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Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 15 of 21 Q. Was it while you were still together? A. Yes. Figueroa Dep. Tr. at 96:1-19. When Defendant argues that the journal or the dream journal would be unfavorable to Ms. Giuffre, Defendant ignores these and other damning facts. Defendant, again, fails to cite any countervailing fact, fails to point to any other evidence, and quotes no other testimony to support her argument that the journals would somehow be favorable to her. Instead, Defendant engages in wild speculation upon a mere “supposition of bad faith.” See Motion at 12, second paragraph. Defendant does not attempt to cite any evidence to support these conspiracy theories, as Ms. Giuffre herself has described the contents of one her journal as memories of her sex abuse and the contents of the other “dream” journal of her (literal) dreams (that they occurred while she was asleep). Defendant does not explain what the evidentiary value of a party’s dreams may have regarding a defamation claim, nor could she. Accordingly, Defendant’s motion should fail for this reason as well — she cannot make any showing whatsoever (much less carry her burden of proof) that the journal would be favorable to her. And, she completely ignores the blindingly obvious fact that the journal would likely be, if anything, highly favorable to Ms. Giuffre, it would simply contain more documentation of Defendant’s involvement in sexual abuse. + Q. What do you do with those notes? A. Nothing, literally nothing. They’re in a notebook that if I need to write it down. Ihave a dream notebook as well where I’ll just write down my dreams and stuff. January 16, 2016, Giuffre Tr. at 195:15-19. 12