Blake Lively- Jason Baldoni and NYT - False Light claims

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

I'm not sure. I read Wayfarer's email has an offer to produce the synced audio and video, provided Lively would stipulate that they would not later call that doctoring evidence, and I did not see where Lively accepted that offer, so to me it is unclear whether that is actually being sent. Lively responded with all that stuff about the scheduling but I don't see where they said "ok, we'll take that video." If Wayfarer provided a separate audio track then I guess Lively could hire a company to do the sync.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:^ and one of them is a woman who has been identified off here but I won’t dox anyone. She spends time on Reddit too. She is obsessed with freedman. No one else cares much about lawyers but she drools over him.

She has ruined this thread.

It's totally exhausting.

+2

I don't want to report them as to not annoy Jeff, but they need to socially pressured to stop spamming about their Freedman obsession.

+ 3. I wish she would get a time out at least

+4. She has her own freedman thread to go obsess over him and refuses to go there because no one responds to her.

The non-Lively Freedman thread was for Freedman cases/info that aren’t relevant to the Lively case.

I don’t follow Freedman cases generally except for that Vin diesel example, and that was because his behavior was so threatening that it seemed likely to become relevant TO the Lively case. WHICH IT NOW HAS because Lively’s lawyers have filed those Vin Diesel pleadings in the Lively docket.

Freedman’s behavior and possible involvement in the ongoing smear is relevant to the Lively case and you not wanting to talk about this here because you support Baldoni is unfortunate for you but not my problem.

You act like we're getting annoyed by the mere act of you simply bringing him up. It's not just that, it's that you are *constantly* bringing him and that's the distinction. It's one thing to make a comment here and there about his relevance, but you talk on and on about him, and no one's even replying to you so I don't even get your goal here.

She should go to her freedman thread and talk to herself.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

I'm not sure. I read Wayfarer's email has an offer to produce the synced audio and video, provided Lively would stipulate that they would not later call that doctoring evidence, and I did not see where Lively accepted that offer, so to me it is unclear whether that is actually being sent. Lively responded with all that stuff about the scheduling but I don't see where they said "ok, we'll take that video." If Wayfarer provided a separate audio track then I guess Lively could hire a company to do the sync.

That's true, but I still feel it's on Baldoni's attorneys to work it out since in an earlier email there they promised to provide the video with sound (or else the dep would have to be delayed). So it was kind of on them to provide film with sound in some way on Friday. That's how we got to the agreement that the dep would go forward on Friday to begin with. If they are going back on that now, it makes them look not great. And the judge had to issue this order early Saturday morning based off the whole idea that the dep was going forward Thursday and this decision needed to be expedited, so they are going to look bad with Liman if they don't uphold their part of this bargain imo.

I don't disagree with you about where the email chain left off on communications. I just do think the impetus is on Baldoni's attorneys to provide the film with sound and make an agreement that works.

Maybe we'll find out in an hour ha.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

I'm not sure. I read Wayfarer's email has an offer to produce the synced audio and video, provided Lively would stipulate that they would not later call that doctoring evidence, and I did not see where Lively accepted that offer, so to me it is unclear whether that is actually being sent. Lively responded with all that stuff about the scheduling but I don't see where they said "ok, we'll take that video." If Wayfarer provided a separate audio track then I guess Lively could hire a company to do the sync.

That's true, but I still feel it's on Baldoni's attorneys to work it out since in an earlier email there they promised to provide the video with sound (or else the dep would have to be delayed). So it was kind of on them to provide film with sound in some way on Friday. That's how we got to the agreement that the dep would go forward on Friday to begin with. If they are going back on that now, it makes them look not great. And the judge had to issue this order early Saturday morning based off the whole idea that the dep was going forward Thursday and this decision needed to be expedited, so they are going to look bad with Liman if they don't uphold their part of this bargain imo.

I don't disagree with you about where the email chain left off on communications. I just do think the impetus is on Baldoni's attorneys to provide the film with sound and make an agreement that works.

Maybe we'll find out in an hour ha.

The Wayfarer reply dropped and I think they made a strong argument in defense of their location.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

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Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

I'm not sure. I read Wayfarer's email has an offer to produce the synced audio and video, provided Lively would stipulate that they would not later call that doctoring evidence, and I did not see where Lively accepted that offer, so to me it is unclear whether that is actually being sent. Lively responded with all that stuff about the scheduling but I don't see where they said "ok, we'll take that video." If Wayfarer provided a separate audio track then I guess Lively could hire a company to do the sync.

