Blake Lively- Jason Baldoni and NYT - False Light claims

[Anonymous]

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Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

The production letter is from Lively in the Lively litigation. The subpoena is to VanZan. The judge has no basis to believe Lively speaks for Van Zan, Van Zan doesn’t even have the same counsel.

[Anonymous]

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Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

But it didn't. The MTC makes no distinction between Lively and Vanzan and implies that Lively has not provided them with subpoena or attached documents, when she has. If the question was whether Vanzan altered the documents before passing them to Lively (the "passing" being a legal fiction anyway because Lively *is* Vanzan), that could have been asked during meet & confer. Either it wasn't, or it was asked and answered and the MTC disregards it.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

I don’t think they need to — Van Zan had produced nothing and the subpoena is to Van Zan in the Jonesworks litigation. Lively inserting herself into the dispute via her own Counsel is actually a stupid move. What she produced in the other litigation to a document request directed to her personally is irrelevant for purposes of this subpoena.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

And how many times do we need to reiterate Garofalo is asking for first source docs? They didn’t get them from Jones so now they are asking Vanzan. Lively is a secondary source and it has not been established who/what Vanzan is and how the entity is related to any parties.

The docs received from Lively are the ones provided by Jonesworks in response to the subpoena, produced exactly as provided by Jonesworks. The production letter shows the docs from Lively are what was produced directly by Jones. What else on those docs does Garofalo profess to need? The metadata she seeks was never there, per the production letter.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

And how many times do we need to reiterate Garofalo is asking for first source docs? They didn’t get them from Jones so now they are asking Vanzan. Lively is a secondary source and it has not been established who/what Vanzan is and how the entity is related to any parties.

The docs received from Lively are the ones provided by Jonesworks in response to the subpoena, produced exactly as provided by Jonesworks. The production letter shows the docs from Lively are what was produced directly by Jones. What else on those docs does Garofalo profess to need? The metadata she seeks was never there, per the production letter.

You are referring to production in the main litigation to Lively herself? Why? The subpoena is to VanZan in separate litigation.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

Are you this dense or just pretending to be? The letter is not from Van Zan, it’s not even in the same case, and it doesn’t relate to the subpoena at issue. It has not been established that Lively can speak on behalf of Van Zan.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

Are you this dense or just pretending to be? The letter is not from Van Zan, it’s not even in the same case, and it doesn’t relate to the subpoena at issue. It has not been established that Lively can speak on behalf of Van Zan.

Dude. Lively is a party in a related litigation (See, e.g., docket entry 3 re statement of relatedness). They are assigned to the same judge for a reason. VanZan is not a party in any of these litigations. Lively clearly has possession and control of the documents that were received directly from Jonesworks in response to the October 14, 2024 VanZan subpoena. That is what the production letter says. Lively produced those documents to Liner Freedman without stripping out any metadata. That is what the production letter says.

Garofalo's MTD indicates none of this. Sure, I guess Garofalo can also ask VanZan to produce exactly the same thing that an actual party, Lively, did, to be sort of a jerk but to be absolutely clear about what was produced. The judge may consider this wasteful. As a PP said, this could have been better handled on a meet and confer. Either way, Garofalo's motion should indicate wtf is going on, and it does not in any way indicate wtf is going on. It wastes everybody's time.

[Anonymous]

MTC not MTD

[Anonymous]

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Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

Are you this dense or just pretending to be? The letter is not from Van Zan, it’s not even in the same case, and it doesn’t relate to the subpoena at issue. It has not been established that Lively can speak on behalf of Van Zan.

Dude. Lively is a party in a related litigation (See, e.g., docket entry 3 re statement of relatedness). They are assigned to the same judge for a reason. VanZan is not a party in any of these litigations. Lively clearly has possession and control of the documents that were received directly from Jonesworks in response to the October 14, 2024 VanZan subpoena. That is what the production letter says. Lively produced those documents to Liner Freedman without stripping out any metadata. That is what the production letter says.

Garofalo's MTD indicates none of this. Sure, I guess Garofalo can also ask VanZan to produce exactly the same thing that an actual party, Lively, did, to be sort of a jerk but to be absolutely clear about what was produced. The judge may consider this wasteful. As a PP said, this could have been better handled on a meet and confer. Either way, Garofalo's motion should indicate wtf is going on, and it does not in any way indicate wtf is going on. It wastes everybody's time.

Well the good news is that by being so confusing, judge might call a hearing and it could be entertaining.

BTW, on the Liner Freedman v Lively docket, a hearing has been called for July 11. Different judge and court so it may be in person as no dial in given.

