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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 9 of 19 Plaintiff's counsel, seeks, among other things, civil forfeiture of two private jets, a mansion in New York, and a private island in the U.S. Virgin Islands. One can hardly imagine a better motive to fabricate testimony than that type of lottery win. To make it even better, there is no purchase price for the ticket, because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis. “Evidence tending to show a witness's bias or motive to fabricate testimony or evidence presented at trial is nearly always relevant.” In re WorldCom, Inc. Sec. Litig., No. 02 CIV 3288 DLC, 2005 WL 375315, at *8 (S.D.N.Y. Feb. 17, 2005) (citing United States v. Abel, 469 U.S. 45, 52 (1985)); Middleton v. Walker, No. 09-CV-5548 JS, 2014 WL 2208177, at *5 (E.D.N.Y. May 27, 2014) (Nevertheless, ‘extrinsic proof tending to establish a reason to fabricate is never collateral and may not be excluded on that ground.””) (quoting People v. Hudy, 73 N.Y.2d 40, 56 (1988)). Moreover, ““bias of a witness is not a collateral issue.’” Jd. (quoting United States v. James, 609 F.2d 36, 46 (2d Cir.1979)) see also see also Abel, 469 U.S. at 52 (noting that under the common law, a showing of bias by extrinsic evidence was always permitted). The discovery sought concerning Ms. Ransome’s financial information, employment, the nature of her engagement with counsel (including the financial structure of those relationships) all goes to Ms. Ransome’s motivation to provide the fabricated testimony she plans to give and bias in this matter. This includes the following document production requests: 1. All Documents containing Communications with Virginia Roberts Giuffre, or any of her attorneys, agents, investigators, from the period 1999-present. 2. All fee agreements for Your engagements with any attorneys for the purpose of pursuing any civil or criminal claims regarding Jeffrey Epstein, Ghislaine Maxwell, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova. 29. A copy of Your most recent paycheck, paycheck stub, earnings statement and any bank statement, credit card statement and any Document reflecting any money owed by You to anyone.