Giuffre_Maxwell_Batch7_p00191.png

Case 1:15-cv-07433-LAP Document 1332-9 Filed 01/08/24 Page 9 of 15 wanted to “further her education” in the U.S., which is why she traveled here in late 2006. She also has alleged that she was “promised” that Mr. Epstein would help her gain admission to FIT, and that Ms. Maxwell also made such extraordinary promises. Whether Ms. Ransome had permission to attend school in the U.S., or to work here, bears directly on whether she reasonably could have relied on any such alleged promise. Moreover, the dates of Ms. Ransome’s travel to and from the U.S., to and from South Africa, and to and from other countries relates directly to whether or not she was in fact present in the U.S. when she claims that she was. The requested documents should be produced. E. Request 15-16: Financial Records to Support Her Claims In her Jane Doe 43 complaint, Ms. Ransome averred that “Defendants Epstein and Maxwell continued to provide [her] with things of value in exchange for [her] continued compliance with Epstein’s sexual demands; however, they failed and refused to perform their promises to help [her] be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education.” See Jane Doe 43 v. Epstein et al., 17-cv-00616, Complaint (Doc. 1) at 16-17. The subpoena thus called for Ms. Ransome to produce documents reflecting any payments received by her from Mr. Epstein (or his associates) and her financial records from the years 2006-07 when she claims she was receiving remuneration from Mr. Epstein. In response, Ms. Ransome contends that these records are a “complete invasion of her privacy” and have “no relevance.” Apart from “relevance” not being the applicable standard, it is hard to imagine documents reflecting her financial payments from Mr. Epstein being any more relevant. During her deposition, Ms. Ransome testified that she had a bank account in NY in 2006-07 and her counsel instructed her not to answer the question “with which bank?” Pottinger Decl. Ex. 1 at 414-15. She testified that in that account she placed her earnings from her 7