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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 12 of 19 26. Any Documents that reflect any criminal charges, tickets, summonses, arrests, investigations concerning You or witnessed by You. 27. Any Documents containing any statement regarding Your experience or contact with Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova, including without limitation any Communication with anyone, any diary, journal, email, letter, witness statement, and summary. 28. Any civil complaint or civil demand filed by You or on Your behalf by which You have ever sought damages or compensation of any form or nature. 30. A copy of your Facebook, Instagram, Twitter, and any other social media application or program for the years 2006-2007 and from 2015 — present. While Ms. Ransome has provided some documents responsive to Questions 2, 3, 5, 6, 7, and 8, as discussed below, the productions are incomplete and an unknown volume of documents have been withheld. Having purposefully interjected herself into this litigation, and initiating another litigation based on the same allegations about which she now plans on testifying in this case, Ms. Ransome must be compelled to produce each of these clearly relevant categories of documents. Il. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION QUESTIONS, AND SHE MUST BE COMPELLED TO RE- APPEAR AND RESPOND The Motion for Protective Order relates primarily to certain deposition questions posed to Ms. Ransome which her counsel (and at times, Plaintiff's counsel) improperly instructed her not to answer. Each question relates to Ms. Ransome’s claims, credibility, bias and motivation for fabrication of her testimony, requiring responses. Category 1 - Personal current financial information. Ms. Ransome refused to answer whether she has any source of income. She stated that her partner rents the home she lives in, implying he financially supports her, but would not state what he does. See Menninger Decl. Ex. A at 9:17-12:21. As such, her partner’s income (or relative lack thereof) and Ms. Ransome’s financial position or ability to earn a living relate 10