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United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
REPLY IN SUPPORT OF NON-PARTY’S MOTION FOR PROTECTIVE ORDER AND
OPPOSITION TO DEFENDANT’S COMBINED MOTION TO COMPEL NON-PARTY
WITNESS TO PRODUCE DOCUMENTS AND RESPOND TO DEPOSITION
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES .......................................................................................................... ii
BACKGROUND ............................................................................................................................ 1
ARGUMENT................................................................................................................................ 12
I. NON-PARTY RANSOME HAS PRODUCED DOCUMENTS OF AND DOES NOT
HAVE DOCUMENTS FOR A NUMBER OF REQUESTS. ...........................................15
II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE
PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY
WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPOSITION QUESTIONS THAT ARE SOLELY MEANT TO EMBARRASS,
INTIMIDATE AND HARASS THIS NON-PARTY........................................................18
IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE
BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG..............................20
V. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO
JANE DOE 43. ...................................................................................................................22
CONCLUSION............................................................................................................................. 23
CERTIFICATE OF SERVICE ..................................................................................................... 24
i
TABLE OF AUTHORITIES
Page
Cases
Amini Innovation Corp. v. McFerran Home Furnishings, Inc.,
300 F.R.D. 406 (C.D. Cal. 2014) .............................................................................................. 12
Blodgett v. Siemens Industry, Inc.,
2016 WL 4203490 (E.D.N.Y. 2016)......................................................................................... 12
Buck v. Indian Mountain Sch.,
2017 WL 421648 (D. Conn. Jan. 31, 2017).............................................................................. 22
City of Pontiac Gen. Employee’s Ret. Sys. v. Lockheed Martin Corp.,
2012 WL 4202657 (S.D.N.Y. Sept. 18, 2012).......................................................................... 22
DaCosta v. City of Danbury,
298 F.R.D. 37 (D. Conn. 2014)........................................................................................... 13, 18
Dart Industries Co., Inc. v. Westwood Chemical Co.,
649 F.2d 646 (9th Cir. 1980) .................................................................................................... 12
Gerber v. Down E. Cmty. Hosp.,
266 F.R.D. 29 (D. Me. 2010).................................................................................................... 22
Hickman v. Taylor,
329 U.S. 495, 67 S. Ct. 385, 91 L.Ed. 451 (1947).................................................................... 22
Katz v. Batavia Marine & Sporting Supplies, Inc.,
984 F.2d 422 (Fed.Cir.1993)..................................................................................................... 12
Liz Claiborne, Inc., v. Mademoiselle Knitwear, Inc.,
No. 96 CIV 2064 (RWS), 1997 WL 53184 .............................................................................. 22
Medical Components, Inc. v. Classic Medical, Inc.,
210 F.R.D. 175 (M.D.N.C. 2002) ............................................................................................. 21
Night Hawk Limited v. Briarpatch Limited,
No. 03 CIV. 1382 (RWS), 2003 WL 23018833 (S.D.N.Y. Dec. 23, 2003) ............................. 23
S.E.C. v. NIR Grp., LLC,
283 F.R.D. 127 (E.D.N.Y. 2012) .............................................................................................. 22
Smartix International LLC v. Garrubbo, Romankow & Capese,
No. 06 CIV 1501 (JGK), 2007 WL 41666035 (S.D.N.Y. Nov. 20, 2007) ............................... 12
ii
Solarex Corp. v. Arco Solar, Inc.,
121 F.R.D. 163 (E.D.N.Y. 1988) .............................................................................................. 21
Tucker v. Am. Int’l Grp., Inc.,
281 F.R.D. 85 (D. Conn. 2012)........................................................................................... 20, 21
United States v. Jacques Dessange, Inc.,
2000 WL 310345 (S.D.N.Y. Mar. 27, 2000) ............................................................................ 22
Upjohn Co. v. United States,
449 U.S. 383 (1981).................................................................................................................. 22
Wells Fargo Bank, N.A. v. Konover,
2009 WL 585434 (D. Conn. Mar. 4, 2009) .............................................................................. 20
William A. Gross Const., Assoc., Inc. v. Am. Mfrs. Mut. Ins. Co.,
262 F.R.D. 354 (S.D.N.Y. 2009) .............................................................................................. 21
Rules
Fed. R. Civ. P. 37.......................................................................................................................... 12
iii
Ransome_000218
Non-Party Sarah Ransome in 2006 on Little St. James Island
4
her story. From this dubious premise, Defendant then argues that Ms. Ransome should therefore be
punished by having to make burdensome and invasive disclosures of such things as her boyfriend’s
cell phone number and information from her current bank account. Unwilling to confine her attacks
to Ms. Ransome, Defendant then levels attacks on the professionalism of Ms. Giuffre’s legal counsel,
stating in her brief: “One can hardly imagine a better motive to fabricate testimony that the type of
lottery win. To make it even better, there is no purchase price for the ticket, because the people who
want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono
basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication” is directly refuted by
the multiple pictures and e-mails non-party Ms. Ransome produced – documentary evidence that
Defendant fails to discuss in her brief. Moreover, non-party Ms. Ransome is identified as a passenger
on Epstein’s own flight logs: __________________________________
Non-party Ms. Ransome’s fulsome production included items such as multiple e-mails with
. These e-mails are direct
evidence of the trafficking of females for the purpose of sex, and the use of fraud and manipulation to
accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms. Ransome’s testimony proves that
what little Defendant did say during her deposition was far from the truth.
