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Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 26 of 29 work-product privilege since its inception in American law.” Gerber v. Down E. Cmty. Hosp., 266 F.R.D. 29, 31 (D. Me. 2010) (citing Hickman v. Taylor, 329 U.S. 495, 497, 510-11, 67 S. Ct. 385, 91 L.Ed. 451 (1947)). Courts have continuously found an attorney’s communications and notes of witness interviews to be privileged work product. See, e.g., City of Pontiac Gen. Employee’s Ret. Sys. v. Lockheed Martin Corp., 2012 WL 4202657, at *1 (S.D.N.Y. Sept. 18, 2012) (denying motion to compel, upholding work-product privilege with respect to witness interviews and accompanying notes, emails, and memoranda); United States v. Jacques Dessange, Inc., 2000 WL 310345, at *3 (S.D.N.Y. Mar. 27, 2000) (finding notes of witness interviews to be core work product); S.E.C. v. NIR Grp., LLC, 283 F.R.D. 127, 134 (E.D.N.Y. 2012) (work product privilege applied to interviews — along with accompanying notes and memoranda - conducted by attorney); Buck v. Indian Mountain Sch., 2017 WL 421648, at *7 (D. Conn. Jan. 31, 2017) (“the disclosure of witness interviews and documents related thereto, is “particularly disfavored’” (quoting Upjohn Co. v. United States, 449 U.S. 383, 399 (1981))). Vv. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO JANE DOE 43. Defendant also claims that non-party Ms. Ransome has not produced all documents covered in the subpoena that relate to Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen, Lesley Groff and Natalya Malesheve, Case Number 1:17 — cv-0016-JGK, which involves a claim under the sexual trafficking statute. Regarding the Jane Doe 43 documents, Ms. Ransome testified that she produced everything that she had that relates to Defendant. See Chart supra. The case law is clear that a party cannot use the subpoena power in this litigation to gather discovery for a different litigation which is exactly what Defendant is trying to do here. See Liz Claiborne, Inc., v. Mademoiselle Knitwear, Inc., No. 96 CIV 2064 (RWS), 1997 WL 53184 at *5 (Sweet, J.) (S.D.N.Y. Feb. 10, 1997) (this Court limiting deposition questioning of party because 22