video, supports the inference that what defendant sent on May 5th, 2023 depicted plaintiff more than a year before the leak. ABMC was openly referring to a BJ video defendant had sent her, and that video does not appear on exhibit E. What else did she say about the video, though? there. It's like very clearly and very obviously not the same one. But do you think that Jane Doe's parents would bribe people like Abby? I would do this if if I was in her position and have loaded parents who seem to pay for her life. I don't know who bullied Abby.
My guess is logistical on them. I do know that I've heard people tell me that Abby said that her father was going to put a hit out on me uh prior to doing any litigation. My guess is he reconsidered because I'm like an e celeb and it would be [ __ ] [ __ ] to so I don't know how serious that was or not.
Maybe he was just mad. Who the [ __ ] knows? Um I don't know. But plaintiff's forensic expert confirmed the [snorts] destruction and fabrication. His report is unrebuted.
Plaintiff provided the expert report of Jesus Pena to defendant on October 16th, 2025 in compliance with the scheduling order. Here are the principal findings.
Exhibit E's timestamps are offset from the chat thread by 10 hours and offset corresponding to no genuine time zone conversion and consistent only with manual reassembly. Like I you really brought in you really brought in an expert witness to nitpick the [ __ ] out of the only logs that have actually been submitted in this [ __ ] case. Really, that's what we're doing.
How did you learn about the idea to put hit out on you? Um, people contacted me, more and more people have been contacting me after stuff, more stuff has come out, um, telling me of more of the plaintiff's behavior towards the beginning of this court case.
Um, what else did this [ __ ] tip should say? the defendants preservation uh method. A third-party tool called Discord log exporter producing an HTML file converted to PDF stripped group message timestamp metadata.
No cryptographic hash values were generated. Again, this is just like a [ __ ] thing that they just keep saying over and over and over again. At the time of preservation or export, foreclosing forensic verification of authenticity. This statement, this is a meaningless statement. The defendant conceded this at deposition. Where is the quote? [laughter] You're telling me that we did six hours of deposition. You couldn't even pull a single quote out of me to to justify this. You couldn't even pull a quote out that looked good. Remember what I said during the deposition? One of the big issues was Joanne or Joan doesn't know anything about like tech. So, she would ask me questions and I would get to answer with a crystal clear explicit answer that was just immaculately preserved for the record in my opinion.
And I guess it actually was because she couldn't even [ __ ] pull a quote out of it to to ver to back up like what she's saying here. Jesus.
The Google Drive files and Discord attachments have been transmitted to ABMC unreoverable by defendants's own act. Defendant testified that by the time I produce anything for this case, those files are not existing anymore. As to native Discord attachments, when a center deletes an attachment, it would delete it from the Discord core servers and then the CDN cache servers.
Defendant admitted running a whole redact of his Discord after the January February 2025 leaks, which was way before anything having to do with ABMC, but it doesn't matter because I still at least have my text logs.
But it's also really [ __ ] because well, they know this. That's why they're running with this new argument of well actually in November right as soon as his stuff leaked he should have known that he was going to get sued by Pixie and that's why he should have preserved every single thing. He should have deleted or wiped or archived any single thing across any of his social media ever because any of those it's like okay dude no matter how [ __ ] it is any push back you offer useless because you are not an expert. Um, I don't know what the case is for us having to get an expert or if we still do that or what it looks like challenging his expertise cuz I think you do a is it dowert or da dber dot before um you go to the judge and challenge his expertise. I would hope he would get to do that before and then he would get thrown out. But the defendant has not rebutted any of these findings.
He served nobert motion within the scheduling order deadline. Never deposed pena. served no interrogatories or document requests directed to the Pena report and disclosed no rebuttal expert.
Um I think our motion I think was after discovery closed. I think it was in the last few months I think. I don't remember. Um there was no reason to depose Pena. I don't know what the [ __ ] I'm not going to pay $50,000 for that.
Serve no interrogatories or document request directed the penny report. I don't need to request documents from Pena. All of his findings were already published on Kiwi Farms in a public forum. So his belated objection to a single footnote of his MSJ reply is procedurally barred and lacks a legal basis.
