Blake Lively- Jason Baldoni and NYT - False Light claims

Anonymous
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Anonymous wrote:The pro-Baldoni people are so hopeful about the MTDs, as though anything good can happen there for them. The best outcome for them there would be NOTHING, or just dismissals without prejudice with vague language from the judge about how there is enough in the complaint to comprehend a claim if repled properly.

Meanwhile, Freedman is basically defying the judge by (1) submitting non-responsive interrogatory answers, and late at that, in defiance of his refusal to extend; (2) not submitting an amended complaint before his deadline ran out, despite the court’s encouragement of him multiple times to do so; and (3) now making statements that Lively’s testimony should be televised, even though that isn’t done at all in federal court (only exception being audio broadcasts of the Supreme Court). I don’t really understand what kind of clown show Freedman is running, but if he’s trying to test Liman’s patience, he’s hitting the right notes. 👏


Blake’s lawyer’s interview with People magazine was a publicity stunt, just like pretty much everything Blake has been doing lately (Seth Meyers’s, that horrendous time speech where she shamelessly used her own mother). All BF did was match their energy. Gottlieb said Blake will testify. Ok and water is wet. It’s the epitome of a non story put out for PR purposes. Of course she’s going to testify, she’s the plaintiff. So when BF comes back with well she’s been testifying since she tried out for this part (very clever by the way, as he’s calling her entire lawsuit “acting” or “fake) it should come as no surprise. In the words of Blake’s dragons, play stupid games, win stupid prizes.


I don’t really understand some of this word salad and it really isn’t responsive to my list of recent questionable actions by Freedman, but it seems that you are doubling down on your bets with him, so … we’ll see how that turns out for you.

How like him, though, to suggest someplace flashy like Madison Square Garden; however, I don’t think even that arena is big enough to contain his ego.


I’m surprised you’re having trouble with my “word salad” since BL is the queen of them. But let me decode, I felt you were cherry-picking and suggesting that BF just randomly made the statement about televising Blake’s deposition out of the blue and completely unprovoked. You just completely failed to mention that BF was actually responding to Blake’s lawyer’s exclusive interview with people mag in which he said lots of misleading things. BF has been pretty quiet lately but they’re poking the bear.


I have never in my entire legal career read wholly non-responsive interrogatory answers like Freedman filed, late (in defiance of the court’s denial of an extension), where some of the questions clearly simply asked for info that the PR rep was entitled to, like, who said these things from your complaint, or what are the facts behind the allegations in your complaint, and instead offered nonsense like “uh what does ‘you’ mean again?” Interested in hearing from other lawyers whether they find “the bear”’s ROG responses normal here. I do not.


Not a litigator but it was very strange. I would expect basic information to be provided like what were the defamatory statements.


Yes, I think there's a chance that Freedman gets his hands slapped by the judge for the interrogatory answers, which are clearly intentionally useless. I think the pro-Baldoni folks are really not concentrating on how bad his legal posture is at this point. What you say in the press does not actually matter. His actual legal filings are a complete mess and he's really baiting a judge that's already reacted badly to his antics.



They actually are fairly typical of interrogatory responses which is why interrogatories are so useless generally.


You're saying this is normal? What kind of litigation do you do. I have never seen an interrogatory response like this before:

INTERROGATORY NO. 3:
Identify each person You allege Leslie Sloane communicated with regarding the Wayfarer Parties.

RESPONSE TO INTERROGATORY NO.3:
Responding Party incorporates by reference his general objections as if fully set forth in response to this Interrogatory. Responding Party objects to this Interrogatory to the extent it is not proportional to the needs of the case or relevant to the claim or defense of any party.
Responding Party further objects to this Interrogatory on the grounds that it is overbroad to the extent is seeks the identification of each person who “Vision PR, Inc. communicated with regarding [any of] the Wayfarer Parties.” Responding Party further objects to this Interrogatory on the grounds that it is vague as to “communicated.” In light of the foregoing objections, Responding Party will not respond to this Interrogatory at this time. Responding Party states that he is willing to meet and confer with Propounding Party regarding this Interrogatory.

