Blake Lively- Jason Baldoni and NYT - False Light claims

[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.

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.

What??? 300 pages ago you all were reveling at the clear prospect of the NYT going down, and now it’s a Hail Mary? You guys sure do switch your stories on a dime, just like Freedman did when that Slave Contract turned out to relate to an entirely different case. Okay, Jan.

What are you talking about, people always said the libel case would be very difficult.

[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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

It really doesn’t. Lively also had an extension denied, and that one was consented to by Freedman.

Yes!!! Absolutely! Lively had an extension denied for the same reason — failure to show good cause! So here is what she did not do in response to that denial:

(1) Decide to just not file an amended complaint, and let the original flawed complaint stand. (Freedman did that!)

(2) File the doc that the extension was denied for, by the deadline, but file a total piece of sh!t that doesn’t comply with recognized legal norms such that it represents a giant middle finger to the party you are responding to. (Freedman didn’t do this. But wait!);

(3) Pull a number (2), above, EXCEPT FILE IT LATE. (Freedman did this!)

So yes Lively also had an extension denied, and in response her lawyers worked all weekend and filed a substantially improved Amended Complaint, whereas Freeman failed here at every turn.

[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.

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.

That’s not true. He amended Jen Abel’s complaint and brought subpoena gate before the court in the case against jones. We also have no idea if he’s reported them to the bar or the court for disciplinary action because that’s probably private.

[Anonymous]

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Anonymous wrote:

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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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

You already admitted you didn’t. But please continue for another 50 pages so we can all tune you out again.

Nah, I litigate. I don’t always call myself “a litigator” because for the kinds of clients we handle, I am often not the one standing up in court at this stage of my career. But I respond to interrogatories, discovery, I write briefs, I prep for and take depositions, I work with experts. and I have stood up in court and made arguments for sure. Let me know what you do, since you don’t give any information on that.

I spent 15 years in litigation at two T10 law firms that actual take cases to court, worked as a litigator in federal government and am currently an AAG.

If you’re an assistant attorney general in this administration, I guess I can understand why you’re always so angry. My (sincere) condolences.

Assistant Attorney General is a position with a state. You appear to be confusing it with Asst US Attorney. You seem very unfamiliar with how litigation works.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

It really doesn’t. Lively also had an extension denied, and that one was consented to by Freedman.

Yes!!! Absolutely! Lively had an extension denied for the same reason — failure to show good cause! So here is what she did not do in response to that denial:

(1) Decide to just not file an amended complaint, and let the original flawed complaint stand. (Freedman did that!)

(2) File the doc that the extension was denied for, by the deadline, but file a total piece of sh!t that doesn’t comply with recognized legal norms such that it represents a giant middle finger to the party you are responding to. (Freedman didn’t do this. But wait!);

(3) Pull a number (2), above, EXCEPT FILE IT LATE. (Freedman did this!)

So yes Lively also had an extension denied, and in response her lawyers worked all weekend and filed a substantially improved Amended Complaint, whereas Freeman failed here at every turn.

You meant she took out the parts where she had been caught lying?

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

It really doesn’t. Lively also had an extension denied, and that one was consented to by Freedman.

Yes!!! Absolutely! Lively had an extension denied for the same reason — failure to show good cause! So here is what she did not do in response to that denial:

(1) Decide to just not file an amended complaint, and let the original flawed complaint stand. (Freedman did that!)

(2) File the doc that the extension was denied for, by the deadline, but file a total piece of sh!t that doesn’t comply with recognized legal norms such that it represents a giant middle finger to the party you are responding to. (Freedman didn’t do this. But wait!);

(3) Pull a number (2), above, EXCEPT FILE IT LATE. (Freedman did this!)

So yes Lively also had an extension denied, and in response her lawyers worked all weekend and filed a substantially improved Amended Complaint, whereas Freeman failed here at every turn.

Interrogatory responses are not filed.

[Anonymous]

Anonymous wrote:

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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

Not sure what you are talking about, judge cannot go beyond the complaint in deciding a motion to dismiss.

You’re not allowed to sue people based on vibes, and then file ROG responses like these when the people you sue ask wtf you are suing them for.

