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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 13 of 19 directly to her motivation to fabricate testimony to seek (a substantial amount of) money in in the Jane Doe 43 litigation. Any concerns about disclosure of this information can be alleviated by production under the protective order. Category 2 - The cell phone number of her partner. Ms. Ransome testified that she first called the Boies Schiller firm on her partner’s phone, and that the majority of her other conversations with counsel were on that same phone. See Menninger Decl. Ex. A at 24:25-28:5. Given the belated disclosure of this witness, and that the first contact happed sometime before November 7, 2016, the date of initial contact and number of contacts in between are highly relevant to the issue of late disclosure. Thus, subpoenas for these records may be required. Any concerns about providing this information can be alleviated by production under the protective order. Category 3 — Allegedly privileged communications with Alan Dershowitz Ms. Ransome refused to answer questions concerning her alleged conversations with Mr. Dershowitz sometime in late 2006 or early 2007, claiming they were related to a legal matter and that she believed Mr. Dershowitz was her attorney. See Menninger Decl. Ex. A at 172:18- 173:12; 180:20-185:23; 199:3-23. Ms. Ransome confirmed in her deposition that Mr. Epstein was present during all conversations she claims to have had with Mr. Dershowitz. She further confirms that Mr. Epstein was there to “support” her and “look after” her regarding some unspecified legal matter, but he was not a party or interested in the dispute. See Menninger Decl., Ex. A at 199:3-23. It is axiomatic that any conversations between Ms. Ransome and Mr. Dershowitz in the presence of Jeffrey Epstein, a third party, are not protected by privilege. Safeco Ins. Co. of Am. v. M.E.S., Inc., 289 F.R.D. 41, 46 (E.D.N.Y. 2011) (“Generally, communications made between a defendant and counsel in the known presence of a third party are not privileged.”). Ms. Ransome must be compelled to respond to these questions. 11