10
These documents do not lie, and moreover make it abundantly clear that Defendant was far
from truthful during her deposition when she denied being a part of Epstein’s sexual abuse
conspiracy. Rather than engage Ms. Ransome’s allegations on the merits, Defendant responds with
technicalities. For example, Defendant attempts to suggest that Ms. Giuffre’s counsel was not diligent
in disclosing Ms. Ransome. Yet if there was any failure of disclosure here, it was entirely
Defendant’s failure. Clearly, witness Ms. Ransome is someone who has relevant evidence in this
case, as her many photographs, e-mails, and other documents undoubtedly establish. And yet
Defendant failed to disclose Ms. Ransome’s existence not only in her Rule 26 disclosures, but also
through (to put it mildly) her inaccurate testimony during her deposition. As a result, Ms. Giuffre’s
legal counsel did not learn of Ms. Ransome’s existence and whereabouts until November.
Furthermore, as Ms. Giuffre’s counsel informed the Court, it was not until the first week in January
that non-party Ms. Ransome was able to meet with counsel in person in Barcelona. Ms. Giuffre’s
counsel was not going to petition to bring a new witness before this Court without conducting
complete due diligence to assure that her testimony was credible. As soon as that in-person meeting
was accomplished in early January, Ms. Giuffre filed the appropriate papers with this Court and
immediately offered to make Ms. Ransome available to Defendant for a deposition. After first
delaying in taking that deposition, Defendant then made this victim of sex trafficking, who had flown
to the United States from Barcelona, sit for ten hours at a deposition and be subject to harassing
questions.
11
ARGUMENT
In light of non-party Ms. Ransome’s diligent efforts to satisfy Defendant’s needs for
discovery, the Court should enter a protective order against further discovery (DE 640) and deny
Defendant’s Combined Motion to Compel1 (DE 655).
As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not
be allowed to use the discovery process as a means of intimidating and harassing a non-party.
Counsel is not permitted to intentionally harass or embarrass a non-party witness during a
deposition. See Smartix International LLC v. Garrubbo, Romankow & Capese, No. 06 CIV 1501
(JGK), 2007 WL 41666035 at *2 (S.D.N.Y Nov. 20, 2007) (court protecting deponent from
annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel
records relating to non-party).
Courts are more vigilant with these protections when the discovery is being sought from a
non-party. “[T]he fact of non-party status may be considered by the Court in weighing the
burdens imposed in the circumstances.” Katz v. Batavia Marine & Sporting Supplies, Inc., 984
F.2d 422, 424 (Fed.Cir.1993); accord Amini Innovation Corp. v. McFerran Home Furnishings,
Inc., 300 F.R.D. 406, 409 (C.D. Cal. 2014); see also Dart Industries Co., Inc. v. Westwood
1
In her Motion to Compel, Defendant failed to comply with Local Rule 37.1 and only inserted
selected text from certain objections. Rule 37.1 requires: “upon any motion or application
involving discovery or disclosure requests or responses under Fed. R. Civ. P. 37, the moving
party shall specify and quote or set forth verbatim in the motion papers each discovery request
and response to which the motion or application is addressed.” For all of the discovery items
upon which Defendant moves, Defendant has wholly failed to do this. Upon a motion to compel,
a court is called upon to evaluate the discovery requests as well as the responses and objections.
Local Rule 37.1 is designed to protect against the exact type of self-serving omission of the
responding party’s objections that Defendant has done in her brief. Accordingly, the Court
should deny Defendant’s motion in its entirety for failure to comply with Local Rule 37.1. See
Blodgett v. Siemens Industry, Inc., 2016 WL 4203490, at *1 (E.D.N.Y. 2016) (denying motion
without prejudice for failure to comply with Local Rule 37.1 (which is the same rule in the
Eastern District of New York)); see also Pottinger Dec. at Exhibit 2, Non-Party Sarah Ransome’s
Responses and Objections to Defendant’s Subpoena Requests.
12
incorrect. To be clear, Ms. Ransome produced documents, or responded that no documents exist,
to Requests 1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 13, 14, 20, 23. Request 24 was withdrawn by Defendant
and non-party Ransome does not have any documents responsive to Request 26. As to the
remaining requests:
Request 12 – Ms. Ransome testified that she does not have any credit card receipts,
cancelled checks, or documents reflecting travel from 2006-2007, other than what she has
already produced. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 367, 402-403.
Request 15 - She testified that she does not have any documents reflecting the money
paid to her by Jeffrey Epstein (she was paid in cash). See Pottinger Dec. at Exhibit 1,
Ransome Tr. at 151-152, 415.
Request 16 - She testified that she was given cash by Epstein during the years 2006-2007
while she was being trafficked by Defendant and Epstein. See Pottinger Dec. at Exhibit 1,
Ransome Tr. at 415-416.
Request 17 - She testified that she lived in Epstein’s apartment and thereafter lived with a
male friend, but she does not have any leases, deeds, or rental agreements for 2006-2007..
See Pottinger Dec. at Exhibit 1, Ransome Tr. at 76-78, 228-229.
Request 19 – Ms. Ransome produced a copy of her FIT essay but testified that she does
not believe she has the application but Jeffrey Epstein or the Defendant likely have a
copy because they claimed to be assisting her with the application and submission
process for FIT). See Pottinger Dec. at Exhibit 1, Ransome Tr. at 171-172, 179-180.