It’s incredibly common to get the premature objection to interrogatories. Talk about making a mountain of a molehill. It’s like you have never actually litigated a case.

[Anonymous]

I'm still waiting for the text messages that reveal the specific plan Baldoni and co had in motion to retaliate and destroy Lively. The basis for this lawsuit is a coordinated retaliatory campaign against Lively for sexual harassment and yet I still have not been able to see or get ahold of documentation that specifically outlines this plan.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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Anonymous wrote:

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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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

You already admitted you didn’t. But please continue for another 50 pages so we can all tune you out again.

Nah, I litigate. I don’t always call myself “a litigator” because for the kinds of clients we handle, I am often not the one standing up in court at this stage of my career. But I respond to interrogatories, discovery, I write briefs, I prep for and take depositions, I work with experts. and I have stood up in court and made arguments for sure. Let me know what you do, since you don’t give any information on that.

I spent 15 years in litigation at two T10 law firms that actual take cases to court, worked as a litigator in federal government and am currently an AAG.

If you’re an assistant attorney general in this administration, I guess I can understand why you’re always so angry. My (sincere) condolences.

Assistant Attorney General is a position with a state. You appear to be confusing it with Asst US Attorney. You seem very unfamiliar with how litigation works.

I understand you are saying you work for a state, but you are wrong to say that all Assistant Attorney Generals do. See, e.g., prior Assistant Attorney General Jonathan Kanter (DOJ Antitrust Division). There are federal AAGs that are not so high up , either — AAG Jolene Ann Lauria is AAG for Administration at DOJ.

So seems like you’re the one who doesn’t know what you’re talking about, actually. Sorry not sorry.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

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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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

It really doesn’t. Lively also had an extension denied, and that one was consented to by Freedman.

Yes!!! Absolutely! Lively had an extension denied for the same reason — failure to show good cause! So here is what she did not do in response to that denial:

(1) Decide to just not file an amended complaint, and let the original flawed complaint stand. (Freedman did that!)

(2) File the doc that the extension was denied for, by the deadline, but file a total piece of sh!t that doesn’t comply with recognized legal norms such that it represents a giant middle finger to the party you are responding to. (Freedman didn’t do this. But wait!);

(3) Pull a number (2), above, EXCEPT FILE IT LATE. (Freedman did this!)

So yes Lively also had an extension denied, and in response her lawyers worked all weekend and filed a substantially improved Amended Complaint, whereas Freeman failed here at every turn.

You meant she took out the parts where she had been caught lying?

lol, let’s just come back to this conversation after Freedman files an amended complaint (assuming he is allowed to do so) that is based on more than vibes, and compare the breadth of the cuts.

[Anonymous]

Anonymous wrote:I'm still waiting for the text messages that reveal the specific plan Baldoni and co had in motion to retaliate and destroy Lively. The basis for this lawsuit is a coordinated retaliatory campaign against Lively for sexual harassment and yet I still have not been able to see or get ahold of documentation that specifically outlines this plan.

You will be waiting a long time.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

You already admitted you didn’t. But please continue for another 50 pages so we can all tune you out again.

Nah, I litigate. I don’t always call myself “a litigator” because for the kinds of clients we handle, I am often not the one standing up in court at this stage of my career. But I respond to interrogatories, discovery, I write briefs, I prep for and take depositions, I work with experts. and I have stood up in court and made arguments for sure. Let me know what you do, since you don’t give any information on that.

I spent 15 years in litigation at two T10 law firms that actual take cases to court, worked as a litigator in federal government and am currently an AAG.

If you’re an assistant attorney general in this administration, I guess I can understand why you’re always so angry. My (sincere) condolences.

Assistant Attorney General is a position with a state. You appear to be confusing it with Asst US Attorney. You seem very unfamiliar with how litigation works.

I understand you are saying you work for a state, but you are wrong to say that all Assistant Attorney Generals do. See, e.g., prior Assistant Attorney General Jonathan Kanter (DOJ Antitrust Division). There are federal AAGs that are not so high up , either — AAG Jolene Ann Lauria is AAG for Administration at DOJ.