I don't mean the objections for disproportion, overbreath, and vagueness. That's normal. Of the 8 interrogatories submitted in the exhibit, Freedman only sort of answered ONE of them, and submitted responses similar to the above for the rest or responses that merely pointed to their initial disclosures. I am used to seeing actual attempts at responses following all of the objections -- at worst pointers to other responses, hand waving that the ROG is premature for a rare response here or there, and promises to supplement the response in the future when more is known. Even with the objections, and even when there are problems with the original request, I am used to seeing some sort of attempt to respond to the question, even if the question must be construed in a way narrow enough to be something that can be answered. What I am NOT used to seeing is a lawyer not giving any helpful response for 90% of their responses, and for three fourths of them flat out saying that they will not respond at all but you can try to meet and confer with us. These questions are not crazily overbroad. Sloane is entitled to know who Freedman thinks she communicated with regarding the matters at issue in the complaint.


Where did the lawyer who said that interrogatory responses like these were typical go? Is anybody on Team Baldoni defending this? *crickets*
Anonymous
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Anonymous wrote:
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Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.
Anonymous
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.
Anonymous
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Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:The pro-Baldoni people are so hopeful about the MTDs, as though anything good can happen there for them. The best outcome for them there would be NOTHING, or just dismissals without prejudice with vague language from the judge about how there is enough in the complaint to comprehend a claim if repled properly.

Meanwhile, Freedman is basically defying the judge by (1) submitting non-responsive interrogatory answers, and late at that, in defiance of his refusal to extend; (2) not submitting an amended complaint before his deadline ran out, despite the court’s encouragement of him multiple times to do so; and (3) now making statements that Lively’s testimony should be televised, even though that isn’t done at all in federal court (only exception being audio broadcasts of the Supreme Court). I don’t really understand what kind of clown show Freedman is running, but if he’s trying to test Liman’s patience, he’s hitting the right notes. 👏


Blake’s lawyer’s interview with People magazine was a publicity stunt, just like pretty much everything Blake has been doing lately (Seth Meyers’s, that horrendous time speech where she shamelessly used her own mother). All BF did was match their energy. Gottlieb said Blake will testify. Ok and water is wet. It’s the epitome of a non story put out for PR purposes. Of course she’s going to testify, she’s the plaintiff. So when BF comes back with well she’s been testifying since she tried out for this part (very clever by the way, as he’s calling her entire lawsuit “acting” or “fake) it should come as no surprise. In the words of Blake’s dragons, play stupid games, win stupid prizes.


I don’t really understand some of this word salad and it really isn’t responsive to my list of recent questionable actions by Freedman, but it seems that you are doubling down on your bets with him, so … we’ll see how that turns out for you.

How like him, though, to suggest someplace flashy like Madison Square Garden; however, I don’t think even that arena is big enough to contain his ego.


I’m surprised you’re having trouble with my “word salad” since BL is the queen of them. But let me decode, I felt you were cherry-picking and suggesting that BF just randomly made the statement about televising Blake’s deposition out of the blue and completely unprovoked. You just completely failed to mention that BF was actually responding to Blake’s lawyer’s exclusive interview with people mag in which he said lots of misleading things. BF has been pretty quiet lately but they’re poking the bear.


I have never in my entire legal career read wholly non-responsive interrogatory answers like Freedman filed, late (in defiance of the court’s denial of an extension), where some of the questions clearly simply asked for info that the PR rep was entitled to, like, who said these things from your complaint, or what are the facts behind the allegations in your complaint, and instead offered nonsense like “uh what does ‘you’ mean again?” Interested in hearing from other lawyers whether they find “the bear”’s ROG responses normal here. I do not.


Not a litigator but it was very strange. I would expect basic information to be provided like what were the defamatory statements.


Yes, I think there's a chance that Freedman gets his hands slapped by the judge for the interrogatory answers, which are clearly intentionally useless. I think the pro-Baldoni folks are really not concentrating on how bad his legal posture is at this point. What you say in the press does not actually matter. His actual legal filings are a complete mess and he's really baiting a judge that's already reacted badly to his antics.



