Blake Lively- Jason Baldoni and NYT - False Light claims

[Anonymous]

Anonymous wrote: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.

Baloney, because somehow Wayfarer found 102 other things to ask her about. Try again.

[Anonymous]

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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.

Perhaps you should check and see what those requests cover. Sexual harassment, retaliation, economic damages, communications with Sony — in other words, the entire substantive part of her case.

[Anonymous]

Anonymous wrote:

Anonymous wrote: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.

Baloney, because somehow Wayfarer found 102 other things to ask her about. Try again.

My guess is that many of them related to his allegations and are longer being pursued for that reason.

[Anonymous]

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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.

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that.

[Anonymous]

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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.

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that.

It is totally Freedman's decision to take Lively's deposition this early, before doc production is even substantially complete, even though Liman has said only one deposition of each witness will be allowed. To me, this is another reckless decision by him done for its performative value and for headlines, which actually risks giving up valuable legal gains he could have made if he waited for all the docs. This is on Freedman.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote: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.

Baloney, because somehow Wayfarer found 102 other things to ask her about. Try again.

My guess is that many of them related to his allegations and are longer being pursued for that reason.

You can actually look at all ~130 of them here: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.1.pdf

They are mostly requests for communications between Lively and other people who worked on the film.

There is no particular onus on Lively to produce all of the most useful documents to Baldoni before the less valuable ones, as long as she is meeting her obligation to meet substantial production and, if she agreed to rolling productions, is actually making them.

[Anonymous]

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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.

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that.

It is totally Freedman's decision to take Lively's deposition this early, before doc production is even substantially complete, even though Liman has said only one deposition of each witness will be allowed. To me, this is another reckless decision by him done for its performative value and for headlines, which actually risks giving up valuable legal gains he could have made if he waited for all the docs. This is on Freedman.

PP. I can see this being another "it's fine, we'll just amend later," and then, oops. Like if he's telling his clients this is a great strategy to get a second deposition later and then the judge refuses. I think June 23 is also the deadline to amend the complaint on the contract claims.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote: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.

Baloney, because somehow Wayfarer found 102 other things to ask her about. Try again.

My guess is that many of them related to his allegations and are longer being pursued for that reason.

Looking at the requests themselves: Nope.

[Anonymous]

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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.

Perhaps you should check and see what those requests cover. Sexual harassment, retaliation, economic damages, communications with Sony — in other words, the entire substantive part of her case.

I mean, it seems like a lot of the retaliation evidence is going to come from the Baldoni parties and/or from the texts from VanZan that Lively has already produced. Actually, if if Lively already produced all of the VanZan texts in her first 2K doc production then I would take issue with Wayfarer's claim that she hasn't produced anything about retaliation, because there were certainly communications about the smear campaign in those communications.

I won't go back and forth with you on this anymore. I still think it was a big miss for you to claim Lively hadn't produced anything responsive to the entire 130 point First RFP when in fact all it said was she hadn't produced anything responsive to 7 particular requests on that RFP (and I'm not sure that would be an accurate characterization given what we know about the VanZan production). You completely misinterpreted and misrepresented the declaration.

[Anonymous]

Anonymous wrote:

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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.

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that.

It is totally Freedman's decision to take Lively's deposition this early, before doc production is even substantially complete, even though Liman has said only one deposition of each witness will be allowed. To me, this is another reckless decision by him done for its performative value and for headlines, which actually risks giving up valuable legal gains he could have made if he waited for all the docs. This is on Freedman.

PP. I can see this being another "it's fine, we'll just amend later," and then, oops. Like if he's telling his clients this is a great strategy to get a second deposition later and then the judge refuses. I think June 23 is also the deadline to amend the complaint on the contract claims.

Good point about the amendment being due on the same day, and yes, I agree on how familiar this feels coming from Freedman. I don't know whether he's hoping to get something from the dep that would affect the amendment, which is maybe the only real good reason to do it this early?

Also noting (which I think I missed before) that Fritz filed a cross motion to compel Lively's production of these sexual harassment, Sony, WME, and Swift communications. Of all the other communications asked for in those 130 RFPs, the Swift ones are the ones that really make Freedman's heart beat faster and that he needs even before Lively's communications with Jenny Slate, her costar on the film.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote: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.