Request 21 – Ms. Ransome testified she did very little modeling because she wasn’t
successful at it and has no documents relating to her modeling) See Pottinger Dec. at
Exhibit 1, Ransome Tr. at 82, 85, 112-113, 216, 415.
Request 25 - She testified she has not had any communication with law enforcement. See
Pottinger Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 9, 12-13, 35-38.
Request 28 - Defendant already has her civil complaint in Jane Doe 43, and Ms.
Ransome already testified that she is involved in that litigation.
Request 30 – Ms. Ransome testified that she does not have a current account on Twitter
or any other social media platform, and does not have the information for any for the
years 2006-2007. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 61.
16
II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE
PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY
WITNESS
Request 10 (Current Passport/Current Visas):
As to Request 10, Ms. Ransome produced her passport during the time that she was being
trafficked by Defendant and Epstein. She does not have Visas from that time period, as she
testified. Non-party Ms. Ransome should not have to produce her current passport, and
Defendant has given no good faith reason for why she should have to.
The remainder of Request 10 is overly broad, seeking “all communications regarding any
of Your passports, visas, visa applications or to her permissions to live, work or study in a
foreign country for the years 2005 – present.” What is responsive and relevant to this case - the
passport she held during the years 2006 and 2007 - has been produced. The reminder is simply
being sought in order to learn the patterns of Ms. Ransome’s travel for purposes of harassing and
intimidating her.
Request 18 (Current Driver’s License):
Despite non-party Ransome having produced her passport showing her travel during the
period she was being trafficked by Defendant and Epstein, Defendant seeks a “copy of her
current driver’s license.” Non-party Ransome is already fearful for her life and has been
followed at least once since she disclosed the abuse she endured at the hands of Defendant and
Epstein. Obtaining a copy of this non-party’s current driver’s license is solely for the purpose of
harassing and intimidating her and should not be permitted. The evidence that is relevant to the
claims from 2006-2007 has already been produced, including the copy of her passport.
Request 29 (Current Bank Statement, Paycheck, Credit Card Statements):
Non-party Ransome testified that she is presently unemployed and is living with her
boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial
17
information from this non-party as set forth in Request 29: “A copy of your most recent
paycheck, paycheck stub, earnings statement and any bank statement, credit card statement and
any document reflecting any money owed by you to anyone.” This type of current financial
information is only being sought for the improper purpose of embarrassing, intimidating, and
harassing this non-party. See DaCosta v. City of Danbury, 298 F.R.D. 37 (D. Conn. 2014)
(protective order granted with respect to personal information of nonparties, including home
addresses, email addresses, phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers).
Request 22 (All Modeling Contracts Signed or Entered into By You):
Non-party Ransome provided testimony that she did very little modeling while in New
York because she was not successful at it, and she also testified that it was mostly freelance
modeling. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 82, 85, 112-113, 216, 415. Despite
receiving this testimony, Defendant is now insisting that she conduct a search for any modeling
contract that Ms. Ransome has signed and produce them. This search is solely for the improper
purpose of embarrassing, harassing, and intimidating this non-party witness, and should be
precluded.
Accordingly, non-party Ransome objects to these Requests which are only being sought
for the purpose of harassing and intimidating this non-party witness, and requests that the Court
protect her from this clearly, highly personal and harassing discovery.
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPOSITION QUESTIONS THAT ARE SOLELY MEANT TO EMBARRASS,
INTIMIDATE AND HARASS THIS NON-PARTY.
Defendant had Ms. Ransome present for a deposition for over ten hours with breaks,
ensuring that Defendant got a full seven (7) hours of tape time as provided by the Rules. Despite
this, Defendant seeks to compel Ms. Ransome to sit for additional questions. The following are
18
the categories of deposition testimony that Defendant seeks for which non-party Ms. Ransome
contends are sought only for the purpose of harassment and intimidation:
Current paycheck records and other banking records. Defendant has now added to
this that she wants her boyfriend’s current income and financial position since non-
party Ms. Ransome testified that she is living with her boyfriend. See Pottinger Dec at
Exhibit 1, Ransome Dep. Tr. at 8-9, 13-14.
Boyfriend’s cell phone number. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at
27-28.
Her parent’s current address information. See Pottinger Dec at Exhibit 1, Ransome
Dep. Tr. at 14.
Communications that non-party Ms. Ransome testified she recalls having with a
reporter in the fall of 2016. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 37-
43, 386-388.
Privileged communications with Alan Dershowitz when he was meeting with Ms.
Ransome about a legal matter. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at
182-186.
Her partner’s occupation. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 13-14.
What hotel Ms. Ransome was staying at in New York for her deposition. See
Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 30-34.
Whether Alan Dershowitz contacted anyone on Ms. Ransome’s behalf. See Pottinger
Dec at Exhibit 1, Ransome Dep. Tr. at 199.
Her stepmother’s phone, e-mail address and physical address – despite the fact that
non-party Ms. Ransome already gave testimony at her lengthy deposition that she
does not have her stepmother’s contact information. See Pottinger Dec. at Exhibit 1,
Ransome Dep. Tr. at 239-240.
When Ms. Ransome provided her photos to her lawyer. See Pottinger Dec. at Exhibit
1, Ransome Dep. Tr. at 363.