They actually are fairly typical of interrogatory responses which is why interrogatories are so useless generally.


You're saying this is normal? What kind of litigation do you do. I have never seen an interrogatory response like this before:

INTERROGATORY NO. 3:
Identify each person You allege Leslie Sloane communicated with regarding the Wayfarer Parties.

RESPONSE TO INTERROGATORY NO.3:
Responding Party incorporates by reference his general objections as if fully set forth in response to this Interrogatory. Responding Party objects to this Interrogatory to the extent it is not proportional to the needs of the case or relevant to the claim or defense of any party.
Responding Party further objects to this Interrogatory on the grounds that it is overbroad to the extent is seeks the identification of each person who “Vision PR, Inc. communicated with regarding [any of] the Wayfarer Parties.” Responding Party further objects to this Interrogatory on the grounds that it is vague as to “communicated.” In light of the foregoing objections, Responding Party will not respond to this Interrogatory at this time. Responding Party states that he is willing to meet and confer with Propounding Party regarding this Interrogatory.

I don't mean the objections for disproportion, overbreath, and vagueness. That's normal. Of the 8 interrogatories submitted in the exhibit, Freedman only sort of answered ONE of them, and submitted responses similar to the above for the rest or responses that merely pointed to their initial disclosures. I am used to seeing actual attempts at responses following all of the objections -- at worst pointers to other responses, hand waving that the ROG is premature for a rare response here or there, and promises to supplement the response in the future when more is known. Even with the objections, and even when there are problems with the original request, I am used to seeing some sort of attempt to respond to the question, even if the question must be construed in a way narrow enough to be something that can be answered. What I am NOT used to seeing is a lawyer not giving any helpful response for 90% of their responses, and for three fourths of them flat out saying that they will not respond at all but you can try to meet and confer with us. These questions are not crazily overbroad. Sloane is entitled to know who Freedman thinks she communicated with regarding the matters at issue in the complaint.


Where did the lawyer who said that interrogatory responses like these were typical go? Is anybody on Team Baldoni defending this? *crickets*


No one cares besides you. When one party asks 100 interrogatories before any discovery takes place, they won’t get answers to some of them.

Tip- no one wants to hear you drone on and on about this.
Anonymous
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.



What sort of law do you practice if you left litigation?

I will argue that bringing this case in the first place for BL wasn’t particularly restrained or professional of Gottlieb. It’s a crap case and he hasn’t done right by his client. But he’s certainly making a boatload off of this.

It’s nice he does pro bono work and all, but that’s par for the course at big firms, they’re expected to. And he obviously chose something that would bring good PR to the firm. I don’t think his motivations were as charitable as you assume.


If Gottlieb had anything to do with the VanZan sham litigation, and I think he did, that is a million degrees worse than anything Freedman did. And just to cut off the inevitable responses, it was a sham because (1) the entity of the defendants were known, and Doe defendants should not have been used, and (2) Van Zan had no standing with respect to any of the claims it purported to bring.


And 3) Baldoni and his co-dependants were never notified about the Vanzan suit.


Yes another good point. Blake’s lawyers should be sanctioned for this, but let’s hear more about how Freedman is too bombastic.
Anonymous
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Anonymous wrote:Did anyone else notice that Blake’s lawyer said the retaliation is the core of the case? I honestly read that as suggesting that even her lawyers know the actual SH claims are weak. Another telling statement in Gottlieb’s interview was that he said they “expect” and “hope” to focus on the smear campaign in discovery, which to me is an admission that they don’t actually have evidence of a smear campaign.


This is almost verbatim how I interpreted as well.


Here’s my prediction on Blake’s lawyers legal strategy, especially after that people magazine interview where Gottlieb called the retaliation the core of the case. If this thing goes all the way to trial, they’re going to start pivoting away from focusing on the harassment. They’re going to tell the jury “it doesn’t matter” whether or not Blake’s claims meet the legal threshold of harassment (because they clearly don’t) and they’re going to say Blake gets protection just for making the claims regardless of the validity of the claims. If they can prove a smear campaign (which I don’t think they’ll be able to but let’s just assume for the moment) this may actually be true under the law (i.e. no retaliation for making a complaint regardless of the validity of the complaint).

