Blake Lively- Jason Baldoni and NYT - False Light claims

[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.

Lively made another production after the email chain, the contents of which we don't know (which you or someone previously (wrongly) used the declaration to support your conclusion that nothing else of value had been produced). No. Wrong.

[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.

As a Lively supporter, I will admit that Freedman occasionally comes through [b]and that I'm genuinely scared of what he may have that might make Lively look bad.

At the same time, there is a decently good chance that Freedman has nothing, and is just hoping to intimidate Lively.

Freedman himself should be a little scared at this point and to me that makes him dangerous. He's had some significant losses here and his clients must be questioning him and/or disappointed with him. If I were a Baldoni supporter, I would be disappointed.

[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.

Lively made another production after the email chain, the contents of which we don't know (which you or someone previously (wrongly) used the declaration to support your conclusion that nothing else of value had been produced). No. Wrong.

You don't know the contents of the next production either, so drop the insufferable attitude. "no, Wrong"-- please, you have no clue one way or the other. The requests that are the subject to the motion to compel were already highlighted as priorities before that production, and all of them remained completely unanswered afterwards.

[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.

As a Lively supporter, I will admit that Freedman occasionally comes through [b]and that I'm genuinely scared of what he may have that might make Lively look bad.

At the same time, there is a decently good chance that Freedman has nothing, and is just hoping to intimidate Lively.

Freedman himself should be a little scared at this point and to me that makes him dangerous. He's had some significant losses here and his clients must be questioning him and/or disappointed with him. If I were a Baldoni supporter, I would be disappointed.

I'm not the least bit disappointed in him. He got public sentiment behind Baldoni quickly and efficiently.

[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.

As a Lively supporter, I will admit that Freedman occasionally comes through [b]and that I'm genuinely scared of what he may have that might make Lively look bad.

At the same time, there is a decently good chance that Freedman has nothing, and is just hoping to intimidate Lively.

Freedman himself should be a little scared at this point and to me that makes him dangerous. He's had some significant losses here and his clients must be questioning him and/or disappointed with him. If I were a Baldoni supporter, I would be disappointed.

Maybe he has something, maybe he doesn't. I seem to recall a lot of Lively supporters doubting him from the get go, claiming he was just threatening Lively with bravado, and then he came out with the video footage and texts that changed a lot of minds.

[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.

Lively made another production after the email chain, the contents of which we don't know (which you or someone previously (wrongly) used the declaration to support your conclusion that nothing else of value had been produced). No. Wrong.

You don't know the contents of the next production either, so drop the insufferable attitude. "no, Wrong"-- please, you have no clue one way or the other. The requests that are the subject to the motion to compel were already highlighted as priorities before that production, and all of them remained completely unanswered afterwards.

Baldoni asked for those other 5 requests specifically one day before Lively made her next production, probably at that point too late to significantly affect the contents of that production honestly (when we do productions the docs often have to be queued up at least the day before because of processing time needed by the vendor).

It is wrong and disingenuous of you to affirmatively represent that Lively hasn't produced anything responsive to Wayfarer's first 130 RFPs, when she has produced materials after the email you are relying on to say this was written, the contents of which you do not know.

[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.

Lively made another production after the email chain, the contents of which we don't know (which you or someone previously (wrongly) used the declaration to support your conclusion that nothing else of value had been produced). No. Wrong.

You don't know the contents of the next production either, so drop the insufferable attitude. "no, Wrong"-- please, you have no clue one way or the other. The requests that are the subject to the motion to compel were already highlighted as priorities before that production, and all of them remained completely unanswered afterwards.

Baldoni asked for those other 5 requests specifically one day before Lively made her next production, probably at that point too late to significantly affect the contents of that production honestly (when we do productions the docs often have to be queued up at least the day before because of processing time needed by the vendor).

It is wrong and disingenuous of you to affirmatively represent that Lively hasn't produced anything responsive to Wayfarer's first 130 RFPs, when she has produced materials after the email you are relying on to say this was written, the contents of which you do not know.

