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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 5 of 29 Non-party, Sarah Ransome, by and through her undersigned counsel, hereby files this Reply in Support of Her Motion for Protective Order (DE 640) and Opposition to Defendant’s Combined Motion to Compel Non-Party Witness to Produce Documents and Respond to Deposition (DE 655). BACKGROUND Non-party Sarah Ransome has already provided significant discovery in this case. She previously flew from Barcelona to New York, sat for a ten-hour deposition, and produced many relevant documents. Indeed, witness Ms. Ransome has provided more significant evidence, including photographic evidence and electronic communications, than Defendant has produced in the two years she has been litigating this matter. Defendant has not produced a single document prior to 2009 and not a single photograph, despite testimony that she was an avid photographer of the young girls at Epstein’s mansions, including taking nude photographs. Specifically, and by way of example, non-party Ms. Ransome produced the following types of highly relevant information about Defendant’s involvement in the sex trafficking and abuse: Ransome_000128 Ransome_00069 Jeffrey Epstein in 2006 on Little Various females on Island in 2006 including Nadia. St. James Island Marcinkova