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Case 1:15-cv-07433-LAP Document 1332-3 Filed 01/08/24 Page 16 of 21 communications with Barden. Indeed, when a party voluntarily waives its work product privilege in an attempt to use her attorney’s work product to her advantage, the party must also produce all related documents, including drafts, e-mail communications relating to the work product, documents considered relating to the work product and any other materials created, received, used or considered relating in any way to Ms. Giuffre or this litigation, which is the very subject- matter of the disclosed work-product. See, e.g., Hickman v. Taylor, 329 U.S. 495, 511 (1947). The Court should accordingly order disclosure of all related communications here. 2. Defendant Also Waived Attorney Client Privilege by Willfully Failing to Include Communications on Her Privilege Log, therefore Forfeiting Any Potential Privilege. Defendant also waived her attorney-client privilege for a separate, independent reason: she failed to properly log communications on her privilege log. A bit of factual background is necessary on this point. In both her earlier (rejected) Motion to Dismiss and her pending Motion for Summary Judgment, Defendant asserted that the qualified pre-litigation privilege shields her defamatory press release from liability. Specifically, Defendant has argued that because she was contemplating an (unspecified and never-filed) lawsuit involving the British Press, she somehow had a “green light” to make whatever defamatory statements she wanted about Ms. Giuffre at the time she issued her press release, i.e., on January 3, 2015. Of course, if Defendant actually contemplated litigation prior to and on January 3, 2015, at the time she issued the defamatory press release, and if Barden was actually as involved in that process as Defendant claims, where are the communications with Barden concerning this contemplated lawsuit that pre-date the issuance of the press release? Put another way, if there was a good-faith anticipated litigation (as the law requires for this defense to apply), and Defendant was working with Barden to issue a statement in relation to that good-faith anticipated 12