Pena has further declared that Discord's native data package is the best evidence a user can source for outgoing Discord direct message communications. That data package also doesn't include any of the underlying media attachments.
outgoing direct message communications.
The third party tools defendant has described using Discord log exporter, Discord chat exporter, and redact may capture two-sided conversations but generate no cryptographic hash values.
Discord the Discord data package doesn't generate any cryptographic hash value.
Does it? Does Discord have it anywhere?
I don't know if I've ever seen in my life. What?
No, there's no there's no nothing in here is media attachments.
A data package requested after deletion does not retrieve deleted messages and the defendant admitted he requested his package only post deletion.
I don't know if I said that. I feel like I've had multiple data packages that I've requested over time. But also that means that the cryptographic hash doesn't matter if you could still delete messages before requesting the the package. Like you understand that how f this is self-defeating. The logic is self-defeating here. It's [ __ ] [ __ ] Defendants claim that there's not like an original Discord file. It's just a term they've made up. Is forensically incorrect, but there's not. You lit Discord is not a one-way communication tool. It's a two-way messaging application.
There is no way to export a full conversation using Discord's data request, but okay.
Defendant refused a neutral forensic examination. On September 18th, 2025, plaintiff's council proposed a neutral third-party forensic expert to examine defendants preserved forensic images and data exports with mutual candidate selection.
What the [ __ ] I don't even know what the [ __ ] this was. This sounds [ __ ] What? For a civil case that you provided no evidence for? Why the [ __ ] would we even do all this [ __ ] What are you talk? These [ __ ] are acting like we're in the [ __ ] CIA. What?
With mutual candidate selection, a protocol narrowly limited to Google Drive, Gmail, and Discord artifacts, and cost shared equally.
Defense council refused. Uh, defendants refusal of a neutral, narrowly scoped, cost shared validation is itself probitative. Shut the [ __ ] up. Oh my god.
What is probative? Means that they can alien probe you. Probative means it um it has uh some kind of ev evidentiary weight towards the claim of basically it's probative. It can be used to say that there's a more than like some increase or decrease the likelihood of something being true. I think it's probative. I think the three preconditions for rule 37E relief are met. The ESI should have been preserved.
Litigation became reasonably foreseeable no later than November 29th, 2024 when the leaks occurred. Maybe for solo.
The category is at issue. Defendants communications with plaintiff ABMC Brooke witness A and witness B. His Twitter communications with Rose. His communications with solo tenny leaks.
And with the seven non-party witnesses defendant himself identified in his initial disclosures and the Google Drive files and discord attachments he transmitted IBMC are squarely within the scope of evidence defendant was obligated to preserve. I guess I'm I guess I maybe this is good for me. I guess or it shows that they're desperate cuz I feel like if you overshoot so hard on some of these um that if you lose on any of them the judge is going to say this is you guys are [ __ ] [ __ ] The ESI was lost because defendant failed to take reasonable steps.
Defendant testified that he was not sure what a litigation hold means [laughter] because I I asked her to clarify the question. She said what was her question? It was something along the lines of um actually wait I just [ __ ] go find it. Oh, what a sneaky little very very very sneaky.
[cough and clears throat] Oh, I don't even know what the [ __ ] this question means.
Her question to me was, "Did you after you received the preservation letter, did you place a litigation hold on your DGG chat logs?" And my response was, "I'm not sure what a litigation hold means.
I don't know what the [ __ ] I don't even know. I don't I don't know. She She's just like random [ __ ] that she just makes up. She just makes up terms, I guess.
Destiny, is this current explosive outburst due to your narcissistic rage?
Yes, true.
Instead of investigating his obligations or requesting clarification, he conveniently instituted no hold, issued no preservation instructions, made no forensic image, used no forensic collection tool, engaged no eiscocovery platform, implemented no collection methodology, engineering, no hash resid.
Excuse me. This question was with regards to my chat. This was with regards to my DGG chat. I like how they're trying to pretend like this was my response to everything having to do with all of our Discord messages. Oh, sheesh.
He continued deleting Discord communications after his duty attached and his nominal preservation, a Discord log exporter HTML to P PDF output was forensically unound on his face.
