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Case 1:15-cv-07433-LAP Document 1332-9 Filed 01/08/24 Page 10 of 15 “modeling contracts.” Jd. She also testified that during the operative time frame she was making money working for an agency in New York who arranged to have her paid $1,500 to “entertain” or “spend time” with “gentlemen” with whom she sometimes engaged in sexual relations on her “own accord.” Jd.at 86-88. Finally, she claims she had “savings” from her previous modeling jobs. All of Ms. Ransome’s financial circumstances at the time, including whether she received money from Mr. Epstein, when and how much, all bear signifcant relevance to her claims that she was given financial incentives by Epstein and Maxwell in exchange for sexual compliance. The subpoena is narrowly tailored to (a) money directly from Epstein or his associates, or (b) from the time frame 2006-07. Any privacy concerns can be alleviated based on the protective order entered in this case. F. Request 18: Driver’s License Response to Request No. 18 promised that “Sarah Ransome’s driver’s license will be produced at her (February 17) deposition in this matter.” Pottinger Dec. Ex. 1 at 17. It was not. Ms. Ransome now contends that she is “fearful for her life” based on her sharing her story with a news reporter from the New York Post.’ A driver’s license contains important identifying information from which background checks and other investigation can occur. It is primarily a public document. But for the fact that Ms. Ransome lives in Spain, and has dual citizenships with the UK and South Africa, such document could be obtained by a simple visit to the Department of Motor Vehicles. Any newfound privacy concerns can be alleviated by a “confidential” designation on the production. > Ms. Ransome testified that she was “followed at least once,” but that was after she contacted the New York Post reporter and blames that reporter for sharing her secret. The supposed “following” occurred prior to Ms. Ransome’s name being identified publicly or to counsel for Ms. Maxwell, and Ms. Ransome admits she did not report the alleged following to any law enforcement authorities. 8