Anonymous wrote:I see this letter people reference above. Technically, it's not Freedman, it's someone else from the lawyer team.
https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.168.0.pdf
They've asked for more time to respond to the doc requests, yes, and also an extension of time to move to amend their pleadings so that it's based off the court's forthcoming MTD rulings - 21 days later. Lively parties don't want to agree to this because the schedule wasn't originally set up to base leave to amend off MTD rulings, so why should they be allowing Baldoni all this extra time to fix his stupid complaint that he's put no effort into so far when he could be working on that right now? (lol - haven't they already given him that roadmap? so what's his problem?) Fritz (the Baldoni lawyer) also faults the Lively parties etc for not giving a reason to allow the extension besides noting that the original schedule is not targeted off MTD rulings, and cites to an ethical rule requiring courtesy and cooperation at all times, so I can see why Freedman couldn't put his name on this letter.
Interested in seeing whatever the Lively attorneys will say in response. Noting that Fritz said the NYT would agree to the extension of time for filing amendments but specifically lodged that they would oppose any amendment anyway (as will any party, really).
The total number of doc requests, 1600, does seem like a lot when aggregated. But if you consider that it is split between 8 different parties it comes out to 200 RFPs per party, and that's not crazy. Each party does not need to be represented by the same law firm, so if this is too much for Freedman et al to handle they could be getting additional help. Seems like Sarowitz can afford it and it's not like these requests are a surprise to them, since Fritz said they were all served at the same time.
My guess is that Liman will give Fritz a short extension on the doc production deadline but not quite as long as he wants. I think Liman may grant the amendment deadline based off his MTD orders, but I'm not sure. It annoys me that Freedman vaingloriously boasted about how the Lively parties had already given him a roadmap re what he'd have to do to fix his complaint, and yet he makes no effort to do anything with that information and now sits here pleading with the judge for more time. I know, I know, parties are liberally granted leave to amend etc. But much of his complaint is garbage and yet he is sitting on his hands, so I hope Liman splits the baby here, too, somehow.