Defendant also failed to preserve Google Drive activity logs that would have established when and by whom the Pixie video was accessed on his Google Drive.
Is there What is a What is a Google Drive activity log? This is the first time I've ever heard it in my entire life. What is a Google Drive activity log?
Is this a Is this a real thing?
Google Drive activity log. The Google Drive activity log tracks historical file changes such as edits, renames, deletions, and sharing updates.
Oh [ __ ] Hey, this might actually be helpful.
[ __ ] I wonder how far this goes back.
Destiny, I think she means legal hold.
It usually just means that you preserve and do not delete data that might be related to the case. That's on her to define. I'm not gonna I don't It's not my [ __ ] job to clarify her [ __ ] question to me. I don't know what the [ __ ] it means when you ask me to put a litigation hold on a public chat room.
If you don't know how to properly phrase the question, then that's on you. Figure it out. Rephrase the question or figure out how to ask something meaningful. I'm not going to sit here and do your [ __ ] job for you to figure out how to ask a meaningful question about preserving chat logs. This that's a meaningless question to me. That's that's on them. Yeah. I'm not here to do her job for her. [ __ ] that.
Did they submit the DM from Disco this way? No. All of their submissions have literally just been um screenshots, edited screenshots. Also, by the way, it's bullied. It's bullied. It's bullied. It's bullied. Just kidding.
[snorts and laughter] Okay, where were we?
Um, defendant on stream screams, bullied, bullied, bullied.
Plaintiff has subpoenaed third party platforms and pursued all available alternative avenues. What if you you subpoenaed Discord and I didn't give you all my DMs?
Even if the defendant were now ordered to produce the source record he admitted having on January 3rd, 2026, the ESI lost a plaintiff cannot be undone. Fact discovery is closed. Defendant's deposition was conducted without it.
Expert reports were filed without it and the trial preparation work product plaintiff would otherwise have generated has been irretrievably misdirected. The defendant has a continuing obligation to update discovery as it becomes available but never did. Why didn't you file any motions to compel then when discovery was open? You had all the time in the world. All the time in the world to file any of nothing has changed. You had all this discovery produced you for a [ __ ] year. I think [sighs] defendant acted with intent to deprive plaintiff of the use of evidence. Yeah.
Okay. The defendant has made six demonstrably false sworn statements.
[laughter] Each of the following sworn statements is provably false on the face of defendant's own subsequent production, deposition testimony, or live stream admissions. Exhibit E is not is u oh exhibit E is a true and correct log of every media file in Google Drive link that I ever sent to ABMC disproven by defendant's own chat thread which shows him sending IBMC Google Drive links on April 24th and May 5th. Neither of which appears on exhibit E.
Exhibit E is literally just a it's literally just a compilation of of what I thought were all the media files sent in the larger um blog. It's it is possible. I guess maybe I didn't add two to the bottom thing. But like for expoliation, you have to prove intent.
Why would I intentionally delete these links that I that I that are included in the above reference log? That's the only reason you even know that they were there. It's just such a stupid argument.
I have preserved the entirety of my communication logs with ABMC including all media files displayed in its own production. None of the 22 items uh exhibit E identifies as having been sent to AMC was produced and the underlying Google Drive files are not ex I mean the logs like logs I don't know for the underlying media itself but I don't even know what this was taken from. I have not permanently uh deleted or destroyed any evidence pertaining to this lawsuit disproven by defendants's own production and his repeated public concessions that the records have been destroyed uh source and that exhibit E is a reconstruction.
If exhibit E is a reconstruction, then why do you care what appears or doesn't appear on exhibit E? Like this is the most convoluted argument ever. They're saying that exhibit E is an artificial file, right? This is their quote from my food chops video. There's no original file. I'm artificially creating a file by reconstructing a log. So they're claiming that exhibit E is fabricated.
But then they're saying that I didn't include two links from a chat thread that's also fabricated on my other fabricated thing. That's all fabric.
