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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 8 of 19 43 (1.e., Plaintiff Ransome)) claimed that Ms. Ransome’s experience (i.e. the basis for her claims in Jane Doe 43) are “highly relevant” to this action. Presumably, Ms. Ransome’s testimony in this case will be precisely what she alleged in the Jane Doe 43 Complaint. Logic follows that either 1) the information relevant to that action is relevant to her testimony in this case, or 2) her testimony is entirely irrelevant to this single count defamation action. We would suggest that the latter is true, as is the case with all other alleged victim witnesses, none of whom know the Plaintiff in this case at all. The proper course of action, then, should be to exclude Ms. Ransome’s testimony altogether because, in Ms. Ransome’s counsel’s own words, the information is not relevant to this single count defamation action. If the Court determines that Ms. Ransome’s testimony is at all relevant, then all of the information sought is relevant to her participation as a witness in this action. First and most fundamentally, the Jane Doe 43 action seeks millions if not hundreds of millions worth of assets as “civil forfeiture.” It appears (although Ms. Ransome refused to answer) that she is unemployed, with no source of income other than from her partner, and lives in a house or apartment rented by him in Spain. See Menninger Decl., Ex. A at 9:17-12:21. She came out of the woodwork to provide testimony after reading an article that extensively describes this lawsuit and Mr. Epstein’s settlement of other lawsuits. She seeks to testify, by contrast to every other witness ever identified, that 1) Ms. Maxwell was actively involved as an assistant to Mr. Epstein in late 2006 to early 2007, and 2) that she was “‘lent out” to other people, including Alan “Dershavitz” (as she pronounces it). See Menninger Decl., Ex. F (Ransome Affidavit). These are two pieces of testimony that Plaintiff has desperately sought to corroborate with witnesses, and there is more than a mere possibility that these pieces of Ms. Ransome’s testimony were suggested to her by Plaintiff's counsel/her counsel. In Jane Doe 43, Ms. Ransome, through