The problem is juries are human and it’s going to be pretty hard to convince them to punish Justin for “retaliation” if they see the harassment claims as bogus. This legal strategy will also play into Justin’s defense and countersuit, which is that the SH claims were made in bad faith to extort the WF parties.

You heard it here first lol. Mark my words. Even though Blake’s PR strategy is all about SH and giving women a voice, in court her lawyers are going to say “look elsewhere, don’t focus on the SH”.


That's exactly the play I believe they're going to do. And that's IF Blake goes through with it. I think she's goint to pull the mental health card at the last minute and settle. But we'll see. Good analyzation of the strategy.


Some of us said this 200+ pages ago. They have no SH case, and retaliation is the only thing holding up her case.

The mere suggestion of retaliation without substantive evidence to prove it is just an assertion of fact, but not a fact that’s provable.

I can’t understand at this point why Blake and Ryan won’t just call it a day and pay Justin his $400k. They have nothing. Why belabor this and drive up legal costs when you don’t have any evidence to substantiate your claims?

Could a jury cite a higher amount for damages , higher than the $400 million?
Anonymous
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.


Nope, I hear it means you get continually distracted by things that don’t matter. Filing a sham law suit is really problematic, having a big personality is not. Getting the procedure you want on for a protective order matters less than getting a more narrow definition of AEO than you wanted. Not getting an extension matters far less than getting a subpoena quashed.
Anonymous
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:
Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.


Nope, I hear it means you get continually distracted by things that don’t matter. Filing a sham law suit is really problematic, having a big personality is not. Getting the procedure you want on for a protective order matters less than getting a more narrow definition of AEO than you wanted. Not getting an extension matters far less than getting a subpoena quashed.


Here, not I hear.
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Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.


Nope, I hear it means you get continually distracted by things that don’t matter. Filing a sham law suit is really problematic, having a big personality is not. Getting the procedure you want on for a protective order matters less than getting a more narrow definition of AEO than you wanted. Not getting an extension matters far less than getting a subpoena quashed.


Those subpoenas were just redrafted and reissued, nbd. Meanwhile, how is getting zero discovery from the NYT (the party with the deepest pockets in this case) working out for the lawyer who files sh!t expecting to find all the facts he needs to support it through the process of discovery?
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Anonymous wrote:The pro-Baldoni people are so hopeful about the MTDs, as though anything good can happen there for them. The best outcome for them there would be NOTHING, or just dismissals without prejudice with vague language from the judge about how there is enough in the complaint to comprehend a claim if repled properly.

Meanwhile, Freedman is basically defying the judge by (1) submitting non-responsive interrogatory answers, and late at that, in defiance of his refusal to extend; (2) not submitting an amended complaint before his deadline ran out, despite the court’s encouragement of him multiple times to do so; and (3) now making statements that Lively’s testimony should be televised, even though that isn’t done at all in federal court (only exception being audio broadcasts of the Supreme Court). I don’t really understand what kind of clown show Freedman is running, but if he’s trying to test Liman’s patience, he’s hitting the right notes. 👏


Blake’s lawyer’s interview with People magazine was a publicity stunt, just like pretty much everything Blake has been doing lately (Seth Meyers’s, that horrendous time speech where she shamelessly used her own mother). All BF did was match their energy. Gottlieb said Blake will testify. Ok and water is wet. It’s the epitome of a non story put out for PR purposes. Of course she’s going to testify, she’s the plaintiff. So when BF comes back with well she’s been testifying since she tried out for this part (very clever by the way, as he’s calling her entire lawsuit “acting” or “fake) it should come as no surprise. In the words of Blake’s dragons, play stupid games, win stupid prizes.