Ms. Ransome testified that she believed that Alan Dershowitz had been retained to be her
lawyer in a legal matter that she was having. Accordingly, counsel objected on privilege grounds
when Defendant’s counsel attempted to obtain specifics about those meetings. In addition,
Defendant attempted to obtain privileged and work product information about Ms. Ransome’s
19
meetings with her counsel in this matter. As the Court can see, the other questions relate to a
number of personal family information that a non-party witness should not be required to
disclose, particularly when she has a justified fear of Defendant and Jeffrey Epstein. Defendant
also requests documents relating to Ms. Ransome’s testimony that she recently had conversations
with a reporter when she was trying to encourage other victims of Defendant and Epstein to
come forward with their stories. After giving fulsome testimony on this topic, Defendant is now
demanding that Ms. Ransome conduct a search for documents relating to this reporter. Again,
non-party Ms. Ransome has produced a significant amount of discovery and has given her
testimony and she should not be forced to undertake an additional burden. Finally, prying into
her current personal financial information or her boyfriend’s personal financial information
should not be condoned. Simply put, all of these categories above for which Defendant seeks
additional testimony have nothing to do with this action and are being sought solely to
embarrass, harass, and intimidate this non-party, which should not be condoned.
IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE
BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG.
Despite being given less than seven days to respond to Defendant’s subpoena and
produce documents, Defendant also wrongly demands that this non-party undertake the burden
and expense of producing a privilege log. New York law protects non-parties from the
significant burden and expense of producing a privilege log. “The burden on the party from
which discovery is sought must, of course, be balanced against the need for the information
sought.” Wells Fargo Bank, N.A. v. Konover, 2009 WL 585434, at *5 (D. Conn. Mar. 4, 2009)
(denying Rule 45 motion to compel production of documents from non-party). “In performing
such a balance, courts have considered the fact that discovery is being sought from a third or
non-party, which weighs against permitting discovery.” Tucker v. Am. Int’l Grp., Inc., 281
20
F.R.D. 85, 92 (D. Conn. 2012) (finding request for production on non-party - including creation
of privilege log - too burdensome); see also Medical Components, Inc. v. Classic Medical, Inc.,
210 F.R.D. 175, 180 n.9 (M.D.N.C. 2002) (“the court should give special weight to the unwanted
burden thrust upon non-parties when evaluating the balance of competing needs.”)). “Within this
[Second] Circuit, courts have held nonparty status to be a ‘significant’ factor in determining
whether discovery is unduly burdensome.” Tucker, 281 F.R.D. at 92 (citing Solarex Corp. v.
Arco Solar, Inc., 121 F.R.D. 163, 179 (E.D.N.Y. 1988) (status as non-party “significant” factor
in denying defendant’s discovery demand)).
Ms. Ransome is a victim of sex trafficking who bravely came forward to help another
victim of abuse. She is not a large corporation with a team of in-house lawyers. In these
circumstances, imposing the burden of producing a privilege log on this non-party is inherently
unfair. A non-party is not required to undertake the burden of filing a privilege log. Defendant is
only seeking to try to have this Court force non-party Ms. Ransome to produce a privilege log in
this matter to impose additional burden on Ms. Ransome.
In addition, Defendant wrongly argues that she is entitled to any communications and
witness interviews between Ms. Giuffre’s lawyers and non-party Ms. Ransome. It is well settled
that documents relating to witness interviews are protected by the work product privilege. In
addition, Defendant wrongly argues that she is entitled to any communications and witness
interviews between Ms. Giuffre’s lawyers and non-party Ms. Ransome. See William A. Gross
Const., Assoc., Inc. v. Am. Mfrs. Mut. Ins. Co., 262 F.R.D. 354, 359 (S.D.N.Y. 2009) (upholding
work-product privilege, finding doctrine “‘extends to notes, memoranda, witness interviews, and
other material’” created in preparation for litigation and trial (emphasis added) (internal citation
omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney
21
relevance of the questions were tenuous at best and appeared to be directed at improperly
gathering information for a different lawsuit); Night Hawk Limited v. Briarpatch Limited, No. 03
CIV. 1382 (RWS), 2003 WL 23018833 (S.D.N.Y. Dec. 23, 2003). Irrespective of this case law
that says a party should not wrongfully seek a non-party’s documents for use in a different
matter, non-party Ms. Ransome did produce the documents that she has that relate directly to
Defendant and Epstein as she testified.
CONCLUSION
Non-party Ms. Ransome respectfully requests that this Court grant her protection from
having to produce any additional discovery or sit for any additional deposition testimony (DE
650). Non-party Ms. Ransome also respectfully requests that the Court deny Defendant’s
Combined Motion to Compel (DE 655).
Dated: March 7, 2017
Respectfully Submitted,
By: /s/ J. Stanley Pottinger
J. Stanley Pottinger (Pro Hac Vice)
Counsel for Sarah Ransome
23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th of March, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served this day on the individuals identified below via transmission
of Notices of Electronic Filing generated by CM/ECF.
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
[email protected]
Sigrid McCawley, Esq.
Meredith Schultz, Esq.
BOIES SCHILLER & FLEXNER, LLP
401 E. Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301
Tel: (954) 356-0011
Fax: (954) 956-0022
[email protected]
[email protected]
David Boies
BOIES SCHILLER & FLEXNER LLP
333 Main Street
Armonk, NY 10504
[email protected]
Bradley J. Edwards (Pro Hac Vice)
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
(954) 524-2820
[email protected]
24
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-52024
[email protected]
Peter Guirguis, Esq.
