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Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 9 of 27 Without waiving such objections, all responsive photographs in non-party Sarah Ransome’s possession are attached hereto as RANSOME 000024-000028, 000069, 000121- 000123, 000126-000135, 000138-000143, 000145-000155, which should be treated as Confidential pursuant to the parties’ Protective Order. 7. Any photographs taken by You, or containing any image of You, at, in or near any home, business, private vehicle (including airplane), or any other property owned or controlled by Jeffrey Epstein. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks an unlimited number of unspecified photographs. Ransome further objects to this request in that it is vague and ambiguous with respect to its reference to “any photographs.” Ransome objects to this Request as overbroad, harassing, and not calculated to lead to discoverable evidence relevant to the Defamation Action. Ransome objects to this Request in that it places an undue burden on this non-party including, for example, requiring the non-party to search for photographs for an unlimited period of time. Without waiving such objections, all responsive photographs in non-party Sarah Ransome’s possession are attached hereto as RANSOME 000022, 42-47, 52, 56-59, 71, 127-131, 152, 153, which should be treated as Confidential pursuant to the parties’ Protective Order. 8. Any photographs that depict any home, business, private vehicle (including airplane), or any other property owned or controlled by Jeffrey Epstein. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks an unlimited number of unspecified photographs. Ransome further objects to this request in that it is vague and ambiguous with respect to its reference to “any photographs.” Ransome objects to this Request as overbroad, harassing,