I don’t really understand some of this word salad and it really isn’t responsive to my list of recent questionable actions by Freedman, but it seems that you are doubling down on your bets with him, so … we’ll see how that turns out for you.

How like him, though, to suggest someplace flashy like Madison Square Garden; however, I don’t think even that arena is big enough to contain his ego.


I’m surprised you’re having trouble with my “word salad” since BL is the queen of them. But let me decode, I felt you were cherry-picking and suggesting that BF just randomly made the statement about televising Blake’s deposition out of the blue and completely unprovoked. You just completely failed to mention that BF was actually responding to Blake’s lawyer’s exclusive interview with people mag in which he said lots of misleading things. BF has been pretty quiet lately but they’re poking the bear.


I have never in my entire legal career read wholly non-responsive interrogatory answers like Freedman filed, late (in defiance of the court’s denial of an extension), where some of the questions clearly simply asked for info that the PR rep was entitled to, like, who said these things from your complaint, or what are the facts behind the allegations in your complaint, and instead offered nonsense like “uh what does ‘you’ mean again?” Interested in hearing from other lawyers whether they find “the bear”’s ROG responses normal here. I do not.


Not a litigator but it was very strange. I would expect basic information to be provided like what were the defamatory statements.


Yes, I think there's a chance that Freedman gets his hands slapped by the judge for the interrogatory answers, which are clearly intentionally useless. I think the pro-Baldoni folks are really not concentrating on how bad his legal posture is at this point. What you say in the press does not actually matter. His actual legal filings are a complete mess and he's really baiting a judge that's already reacted badly to his antics.



They actually are fairly typical of interrogatory responses which is why interrogatories are so useless generally.


You're saying this is normal? What kind of litigation do you do. I have never seen an interrogatory response like this before:

INTERROGATORY NO. 3:
Identify each person You allege Leslie Sloane communicated with regarding the Wayfarer Parties.

RESPONSE TO INTERROGATORY NO.3:
Responding Party incorporates by reference his general objections as if fully set forth in response to this Interrogatory. Responding Party objects to this Interrogatory to the extent it is not proportional to the needs of the case or relevant to the claim or defense of any party.
Responding Party further objects to this Interrogatory on the grounds that it is overbroad to the extent is seeks the identification of each person who “Vision PR, Inc. communicated with regarding [any of] the Wayfarer Parties.” Responding Party further objects to this Interrogatory on the grounds that it is vague as to “communicated.” In light of the foregoing objections, Responding Party will not respond to this Interrogatory at this time. Responding Party states that he is willing to meet and confer with Propounding Party regarding this Interrogatory.

I don't mean the objections for disproportion, overbreath, and vagueness. That's normal. Of the 8 interrogatories submitted in the exhibit, Freedman only sort of answered ONE of them, and submitted responses similar to the above for the rest or responses that merely pointed to their initial disclosures. I am used to seeing actual attempts at responses following all of the objections -- at worst pointers to other responses, hand waving that the ROG is premature for a rare response here or there, and promises to supplement the response in the future when more is known. Even with the objections, and even when there are problems with the original request, I am used to seeing some sort of attempt to respond to the question, even if the question must be construed in a way narrow enough to be something that can be answered. What I am NOT used to seeing is a lawyer not giving any helpful response for 90% of their responses, and for three fourths of them flat out saying that they will not respond at all but you can try to meet and confer with us. These questions are not crazily overbroad. Sloane is entitled to know who Freedman thinks she communicated with regarding the matters at issue in the complaint.


Where did the lawyer who said that interrogatory responses like these were typical go? Is anybody on Team Baldoni defending this? *crickets*


No one cares besides you. When one party asks 100 interrogatories before any discovery takes place, they won’t get answers to some of them.

Tip- no one wants to hear you drone on and on about this.


Weak sauce, even for you. I am still waiting to hear some lawyer say they have seen responses like this before and they are totes normal, OR for a pro-Baldoner to admit that this seems unusual and bad to them. I can just repost this every few pages like I did with the PO decision.
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Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.


