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Case 1:15-cv-07433-LAP Document 1331-27 Filed 01/05/24 Page 4 of 11 2. Plaintiff says Mr. Barden’s declaration “and the briefing” to which it was attached reference his “‘intent’ (and other synonymous phrases) . . . at least 62 times.” Mot. 3 (emphasis omitted). She suggests it is improper for a declaration and the briefs to which it is attached to reference or discuss intent. The suggestion is misguided. If intent is a relevant question of fact, of course there is nothing wrong with discussing it. 3. Plaintiff says Mr. Barden’s declaration “reveals attorney client [sic] legal advice sol given to Defendant, such as” these two sentences in the declaration: “I did not ask Ms. Maxwell to respond point by point to Ms. Giuffre’s factual allegations in the CVRA joinder motion. What we needed to do was issue an immediate denial and that necessarily had to be short and to the point.” Doc.542-7, Ex.K ¥ 13. Neither of the two sentences “reveals” attorney-client communications. To the contrary, the first sentence references a non-communication with Ms. Maxwell, i.e., what Mr. Barden did not talk to Ms. Maxwell about. The second sentence simply discloses attorney Barden’s thought process, which by definition is not an attorney-client communication. We italicize plaintiff's use of “such as,” connoting—disingenuously, we submit—the introduction of an example. Besides these two frivolous examples of attorney-client communications, plaintiff identifies no others. 4. Supplementing her lengthy summary-judgment brief and oral argument, plaintiff re- urges her point that really it was Ms. Maxwell personally, and not Mr. Barden, who directed Mr. Gow to issue the January 2015 statement. Mot. 3. We suggest plaintiff's persistent repetition of her arguments—as with any repetition, they have become familiar, but not more persuasive— suggests her recognition that we have advanced meritorious and weighty arguments for summary ‘Mot. 3 (emphasis supplied).