That's true, but I still feel it's on Baldoni's attorneys to work it out since in an earlier email there they promised to provide the video with sound (or else the dep would have to be delayed). So it was kind of on them to provide film with sound in some way on Friday. That's how we got to the agreement that the dep would go forward on Friday to begin with. If they are going back on that now, it makes them look not great. And the judge had to issue this order early Saturday morning based off the whole idea that the dep was going forward Thursday and this decision needed to be expedited, so they are going to look bad with Liman if they don't uphold their part of this bargain imo.

I don't disagree with you about where the email chain left off on communications. I just do think the impetus is on Baldoni's attorneys to provide the film with sound and make an agreement that works.

Maybe we'll find out in an hour ha.

The Wayfarer reply dropped and I think they made a strong argument in defense of their location.

If it's true that the cases Lively cited are all about avoiding deposition in Pakistan that is legit hilarious. I think Wayfarer is right, conjecture and speculation isn't enough and it was presumptuous to declare that the deposition would take place at Lively's attorneys office. However I am sure Lively wants the last word and will file leave to reply with another letter tonight.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

I'm not sure. I read Wayfarer's email has an offer to produce the synced audio and video, provided Lively would stipulate that they would not later call that doctoring evidence, and I did not see where Lively accepted that offer, so to me it is unclear whether that is actually being sent. Lively responded with all that stuff about the scheduling but I don't see where they said "ok, we'll take that video." If Wayfarer provided a separate audio track then I guess Lively could hire a company to do the sync.

That's true, but I still feel it's on Baldoni's attorneys to work it out since in an earlier email there they promised to provide the video with sound (or else the dep would have to be delayed). So it was kind of on them to provide film with sound in some way on Friday. That's how we got to the agreement that the dep would go forward on Friday to begin with. If they are going back on that now, it makes them look not great. And the judge had to issue this order early Saturday morning based off the whole idea that the dep was going forward Thursday and this decision needed to be expedited, so they are going to look bad with Liman if they don't uphold their part of this bargain imo.

I don't disagree with you about where the email chain left off on communications. I just do think the impetus is on Baldoni's attorneys to provide the film with sound and make an agreement that works.

Maybe we'll find out in an hour ha.

The Wayfarer reply dropped and I think they made a strong argument in defense of their location.

Link please?

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Do you guys think Wayfarer will respond today about the deposition protective order? If they don't I assume tomorrow AM Liman will issue an order for Lively. I don't see why this was such an emergency that he needed to set a very short weekend deadline.

Lively’s lawyers asked Liman to request Baldoni’s response be put on an expedited schedule, given that the deposition is on Thursday.

I’m sure Baldoni’s team will respond, though I’m not sure what they’ll say. I think they will say that as the attys taking the dep, they get to pick the place, and nothing Lively’s team has said overcomes that presumption. Maybe they will try to distinguish the vin diesel example because there was an actual (supposed) death threat. I think they will address the Freedman statements head on somehow and say these kinds of out of court statements are allowed. And maybe they will say something like Lively is not required to know in advance exactly who will be deposing her.

I can see Liman allowing the dep to proceed at Freedman’s firm if it could be assured that it will not be a circus or other media event, but if not I think Liman will allow Lively’s firm to host. Crazy the lawyers have to fight about this.

PP. I feel like the date is not set in stone. It's a date they can change at will. Reading between the lines, both sets of attorneys would not mind postponing it (definitely Wayfarer wants to, and I think Lively also wants more time to review the video) but nobody wants to be the one to say it, because there will be media reports that one side chickened out. If I were Liman, I'd make them meet and confer again and figure it out. Regarding Lively not being required to know who is deposing her, true, and if I were Wayfarer I would give a very long list of any possible attorney or support staff and all the Wayfarer defendants who might potentially be there, to allay the concern that Perez Hilton will show up, or something, if that's the concern.

Actually at this point they should just reschedule, because the date and time are known, and even though Lively got all cute by redacting all "your office" and "our office" in the last submission (including the state they have to fly to, gee, what a mystery that is), those were already unredacted in the prior submissions by Wayfarer. Whichever office is picked, the paparazzi will already know where to go... having it at Lively's lawyers doesn't actually protect her from a media frenzy. And I wouldn't be that surprised if any East Coast content creators tried to show up to get attention for themselves.