Agree. The PP putting this lawyer down is a jerk, and I note nobody is commenting about how they love working with attorneys who are like Freedman. I think most of the pro-Baldoners left on this thread are not attorneys and don’t really know what they’re talking about tbh.
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Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.


Nope, I hear it means you get continually distracted by things that don’t matter. Filing a sham law suit is really problematic, having a big personality is not. Getting the procedure you want on for a protective order matters less than getting a more narrow definition of AEO than you wanted. Not getting an extension matters far less than getting a subpoena quashed.


Those subpoenas were just redrafted and reissued, nbd. Meanwhile, how is getting zero discovery from the NYT (the party with the deepest pockets in this case) working out for the lawyer who files sh!t expecting to find all the facts he needs to support it through the process of discovery?


Everyone knows that the NYTimes lawsuit was a “Hail Mary.” Personally, I think the Court shouldn't be quick to dismiss because of the Times reliance on their independent review of the texts, the sham litigation, etc . . But Liman seems inclined to rely on the public use doctrine.

In any case, the purpose of this litigation was primarily PR and no question it was a home run in providing a quick rebuttal to The NY Times hit piece.
Anonymous
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Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.


DP, who listened to the PO hearing, who doesn’t like Freedman and makes somewhat hostile posts about him here. I have worked with (and against) other attorneys who are openly hostile to opposing counsel from the starting point (rather than having such a take on opposing counsel be earned over time due to dirty tricks or whatever), and it’s never good. These have always been the worst attorneys to deal with in my career and have been uniformly terrible people. Their egos cannot be appeased and even when they are on your side, they are impossible to work with.

The other thing I’ve heard about Freedman specifically is that he files things prematurely before he has the facts to back them up, expecting to gain those facts through discovery. That’s not the way complaints are supposed to work — you’re supposed to have the basics to support your claim in hand before filing. You shouldn’t be signing court filings that are guesses. But he doesn’t see a problem with that.


PP here and one of my issues with Freedman is that he has a history of doing things that I think are unethical with respect to the media. For instance in that article I linked to, they mention a case he handled against Bravo where he went on TMZ and waived around a document with the title "Slave Contract," implying that this was one of the contracts with Bravo at issue in his case. Later it turned out that was a prop contract that had nothing to do with the case. When I practiced, I encountered lawyers like this who have very loose relationships with truth and ethics and it's just so far from who I am as a person and a lawyer, it really drove me crazy. There is a whole school of thought in litigation that it's okay to pushed the boundaries of professional or personal ethics in order to zealously advocate for your client, he's far from alone in this. I dislike it and it wore me down over time and eventually I just decided I didn't want to spend so much of my professional life engaged in conflict with people who had such a different approach to me.

Lawyers disagree on this. I have old colleagues I like and respect who are not bothered by this stuff. Everyone is different. But for me, Freedman crosses a line. I feel similarly about his "Exhibit A" (which is just clearly a violation of procedural rules and is almost certainly going to be stricken at some point) and about some of the "leaks" or "receipts" Freedman has produced that I think are intentionally misleading.


You don’t seem cut out for litigation and that is reflected in your analysis.


Not being "cut out for" the kind of litigation where people lie about "slave contracts" to the press in order to undercut the opposition is a good thing.


It's like saying someone isn't "cut out for" dirty political campaigns. It means you're too decent to pull this crap.


Agree. The PP putting this lawyer down is a jerk, and I note nobody is commenting about how they love working with attorneys who are like Freedman. I think most of the pro-Baldoners left on this thread are not attorneys and don’t really know what they’re talking about tbh.


And you’d be wrong. I am, and I can tell there is at least one other pro Baldoni lawyer poster on just this page. However, I do appreciate that the two most prolific Lively posters have confirmed what we have long known, neither are litigators.
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Anonymous wrote:The pro-Baldoni people are so hopeful about the MTDs, as though anything good can happen there for them. The best outcome for them there would be NOTHING, or just dismissals without prejudice with vague language from the judge about how there is enough in the complaint to comprehend a claim if repled properly.

