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Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 1 of 10 B. ©: | E.'S, SCHALLER & Fob Ee xX NIE R Eg) Dy 40/ EAST LAS OLAS BOULEVARD® SUITE [200* FORT LAUDERDALE, FL 3330). 22) * PH G54 54,356 DUe2 Sigrid McCawley, Esq. smecawlev@bstllp,com January 30, 2017 Confidential Sealed Filing VIA EMAIL & FACSIMILE: (212) 805-7925 Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 SwectNYSDChambers@nysd.uscourts.gov Re: Giuffre v. Maxwell, Case No.: 15-cy-07433-RWS Dear Judge Swect, This is a reply letter in support of Ms. Giuffre’s letter motion to allow for the newly- discovered witness, Sarah Ransome, to be called as a witness at trial because she can testify about Defendant's involvement in Epstein’s sex trafficking ring based on first-hand experiences and first-hand observations. Defendant Violated Rule 26 By Failing To Disclose This Critical Witness Defendant argues that Ms. Giuffre is somehow to blame for the fact that Sarah Ransome is only now being discussed as a witness in this case. But Ms. Giuffre only recently learned about this witness because Defendant failed to properly disclose her months earlier. In her response, Defendant does not address the fact that Ms, Ransome and Ms, Maxwell know each other. Indeed, Defendant does not address the fact that Ms. Ransome and she spent time together on Mr, Epstein’s private island, as reflected in the flight logs showing Ms, Ransome flying to and from the island (where Ms, Maxwell was present): le PIAL Sen ase Msp | aA eee Stiaew i aa | aia ¥ Lt AL -pse ae Sa or FRU a \d.j [GAIS16 - NAOASE Hew TLST ee aie Sereno 4 Saar) AN IST (EWR aos eS Ree niche ev AS 1 6 A) ee evel pe its fas LesceoeT woe It 4 | 13 PBzr | Ts 422} GeRALo LeccouRT Sv | Gwe t yo ee y EIN ate serie | cenity thei Ia elstements mao by me onthls form ore tue. WWW.BSFLLP.COM