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Case 1:15-cv-07433-LAP Document 1332-9 Filed 01/08/24 Page 12 of 15 Il. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION QUESTIONS, AND SHE MUST BE COMPELLED TO RE- APPEAR AND RESPOND During her deposition, Ms. Ransome’s counsel (and Plaintiff's counsel) instructed her not to answer a number of non-privileged questions. The record of the deposition is replete with such frivolous objections. For example, at page 7, her attorney instructed her not to give her “current address,” whether she “has any source of income,” “her family’s location, things of that nature,” and her partner’s “cellphone number.” None of these questions call for privileged information. Pottinger Dec. Ex. 1 at 7, 10-12, 15. When asked who was paying for her hotel in New York, Mr. Guirguis instructed Ms. Ransome not to answer, and then Ms. McCawley (appearing on behalf of Plaintiff and NOT on behalf of Ms. Ransome), instructed her to answer. Id. at 31-33. Her attorneys (and Plaintiff's counsel) took breaks while questions were pending to consult with Ms. Ransome before she answered. In sum, there were a significant number of deposition questions posed to Ms. Ransome that she was improperly instructed not to answer and for which she should be compelled to return to a deposition and answer. Category 1 - Personal current financial information. In opposition, Ms. Ransome asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare Motion at 10-11; Opp’n at 19. Category 2 - the cell phone number of her partner. In opposition, Ms. Ransome asserts, without factual or legal support, that her partner’s cellphone number is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance assertion asserted by the motion, this issue should be deemed admitted. Compare Motion at 11; Opp’n at 19. 10