It's just like defendants denial of plaintiffs RFA number 12 which asked him to admit he had deleted DMs with Discord user liquid. They included a bunch of like random people but none of these people have anything to do with this court case. I don't know why the [ __ ] they thought Dan Saltman is founder or why they would have any access to any of these messages, but okay. Dan Saltman is founder and CEO of DACA.dev, the tool defendant claims he used to preserve evidence. Oh no, it wrote [snorts] it's deep, guys. The defendant produced no communications with Saltman despite confirming their business relationship and friendship. H you know what you could have done if you think that I was communicating with uh Dan about this court case in a way that was trying to hide it from you guys? You could have just deposed him. Why didn't they Why didn't they issue him a subpoena or try to depose Dan? H In fact, did they do a single [ __ ] deposition besides mine and um uh Roses that they were so [ __ ] horny and excited to do? I'm pretty sure all the other requests were mine or I guess all the others is not that much because I requested um they would have requested two. I would have requested one, two, three.
Oh, I wanted to do Aby's but she wasn't anywhere to be found.
Four to two. That's a considering it's I'm the defendant. I feel like the plaintiff would generally you produced way too much. That's why it's easy for them to throw so much [ __ ] and make us sound important. Yeah. I wonder actually. Maybe I don't know. Maybe I'll ask my legal team out after this. Should we just not produced anything? [snorts] Said [ __ ] it. [clears throat] Also, by the way, you can tell every [ __ ] I talked to around me, I said, "Hey, I'm not talking about this [ __ ] anymore.
Scorecase [ __ ] Don't care. Don't talk to me about it. Talk to it after." But if they don't believe me on that, then why didn't you depose any of these people? Why didn't you subpoena any of these people? If you think that I'm hiding stuff, go ask them.
Defendants testimony that I produced every communication I've ever had with Abby, and I don't believe I permanently lead an AMS with Abby at all. Disproven by the production itself. The two-way ABMC thread shows ABMC's transmissions, but none of the 22 outbound items defend its own exhibit E identifies. Exhibit E is literally just a spreadsheet I made showing the um the things that were part of the chat messages that I included above. It's just a spreadsheet. A Discord thread cannot be complete and missing one party's transmissions.
Defendant either deleted his outbound transmissions or fabricated a complete production by stripping his outbound transmissions from a more comprehensive source. It's just not true. What did they put for Dan here? See, Daniel Saltman, LinkedIn, Dan is the CEO and founder of Redactive Dev. Plaintiff respectfully requests that the court take judicial notice of Saltman's public identification as founder and CEO of Redact. Nice. Oh, cuz they want to get Dan's name thrown in here as well. What a disgusting little [ __ ] leerous like [ __ ] What an unbelievably disgusting human being. A pattern of six demonstrably false sworn statements is direct evidence of a purpose of hiding adverse evidence. Wait. Um, what I don't get is how does getting Dan's name in the case help them? It's not. It's just about like having his name here that people can link and try to disparrage him for [ __ ] Hassan himself might have [ __ ] told Pixie, "Hey, throw Dan in there." It wouldn't surprise me if Hassan's already referenced it. Did you know that Dan Saltman is a revenge porn court case? The defendant selectively preserved evidence that helped him and destroyed what did not. Defendant has admitted his deletion practice is selective and account dependent. asked that deposition whether it was his custom to delete messages when he stopped communicating with people. The defendant answered, "Sometimes it depends on the account." [laughter] What? This is your really?
What a crazy answer. Oh my god. What did he really say that he did not delete his messages with Rose? Uh, I did. Don't know where you're getting that from.
That's a [ __ ] lie. As to Abby, he did not deny deleting, stating only that there are plenty of other people I've deleted messages with. Oh my god, bro.
They must have been having a struggle session after my deposition. Holy [ __ ] We got to be able to pull something out of here, guys, cuz we literally kicked up a [ __ ] [ __ ] stom over having this deposition for so many [ __ ] months.
We got to pull something. Oh my god.
Quotech chimping. It's not even good quote chimping. Like it's just just like uh the production confirms the selectivity.
