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Case 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 4 of 16 EMERY CELLI BRINCKERHOFF & ABADY LLP Page 3 “Clinton[ ] and Trump must pay for what they did to us as must the rest of the men that were involved in their seedy inner circle.” Ex. 4 (RANSOME_000284); “TMly friend had sexual intercourse with Clinton, Prince Andrew and Richard Branson, sex tapes were in fact filmed on each separate occasion ... I eventually managed to persuade her to send me some of the video footage which she kept, implicating all three all men ... I have backed up the footage on several USB sticks and have securely sent them to various different locations throughout Europe.” Ex. 5 (RANSOME_000295); “[A]nother friend ... was one of the many girls that had sexual relations with Donald Trump ... She confided in me about her casual ‘friendship’ with Donald. Mr. Trump definitely seemed to have a thing for her and she told me how he kept going on about how he liked her ‘pert nipples’. Donald Trump liked flicking and sucking her nipples until they were raw. One evening when we were showering together she showed me her nipples. They looked incredibly painful as they were red and swollen and I remember wincing when I looked at them. I also know she had sexual relations with Trump at Jeffery’s NY mansion on regular occasions as I once met Jen for coffee, just before she was going to meet Trump and Epstein together at his mansion.” Ex. 6 (RANSOME_000296); Importantly, the Emails, which fatally undermine Ms. Ransome’s credibility, were not available to Ms. Maxwell’s counsel when she examined Ms. Ransome in the deposition in this case. false For this reason, the deposition transcript standing alone leaves an incomplete and, thus, impression of Ms, Ransome and her outrageous claims. This Court should not allow its power to enter and modify a protective order to be manipulated so as to authorize selective disclosure of de-contextualized materials. If the Ransome deposition is made public, the Emails must also be as well. Cc Respectfully submitted, ZX: Celli, wl: } +) Counsel for Plaintiff and Defendant (by Email)