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Case 1:15-cv-07433-LAP Document 1332-9 Filed 01/08/24 Page 13 of 15 Category 3 — Allegedly privileged communications with Alan Dershowitz In opposition, Ms. Ransome has now backtracked from her deposition testimony and claims she “believed” that Alan Dershowitz was her attorney, even though she then testified that a third person, Mr. Epstein, was in the room during her conversations with Mr. Dershowitz. Because there was an improper assertion of privilege by her attorneys to the questions posed, Ms. Ransome should be ordered to respond to those deposition questions. See Motion at 11-12; Opp’n at 19-20. The Witness’s Abandoned Objections Ms. Ransome did not oppose the specific requests that she answer the following deposition questions, all of which she was instructed not to answer without any claim of privilege or protection. See Mot. at 12. Ms. Ransome should also be required to answer these questions: 1. Her partner’s occupation (motivation for fabrication) 2. Her parents’ addresses (she claims that they spoke with Ms. Maxwell and Mr. Epstein and have knowledge of her “coming forward”) 3. Where she was staying while in NY (paid for by Plaintiff's Counsel, motive for fabrication and bias) 4. Whether Alan Dershowitz contacted anyone on her behalf (communications with others by counsel not privileged) 5. Her stepmother’s phone number and email address and physical address (she claims that they spoke with Ms. Maxwell and Mr. Epstein) 6. When she provided her photos to her lawyer (date of communication and production to attorney not privileged) CONCLUSION For the reasons articulated in the Motion to Compel and further supported in this Reply, Defendant requests the entry of an Order: 1. Compelling production of all documents responsive to the subpoena, including communications with counsel because privilege has been waived. These include specifically, but are not limited to: 11