[Anonymous]

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Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

Are you this dense or just pretending to be? The letter is not from Van Zan, it’s not even in the same case, and it doesn’t relate to the subpoena at issue. It has not been established that Lively can speak on behalf of Van Zan.

Dude. Lively is a party in a related litigation (See, e.g., docket entry 3 re statement of relatedness). They are assigned to the same judge for a reason. VanZan is not a party in any of these litigations. Lively clearly has possession and control of the documents that were received directly from Jonesworks in response to the October 14, 2024 VanZan subpoena. That is what the production letter says. Lively produced those documents to Liner Freedman without stripping out any metadata. That is what the production letter says.

Garofalo's MTD indicates none of this. Sure, I guess Garofalo can also ask VanZan to produce exactly the same thing that an actual party, Lively, did, to be sort of a jerk but to be absolutely clear about what was produced. The judge may consider this wasteful. As a PP said, this could have been better handled on a meet and confer. Either way, Garofalo's motion should indicate wtf is going on, and it does not in any way indicate wtf is going on. It wastes everybody's time.

Ok, continue playing dumb.

[Anonymous]

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Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

Are you this dense or just pretending to be? The letter is not from Van Zan, it’s not even in the same case, and it doesn’t relate to the subpoena at issue. It has not been established that Lively can speak on behalf of Van Zan.

Dude. Lively is a party in a related litigation (See, e.g., docket entry 3 re statement of relatedness). They are assigned to the same judge for a reason. VanZan is not a party in any of these litigations. Lively clearly has possession and control of the documents that were received directly from Jonesworks in response to the October 14, 2024 VanZan subpoena. That is what the production letter says. Lively produced those documents to Liner Freedman without stripping out any metadata. That is what the production letter says.

Garofalo's MTD indicates none of this. Sure, I guess Garofalo can also ask VanZan to produce exactly the same thing that an actual party, Lively, did, to be sort of a jerk but to be absolutely clear about what was produced. The judge may consider this wasteful. As a PP said, this could have been better handled on a meet and confer. Either way, Garofalo's motion should indicate wtf is going on, and it does not in any way indicate wtf is going on. It wastes everybody's time.

By this logic, every one of Blake’s request for documents to third parties and subsequent motions to compel was wasteful and whatever other criticisms you’ve thrown Garofao’s way.

[Anonymous]

Dog pool posted some absolutely whacky stuff relating to Freedman, any celebrity he can possibly think of, and citing to reddit posts. I don't have the patience to summarize but maybe someone else does.

[Anonymous]

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Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

How do they know Vanzan didn't strip metadata before sending to Lively? It's a reasonable ask. MTC would have been stronger had they laid out this argument.

Because the production letter says they didn’t strip out any metadata. It says metadata is provided as existed but some was missing from Jones.

Are you this dense or just pretending to be? The letter is not from Van Zan, it’s not even in the same case, and it doesn’t relate to the subpoena at issue. It has not been established that Lively can speak on behalf of Van Zan.

Dude. Lively is a party in a related litigation (See, e.g., docket entry 3 re statement of relatedness). They are assigned to the same judge for a reason. VanZan is not a party in any of these litigations. Lively clearly has possession and control of the documents that were received directly from Jonesworks in response to the October 14, 2024 VanZan subpoena. That is what the production letter says. Lively produced those documents to Liner Freedman without stripping out any metadata. That is what the production letter says.

Garofalo's MTD indicates none of this. Sure, I guess Garofalo can also ask VanZan to produce exactly the same thing that an actual party, Lively, did, to be sort of a jerk but to be absolutely clear about what was produced. The judge may consider this wasteful. As a PP said, this could have been better handled on a meet and confer. Either way, Garofalo's motion should indicate wtf is going on, and it does not in any way indicate wtf is going on. It wastes everybody's time.

By this logic, every one of Blake’s request for documents to third parties and subsequent motions to compel was wasteful and whatever other criticisms you’ve thrown Garofao’s way.

No, it’s really not the same to ask for one specific thing, and get that thing produced to you by a party, and then ask a non party for that one same specific thing already produced to be produced in the same way all over again.

Lively’s MTCs are substantively different. When you ask two different sources for “all your communications about the movie” you will get different responses from wayfarer vs a Sony rep. They will have sent and received different communications. Different doc reviewers may even mark the same comms as responsive or not, depending on instructions. Those requests are fuzzier and different than the request involved here, which involve precisely the set of same docs under Lively’s control.

When Lively did ask a third party for exactly the same thing she had asked TAG for, she explained what she had already received from TAG and why she had reason to believe TAG’s production had been deficient (i.e, TAG’s production did not include a single communication involving Case or Koslow). So, totally different than the situation here. Get it?

How about acknowledging Garofalo’s MTC is deceptively written? Nothing you would change there?