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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 19 of 29 Ransome 02/17/17 Dep. Tr. at 382:14 to 386:16. Q. So did you produce the February ‘04, ‘07, 4:01 p.m. email from yourself to Nataly Malyshev to your attorneys? Q. Did you give that email to your lawyer? A. [ve given all my email correspondence to my lawyers. A. I’ve given all my emails to my lawyers. Q. Okay. The next email down A. Mm-hmm. says "Sarah Ransome, February 5, 2007, at 10:09 p.m." - Can you read the text of that email on this document? Q. What does the 10:09 p.m. email say? A. As I’ve specified before, this is a screenshot”, okay, of the actual Yahoo email. This is a screenshot. So technically I can’t read that anyways, seeing as it’s a screen shot. Q. Did you search your Inbox for | A. I did. I wanted to be thorough with my research, so I, documents responsive to the during that time frame, went through every single email. subpoena that I showed you a little while ago? Q. You went through each one? A. I went through all of my emails to make sure I gave all my evidence to my lawyers. Q. Did you search for keywords or did | A. I read each email. you just read each email? Q. And did you print out each email? | A. I didn’t print out. I saved them to a USB stick. Q. All of them or just the ones that you | A. Just the ones that were for -- just anything related to thought were needed? Jeffrey, I sent over. I. NON-PARTY RANSOME HAS PRODUCED DOCUMENTS OF AND DOES NOT HAVE DOCUMENTS FOR A NUMBER OF REQUESTS. Defendant’s Motion to Compel* is misleading because it suggests that non-party Ms. Ransome refused to produce documents in response to all thirty categories in the subpoena. That is > Ms. Ransome produced both screen shots and the associated emails. Defendant asked about the screenshots during the deposition, rather than about the supplemental production of the actual emails. Defendant also requested additional pieces of the email chains which non-party Ransome has provided the Defendant the additional pieces of the email chains to the extent they were responsive to the Defendant’s subpoena. > Defendant also requested a copy of the CD of photographs that non-party Ms. Ransome already produced in hard copy. A copy of said CD has been made and sent to Defendant. 15