Baloney, because somehow Wayfarer found 102 other things to ask her about. Try again.

My guess is that many of them related to his allegations and are longer being pursued for that reason.

You can actually look at all ~130 of them here: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.1.pdf

They are mostly requests for communications between Lively and other people who worked on the film.

There is no particular onus on Lively to produce all of the most useful documents to Baldoni before the less valuable ones, as long as she is meeting her obligation to meet substantial production and, if she agreed to rolling productions, is actually making them.

Based on the email chain, I don’t think these have been produced either. She either responded that she had no such relevant documents or they are prioritizing the documents that go to the heart of her case, amd leaving these for the next motion to compel.

[Anonymous]

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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.

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that.

It is totally Freedman's decision to take Lively's deposition this early, before doc production is even substantially complete, even though Liman has said only one deposition of each witness will be allowed. To me, this is another reckless decision by him done for its performative value and for headlines, which actually risks giving up valuable legal gains he could have made if he waited for all the docs. This is on Freedman.

PP. I can see this being another "it's fine, we'll just amend later," and then, oops. Like if he's telling his clients this is a great strategy to get a second deposition later and then the judge refuses. I think June 23 is also the deadline to amend the complaint on the contract claims.

Good point about the amendment being due on the same day, and yes, I agree on how familiar this feels coming from Freedman. I don't know whether he's hoping to get something from the dep that would affect the amendment, which is maybe the only real good reason to do it this early?

Also noting (which I think I missed before) that Fritz filed a cross motion to compel Lively's production of these sexual harassment, Sony, WME, and Swift communications. Of all the other communications asked for in those 130 RFPs, the Swift ones are the ones that really make Freedman's heart beat faster and that he needs even before Lively's communications with Jenny Slate, her costar on the film.

Hmm, I wonder what he might have learned about those texts from Venable that led to his prioritizing them. I’m sure no reason for any Lively supporters to be concerned given that you all are convinced of his incompetence.

[Anonymous]

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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.

Perhaps you should check and see what those requests cover. Sexual harassment, retaliation, economic damages, communications with Sony — in other words, the entire substantive part of her case.

I mean, it seems like a lot of the retaliation evidence is going to come from the Baldoni parties and/or from the texts from VanZan that Lively has already produced. Actually, if if Lively already produced all of the VanZan texts in her first 2K doc production then I would take issue with Wayfarer's claim that she hasn't produced anything about retaliation, because there were certainly communications about the smear campaign in those communications.

I won't go back and forth with you on this anymore. I still think it was a big miss for you to claim Lively hadn't produced anything responsive to the entire 130 point First RFP when in fact all it said was she hadn't produced anything responsive to 7 particular requests on that RFP (and I'm not sure that would be an accurate characterization given what we know about the VanZan production). You completely misinterpreted and misrepresented the declaration.

Read the email chain.

[Anonymous]

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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.

Perhaps you should check and see what those requests cover. Sexual harassment, retaliation, economic damages, communications with Sony — in other words, the entire substantive part of her case.

I mean, it seems like a lot of the retaliation evidence is going to come from the Baldoni parties and/or from the texts from VanZan that Lively has already produced. Actually, if if Lively already produced all of the VanZan texts in her first 2K doc production then I would take issue with Wayfarer's claim that she hasn't produced anything about retaliation, because there were certainly communications about the smear campaign in those communications.

I won't go back and forth with you on this anymore. I still think it was a big miss for you to claim Lively hadn't produced anything responsive to the entire 130 point First RFP when in fact all it said was she hadn't produced anything responsive to 7 particular requests on that RFP (and I'm not sure that would be an accurate characterization given what we know about the VanZan production). You completely misinterpreted and misrepresented the declaration.

Read the email chain.

Between the two, it’s clear nothing of substance has been produced.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

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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.

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that.

Given that the deposition is a subject of the conference on discovery issues between WF and Lively lawyers, not clear at all it’s going to actually happen on June 23rd.