MINTZ & GOLD, LLP
600 Third Avenue
New York, NY 10016
(212) 696-4848
[email protected]
/s/ J. Stanley Pottinger
J. Stanley Pottinger
4
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
25
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
REPLY IN SUPPORT OF NON-PARTY’S MOTION FOR PROTECTIVE ORDER AND
OPPOSITION TO DEFENDANT’S COMBINED MOTION TO COMPEL NON-PARTY
WITNESS TO PRODUCE DOCUMENTS AND RESPOND TO DEPOSITION
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES .......................................................................................................... ii
BACKGROUND ............................................................................................................................ 1
ARGUMENT................................................................................................................................ 12
I. NON-PARTY RANSOME HAS PRODUCED DOCUMENTS OF AND DOES NOT
HAVE DOCUMENTS FOR A NUMBER OF REQUESTS. ...........................................15
II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE
PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY
WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPOSITION QUESTIONS THAT ARE SOLELY MEANT TO EMBARRASS,
INTIMIDATE AND HARASS THIS NON-PARTY........................................................18
IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE
BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG..............................20
V. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO
JANE DOE 43. ...................................................................................................................22
CONCLUSION............................................................................................................................. 23
CERTIFICATE OF SERVICE ..................................................................................................... 24
i
TABLE OF AUTHORITIES
Page
Cases
Amini Innovation Corp. v. McFerran Home Furnishings, Inc.,
300 F.R.D. 406 (C.D. Cal. 2014) .............................................................................................. 12
Blodgett v. Siemens Industry, Inc.,
2016 WL 4203490 (E.D.N.Y. 2016)......................................................................................... 12
Buck v. Indian Mountain Sch.,
2017 WL 421648 (D. Conn. Jan. 31, 2017).............................................................................. 22
City of Pontiac Gen. Employee’s Ret. Sys. v. Lockheed Martin Corp.,
2012 WL 4202657 (S.D.N.Y. Sept. 18, 2012).......................................................................... 22
DaCosta v. City of Danbury,
298 F.R.D. 37 (D. Conn. 2014)........................................................................................... 13, 18
Dart Industries Co., Inc. v. Westwood Chemical Co.,
649 F.2d 646 (9th Cir. 1980) .................................................................................................... 12
Gerber v. Down E. Cmty. Hosp.,
266 F.R.D. 29 (D. Me. 2010).................................................................................................... 22
Hickman v. Taylor,
329 U.S. 495, 67 S. Ct. 385, 91 L.Ed. 451 (1947).................................................................... 22
Katz v. Batavia Marine & Sporting Supplies, Inc.,
984 F.2d 422 (Fed.Cir.1993)..................................................................................................... 12
Liz Claiborne, Inc., v. Mademoiselle Knitwear, Inc.,
No. 96 CIV 2064 (RWS), 1997 WL 53184 .............................................................................. 22
Medical Components, Inc. v. Classic Medical, Inc.,
210 F.R.D. 175 (M.D.N.C. 2002) ............................................................................................. 21
Night Hawk Limited v. Briarpatch Limited,
No. 03 CIV. 1382 (RWS), 2003 WL 23018833 (S.D.N.Y. Dec. 23, 2003) ............................. 23
S.E.C. v. NIR Grp., LLC,
283 F.R.D. 127 (E.D.N.Y. 2012) .............................................................................................. 22
Smartix International LLC v. Garrubbo, Romankow & Capese,
No. 06 CIV 1501 (JGK), 2007 WL 41666035 (S.D.N.Y. Nov. 20, 2007) ............................... 12
ii
Solarex Corp. v. Arco Solar, Inc.,
121 F.R.D. 163 (E.D.N.Y. 1988) .............................................................................................. 21
Tucker v. Am. Int’l Grp., Inc.,
281 F.R.D. 85 (D. Conn. 2012)........................................................................................... 20, 21
United States v. Jacques Dessange, Inc.,
2000 WL 310345 (S.D.N.Y. Mar. 27, 2000) ............................................................................ 22
Upjohn Co. v. United States,
449 U.S. 383 (1981).................................................................................................................. 22
Wells Fargo Bank, N.A. v. Konover,
2009 WL 585434 (D. Conn. Mar. 4, 2009) .............................................................................. 20
William A. Gross Const., Assoc., Inc. v. Am. Mfrs. Mut. Ins. Co.,
262 F.R.D. 354 (S.D.N.Y. 2009) .............................................................................................. 21
Rules
Fed. R. Civ. P. 37.......................................................................................................................... 12
iii
Ransome_000218
Non-Party Sarah Ransome in 2006 on Little St. James Island
4
her story. From this dubious premise, Defendant then argues that Ms. Ransome should therefore be
punished by having to make burdensome and invasive disclosures of such things as her boyfriend’s
cell phone number and information from her current bank account. Unwilling to confine her attacks
to Ms. Ransome, Defendant then levels attacks on the professionalism of Ms. Giuffre’s legal counsel,
stating in her brief: “One can hardly imagine a better motive to fabricate testimony that the type of
lottery win. To make it even better, there is no purchase price for the ticket, because the people who
want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono
basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication” is directly refuted by
the multiple pictures and e-mails non-party Ms. Ransome produced – documentary evidence that
Defendant fails to discuss in her brief. Moreover, non-party Ms. Ransome is identified as a passenger
on Epstein’s own flight logs: __________________________________
Non-party Ms. Ransome’s fulsome production included items such as multiple e-mails with
. These e-mails are direct
evidence of the trafficking of females for the purpose of sex, and the use of fraud and manipulation to
accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms. Ransome’s testimony proves that
what little Defendant did say during her deposition was far from the truth.
