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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 14 of 19 Category 4 — Ms. Ransome’s current medical provider Ms. Maxwell will withdraw this question. The Witness’s Abandoned Objections Notably absent from the Motion for Protective Order are several other questions posed to Ms. Ransome that she was instructed not to answer without any claim of privilege or protection. Ms. Ransome should also be required to answer these questions, in particular since she has not sought a protective order on these lines of questioning, nor could she. 1. Her partner’s occupation (motivation for fabrication) 2. Her parents’ addresses (she claims that they spoke with Ms. Maxwell and Mr. Epstein and have knowledge of her “coming forward”) 3. Where she was staying while in NY (paid for by Plaintiff's Counsel, motive for fabrication and bias) 4. Whether Alan Dershowitz contacted anyone on her behalf (communications with others by counsel not privileged) 5. Her stepmother’s phone number and email address and physical address (she claims that they spoke with Ms. Maxwell and Mr. Epstein) 6. When she provided her photos to her lawyer (date of communication and production to attorney not privileged) There simply was no basis for instructing the witness not to answer these questions, all of which are relevant and none of which are privileged. Ms. Ransome should be compelled to re-appear to answer all questions previously posed to her where she was instructed to answer, excepting the name of her current doctor who prescribed her SSRI medication. IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD In addition to being required to re-appear and respond to non-privileged questions, it became clear at Ms. Ransome’s deposition that her counsel has withheld from production a number of relevant and responsive documents. The first and most obvious category of withheld documents are email communications between Ms. Ransome and her acquaintances while associated with Mr. Epstein (including the 12