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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 7 of 19 26(b)(5)); see also In re Grand Jury Subpoena, 274 F.3d 563, 575-76 (1st Cir.2001) (stating that a “party that fails to submit a privilege log” pursuant to Fed. R. Civ. P. 45(d)(2) “is deemed to waive the underlying privilege claim”). Of course, the need for a log to assess any alleged claims of privilege is particularly necessary in this case. It is entirely unclear when Ms. Ransome became represented, and by whom, and related to what matter(s). What is clear is that there is at least one, if not more, of her communications with the Boies Schiller firm when Plaintiff was an unrepresented non-party potential witness. Indeed, the Boies Schiller firm claims they do not represent her as a witness in this litigation. Thus, any communication between Boies Schiller and Ms. Ransome relating to her testimony in this case is not protected by any privilege and must be produced. Of course, without the required log it is impossible to determine how many improperly categorized “privileged” communications exist. Based on Ms. Ransome’s failure to provide a privilege log, any claim of privilege has been waived. IL. DOCUMENTS RELATED TO JANE DOE 43 V. JEFFREY EPSTEIN, ET AL., 17- CV-00616-JGK (S.D.N.Y.) ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY IN THIS ACTION In her Responses, Ms. Ransome argues primarily that the documents sought are not related to her witness testimony in this case. The objection reads: Ransome further objects to this request in that the face of the request demonstrates that the Defendant is abusing the subpoena power by serving a subpoena on a non-party that seeks discovery unrelated to the underlying matter, but instead allegedly relevant to another Federal Action styled Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Lesley Groff, and Natalya Malyshev Case Number 1:17-cv-00616-JGK (S.D.N.Y.). Ransome objects to this Request as overbroad, harassing, and not calculated to lead to discoverable evidence relevant to the Defamation Action. See Menninger Decl. Ex. E, Responses 9-30. This argument is perplexing. In Plaintiff's Motion to Reopen Discovery, Plaintiff (through Ms. McCawley, who does not represent witness Ransome, but does represent Jane Doe 5