I actually disagree with you on this and think Gottlieb really wants to hold Baldoni’s team to this early Lively dep, specifically because Baldoni’s firm doesn’t really have time to go through all the docs before the dep and probably doesn’t even have all the docs. But Baldoni’s attorneys (see what I did there, in deference to the above haha) *insisted* on performing Lively’s dep as early as possible, and now Lively’s attys want to hold them to that terrible strategic decision.

I think they wanted to depose Lively early to try to bully her into settling. But now that they realize that is t happening, they are stuck with that dumb strategy. You could see Garofalo struggling to get out of it in the email, but she’s stuck.

I see your point about the film, but I also think once they found out it was really only 150 hours, they calmed down. That’s just 3 days of viewing between 3 associates, and while you need time to prep the client I think they’ll be okay. If they got it Friday I bet between associates and contract attorneys, they’ve almost viewed it all by now and identified the potentially hot reels for prepping.

Agree with you about the long list — I bet the list will include both Freedman and Garofalo.

PP. Originally when the date was June 23, I thought it made good sense for Lively to get it over with early, before a lot of documents came in... now that a lot of production has been done, it's probably more of a balancing act... Lively having what she wants (video) vs Wayfarer not having certain things yet (but perhaps by now, they do). The Taylor Swift texts, for example, even though they are not important to the case IMO, are probably something Wayfarer would like to have prior to the depo and Lively would prefer they did not. I don't remember the date by which she was supposed to produce them.

The video doesn't have sound (which, I learned on reddit, is normal for the raw footage) so it may take additional time to get the synced versions Wayfarer offered, which is important because some of Lively's allegations indicated things that Baldoni said at specific times.

I'm not sure if Wayfarer's strategy was to get her to settle or try and get a second bite at the apple when more documents came in later, so it's smart that Lively's team is making a record calling them out on that in advance.

Garofalo's email where she wrote "talk about posturing" was pretty funny.

Oh, I thought the email reflected that Baldoni had promised to get Lively the video with sound by COB Friday, 7/11? Plenty of time for a team to review 150 hours over the weekend imo.

I actually enjoyed the Lively email that preceded Garofalo’s, for getting it all out in the open. Because it was weird for Lively’s attorneys to say we agree to proceed with the dep if you can give us the film with sound by 7/11, and for Baldoni’s team to say yes we will get you the film by 7/11 but will reschedule the dep as per your wishes. That was wild gaslighting.

I'm not sure. I read Wayfarer's email has an offer to produce the synced audio and video, provided Lively would stipulate that they would not later call that doctoring evidence, and I did not see where Lively accepted that offer, so to me it is unclear whether that is actually being sent. Lively responded with all that stuff about the scheduling but I don't see where they said "ok, we'll take that video." If Wayfarer provided a separate audio track then I guess Lively could hire a company to do the sync.

That's true, but I still feel it's on Baldoni's attorneys to work it out since in an earlier email there they promised to provide the video with sound (or else the dep would have to be delayed). So it was kind of on them to provide film with sound in some way on Friday. That's how we got to the agreement that the dep would go forward on Friday to begin with. If they are going back on that now, it makes them look not great. And the judge had to issue this order early Saturday morning based off the whole idea that the dep was going forward Thursday and this decision needed to be expedited, so they are going to look bad with Liman if they don't uphold their part of this bargain imo.

I don't disagree with you about where the email chain left off on communications. I just do think the impetus is on Baldoni's attorneys to provide the film with sound and make an agreement that works.

Maybe we'll find out in an hour ha.

The Wayfarer reply dropped and I think they made a strong argument in defense of their location.

Link please?

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.418.0.pdf

[Anonymous]

I actually don't think this Shuster letter is helpful for them. It does not address the Freedman issue head on, or the fact that the Vin Diesel dep location was moved precisely because of similar "security concerns." Moreover, it's filled with hateful asides to Lively like "Perhaps Lively is merely trying to deflect from the paucity of her claims which will be highlighted by her deposition testimony" and "Lively’s foot-stomping and use of her celebrity status may have enabled her to seize control of the film, which is the crux of this dispute, her counsel’s tantrum has no place in this Court." (Oh the irony of this given the very large and muscular Mr. Vin Diesel's similar concerns which prevailed.)

