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Case 1:15-cv-07433-LAP Document 1332-9 Filed 01/08/24 Page 8 of 15 ‘| Dsco0272 1/2/2007 1:46 PM JPG File 2,152 a) DSC00273 1/2/2007 1:47 PM JPG File 2,100 (a) DSCO0274 1/2/2007 1:47 PM J 2,370 i) DSco0283 1/2/2007 1:49 PM J 2,370 | ja] Dsco0284 1/2/2007 1:49 PM J 2,361 (a) DSCO0285 1/2/2007 1:49 PM J 2,370 | Dsco0286 1/2/2007 1:49 PM J 2,270 l@) DSco0293 1/2/2007 2:09 PM JPG File 2,266 la) DSC00296 1/2/2007 2:10 PM JPG File 2,088 See, e.g., Menninger Decl. Ex. J (screenshots of contents of disk produced). Furthermore, Plaintiff was asked to produce the photos in “native format.” As to print photographs, she provided some copies of the fronts of photos and some backs of photos, but she produced the fronts and backs separately so there is no way to discern which front goes with which back. Ms. Ransome should be ordered to produce a// responsive photographs in their native format, or permit inspection of the same. D. Request 9-12: Passports, Visas and Other Travel Documents In Response 9, Ms. Ransome promised that her “current passport is attached.” Pottinger Decl. Ex. 1 at 10. It was not. Ms. Ransome instead produced one of her expired passports, specifically her British passports. She did not produce her South African passport from 2006-07, nor did she produce either her current or her prior South African passports. In fact, Ms. Ransome had her current passport both in NY and she presented it at the time she signed her declaration in Barcelona. Ms. Ransome also produced no documents either reflecting her visas to travel, work or study in the US (Request 10) or any communication regarding such visas (Request | 1). These documents are calculated to lead to admissible discovery, not, as the witness baldly proclaims, intended to “harass” her. Ms. Ransome’s story is premised on the notion that she KB aw KB aw KB