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Case 1:15-cv-07433-LAP Document 1331-27 Filed 01/05/24 Page 2 of 11 Defendant Ghislaine Maxwell, through counsel, submits this Response to plaintiffs “Motion to Compel All Work Product and Attorney Client [sic] Communications with Philip Barden” (Doc.637). PROCEDURAL BACKGROUND On February 24, 2016, we served on plaintiff's counsel Ms. Maxwell’s Initial Fed. R. Civ. P. 26(a)(1)(A) Disclosures. The third-listed individual we identified who “likely [has] discoverable information” was Philip Barden, who, we disclosed, had information “concerning press statements . . . at issue in this matter”: 3. Philip Barden Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square (020) 7628-7576 Philip.Barden@devonshires.co.uk Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. Menninger Decl., Ex.A. Plaintiff never sought to depose Mr. Barden. On June 23, 2016, this Court ordered that the parties complete all fact discovery by July 29, 2016. See Doc.317 at 2. Plaintiff propounded discovery requests as follows: 10/27/2015 Plaintiff's First Set of Requests for Production 4/14/2016 Plaintiff's Second Set of Requests for Production 5/27/2016 [Plaintiff's First Set of Interrogatories 5/27/2016 Plaintiff's Request for Admissions The First Set propounded thirty-nine (39) requests for production. The Second Set propounded an additional forty-three (43) requests for production. None requested Mr. Barden’s