10
These documents do not lie, and moreover make it abundantly clear that Defendant was far
from truthful during her deposition when she denied being a part of Epstein’s sexual abuse
conspiracy. Rather than engage Ms. Ransome’s allegations on the merits, Defendant responds with
technicalities. For example, Defendant attempts to suggest that Ms. Giuffre’s counsel was not diligent
in disclosing Ms. Ransome. Yet if there was any failure of disclosure here, it was entirely
Defendant’s failure. Clearly, witness Ms. Ransome is someone who has relevant evidence in this
case, as her many photographs, e-mails, and other documents undoubtedly establish. And yet
Defendant failed to disclose Ms. Ransome’s existence not only in her Rule 26 disclosures, but also
through (to put it mildly) her inaccurate testimony during her deposition. As a result, Ms. Giuffre’s
legal counsel did not learn of Ms. Ransome’s existence and whereabouts until November.
Furthermore, as Ms. Giuffre’s counsel informed the Court, it was not until the first week in January
that non-party Ms. Ransome was able to meet with counsel in person in Barcelona. Ms. Giuffre’s
counsel was not going to petition to bring a new witness before this Court without conducting
complete due diligence to assure that her testimony was credible. As soon as that in-person meeting
was accomplished in early January, Ms. Giuffre filed the appropriate papers with this Court and
immediately offered to make Ms. Ransome available to Defendant for a deposition. After first
delaying in taking that deposition, Defendant then made this victim of sex trafficking, who had flown
to the United States from Barcelona, sit for ten hours at a deposition and be subject to harassing
questions.
11
ARGUMENT
In light of non-party Ms. Ransome’s diligent efforts to satisfy Defendant’s needs for
discovery, the Court should enter a protective order against further discovery (DE 640) and deny
Defendant’s Combined Motion to Compel1 (DE 655).
As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not
be allowed to use the discovery process as a means of intimidating and harassing a non-party.
Counsel is not permitted to intentionally harass or embarrass a non-party witness during a
deposition. See Smartix International LLC v. Garrubbo, Romankow & Capese, No. 06 CIV 1501
(JGK), 2007 WL 41666035 at *2 (S.D.N.Y Nov. 20, 2007) (court protecting deponent from
annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel
records relating to non-party).
Courts are more vigilant with these protections when the discovery is being sought from a
non-party. “[T]he fact of non-party status may be considered by the Court in weighing the
burdens imposed in the circumstances.” Katz v. Batavia Marine & Sporting Supplies, Inc., 984
F.2d 422, 424 (Fed.Cir.1993); accord Amini Innovation Corp. v. McFerran Home Furnishings,
Inc., 300 F.R.D. 406, 409 (C.D. Cal. 2014); see also Dart Industries Co., Inc. v. Westwood
1
In her Motion to Compel, Defendant failed to comply with Local Rule 37.1 and only inserted
selected text from certain objections. Rule 37.1 requires: “upon any motion or application
involving discovery or disclosure requests or responses under Fed. R. Civ. P. 37, the moving
party shall specify and quote or set forth verbatim in the motion papers each discovery request
and response to which the motion or application is addressed.” For all of the discovery items
upon which Defendant moves, Defendant has wholly failed to do this. Upon a motion to compel,
a court is called upon to evaluate the discovery requests as well as the responses and objections.
Local Rule 37.1 is designed to protect against the exact type of self-serving omission of the
responding party’s objections that Defendant has done in her brief. Accordingly, the Court
should deny Defendant’s motion in its entirety for failure to comply with Local Rule 37.1. See
Blodgett v. Siemens Industry, Inc., 2016 WL 4203490, at *1 (E.D.N.Y. 2016) (denying motion
without prejudice for failure to comply with Local Rule 37.1 (which is the same rule in the
Eastern District of New York)); see also Pottinger Dec. at Exhibit 2, Non-Party Sarah Ransome’s
Responses and Objections to Defendant’s Subpoena Requests.
12
incorrect. To be clear, Ms. Ransome produced documents, or responded that no documents exist,
to Requests 1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 13, 14, 20, 23. Request 24 was withdrawn by Defendant
and non-party Ransome does not have any documents responsive to Request 26. As to the
remaining requests:
Request 12 – Ms. Ransome testified that she does not have any credit card receipts,
cancelled checks, or documents reflecting travel from 2006-2007, other than what she has
already produced. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 367, 402-403.
Request 15 - She testified that she does not have any documents reflecting the money
paid to her by Jeffrey Epstein (she was paid in cash). See Pottinger Dec. at Exhibit 1,
Ransome Tr. at 151-152, 415.
Request 16 - She testified that she was given cash by Epstein during the years 2006-2007
while she was being trafficked by Defendant and Epstein. See Pottinger Dec. at Exhibit 1,
Ransome Tr. at 415-416.
Request 17 - She testified that she lived in Epstein’s apartment and thereafter lived with a
male friend, but she does not have any leases, deeds, or rental agreements for 2006-2007..
See Pottinger Dec. at Exhibit 1, Ransome Tr. at 76-78, 228-229.
Request 19 – Ms. Ransome produced a copy of her FIT essay but testified that she does
not believe she has the application but Jeffrey Epstein or the Defendant likely have a
copy because they claimed to be assisting her with the application and submission
process for FIT). See Pottinger Dec. at Exhibit 1, Ransome Tr. at 171-172, 179-180.
Request 21 – Ms. Ransome testified she did very little modeling because she wasn’t
successful at it and has no documents relating to her modeling) See Pottinger Dec. at
Exhibit 1, Ransome Tr. at 82, 85, 112-113, 216, 415.