Meanwhile, Freedman is basically defying the judge by (1) submitting non-responsive interrogatory answers, and late at that, in defiance of his refusal to extend; (2) not submitting an amended complaint before his deadline ran out, despite the court’s encouragement of him multiple times to do so; and (3) now making statements that Lively’s testimony should be televised, even though that isn’t done at all in federal court (only exception being audio broadcasts of the Supreme Court). I don’t really understand what kind of clown show Freedman is running, but if he’s trying to test Liman’s patience, he’s hitting the right notes. 👏


Blake’s lawyer’s interview with People magazine was a publicity stunt, just like pretty much everything Blake has been doing lately (Seth Meyers’s, that horrendous time speech where she shamelessly used her own mother). All BF did was match their energy. Gottlieb said Blake will testify. Ok and water is wet. It’s the epitome of a non story put out for PR purposes. Of course she’s going to testify, she’s the plaintiff. So when BF comes back with well she’s been testifying since she tried out for this part (very clever by the way, as he’s calling her entire lawsuit “acting” or “fake) it should come as no surprise. In the words of Blake’s dragons, play stupid games, win stupid prizes.


I don’t really understand some of this word salad and it really isn’t responsive to my list of recent questionable actions by Freedman, but it seems that you are doubling down on your bets with him, so … we’ll see how that turns out for you.

How like him, though, to suggest someplace flashy like Madison Square Garden; however, I don’t think even that arena is big enough to contain his ego.


I’m surprised you’re having trouble with my “word salad” since BL is the queen of them. But let me decode, I felt you were cherry-picking and suggesting that BF just randomly made the statement about televising Blake’s deposition out of the blue and completely unprovoked. You just completely failed to mention that BF was actually responding to Blake’s lawyer’s exclusive interview with people mag in which he said lots of misleading things. BF has been pretty quiet lately but they’re poking the bear.


I have never in my entire legal career read wholly non-responsive interrogatory answers like Freedman filed, late (in defiance of the court’s denial of an extension), where some of the questions clearly simply asked for info that the PR rep was entitled to, like, who said these things from your complaint, or what are the facts behind the allegations in your complaint, and instead offered nonsense like “uh what does ‘you’ mean again?” Interested in hearing from other lawyers whether they find “the bear”’s ROG responses normal here. I do not.


Not a litigator but it was very strange. I would expect basic information to be provided like what were the defamatory statements.


Yes, I think there's a chance that Freedman gets his hands slapped by the judge for the interrogatory answers, which are clearly intentionally useless. I think the pro-Baldoni folks are really not concentrating on how bad his legal posture is at this point. What you say in the press does not actually matter. His actual legal filings are a complete mess and he's really baiting a judge that's already reacted badly to his antics.



They actually are fairly typical of interrogatory responses which is why interrogatories are so useless generally.


You're saying this is normal? What kind of litigation do you do. I have never seen an interrogatory response like this before:

INTERROGATORY NO. 3:
Identify each person You allege Leslie Sloane communicated with regarding the Wayfarer Parties.

RESPONSE TO INTERROGATORY NO.3:
Responding Party incorporates by reference his general objections as if fully set forth in response to this Interrogatory. Responding Party objects to this Interrogatory to the extent it is not proportional to the needs of the case or relevant to the claim or defense of any party.
Responding Party further objects to this Interrogatory on the grounds that it is overbroad to the extent is seeks the identification of each person who “Vision PR, Inc. communicated with regarding [any of] the Wayfarer Parties.” Responding Party further objects to this Interrogatory on the grounds that it is vague as to “communicated.” In light of the foregoing objections, Responding Party will not respond to this Interrogatory at this time. Responding Party states that he is willing to meet and confer with Propounding Party regarding this Interrogatory.

