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Case 1:15-cv-07433-LAP Document 1332-16 Filed 01/08/24 Page 3 of 16 EMERY CELLI BRINCKERHOFF & ABADY LLP Page 2 privately. Nevertheless, we write in an abundance of caution and to avoid the risk of a de- contextualized and one-sided disclosure. In a letter from her counsel Boise Shiller Flexner LLP to Laura Menninger on May 5, 2017, Ms. Giuffre purported to give notice of her “withdrawal of her confidentiality designation of Ms. Ransome’s deposition transcript in its entirety.” We understand Ms. Maxwell will move to oppose this de-designation. If the Court allows Ms. Giuffre to remove the confidentiality designation from the Ransome deposition, the Emails should be disclosed at the same time to allow the public to understand the full context of Ms. Ransome’s testimony, and to assess the credibility (or lack thereof) of Ms. Ransome. Ms. Giuffre should not be permitted to use this Court’s power to make a false and heinous public accusation against Intervenor (like the publicly filed false affidavits in prior litigation concerning Intervenor) and then shield from disclosure all proof that the accusation is perjurious (as she has done previously in this case by designating her book manuscript and emails to the press, which show her claims against Intervenor to be false, as confidential). Intervenor seeks the de-designation of the Emails to challenge Ms. Ransome’s false and defamatory accusations that, among other things, she had sexual intercourse with Intervenor when she was twenty-three. Ms. Ransome’s allegations concerning Intervenor are categorically false. Prof. Dershowitz has never met or had contact with Ms. Ransome, was not her lawyer, and certainly never had a sexual encounter with her. Prior to this action, Intervenor had never heard of Ms. Ransome. Her testimony was fabricated from whole cloth. Ms. Ransome’s testimony also contains a slew of other incendiary claims concerning the sexual proclivities of Donald Trump, Bill Clinton, and other prominent individuals. The Emails are a necessary antidote to Ms. Ransome’s deposition misstatements because they demonstrate she manifestly lacks credibility. For example, she writes: e “My emails have been hacked. I have reached out to the Russians for help and they are coming to my aid. Thank goodness for Anonymous!!!! I will make sure that they all go behind bars. I have already sent everything I need to so, the CIA, hacking my emails etc were too late. I also have numerous devices, with systems that are unhackable and I have film footage all over Europe itching to be released.” Ex. | (RANSOME _ 000521); e Her friend was “approached, by Special Agents Forces Men sent directly by Hilary [sic] Clinton herself, in order to protect her presidential campaign.” Ex. 2 (RANSOME 000295); e “J will make sure that neither that evil bitch Hillary or that Paedophile Trump gets elected. I will also make sure that everyone on the God damn planet see’s [sic] that footage and photo’s [sic] and will release them to Wiki leaks by Sunday. I will take down Epstein and his bunch of fuck wit cronies myself!!!!!!!!!! I have also gone to a Russian news paper.” Ex. 3 (RANSOME 000368);