Blake Lively- Jason Baldoni and NYT - False Light claims

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Oh hey suddenly Baldoni's attorneys have a problem with relying on double hearsay!

Here's the quote from the opposition about that: "The crux of the Motion is that because a Daily Mail reporter quoted an unidentified “insider” as stating that the Wayfarer Parties obtained unspecified information from Ms. Swift, Ms. Lively should not be compelled to produce relevant communications with Ms. Swift in her own possession. (Dkt. 325, p. 2). Tellingly, Ms. Lively does not cite any legal authority for the proposition that such double-hearsay is a proper basis to preclude the Wayfarer Parties from obtaining relevant discovery from Ms. Lively, especially information which the Wayfarer Parties believe will further exculpate them."

Like, it's fine to rely on double hearsay as the basis for your affidavit accusing opposing counsel of extortion, but when it's double hearsay citing to a Daily Mail reporter, sheesh, what are you thinking?

As a different Lively supporters than the others above (I posted the docket update), I also tend to think Liman will require Lively to produce the Swift communications - at least those relevant to the remaining claims. I think this motion was designed to ferret out what communications Baldoni had received from Venable, and they are now being shown to say they have received no documents and are even calling the Daily Mail report saying they got what they wanted into question. I don't think Baldoni's attorneys are quite admitting that they didn't receive any information from Venable (as opposed to docs), but it seems clear that they won't be able to come in to Lively's dep showing docs from Venable that Lively hasn't seen. And if they do, these responses here seem to give Lively's attys reason to stop the dep imho.

I'm personally "they got nothing, but want to leave the theory open that Swift's team decided to give her some phantom information not contained in a document instead of pursuing the motion to quash." I also noticed that Freedman was asked about this on Megyn Kelly and danced around it, without repeating his allegations of extortion by Lively and Gottlieb (recall Liman's comment that putting that letter into the court record protects it from defamation,
and should not give it greater credibility, and note that he won't make those statements out of court).

This doesn’t seem complicated, Venable likely showed Liman certain documents without giving him copies. If Lively doesnt produce them, he can then renew his subpoena or perhaps they agreed to another procedure by which he can obtain them.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Did Wayfarer allege that all they'd turned over was the Jones stuff, or is that speculation?

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Did Wayfarer allege that all they'd turned over was the Jones stuff, or is that speculation?

In the declaration dated today, WF's lawyer states they have yet to receive a single document from Lively responsive to their document requests. In the email chain, he says all 2000 plus documents they’ve received from Liverly related to the VanZan subpoena.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

I think Wayfarer said this in the email. But again,Lively has made at least one more production, and even not including that Lively’s production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wayfarer, Wallace, and Wayfarer put together lol.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Did Wayfarer allege that all they'd turned over was the Jones stuff, or is that speculation?

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Did Wayfarer allege that all they'd turned over was the Jones stuff, or is that speculation?

In the declaration dated today, WF's lawyer states they have yet to receive a single document from Lively responsive to their document requests. In the email chain, he says all 2000 plus documents they’ve received from Liverly related to the VanZan subpoena.

Thank you.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Oh hey suddenly Baldoni's attorneys have a problem with relying on double hearsay!

Here's the quote from the opposition about that: "The crux of the Motion is that because a Daily Mail reporter quoted an unidentified “insider” as stating that the Wayfarer Parties obtained unspecified information from Ms. Swift, Ms. Lively should not be compelled to produce relevant communications with Ms. Swift in her own possession. (Dkt. 325, p. 2). Tellingly, Ms. Lively does not cite any legal authority for the proposition that such double-hearsay is a proper basis to preclude the Wayfarer Parties from obtaining relevant discovery from Ms. Lively, especially information which the Wayfarer Parties believe will further exculpate them."

Like, it's fine to rely on double hearsay as the basis for your affidavit accusing opposing counsel of extortion, but when it's double hearsay citing to a Daily Mail reporter, sheesh, what are you thinking?

