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.

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.

Freedman sure does live rent-free in your head.

[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

The disclosures are never meant to be put under so much review. No one should draw anything from the inclusion or exclusion of anyone. This list is also way too long. Again showing this clown does not know how to litigate.

[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.

Freedman sure does live rent-free in your head.

No just a lawyer that looked at a few of the pleadings and they are not SDNY level. He will be crushed as this case moves forward.

[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.

Freedman sure does live rent-free in your head.

Is she Kat Ortega super fan/stalker?

[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

Kind of fun scrolling through those names, thanks. Bradley Cooper is in it (google tells me Blake thanked him in the end credits). Hugh Jackman is not.

[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.

You are singing my song. I agree with this 100%!

[Anonymous]

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

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

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

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

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

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

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

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

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

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

[Anonymous]

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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.

Freedman sure does live rent-free in your head.

No just a lawyer that looked at a few of the pleadings and they are not SDNY level. He will be crushed as this case moves forward.

Right, which is why you post about him constantly here in an obsessive manner.

[Anonymous]

Anonymous wrote:

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.

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.

Someone doesn’t deal with many successful plaintiff’s counsel. They are almost never big law alums.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

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Anonymous wrote:

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Anonymous wrote:

Anonymous wrote:

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.

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.

Freedman sure does live rent-free in your head.

No just a lawyer that looked at a few of the pleadings and they are not SDNY level. He will be crushed as this case moves forward.

Right, which is why you post about him constantly here in an obsessive manner.

DP but obviously Freedman gets discussed frequently on this thread because he's a main player in the case, and he makes himself the story frequently. No one is "obsessed" with him

[Anonymous]

Someone posted this excerpt on Reddit from an interview Twohey gave to NPR in Dec. I had never seen it. Interesting. Sounds like even BL knows her SH claims won’t hold up in court, which many of us have being saying all along. She’s really focused on the smear campaign. Problem is she may really have gotten it wrong. I think there’s a good chance the smear campaign never happened. Also interesting that lively seemingly knew her accusations were mild but went on to use them as leverage for maximum control over the movie. She told Twohey she never planned to go public but she certainly seemed to benefit from implying that she would. I wonder if Twohey will be called as a witness or if at minimum her public statements will be read into evidence.

“And she told me, like, listen. This was actually not the worst that I have experienced in Hollywood. I've actually experienced far worse misconduct. You know, I spoke up because I wanted to address it, and I thought that I had, and I never had any intentions of discussing this or going public with my accusations. And so to watch what happened next and to experience what she now is alleging was this complete campaign of retaliation felt, in many ways, much more sinister than the underlying misconduct.“

[Anonymous]

Anonymous wrote:

Anonymous wrote:

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Anonymous wrote:

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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.

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.

Someone doesn’t deal with many successful plaintiff’s counsel. They are almost never big law alums.

DP. Agree, everyone who’s practiced law for more than a minute knows that biglaw isn’t all that in many areas, especially for Ps work. Sometimes I wonder if this so called lawyer PP is a law student on summer break.

[Anonymous]

Anonymous wrote:

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Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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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.

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.

Freedman sure does live rent-free in your head.

No just a lawyer that looked at a few of the pleadings and they are not SDNY level. He will be crushed as this case moves forward.

Right, which is why you post about him constantly here in an obsessive manner.

DP but obviously Freedman gets discussed frequently on this thread because he's a main player in the case, and he makes himself the story frequently. No one is "obsessed" with him

Dp. No, we’ve noticed you’re totally obsessed…

[Anonymous]

Hudson filed for leave to file a Reply on Fritz's Opposition to the Swift motion for a PO, in part because Fritz brought their own motion to compel on the harassment and damages etc docs.

I think this is saying that Gottlieb added Swift's name to Lively's own Initial Disclosures (which Fritz was using as a reason why her communications must be compelled). I think Hudson says they only did this after Freedman went to the press and said they got everything they had wanted from Swift, then bringing into question communications Freedman had received from Swift. Hudson also properly (I think) calls out Fritz's demand for all the harassment/damages docs first, saying they have no duty to produce docs in the order Baldoni wants absent some mutual agreement, which Fritz never asked for. Nevertheless, Hudson proposes to give Fritz these docs by this Friday, if Fritz gives them all the movie footage which Baldoni's side still has not released -- Hudson specifically says they should get this footage in advance of Lively's deposition.

This is all *a lot* to be putting in front of the judge before a holiday when the dep and amendment is due on Monday.

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.354.0.pdf

[Anonymous]

Anonymous wrote:

Anonymous wrote:

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Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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

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

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

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

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

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

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

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

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

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

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

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.

Someone doesn’t deal with many successful plaintiff’s counsel. They are almost never big law alums.

DP. Agree, everyone who’s practiced law for more than a minute knows that biglaw isn’t all that in many areas, especially for Ps work. Sometimes I wonder if this so called lawyer PP is a law student on summer break.

Yes, all of your own theories and legal analysis have been so very excellent so far. Like the alleged sock puppeting that some Baldoni fan has been claiming that Jeff specifically came into the thread to say didn't happen/was a mistake.

The truth here is that Baldoni's high ticket claims are all gone, and he is facing paying (lol, having his rich benefactor Sarowitz pay) attorneys fees, triple damages, and punitives through 47.1, which is not even counting potential damages from Lively's own remaining claims. You don't think Baldoni will come out of this potentially owing her millions? (Maybe he should settle RIGHT NOW lol.)