Giuffre_Maxwell_Batch7_p00157.png

Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 2 of 27 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS Vv. Ghislaine Maxwell, Defendant. / NON-PARTY SARAH RANSOME?’s RESPONSES AND OBJECTIONS TO DEFENDANT’S SUBPOENA REQUESTS Sarah Ransome, a non-party to this action, hereby responds to the Subpoena Duces Tecum noticed by Defendant Maxwell, and submits these responses and objections (“Responses”) to the document requests contained therein. PRELIMINARY STATEMENT AND GENERAL OBJECTIONS Defendant, Maxwell has served non-party Sarah Ransome with a subpoena duces tecum seeking an array of documents that are both irrelevant to this matter and entirely privileged. Defendant’s subpoena is solely meant to harass and place an undue burden on Ms. Ransome. To be discoverable, information sought must be relevant to the underlying action. Fed. R. Civ. P. 26(b)(1). Where discovery is sought from third parties, the Court must weigh the probative value of the information against the burden of production on said non-party. In re Biovail Corp. Sec. Litig., 247 F.R.D. 72, 74 (S.D.N.Y. 2007) (citing Concord Boat Corp. v. Brunswick Corp., 169 F.R.D. 44, 48-49 (S.D.N.Y.1996)); Fed.R.Civ.P. 45(c)(2)(B). In order to determine whether a subpoena imposes an undue burden, the Court should consider: 1) relevance, 2) the need of the party for the documents, 3) the breadth of the document request, 4) the time period covered by it, 5) the particularity with which the documents are described, and 6) the burden imposed. Jd.