And neither do you so it remains possible that everything I said is absolutely correct. Are the same person who has been insisting for literally months that Lively had produced lots of documents and it was outrageous that Baldoni had not. I think you are.

[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.

As a Lively supporter, I will admit that Freedman occasionally comes through [b]and that I'm genuinely scared of what he may have that might make Lively look bad.

At the same time, there is a decently good chance that Freedman has nothing, and is just hoping to intimidate Lively.

Freedman himself should be a little scared at this point and to me that makes him dangerous. He's had some significant losses here and his clients must be questioning him and/or disappointed with him. If I were a Baldoni supporter, I would be disappointed.

Maybe he has something, maybe he doesn't. I seem to recall a lot of Lively supporters doubting him from the get go, claiming he was just threatening Lively with bravado, and then he came out with the video footage and texts that changed a lot of minds.

Since then though his entire complaint got dismissed even though Freedman had insisted he'd be able to amend everything, and then he got on TV saying he'd amend 4 claims instead of the 2 he actually has, so that even prior ardent Reddit admirers have started to hate Freedman, so ... could go either way, really.

[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.

Lively made another production after the email chain, the contents of which we don't know (which you or someone previously (wrongly) used the declaration to support your conclusion that nothing else of value had been produced). No. Wrong.

You don't know the contents of the next production either, so drop the insufferable attitude. "no, Wrong"-- please, you have no clue one way or the other. The requests that are the subject to the motion to compel were already highlighted as priorities before that production, and all of them remained completely unanswered afterwards.

Baldoni asked for those other 5 requests specifically one day before Lively made her next production, probably at that point too late to significantly affect the contents of that production honestly (when we do productions the docs often have to be queued up at least the day before because of processing time needed by the vendor).

It is wrong and disingenuous of you to affirmatively represent that Lively hasn't produced anything responsive to Wayfarer's first 130 RFPs, when she has produced materials after the email you are relying on to say this was written, the contents of which you do not know.

And neither do you so it remains possible that everything I said is absolutely correct. Are the same person who has been insisting for literally months that Lively had produced lots of documents and it was outrageous that Baldoni had not. I think you are.

"It remains possible that everything I said is correct" is not a take I'd be proud of here. You've affirmatively represented something you don't know is true. Won't respond to this further.

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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.

Lively made another production after the email chain, the contents of which we don't know (which you or someone previously (wrongly) used the declaration to support your conclusion that nothing else of value had been produced). No. Wrong.

You don't know the contents of the next production either, so drop the insufferable attitude. "no, Wrong"-- please, you have no clue one way or the other. The requests that are the subject to the motion to compel were already highlighted as priorities before that production, and all of them remained completely unanswered afterwards.

Baldoni asked for those other 5 requests specifically one day before Lively made her next production, probably at that point too late to significantly affect the contents of that production honestly (when we do productions the docs often have to be queued up at least the day before because of processing time needed by the vendor).

It is wrong and disingenuous of you to affirmatively represent that Lively hasn't produced anything responsive to Wayfarer's first 130 RFPs, when she has produced materials after the email you are relying on to say this was written, the contents of which you do not know.

And neither do you so it remains possible that everything I said is absolutely correct. Are the same person who has been insisting for literally months that Lively had produced lots of documents and it was outrageous that Baldoni had not. I think you are.

"It remains possible that everything I said is correct" is not a take I'd be proud of here. You've affirmatively represented something you don't know is true. Won't respond to this further.

Which is exactly what you did as well. But you did it more rudely, as in your way.

[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.

As a Lively supporter, I will admit that Freedman occasionally comes through [b]and that I'm genuinely scared of what he may have that might make Lively look bad.

At the same time, there is a decently good chance that Freedman has nothing, and is just hoping to intimidate Lively.

Freedman himself should be a little scared at this point and to me that makes him dangerous. He's had some significant losses here and his clients must be questioning him and/or disappointed with him. If I were a Baldoni supporter, I would be disappointed.