As a different Lively supporters than the others above (I posted the docket update), I also tend to think Liman will require Lively to produce the Swift communications - at least those relevant to the remaining claims. I think this motion was designed to ferret out what communications Baldoni had received from Venable, and they are now being shown to say they have received no documents and are even calling the Daily Mail report saying they got what they wanted into question. I don't think Baldoni's attorneys are quite admitting that they didn't receive any information from Venable (as opposed to docs), but it seems clear that they won't be able to come in to Lively's dep showing docs from Venable that Lively hasn't seen. And if they do, these responses here seem to give Lively's attys reason to stop the dep imho.

I'm personally "they got nothing, but want to leave the theory open that Swift's team decided to give her some phantom information not contained in a document instead of pursuing the motion to quash." I also noticed that Freedman was asked about this on Megyn Kelly and danced around it, without repeating his allegations of extortion by Lively and Gottlieb (recall Liman's comment that putting that letter into the court record protects it from defamation,
and should not give it greater credibility, and note that he won't make those statements out of court).

This doesn’t seem complicated, Venable likely showed Liman certain documents without giving him copies. If Lively doesnt produce them, he can then renew his subpoena or perhaps they agreed to another procedure by which he can obtain them.

As we've said before in this thread, that doesn't really make any sense as a reason to withdraw the subpoena, certainly against Venable, since Freedman has said he isn't going to depose Swift -- how else would he expect to get in evidence of Gottlieb's supposed extortion of her, since the only communications about it (per the rumors) involved Venable and not Swift herself?

Maybe if there was some text from Lively to Swift asking her to delete her texts, and Venable told Freedman that there was such a text, then requiring the Swift communications could be a trap to show this happened, and one that Lively's attorneys are trying to avoid to get this thrown out.

There is also always the possibility that there was nothing, and never was anything, and that Freedman is basically a liar and poseur, and that the only thing he got from the Venable encounter was the PR statement that Swift wasn't involved with IEWU and never was, to tend to show that Lively was a liar, and that's all he really mostly ever wanted except seeing his name in the headlines again.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol. This also isn't counting any docs that Reynolds and Sloane produced.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Oh hey suddenly Baldoni's attorneys have a problem with relying on double hearsay!

Here's the quote from the opposition about that: "The crux of the Motion is that because a Daily Mail reporter quoted an unidentified “insider” as stating that the Wayfarer Parties obtained unspecified information from Ms. Swift, Ms. Lively should not be compelled to produce relevant communications with Ms. Swift in her own possession. (Dkt. 325, p. 2). Tellingly, Ms. Lively does not cite any legal authority for the proposition that such double-hearsay is a proper basis to preclude the Wayfarer Parties from obtaining relevant discovery from Ms. Lively, especially information which the Wayfarer Parties believe will further exculpate them."

Like, it's fine to rely on double hearsay as the basis for your affidavit accusing opposing counsel of extortion, but when it's double hearsay citing to a Daily Mail reporter, sheesh, what are you thinking?

As a different Lively supporters than the others above (I posted the docket update), I also tend to think Liman will require Lively to produce the Swift communications - at least those relevant to the remaining claims. I think this motion was designed to ferret out what communications Baldoni had received from Venable, and they are now being shown to say they have received no documents and are even calling the Daily Mail report saying they got what they wanted into question. I don't think Baldoni's attorneys are quite admitting that they didn't receive any information from Venable (as opposed to docs), but it seems clear that they won't be able to come in to Lively's dep showing docs from Venable that Lively hasn't seen. And if they do, these responses here seem to give Lively's attys reason to stop the dep imho.

I'm personally "they got nothing, but want to leave the theory open that Swift's team decided to give her some phantom information not contained in a document instead of pursuing the motion to quash." I also noticed that Freedman was asked about this on Megyn Kelly and danced around it, without repeating his allegations of extortion by Lively and Gottlieb (recall Liman's comment that putting that letter into the court record protects it from defamation,
and should not give it greater credibility, and note that he won't make those statements out of court).

This doesn’t seem complicated, Venable likely showed Liman certain documents without giving him copies. If Lively doesnt produce them, he can then renew his subpoena or perhaps they agreed to another procedure by which he can obtain them.