I don't mean the objections for disproportion, overbreath, and vagueness. That's normal. Of the 8 interrogatories submitted in the exhibit, Freedman only sort of answered ONE of them, and submitted responses similar to the above for the rest or responses that merely pointed to their initial disclosures. I am used to seeing actual attempts at responses following all of the objections -- at worst pointers to other responses, hand waving that the ROG is premature for a rare response here or there, and promises to supplement the response in the future when more is known. Even with the objections, and even when there are problems with the original request, I am used to seeing some sort of attempt to respond to the question, even if the question must be construed in a way narrow enough to be something that can be answered. What I am NOT used to seeing is a lawyer not giving any helpful response for 90% of their responses, and for three fourths of them flat out saying that they will not respond at all but you can try to meet and confer with us. These questions are not crazily overbroad. Sloane is entitled to know who Freedman thinks she communicated with regarding the matters at issue in the complaint.


Where did the lawyer who said that interrogatory responses like these were typical go? Is anybody on Team Baldoni defending this? *crickets*


No one cares besides you. When one party asks 100 interrogatories before any discovery takes place, they won’t get answers to some of them.

Tip- no one wants to hear you drone on and on about this.


Weak sauce, even for you. I am still waiting to hear some lawyer say they have seen responses like this before and they are totes normal, OR for a pro-Baldoner to admit that this seems unusual and bad to them. I can just repost this every few pages like I did with the PO decision.


Go ahead, you’ll drone on and one regardless. Can never see the forest for the trees.
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Anonymous wrote:I really don't get the personal animus shown here towards Freedman. Gottlieb has been far more nasty in his pleadings, and refusing to agree to a first request for an extension is not normal practice. Being a bit of a blowhard is pretty much a character trait for plaintiff attorneys and will be something the judge sees day in and day out. It certainly isn't something that will "turn him against" Freedman as one poster hopes.


I wouldn't say I have "personal" animus towards Freedman, but as a lawyer I've known many like him and it's one of the reasons I left litigation. It is not a style or personality type I enjoy, so I'm predisposed to dislike him. Also early in following this case, I read this profile of him (from last summer), and there's a lot of details in there that give me the ick:

https://www.hollywoodreporter.com/business/business-news/entertainment-lawyer-bryan-freedman-hollywood-dark-knight-1235919993/

I do think he's an effective lawyer for the kind of cases he takes on and I don't think he's dumb. But I cannot stand his approach to the media and I find his personality grating.

I also happened to have a lot of respect for Gottlieb based on some of his prior pro bono work (for instance defending GA poll workers against attacks from Giuliani after the 2020 election) and his style is preferable to me -- more restrained and professional IMO.

I just don't enjoy bombastic lawyers unless they are funny. Freedman is a specific kind of litigator, a media-savvy pitbull. I've known others like him. It is effective but I don't enjoy it. That's all.



What sort of law do you practice if you left litigation?

I will argue that bringing this case in the first place for BL wasn’t particularly restrained or professional of Gottlieb. It’s a crap case and he hasn’t done right by his client. But he’s certainly making a boatload off of this.

It’s nice he does pro bono work and all, but that’s par for the course at big firms, they’re expected to. And he obviously chose something that would bring good PR to the firm. I don’t think his motivations were as charitable as you assume.


If Gottlieb had anything to do with the VanZan sham litigation, and I think he did, that is a million degrees worse than anything Freedman did. And just to cut off the inevitable responses, it was a sham because (1) the entity of the defendants were known, and Doe defendants should not have been used, and (2) Van Zan had no standing with respect to any of the claims it purported to bring.


And 3) Baldoni and his co-dependants were never notified about the Vanzan suit.


Yes another good point. Blake’s lawyers should be sanctioned for this, but let’s hear more about how Freedman is too bombastic.


If this was unethical or otherwise wrong, then Freedman sure ought to be moving to disqualify these lawyers from the case, or moving to strike the evidence obtained by said subpoenas, or otherwise bringing the matter to Judge Lima ‘s attention. As it turns out, Freedman may have a bit of a dilemma here since he has used similar subpoenas in cases of his own.

But anyway, if it’s wrong, one thing Freedman should not be doing is continuing to serve discovery on a law firm that Freedman thinks has broken some serious ethical boundary without bringing the matter to the judge’s attention. And yet, Freedman does absolutely mothing even though he commented to the press about this at least a week ago, maybe more.
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