Maybe he has something, maybe he doesn't. I seem to recall a lot of Lively supporters doubting him from the get go, claiming he was just threatening Lively with bravado, and then he came out with the video footage and texts that changed a lot of minds.

Since then though his entire complaint got dismissed even though Freedman had insisted he'd be able to amend everything, and then he got on TV saying he'd amend 4 claims instead of the 2 he actually has, so that even prior ardent Reddit admirers have started to hate Freedman, so ... could go either way, really.

DP. lol the ‘4 versus 2’ whackadoodle poster!!

[Anonymous]

jsteele wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Ok, none of you are sock puppeting. There’s a mysterious stranger who dips in, posts pro Lively things, sounds like you, but is someone else. Got it.

Hey, ask Jeff if you need to. Do it publicly by linking to our posts in the Website Feedback channel.

I don’t need it, he would not have removed the posts if they weren’t sock puppeting. I have a very good idea of who's the liar.

Just FYI, I don't know to which posts you are referring but the most recent post I deleted for "sock puppeting" was not actually a case of sock puppeting. Rather, a poster reported a post for sock puppeting, but I determined the post was not sock puppeted. Then the same post was reported a second time for sock puppeting. That time, I was about half asleep and not fully cognizant of what I was doing and I deleted the post. I immediately realized that I should not have deleted it.

Since that incident, I have been receiving 10 or more reports per day about sock puppeting in this thread. I have been summarily deleting them and not even bothering to check. I really wish the reports would stop.

Also, if all posters in this thread are going to so is accuse each other of sock puppeting and then drive me crazy with reports, I don't really see a reason to keep this thread going. So either get back to discussing the topic of the thread or prepare for it to be locked.

Public service announcement to the thread, for anyone who missed this post from Jeff from earlier today, to please stop sending him sock puppeting inquiries or he is going to close the thread.

[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.

As a Lively supporter, I will admit that Freedman occasionally comes through [b]and that I'm genuinely scared of what he may have that might make Lively look bad.

At the same time, there is a decently good chance that Freedman has nothing, and is just hoping to intimidate Lively.

Freedman himself should be a little scared at this point and to me that makes him dangerous. He's had some significant losses here and his clients must be questioning him and/or disappointed with him. If I were a Baldoni supporter, I would be disappointed.

I'm not the least bit disappointed in him. He got public sentiment behind Baldoni quickly and efficiently.

Good PR guy/so so lawyer? He never had the guns or chops to fight biglaw. He is a loudmouth. He won public opinion but is heading towards a loss in this case. Baldoni will owe her millions.

[Anonymous]

Here's something I've been wondering.

Kevin Fritz attached its initial disclosures to today's filing. These disclosures were filed on February 18th, four days after Freedman's call with the undisclosed "source" about the Taylor Swift call.

Whoever was Freedman's "source" for the information on his affidavit that got struck would, I think, be on that Initial Disclosures list.

Taylor Swift is on it. Michael Gottlieb is on it. Do you know who is NOT on it? Taylor Swift's dad.

Wonder if somebody else on Baldoni's Initial Disclosures would have been Freedman's supposed source. None of the names are redacted, just addresses etc.

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.5.pdf" target="_new" rel="nofollow"> https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.5.pdf

[Anonymous]

Anonymous wrote:Here's something I've been wondering.

Kevin Fritz attached its initial disclosures to today's filing. These disclosures were filed on February 18th, four days after Freedman's call with the undisclosed "source" about the Taylor Swift call.

Whoever was Freedman's "source" for the information on his affidavit that got struck would, I think, be on that Initial Disclosures list.

Taylor Swift is on it. Michael Gottlieb is on it. Do you know who is NOT on it? Taylor Swift's dad.

Wonder if somebody else on Baldoni's Initial Disclosures would have been Freedman's supposed source. None of the names are redacted, just addresses etc.

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.5.pdf" target="_new" rel="nofollow"> https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.5.pdf

Not if they only had second hand knowledge.