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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 17 of 29 Chemical Co., 649 F.2d 646 (9th Cir. 1980) (“While discovery is a valuable right and should not be unnecessarily restricted, the ‘necessary’ restriction may be broader when a non-party is the target of discovery.”). Courts have routinely denied the discovery of non-parties when it is clear that the purpose is to obtain personal information for intimidating or harassing the witness. See DaCosta v. City of Danbury, 298 F.R.D. 37 (D. Conn. 2014) (protective order granted with respect to personal information of nonparties, including home addresses, email addresses, phone numbers, dates of birth, children’s names, financial account numbers, and social security numbers). Despite Ms. Ransome’s robust production, Defendant comes before this Court to seek additional information solely for the purpose of harassing and intimidating this witness. Defendant’s onerous subpoena contained thirty (30) separate categories of requests. Nevertheless, Ms. Ransome produced the documents she had and sat in a deposition for over ten hours with Defendant’s counsel. In fact, Ms. Ransome testified that she had produced all of the photographs and documents that she has that relate to Defendant and Epstein. Ransome 02/17/17 Dep. Tr. at 364:17 to 367:6 Q. Okay. If I could have you turn to | A. Mm-hmm. the last three pages, where it says "Documents to be Produced." Q. Have you seen that list before? Q. Did you conduct a search of your records to produce documents? Q. After looking at this list, did you go A. Yes, I have. A. Yes, I believe that I produced every single document I can. A. As I said, I looked at everything I had during that back and look through your | time frame and I produced everything I can during that photographs in Barcelona? time frame that I was with Jeffrey. Q. Just tell me what you did in A. Okay. So I went through a box of about over 5,000 order to make sure you had produced __| photos that I had, and I went through every single photo, everything that was called for in this every single disk, everything that I had. I went through list. all my emails. I tried to look for the BlackBerry sim card, which I had hoped that I had kept, which had all Ghislaine’ s messages on and Jeffrey’s and Lesley’s, and stupidly I misplaced that, which is really annoying. But I myself, you know, considering my objective is to 13