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Case 1:15-cv-07433-LAP Document 1331-19 Filed 01/05/24 Page 2 of 12 Plaintiff Virginia Giuffre, argued in her Opposition to Summary Judgment that Defendant had waived her attorney-client and work-product privilege by submitting a lengthy self-serving affidavit by her attorney Philip Barden in support of her motion for Summary Judgment that discussed Mr. Barden’s “intent” in allegedly being the main drafter of Defendant’s January 2, 2015 press release. (DE 586 at p. 34) In Reply, Defendant conceded that in submitting Barden’s declaration, she had waived the work-product privilege, but denied a waiver of the attorney- client privilege. (DE 620 at p. 11) Despite admitting that Mr. Barden waived the work-product privilege, Defendant failed to produce all other work product documents. This Motion seeks production of those documents along with production of all documents previously withheld on the ground of attorney-client privilege because those, too, were waived by Defendant’s approval to submit Mr. Barden’s self-serving declaration in support of Summary Judgment. Specifically, Ms. Giuffre, hereby moves this Court to Order Defendant to produce all work product documents (including any internal e-mail communications) and all attorney-client communications she has had with her attorney, Philip Barden, relating to his representation of her, as well as all documents drafted, edited, or considered by Philip Barden in relation to his representation of Ghislaine Maxwell, which would include, but not be limited to, those privileged documents Defendant listed on her privilege log and order Mr. Barden to sit for his deposition in New York relating to the subject matter of his waiver. See Schultz Dec. at Composite Exhibit 1. L BACKGROUND In her Motion for Summary Judgment, Defendant relies on a post hoc, self-serving Declaration (“Barden Declaration”) from her English attorney Philip Barden. See Schultz Dec at Exhibit 2, Barden Declaration. Both the Declaration and the briefing for which it was drafted