Request 25 - She testified she has not had any communication with law enforcement. See
Pottinger Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 9, 12-13, 35-38.
Request 28 - Defendant already has her civil complaint in Jane Doe 43, and Ms.
Ransome already testified that she is involved in that litigation.
Request 30 – Ms. Ransome testified that she does not have a current account on Twitter
or any other social media platform, and does not have the information for any for the
years 2006-2007. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 61.
16
II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE
PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY
WITNESS
Request 10 (Current Passport/Current Visas):
As to Request 10, Ms. Ransome produced her passport during the time that she was being
trafficked by Defendant and Epstein. She does not have Visas from that time period, as she
testified. Non-party Ms. Ransome should not have to produce her current passport, and
Defendant has given no good faith reason for why she should have to.
The remainder of Request 10 is overly broad, seeking “all communications regarding any
of Your passports, visas, visa applications or to her permissions to live, work or study in a
foreign country for the years 2005 – present.” What is responsive and relevant to this case - the
passport she held during the years 2006 and 2007 - has been produced. The reminder is simply
being sought in order to learn the patterns of Ms. Ransome’s travel for purposes of harassing and
intimidating her.
Request 18 (Current Driver’s License):
Despite non-party Ransome having produced her passport showing her travel during the
period she was being trafficked by Defendant and Epstein, Defendant seeks a “copy of her
current driver’s license.” Non-party Ransome is already fearful for her life and has been
followed at least once since she disclosed the abuse she endured at the hands of Defendant and
Epstein. Obtaining a copy of this non-party’s current driver’s license is solely for the purpose of
harassing and intimidating her and should not be permitted. The evidence that is relevant to the
claims from 2006-2007 has already been produced, including the copy of her passport.
Request 29 (Current Bank Statement, Paycheck, Credit Card Statements):
Non-party Ransome testified that she is presently unemployed and is living with her
boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial
17
information from this non-party as set forth in Request 29: “A copy of your most recent
paycheck, paycheck stub, earnings statement and any bank statement, credit card statement and
any document reflecting any money owed by you to anyone.” This type of current financial
information is only being sought for the improper purpose of embarrassing, intimidating, and
harassing this non-party. See DaCosta v. City of Danbury, 298 F.R.D. 37 (D. Conn. 2014)
(protective order granted with respect to personal information of nonparties, including home
addresses, email addresses, phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers).
Request 22 (All Modeling Contracts Signed or Entered into By You):
Non-party Ransome provided testimony that she did very little modeling while in New
York because she was not successful at it, and she also testified that it was mostly freelance
modeling. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 82, 85, 112-113, 216, 415. Despite
receiving this testimony, Defendant is now insisting that she conduct a search for any modeling
contract that Ms. Ransome has signed and produce them. This search is solely for the improper
purpose of embarrassing, harassing, and intimidating this non-party witness, and should be
precluded.
Accordingly, non-party Ransome objects to these Requests which are only being sought
for the purpose of harassing and intimidating this non-party witness, and requests that the Court
protect her from this clearly, highly personal and harassing discovery.
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPOSITION QUESTIONS THAT ARE SOLELY MEANT TO EMBARRASS,
INTIMIDATE AND HARASS THIS NON-PARTY.
Defendant had Ms. Ransome present for a deposition for over ten hours with breaks,
ensuring that Defendant got a full seven (7) hours of tape time as provided by the Rules. Despite
this, Defendant seeks to compel Ms. Ransome to sit for additional questions. The following are
18
the categories of deposition testimony that Defendant seeks for which non-party Ms. Ransome
contends are sought only for the purpose of harassment and intimidation:
Current paycheck records and other banking records. Defendant has now added to
this that she wants her boyfriend’s current income and financial position since non-
party Ms. Ransome testified that she is living with her boyfriend. See Pottinger Dec at
Exhibit 1, Ransome Dep. Tr. at 8-9, 13-14.
Boyfriend’s cell phone number. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at
27-28.
Her parent’s current address information. See Pottinger Dec at Exhibit 1, Ransome
Dep. Tr. at 14.
Communications that non-party Ms. Ransome testified she recalls having with a
reporter in the fall of 2016. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 37-
43, 386-388.
Privileged communications with Alan Dershowitz when he was meeting with Ms.
Ransome about a legal matter. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at
182-186.
Her partner’s occupation. See Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 13-14.
What hotel Ms. Ransome was staying at in New York for her deposition. See
Pottinger Dec at Exhibit 1, Ransome Dep. Tr. at 30-34.
Whether Alan Dershowitz contacted anyone on Ms. Ransome’s behalf. See Pottinger
Dec at Exhibit 1, Ransome Dep. Tr. at 199.
Her stepmother’s phone, e-mail address and physical address – despite the fact that
non-party Ms. Ransome already gave testimony at her lengthy deposition that she
does not have her stepmother’s contact information. See Pottinger Dec. at Exhibit 1,
Ransome Dep. Tr. at 239-240.
When Ms. Ransome provided her photos to her lawyer. See Pottinger Dec. at Exhibit
1, Ransome Dep. Tr. at 363.
