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Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 3 of 10 BOIES, SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -3- Confidential Sealed Filing involvement in the sex trafficking ring, like Ms. Giuffre, Ms. Ransome was also required to engage in sexual acts with Jeffrey Epstein and Alan Dershowitz. In addition to spending time with Jeffrey on his island, I spent time with him in New York City...Among the people he lent me to was his friend Alan Dershowitz. On one occasion I was in a bedroom at Jeffrey’s New York townhouse with Jeffrey and Nadia Marcinkova. Afier a short time, Alan Dershowitz entered the room after which Jeffrey left the room and Nadia and I had sex with Dershowitz... See Exhibit A. Affidavit of Sarah Ransome. The testimony of Ms. Ransome goes to the heart of this defamation claim — whether or not Ms. Giuffre was truthful in her claims about Defendant’s involvement in Epstein’s sex trafficking ring, and the Court should allow the jury to hear her. Ms. Giuffre Has Diligently Participated In Discovery And Promptly Disclosed Ms. Ransome After Conducting Due Diligence Defendant also insinuates that Ms, Giuffre has delayed in disclosing Ms. Ransome. But as the Court is well aware, Ms. Giuffre has previously diligently disclosed close to 100 individuals who may have relevant information in her Rule 26 disclosures, By contrast, Defendant’s Rule 26 disclosures never listed Ms. Ransome as a witness, despite the fact that Defendant was in her company on several occasions including on Epstein’s island, where Ms. Ransome was one of several girls being sexually trafficked for Epstein upon the direction and insistence of Defendant. After being contacted by Ms. Ransome, counsel for Ms. Giuffre properly conducted a due diligence investigation into whether the information she provided had merit. Specifically, Ms. Giuffre’s counsel undertook the expense to fly to Europe to meet in person with this newly disclosed witness on January 4, 2017, returning on January 6, 2017, to fully evaluate her credibility. Upon evaluating the witness and upon the witness confirming that she was willing to sign an affidavit under oath regarding her testimony, Ms. Giuffre arranged to have a sworn affidavit executed at the U.S. Embassy in the country where Ms. Ransome resides. Ms. Giuffre then issued revised Rule 26 disclosures on January 13, 2017 and informed Defendant that she would produce Ms. Ransome for a deposition as a newly-disclosed witness immediately so as to avoid any prejudice or delay in the March 13, 2017 trial date. In short, Ms. Giuffre acted promptly and reasonably after being contacted by this victim of Epstein’s and Defendant's sex trafficking ring. Defendant Will Not Be Prejudiced Because Ms. Ransome is Readily Available for Deposition