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Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 2 of 10 BOIES, SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -2- Confidential Sealed Filing As reflected in the above flight log. on December 10, 2006 (Flight #1919), Sarah Ransome flew from EWR (Newark, NJ) to TIST (USVI) with Jeffrey Epstein, Jennifer Kalin, and Natalya Malyshev. On December 14, 2006 (Flight #1920), Sarah Ransome flew from TIST (USVI) to EWR (Newark, NJ) with Jeffrey Epstein and Nadia Marcinkova. See Giuffre 07139. Ms. Ransome was also flown commercially to Jeffrey Epstein’s Island several times. Defendant was obligated under Rule 26 to include Ms. Ransome in her Rule 26 disclosures: Defendant knows that Ms. Ransome is an “individual likely to have discoverable information.” Fed. R. Civ. P. 26(a)(A)(i). As Ms. Ransome will testify, Defendant was on the island with her and interacted with her on a regular basis. Defendant's refusal to disclose her is not only (yet another) discovery violation, but also a part of the secrecy that Defendant and Epstein strove to maintain surrounding their sex trafficking ring. Defendant should not be allowed to participate in a sex trafficking ring, conceal the witnesses (and victims) of that ring, and then proclaim “surprise” when Ms. Giuffre succeeds in locating one of the victims. Simply put, she should not be allowed to benefit from her obvious failure to properly disclose Ms. Ransome. Ms. Ransome’s Testimony is Not Cumulative And Has Highly Relevant Evidence Defendant also advances the remarkable argument that it is “unlikely” that Ms. Ransome will have relevant information. Yet Ms. Ransome witnessed — first hand — Defendant’s involvement in sex trafficking with Jeffrey Epstein. Nor will her testimony be cumulative. First, at the heart of this case is Defendant’s sworn testimony that she was not involved in sex trafficking with Epstein. Ms. Ransome can directly refute Defendant’s sworn testimony under oath in numerous ways. ...the primary purpose of those visits was to have me have sexual relations with Jeffrey, Nadia Marcinkova, and various other girls and guests brought to the island...During one of my first visits to the island I met Ghislaine Maxwell. Watching her interact with the other girls on the island, it became clear to me that she recruited all or many of them to the island. Once they were there, she appeared to be in charge of their activities, including what they did, who they did it with, and how they were supposed to stay in line. She assumed the same supervisory role with me as soon as I arrived. Some of the girls appeared to be 18 or older but many appeared to be young teenagers. Exhibit A, Affidavit of Sarah Ransome. In addition, Defendant has made known her plan to put forth Alan Dershowitz as a witness at trial to testify that Ms. Giuffre is lying, and that he never had sex with her or anyone else provided by Jeffrey Epstein. While Ms. Giuffre contends that Dershowitz’s testimony is not relevant to this case concerning Defendant, in the event that the Court disagrees, Ms. Ransome directly contradicts this testimony because, as part of her