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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 23 of 29 the categories of deposition testimony that Defendant seeks for which non-party Ms. Ransome contends are sought only for the purpose of harassment and intimidation: e Current paycheck records and other banking records. Defendant has now added to this that she wants her boyfriend’s current income and financial position since non- party Ms. Ransome testified that she is living with her boyfriend. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 8-9, 13-14. e Boyfriend’s cell phone number. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 27-28. e Her parent’s current address information. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 14. e Communications that non-party Ms. Ransome testified she recalls having with a reporter in the fall of 2016. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 37- 43, 386-388. e Privileged communications with Alan Dershowitz when he was meeting with Ms. Ransome about a legal matter. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 182-186. e Her partner’s occupation. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 13-14. e What hotel Ms. Ransome was staying at in New York for her deposition. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 30-34. e Whether Alan Dershowitz contacted anyone on Ms. Ransome’s behalf. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 199. e Her stepmother’s phone, e-mail address and physical address — despite the fact that non-party Ms. Ransome already gave testimony at her lengthy deposition that she does not have her stepmother’s contact information. See Pottinger Dec. at Exhibit 1, Ransome Dep. Tr. at 239-240. e When Ms. Ransome provided her photos to her lawyer. See Pottinger Dec. at Exhibit 1, Ransome Dep. Tr. at 363. Ms. Ransome testified that she believed that Alan Dershowitz had been retained to be her lawyer in a legal matter that she was having. Accordingly, counsel objected on privilege grounds when Defendant’s counsel attempted to obtain specifics about those meetings. In addition, Defendant attempted to obtain privileged and work product information about Ms. Ransome’s 19