Giuffre_Maxwell_Batch7_p00146.png

Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 20 of 29 incorrect. To be clear, Ms. Ransome produced documents, or responded that no documents exist, to Requests 1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 13, 14, 20, 23. Request 24 was withdrawn by Defendant and non-party Ransome does not have any documents responsive to Request 26. As to the remaining requests: e Request 12 — Ms. Ransome testified that she does not have any credit card receipts, cancelled checks, or documents reflecting travel from 2006-2007, other than what she has already produced. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 367, 402-403. e Request 15 - She testified that she does not have any documents reflecting the money paid to her by Jeffrey Epstein (she was paid in cash). See Pottinger Dec. at Exhibit 1, Ransome Tr. at 151-152, 415. e Request 16 - She testified that she was given cash by Epstein during the years 2006-2007 while she was being trafficked by Defendant and Epstein. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 415-416. e Request 17 - She testified that she lived in Epstein’s apartment and thereafter lived with a male friend, but she does not have any leases, deeds, or rental agreements for 2006-2007.. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 76-78, 228-229. e Request 19 — Ms. Ransome produced a copy of her FIT essay but testified that she does not believe she has the application but Jeffrey Epstein or the Defendant likely have a copy because they claimed to be assisting her with the application and submission process for FIT). See Pottinger Dec. at Exhibit 1, Ransome Tr. at 171-172, 179-180. e Request 21 — Ms. Ransome testified she did very little modeling because she wasn’t successful at it and has no documents relating to her modeling) See Pottinger Dec. at Exhibit 1, Ransome Tr. at 82, 85, 112-113, 216, 415. e Request 25 - She testified she has not had any communication with law enforcement. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 183-184, 189. e Request 27 - She testified that she has never written a book or any similar writings about her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 9, 12-13, 35-38. e Request 28 - Defendant already has her civil complaint in Jane Doe 43, and Ms. Ransome already testified that she is involved in that litigation. e Request 30 — Ms. Ransome testified that she does not have a current account on Twitter or any other social media platform, and does not have the information for any for the years 2006-2007. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 61. 16