Defendant retained the full two-sided rose discord thread which was not publicly available. That two-sided disc the two-sided rose thread was just that's not from Discord though. That's just a Discord chat exporter chat thread. Solo Tiny Leaks leaked only excerpts but deleted his Abby MC side and produced two inconsistent versions of the thread. The only outbound intimate content attachment defendant produced anywhere in his production is the video of plaintiff transmitted to Rose on April 9th, 2022. The one video solo tiny I don't even know if that was part of my Rose production. The fact that this bait stamp is so far away from this one makes me think that it wasn't even part of the same production because the bait stamps for the full convo with rose was 1618 to 919.
This is 500 documents later. My guess is that this probably wasn't even related to the one video solely solo tiny leaks had publicly leaked after which denial was no longer realistic. Every other outbound attachment is missing.
Defendant produced his received attachments at separate bait stamps. He produced uh he produced no send attachments on any form. The asymmetry is not preservation failure. It is selection. The defendant has twice admitted the destruction of his ABMC communications was an intentional carveout on redirect by his own council.
I produced every communication I've ever had with Abby. I don't believe anything has been deleted with the Abby stuff.
Even though I'm pretty sure the request for the preservation of evidence wouldn't have even initially covered Abby. 2 weeks after his deposition, he stated on live stream. Wait, where is the carveout? I produced every communication I have ever had with Abby.
I don't believe anything has been deleted with the Aby's stuff. 2 weeks after his deposition, he stated on live stream, Abby was not a part of the court case at the time, though. So technically, I could have just said I have nothing wrong with Abby, and I would have been fully within my rights to wipe all of it. my rights took my right to wipe all of it, but I didn't.
Can you read? I could have, but I didn't. The point is not the defendant wiped all of the ABMC material. He produced chat threads with critical content and metadata missing. This means nothing. The point is the defendant has admitted twice and under oath that he believed the ABMC communications were outside the scope of his preservation obligation. I mean, they were, but I produced it anyway because I archived all of it. That admitted state of mind is direct evidence of intent to deprive.
A litigant who believes responsive material falls outside his preservation duty has the requisite mental state to destroy that material selectively. How could responsive material fall outside of my preservation duty? If it's responsive, then wouldn't that be within my preservation duty? I don't understand. I don't even know what the [ __ ] that means. Defendant did exactly that. He kept the messages while destroying the attachments, the items that would have directly evidenced the cardi transmissions at the heart of this case. Oh, the defendant produced nothing for the categories of documents and individuals he himself identified as relevant. I said these people might have information. That's it. That doesn't mean I'm producing every single conversation. Again, they literally could have asked I don't know why they have some names up here that I don't think they should, but whatever. He produced zero communications with the seven non-party witnesses he himself identified including Cherry and Lauren de Lagona with whom he acknowledged intimate relationships has nothing to do with this court case. I haven't spoken to either of them with regards to this court. I don't know what the [ __ ] they like if you wanted any of this. You could have just asked. A litigant cannot identify witnesses as having discoverable information. I'm pretty sure for interrogatories it's potentially discoverable information and they're quite broad is my understanding.
Either his initial disclosures were false or he destroyed or withholds what he himself swore was relevant. Plaintiff served a third set of RFPs on November 16th, 2025 specifically reaching communications with fornamed individuals about plaintiff. Uh the defendant objected that concerning defendants um use of law is vague and ambiguous and assumes facts and evidence irreconcilable of his own. April 25th blah blah. Okay, good [snorts] one. This motion is timely. The standard is as soon as reasonably possible after discovery of the facts that underly this motion. H destiny and people wonder why you were so careful in how you replied to Willie Mack. H really makes you think pursuing discovery about discovery tolls the spoliation filing obligation. Um the rule 372 intent to deprive element typically cannot be established without the spoliator's own deposition testimony and the advisory committee note expressly contemplates the intent finding may be made by the court on a pre-trial motion. They also apply the multiffactor test timing of motion prejudice reasonable explanation closess to trial each factor supports. Why did but no so stupid. Is it justifiable and defendable that I now blame Lauren more for the case than I blame Pixie? I mean I don't know they're both adults and they both should know better. Remind me again what they wanted you to turn over.
