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Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 27 of 27 the underlying action. Ransome objects to Defendant being permitted to utilize the underlying action to obtain backdoor discovery into a separate action entirely unrelated to whether or not Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this request in that the face of the request demonstrates that the Defendant is abusing the subpoena power by serving a subpoena on a non-party that seeks discovery unrelated to the underlying matter, but instead allegedly relevant to another Federal Action styled JANE DOE 43 v. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Lesley Groff, and Natalya Malyshev Case Number 1:17-cv-00616-JGK (S.D.N.Y.). Ransome objects to this Request as overbroad, harassing, and not calculated to lead to discoverable evidence relevant to the Defamation Action. Ransome objects to this Request in that it represents a complete invasion of privacy. A non-party should not be subjected to undue harassment serving no admissible purpose. Dated: February 13, 2017 Respectfully Submitted, By: /s/ J. Stanley Pottinger J. Stanley Pottinger 49 Twin Lakes Road South Salem, New York 10590-1012 914-763-8333 CERTIFICATE OF SERVICE I certify that on February 13, 2017, I electronically served this Objection to Subpoena via Email on the following. Laura A. Menninger Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10" Avenue Denver, CO 80203 Imenninger@hmflaw.com By: /s/ J. Stanley Pottinger 26