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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 3 of 19 Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Combined Motion to Compel Non-Party Witness to Produce Documents and Respond to Deposition Questions, and Response to Motion for Protective Order for Non-Party Witness (ECF 640)! and further states as follows: STATEMENT OF CONFERRAL The undersigned has conferred with Mr. Stanley Pottinger, who represents both Plaintiff and non-party witness Ms. Ransome, via email and telephone on the issues raised in this motion and has been unable to resolve these issues without court intervention. INTRODUCTION Counsel for Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January belatedly disclosed a “new witness” counsel apparently had known about for months.” Plaintiff then asked this Court to re-open discovery for the deposition of Ms. Ransome, promised to make her available “immediately” for deposition and agreed to accept a subpoena for her to produce documents, in an attempt to “cure” her own late disclosure. Now, after having created a last- minute scramble to conduct discovery on facts far removed in time and circumstance from Plaintiff's defamation claim, Plaintiff now complains that too much is being asked of her “witness.” Plaintiff protests that the requested documents and testimony sought -- all of which relate to Ms. Ransome’s allegations and credibility -- are irrelevant to this single count defamation action. Of course, the defense has said since learning of her that Ms. Ransome’s story is irrelevant to this case. But, if Plaintiff insists that Ms. Ransome should testify at trial, she must comply with properly served and propounded subpoena for testimony and records. ' To avoid excessive and duplicative briefing on overlapping issues, Ms. Maxwell is submitting her Response to the Motion for Protective Order together with her Motion to Compel. > In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic, Plaintiff claimed she had “recently” learned of this “new” witness. As it turns out, Plaintiff's counsel Bradley Edwards, Paul Cassell and Stanley Pottinger had already signed a fee agreement to represent this witness more than two months earlier, on November 7, 2016. Plaintiff’s counsel still has not explained why they waited more than two months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery. 1