Sorry, meant Freedman, not Liman. I do not think Venable showed Liman any documents.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol. This also isn't counting any docs that Reynolds and Sloane produced.

Again, WF's Counsel submitted a declaration today saying they have yet to receive a single document responsive to their First Request for Documents from Lively. Guess Gottlieb et al was too busy drafting Motions for Sanctions.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Oh hey suddenly Baldoni's attorneys have a problem with relying on double hearsay!

Here's the quote from the opposition about that: "The crux of the Motion is that because a Daily Mail reporter quoted an unidentified “insider” as stating that the Wayfarer Parties obtained unspecified information from Ms. Swift, Ms. Lively should not be compelled to produce relevant communications with Ms. Swift in her own possession. (Dkt. 325, p. 2). Tellingly, Ms. Lively does not cite any legal authority for the proposition that such double-hearsay is a proper basis to preclude the Wayfarer Parties from obtaining relevant discovery from Ms. Lively, especially information which the Wayfarer Parties believe will further exculpate them."

Like, it's fine to rely on double hearsay as the basis for your affidavit accusing opposing counsel of extortion, but when it's double hearsay citing to a Daily Mail reporter, sheesh, what are you thinking?

As a different Lively supporters than the others above (I posted the docket update), I also tend to think Liman will require Lively to produce the Swift communications - at least those relevant to the remaining claims. I think this motion was designed to ferret out what communications Baldoni had received from Venable, and they are now being shown to say they have received no documents and are even calling the Daily Mail report saying they got what they wanted into question. I don't think Baldoni's attorneys are quite admitting that they didn't receive any information from Venable (as opposed to docs), but it seems clear that they won't be able to come in to Lively's dep showing docs from Venable that Lively hasn't seen. And if they do, these responses here seem to give Lively's attys reason to stop the dep imho.

I'm personally "they got nothing, but want to leave the theory open that Swift's team decided to give her some phantom information not contained in a document instead of pursuing the motion to quash." I also noticed that Freedman was asked about this on Megyn Kelly and danced around it, without repeating his allegations of extortion by Lively and Gottlieb (recall Liman's comment that putting that letter into the court record protects it from defamation,
and should not give it greater credibility, and note that he won't make those statements out of court).

This doesn’t seem complicated, Venable likely showed Liman certain documents without giving him copies. If Lively doesnt produce them, he can then renew his subpoena or perhaps they agreed to another procedure by which he can obtain them.

As we've said before in this thread, that doesn't really make any sense as a reason to withdraw the subpoena, certainly against Venable, since Freedman has said he isn't going to depose Swift -- how else would he expect to get in evidence of Gottlieb's supposed extortion of her, since the only communications about it (per the rumors) involved Venable and not Swift herself?

Maybe if there was some text from Lively to Swift asking her to delete her texts, and Venable told Freedman that there was such a text, then requiring the Swift communications could be a trap to show this happened, and one that Lively's attorneys are trying to avoid to get this thrown out.

There is also always the possibility that there was nothing, and never was anything, and that Freedman is basically a liar and poseur, and that the only thing he got from the Venable encounter was the PR statement that Swift wasn't involved with IEWU and never was, to tend to show that Lively was a liar, and that's all he really mostly ever wanted except seeing his name in the headlines again.

As one of you pointed out of the time, there was little value in getting documents from Swift if she was unwilling to testify in support of them. If I were Freedman and they were willing to make a deal to get the subpoena to go away as long as it didn't mandate further participation from Taylor, I would absolutely have asked if I could see any documents they thought I'd be interested in without requiring it to be produced. Then, get the documents from Lively or raise a stink if she doesn't produce them. I don't think Freedman gave up on the subpoena in exchange for nothing, he had good grounds for the subpoena. And he can reissue it if necessary. If its reissued because Blake withheld documents, Taylor might be more willing to comply.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol. This also isn't counting any docs that Reynolds and Sloane produced.

Again, WF's Counsel submitted a declaration today saying they have yet to receive a single document responsive to their First Request for Documents from Lively. Guess Gottlieb et al was too busy drafting Motions for Sanctions.