None of this makes it sound like Shuster is taking the security concerns very seriously or making any attempt to avoid a dangerous spectacle or pileup of people outside. They completely ignored the glaring Vin Diesel switch effectuated by their lead counsel, or the behavior of Freedman as explained in Exhibit 2. They just ignore these like they're not there.

The Pakistan case that Lively cited actually states what Lively cited it for -- that multiple courts have found that security can be a factor and even the deciding factor in determining where the dep should occur. Whereas at least some of the cases Shuster cites are entirely distinguishable.

And Shuster's seemingly main point that they need to host the dep because of their 20K documents is preposterous. Everything is electronic these days and remotely accessible. Liman was elected to the bench in 2019, so he's done deps recently enough to recognize that, as well.

I'm not saying Liman will definitely side with Lively. But I find Shuster's unserious and insulting tone in here unhelpful for the proposition that their firm will treat Lively respectfully and watch out for her security. So I tend to think he will, while still perhaps protecting the info from Shuster of exactly who will take the deposition etc.

[Anonymous]

Liman is going to side with Lively because he gives her everything she wants, so don't be surprised.

[Anonymous]

Anonymous wrote:I actually don't think this Shuster letter is helpful for them. It does not address the Freedman issue head on, or the fact that the Vin Diesel dep location was moved precisely because of similar "security concerns." Moreover, it's filled with hateful asides to Lively like "Perhaps Lively is merely trying to deflect from the paucity of her claims which will be highlighted by her deposition testimony" and "Lively’s foot-stomping and use of her celebrity status may have enabled her to seize control of the film, which is the crux of this dispute, her counsel’s tantrum has no place in this Court." (Oh the irony of this given the very large and muscular Mr. Vin Diesel's similar concerns which prevailed.)

None of this makes it sound like Shuster is taking the security concerns very seriously or making any attempt to avoid a dangerous spectacle or pileup of people outside. They completely ignored the glaring Vin Diesel switch effectuated by their lead counsel, or the behavior of Freedman as explained in Exhibit 2. They just ignore these like they're not there.

The Pakistan case that Lively cited actually states what Lively cited it for -- that multiple courts have found that security can be a factor and even the deciding factor in determining where the dep should occur. Whereas at least some of the cases Shuster cites are entirely distinguishable.

And Shuster's seemingly main point that they need to host the dep because of their 20K documents is preposterous. Everything is electronic these days and remotely accessible. Liman was elected to the bench in 2019, so he's done deps recently enough to recognize that, as well.

I'm not saying Liman will definitely side with Lively. But I find Shuster's unserious and insulting tone in here unhelpful for the proposition that their firm will treat Lively respectfully and watch out for her security. So I tend to think he will, while still perhaps protecting the info from Shuster of exactly who will take the deposition etc.

I agree with this. I think the decision to personally insult Lively throughout the letter was a very odd choice given the crux of the issue is whether they will take Lively's security concerns sufficiently seriously without Liman requiring it. I read this and, legal arguments aside, I come away with the impression that they would be pleased if the depo became a circus or something bad happened to Lively. That's not the image these lawyers should want to leave Liman with. Now, for what it's worth, I think Lively has made a credible case that the depo may be a circus if Baldoni's lawyers are left unattended, but I'm not sure she's really shown security concerns per se (being harassed by paps vs the alleged death threat in the VD case are very, very different). I think Baldoni's lawyers would have been better served by playing their response straight.

[Anonymous]

Agreed the insults in the letter are unnecessary, but also don't think they've given great reasons for changing the location. They invoke security but they don't actually articulate anything other than speculation. Vin Diesel is a different court with different circumstances. The concerns of paparazzi and Freedman being a jerk would also exist at Lively's attorney's offices. They are just speculating that Wayfarer is going to set something up. If I were Wayfarer I would just agree to her demand with an agreement my clients could do the same, but they're not obligated to do that. It was OTT for Lively's lawyer to write "the deposition will take place at our offices and we're serving lunch" instead of asking.

I think the most fair thing to do would be say the request for a list is moot as Wayfarer's letter says "may include counsel and parties" but granted to the extent anyone other than firm staff will be present, and to have the parties agree to a location with an agreement that the date and time of any depositions will be sealed and redacted on the docket. And I'd do that for all depositions, not just Lively.

[Anonymous]

Liman granted Lively's request for a protective order - Gottlieb must provide opposing counsel a private room etc.

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.419.0.pdf

Sorry to gloat, but I was actually right here.