As Law&Crime reported earlier this month, the release of the image that sparked Trump's lawsuit was significant for the Journal's defense precisely because the truth is what's at issue in a defamation action. After denying the letter's existence, the White House shifted gears and claimed that the signature on the letter is not Trump's. But the Journal seems to claim that the response is a red herring for the lawsuit, as the article did not claim Trump "personally crafted the letter." "Any allegation that President Trump wrote a bawdy birthday note is thus consistent with his public reputation—which he has himself acknowledged—for using 'locker room' talk and does not plausibly state any harm," the filing added. Engel also authored a draft memo in the event that Trump decided to invoke the Insurrection Act in the aftermath of George Floyd's murder.