It's a really bad look to be so behind in document production as the plaintiff, especially when one's counsel have been bombing the Court with all types of motions, including discovery motions. In essence, all Lively's team has done is sent over the WF defendants copies of their own texts.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol. This also isn't counting any docs that Reynolds and Sloane produced.

Again, WF's Counsel submitted a declaration today saying they have yet to receive a single document responsive to their First Request for Documents from Lively. Guess Gottlieb et al was too busy drafting Motions for Sanctions.

Actually, you're totally misreading the declaration. "The Requests" as they are defined in the declaration are narrowed to include a limited set of 7 particular document requests from that first set of RFPs Wayfarer issues (including the 2 Swift requests and 5 requests dealing with harassment, Sony, WME, and damages). Since that first set of RFPs included at least 109 doc requests, it is certainly a mistatement to say that Wayfarer has "yet to receive a single document responsive to their First Request for Documents from Lively" as you have done above when all that declaration is actually saying is that Wayfarer hasn't received anything responsive to those 7 particular requests yet from Lively. Check the declaration again -- what you have said is not what it says.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol. This also isn't counting any docs that Reynolds and Sloane produced.

Again, WF's Counsel submitted a declaration today saying they have yet to receive a single document responsive to their First Request for Documents from Lively. Guess Gottlieb et al was too busy drafting Motions for Sanctions.

It's a really bad look to be so behind in document production as the plaintiff, especially when one's counsel have been bombing the Court with all types of motions, including discovery motions. In essence, all Lively's team has done is sent over the WF defendants copies of their own texts.

I would take accusations from both sides that the other is "behind" in production with a grain of salt. First of all, the discovery deadline has not passed -- parties will often wait until the last minute and then dump a bunch of docs. And that's allowed, for the most part. Second, both parties have likely requested documents that don't exist or which the other side will argue aren't relevant. This is also standard. Like if Baldoni's request for documents asked that Blake provide all documents where she talks about trying to steal the movie and her intentions to make up some SH allegations to do so, it's likely she has not produced those because they don't exist. Likewise, we know Blake is asking for documents where Baldoni/Wayfarer/Freedman conspire with content creators to smear Blake. Those may also not exist. So saying your opponent has "failed" to produce documents doesn't always mean they are dragging their feet. It can can mean there is nothing responsive, or that the party is in the process of objecting to the request. Both sides are doing this.

None of this matters in the end. Honestly, at this point, I don't think the bickering is going to be that determinative unless/until we get to summary judgment and agreed stipulations before trial. The back and forth over discovery will largely be small potatoes.

[Anonymous]

According to the declaration, Lively has yet to produce documents to support her claims of sexual harassment and retaliation, her communications regarding the same with Sony et al, or her economic damages. That’s her entire case.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties. That’s astoundingly bad.

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones. Given she’s the plaintiff, that’s not great.

To be fair, the email notes she was making another production the next day, which would have happened by now.

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails? This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol. This also isn't counting any docs that Reynolds and Sloane produced.

Again, WF's Counsel submitted a declaration today saying they have yet to receive a single document responsive to their First Request for Documents from Lively. Guess Gottlieb et al was too busy drafting Motions for Sanctions.

Actually, you're totally misreading the declaration. "The Requests" as they are defined in the declaration are narrowed to include a limited set of 7 particular document requests from that first set of RFPs Wayfarer issues (including the 2 Swift requests and 5 requests dealing with harassment, Sony, WME, and damages). Since that first set of RFPs included at least 109 doc requests, it is certainly a mistatement to say that Wayfarer has "yet to receive a single document responsive to their First Request for Documents from Lively" as you have done above when all that declaration is actually saying is that Wayfarer hasn't received anything responsive to those 7 particular requests yet from Lively. Check the declaration again -- what you have said is not what it says.

And this is one rare case where I'm going to throw the whole "a real lawyer would know to check the definitions" before making such a gross overstatement etc, which you have thrown so much at me, right back on to you.