Ms. Ransome testified that she believed that Alan Dershowitz had been retained to be her
lawyer in a legal matter that she was having. Accordingly, counsel objected on privilege grounds
when Defendant’s counsel attempted to obtain specifics about those meetings. In addition,
Defendant attempted to obtain privileged and work product information about Ms. Ransome’s
19
meetings with her counsel in this matter. As the Court can see, the other questions relate to a
number of personal family information that a non-party witness should not be required to
disclose, particularly when she has a justified fear of Defendant and Jeffrey Epstein. Defendant
also requests documents relating to Ms. Ransome’s testimony that she recently had conversations
with a reporter when she was trying to encourage other victims of Defendant and Epstein to
come forward with their stories. After giving fulsome testimony on this topic, Defendant is now
demanding that Ms. Ransome conduct a search for documents relating to this reporter. Again,
non-party Ms. Ransome has produced a significant amount of discovery and has given her
testimony and she should not be forced to undertake an additional burden. Finally, prying into
her current personal financial information or her boyfriend’s personal financial information
should not be condoned. Simply put, all of these categories above for which Defendant seeks
additional testimony have nothing to do with this action and are being sought solely to
embarrass, harass, and intimidate this non-party, which should not be condoned.
IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE
BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG.
Despite being given less than seven days to respond to Defendant’s subpoena and
produce documents, Defendant also wrongly demands that this non-party undertake the burden
and expense of producing a privilege log. New York law protects non-parties from the
significant burden and expense of producing a privilege log. “The burden on the party from
which discovery is sought must, of course, be balanced against the need for the information
sought.” Wells Fargo Bank, N.A. v. Konover, 2009 WL 585434, at *5 (D. Conn. Mar. 4, 2009)
(denying Rule 45 motion to compel production of documents from non-party). “In performing
such a balance, courts have considered the fact that discovery is being sought from a third or
non-party, which weighs against permitting discovery.” Tucker v. Am. Int’l Grp., Inc., 281
20
F.R.D. 85, 92 (D. Conn. 2012) (finding request for production on non-party - including creation
of privilege log - too burdensome); see also Medical Components, Inc. v. Classic Medical, Inc.,
210 F.R.D. 175, 180 n.9 (M.D.N.C. 2002) (“the court should give special weight to the unwanted
burden thrust upon non-parties when evaluating the balance of competing needs.”)). “Within this
[Second] Circuit, courts have held nonparty status to be a ‘significant’ factor in determining
whether discovery is unduly burdensome.” Tucker, 281 F.R.D. at 92 (citing Solarex Corp. v.
Arco Solar, Inc., 121 F.R.D. 163, 179 (E.D.N.Y. 1988) (status as non-party “significant” factor
in denying defendant’s discovery demand)).
Ms. Ransome is a victim of sex trafficking who bravely came forward to help another
victim of abuse. She is not a large corporation with a team of in-house lawyers. In these
circumstances, imposing the burden of producing a privilege log on this non-party is inherently
unfair. A non-party is not required to undertake the burden of filing a privilege log. Defendant is
only seeking to try to have this Court force non-party Ms. Ransome to produce a privilege log in
this matter to impose additional burden on Ms. Ransome.
In addition, Defendant wrongly argues that she is entitled to any communications and
witness interviews between Ms. Giuffre’s lawyers and non-party Ms. Ransome. It is well settled
that documents relating to witness interviews are protected by the work product privilege. In
addition, Defendant wrongly argues that she is entitled to any communications and witness
interviews between Ms. Giuffre’s lawyers and non-party Ms. Ransome. See William A. Gross
Const., Assoc., Inc. v. Am. Mfrs. Mut. Ins. Co., 262 F.R.D. 354, 359 (S.D.N.Y. 2009) (upholding
work-product privilege, finding doctrine “‘extends to notes, memoranda, witness interviews, and
other material’” created in preparation for litigation and trial (emphasis added) (internal citation
omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney
21
relevance of the questions were tenuous at best and appeared to be directed at improperly
gathering information for a different lawsuit); Night Hawk Limited v. Briarpatch Limited, No. 03
CIV. 1382 (RWS), 2003 WL 23018833 (S.D.N.Y. Dec. 23, 2003). Irrespective of this case law
that says a party should not wrongfully seek a non-party’s documents for use in a different
matter, non-party Ms. Ransome did produce the documents that she has that relate directly to
Defendant and Epstein as she testified.
CONCLUSION
Non-party Ms. Ransome respectfully requests that this Court grant her protection from
having to produce any additional discovery or sit for any additional deposition testimony (DE
650). Non-party Ms. Ransome also respectfully requests that the Court deny Defendant’s
Combined Motion to Compel (DE 655).
Dated: March 7, 2017
Respectfully Submitted,
By: /s/ J. Stanley Pottinger
J. Stanley Pottinger (Pro Hac Vice)
Counsel for Sarah Ransome
23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th of March, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served this day on the individuals identified below via transmission
of Notices of Electronic Filing generated by CM/ECF.
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
[email protected]
Sigrid McCawley, Esq.
Meredith Schultz, Esq.
BOIES SCHILLER & FLEXNER, LLP
401 E. Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301
Tel: (954) 356-0011
Fax: (954) 956-0022
[email protected]
[email protected]
David Boies
BOIES SCHILLER & FLEXNER LLP
333 Main Street
Armonk, NY 10504
[email protected]
Bradley J. Edwards (Pro Hac Vice)
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
(954) 524-2820
[email protected]
24
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-52024
[email protected]
Peter Guirguis, Esq.
MINTZ & GOLD, LLP
600 Third Avenue
New York, NY 10016
(212) 696-4848
[email protected]
/s/ J. Stanley Pottinger
J. Stanley Pottinger
4
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
25