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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 27 of 29 relevance of the questions were tenuous at best and appeared to be directed at improperly gathering information for a different lawsuit); Night Hawk Limited v. Briarpatch Limited, No. 03 CIV. 1382 (RWS), 2003 WL 23018833 (S.D.N.Y. Dec. 23, 2003). Irrespective of this case law that says a party should not wrongfully seek a non-party’s documents for use in a different matter, non-party Ms. Ransome did produce the documents that she has that relate directly to Defendant and Epstein as she testified. CONCLUSION Non-party Ms. Ransome respectfully requests that this Court grant her protection from having to produce any additional discovery or sit for any additional deposition testimony (DE 650). Non-party Ms. Ransome also respectfully requests that the Court deny Defendant’s Combined Motion to Compel (DE 655). Dated: March 7, 2017 Respectfully Submitted, By: /s/ J. Stanley Pottinger J. Stanley Pottinger (Pro Hac Vice) Counsel for Sarah Ransome 23