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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 15 of 19 people she has sued). Counsel for Ms. Ransome only produced selective portions of email chains. By way of example, Menninger Decl. Exhibit G shows an email chain containing six communications she had with Natalia Malyshev, an alleged co-conspirator, yet only two of those emails were produced. The emails produced are in “screenshot” format rather than providing a complete production of the emails with metadata. Menninger Decl. Exhibit H shows 14 separate communications with Leslie Goff, an alleged co-conspirator, yet only four (4) emails were produced. Again, they were produced in “screenshot” format rather than providing a complete production of the emails with metadata. The same incomplete productions occur with respect to Sarah Kellen (an alleged co-conspirator) and Pumla Griszell (a woman Ms. Ransome allegedly met though Mr. Epstein and to whom she claims to have reported problems with Epstein). Ms. Ransome must be compelled to produce these documents which likely contain impeachment information, as well as any other documents that are being withheld regarding communications between her and any person whom she claims to have met through Mr. Epstein, or relating to or referencing any of the Defendants in the Jane Doe 43 Complaint. Ms. Ransome also admitted to possessing multiple email communications with the reporter Maureen Callahan, her first contact in attempting to “come forward” with her story. These emails, including a picture she claims to have sent Ms. Callahan, are obviously responsive to RFP 3 for “All Documents that reference, relate to, or mention, whether by name or otherwise, the following individuals: Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova.” There is no basis for withholding these documents, and they must be produced. Ms. Ransome also failed to provide a complete copy of her application to the Fashion Institute of Technology (“F.I.T.”), despite the fact that her claims center around an alleged 13