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Case 1:15-cv-07433-LAP Document 1331-19 Filed 01/05/24 Page 8 of 12 Inc., 783 F. Supp. 2d 373, 380 (E.D.N.Y. 2011) (waiver where party filed attorney-client communications on “publically-accessible electronic docket” and voluntarily sent copy to opposing counsel); accord First Am. CoreLogic, Inc. v. Fiserv, Inc., 2010 WL 4975566, at *2 (E.D.Tex. Dec. 2, 2010) (finding waiver of attorney-client privilege when party attached privileged communications to motion for protective order and served the documents on all parties); Tardiff v. Knox Cnty., 2007 WL 2413033, at **1—2 (D.Me. Aug. 21, 2007) (noting party's concession of waiver of attorney-client privilege when party submitted privileged email communications as an exhibit to court filing); Malkovich v. Best Buy Enter. Servs., Inc., 2006 WL 1428228, at *1 (D. Minn. May 22, 2006) (“By submitting the affidavit and accompanying exhibits, Plaintiff has waived the attorney-client privilege....”). Defendant has withheld communications between herself and her attorney Mr. Barden on the basis of “attorney-client privilege.” That privilege was waived by her affirmative submission of Mr. Barden’s declaration which included references to attorney-client communications between Maxwell and Mr. Barden. Accordingly, all communications, whether they are logged or not, between Defendant and Mr. Barden and any related communications Defendant has withheld from production based on a claim of attorney- client privilege must be produced and the Court direct Mr. Barden to sit for a deposition in New York regarding this subject matter. As articulated in Ms. Giuffre’s Response in Opposition to Defendant’s Motion for Summary Judgment, if the Court were to consider the Barden Declaration (which it should not), it would be ruling on a less than complete record because, based on this Declaration, it is necessary that Defendant disclose all communications with him and possibly others. Ms. Giuffre doesn’t have those communications, the Court doesn’t have those communications. It is highly prejudicial to allow Defendant to attempt to take advantage of a work product waiver through the