It's they it's nothing. They just they're trying to find any hole they can to do like a God of the gaps argument, but with Pixie's porn videos. It's like they're trying to say like, "Oh, we don't have this particular thing here, and even though we never asked for it, we think that that's where the videos were." Proposed neutral forensic examination. What a worthlessly unlicable, inapplicable phrase. Jesus Christ. The presumption that destroyed evidence was unfavorable to the foliator is itself the evidence on which the merits dispute is resolved. applied here. The court is authorized to establish as a matter of fact or to instruct the jury that the destroyed Google Drive files the defendant transmitted to ABMC on April 24th, May 5th, and November 3rd, 2023 contained one or more of the three intimate recordings of plaintiff the defendant admitted at deposition he made. We made with that presumption in place, two undisputed facts complete the merits analysis true based Jesus text to proposed order. What happened to innocent until proven guilty? Why does the defendant have to prove the innocence? It's I mean this is just a request they're making. This is their motion. We should just get the whole case. The whole case should just be awarded to us based. But if you decide not to just win us the whole case based on this motion, but we're we're just going to go ahead and say that these two Google Drive files definitely were the plaintiff's video or we're going to have to say that the jury must presume that these were the videos of the plaintiff plus attorney's fees.
Actually, king queen behavior.
Apparently, exhibit J and M have unredacted names that shouldn't be there, but much concerned at all about this. Um, I mean, I I don't know. I don't know about anything. I don't think so. I mean, it's all [ __ ] Like I said, the only thing that is a concern is could you possibly like kick up so much dust that the judge is like, "Fuck me, dude. I don't [ __ ] know. It's too much. I don't know. This [ __ ] is complicated." You know, go to go to trial. But I don't know if um I mean I like the triing would be annoying just because it would be three more months of me being in limbo. But I mean at this point like how many months are we into this?
These are just the questions I think that they asked. At the end of the day, isn't it plain's job to produce evidence that transmission happened after Cardi took effect? Yep, they have. And their evidence is ABMC's hearsay that she [snorts] said like it was her saying on that whatever redacted Discord message assuming that's even what that is. I don't even know because it's so [ __ ] telling somebody three years ago that I sent her a video of Pixie and that but that's the only evidence that they have is that her DM to the I think it was Snick dude but that's but they have no other evidence.
So, it's the whole assuming we go to trial.
Um, the entire court case is just going to be Abby on the stand trying to prove that I sent her a video that I'd never sent her. Nothing changes. The MSJ MSJ still comes down to if the judge thinks it's likely that ABMC uh will testify that she received the videos. A MC did not respond a subpoena or deposition request. I don't know if that's enough to save it. I could be wrong, but I don't know if it's strong enough evidence to take a case to trial.
Is it? If you just have a friend who says, "I got a video," and their only evidence is them saying, "I got a video," but they don't have a log of it or anything. If you were to take that up through like an MSJ, even if she were to say that, like, "I'll testify in court that I got the video, but I have no evidence or proof of it whatsoever."
Would that survive like an ordinary reading of that? I don't know. Maybe. I have no idea. Destiny, it would technically be up to the jury at that point, but like, well, there are some standards for an MSJ. Like I think you have to read the evidence in the most favorable to the against the movement, but you don't have to read it as being 100% true like you would with a motion to dismiss. But I I don't know like what the standard is for how much they would let that dispute go. I don't know. I also don't even know like assuming you got through that court case. I'm not I'm still not 100% sure how damages are calculated. I know that there is a statutory amount listed, but I don't think that statuto amount is necessarily guaranteed. I think that's like a cap on what you can get, but I don't even know what damages they'd be able to talk about because the It's not like Abby posted it anywhere. So, I don't even know. Like, even if they were to win through all of that, I don't even know if that goes anywhere. I I I don't know.
I have no idea. I don't think it's enough. Jane do skipping her deposition without notifying the court was so crazy. No, it wasn't. Nobody gives a [ __ ] It doesn't matter. Do whatever you want.
be um be ungovernable, I guess, because there's no consequences for literally anything in this in the current era of law in the United States.
What can be done about this offensive slush fund situation? Well, I'm going to get evidence that Lauren Deaguna pushed this court case against me for lawfare purposes and then I'm going to try to apply to that slush fund and I'll get money from it. Okay, that's what we got to do.
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