So seems like you’re the one who doesn’t know what you’re talking about, actually. Sorry not sorry.

In which case, I would not have distinguished my federal service from my current position. Reading is fundamental.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

Not sure what you are talking about, judge cannot go beyond the complaint in deciding a motion to dismiss.

You’re not allowed to sue people based on vibes, and then file ROG responses like these when the people you sue ask wtf you are suing them for.

It’s incredibly common to get the premature objection to interrogatories. Talk about making a mountain of a molehill. It’s like you have never actually litigated a case.

DP here, but it *is* uncommon to use the premature objection to an interrogatory that is just "please identify the defamatory statements you are accusing the defendant of making." They are arguing that it's too early to identify even one example of alleged behavior justifying their entire action against Sloane. That is definitely unusual.

Of course, it's also unusual for a complaint to have such egregious group pleading issues that it would be necessary for a defendant to ask the plaintiff "uh, what specifically are you suing me for" in an interrogatory. So I guess that's why I've never seen it before. Usually the response to a question like this would just be to refer to the portion of the complaint that outlines the defendant's alleged behavior.

And at risk of invoking some kind of seizure in the pro-Baldoni folks, I'll point out that one way to avoid this predicament, where you are suing someone for something but you can't specify what and you have to keep asking for more discovery in the hopes that it will produce for you a specific cause of action, is to file a Doe lawsuit in which to subpoena evidence you believe may give rise to a cause of action, and then use that evidence to file a complaint wherein you may properly plead specific causes of action against specific defendants. [ducks]

[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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

Not sure what you are talking about, judge cannot go beyond the complaint in deciding a motion to dismiss.

You’re not allowed to sue people based on vibes, and then file ROG responses like these when the people you sue ask wtf you are suing them for.

It’s incredibly common to get the premature objection to interrogatories. Talk about making a mountain of a molehill. It’s like you have never actually litigated a case.

DP here, but it *is* uncommon to use the premature objection to an interrogatory that is just "please identify the defamatory statements you are accusing the defendant of making." They are arguing that it's too early to identify even one example of alleged behavior justifying their entire action against Sloane. That is definitely unusual.

Of course, it's also unusual for a complaint to have such egregious group pleading issues that it would be necessary for a defendant to ask the plaintiff "uh, what specifically are you suing me for" in an interrogatory. So I guess that's why I've never seen it before. Usually the response to a question like this would just be to refer to the portion of the complaint that outlines the defendant's alleged behavior.

And at risk of invoking some kind of seizure in the pro-Baldoni folks, I'll point out that one way to avoid this predicament, where you are suing someone for something but you can't specify what and you have to keep asking for more discovery in the hopes that it will produce for you a specific cause of action, is to file a Doe lawsuit in which to subpoena evidence you believe may give rise to a cause of action, and then use that evidence to file a complaint wherein you may properly plead specific causes of action against specific defendants. [ducks]

As we have repeatedly discussed, Doe cases are only appropriate when defendants are unknown and cannot be named. Which you would know if you were a litigator.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

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.

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.

I litigate. So let me know what you think of those ROG responses. Totally normal, eh?

This is again missing the forest for the trees. Suppose they are inadequate? He’ll lose a motion to compel, write some bullshit vague but somewhat more detailed response and it won’t matter an iota for the outcome of this case. But if you want to waste your time on this, go ahead.

All of this matters in terms of building credibility with the judge. Judge Lyman denied their request for an extension, and these ROG responses are what they filed, late.

It all matters. And what facts Freedman has and shares (or can’t share) now may matter especially in deciding whether to grant that MTD with or without prejudice.

It all matters. Always.

Not sure what you are talking about, judge cannot go beyond the complaint in deciding a motion to dismiss.

You’re not allowed to sue people based on vibes, and then file ROG responses like these when the people you sue ask wtf you are suing them for.

It’s incredibly common to get the premature objection to interrogatories. Talk about making a mountain of a molehill. It’s like you have never actually litigated a case.

DP here, but it *is* uncommon to use the premature objection to an interrogatory that is just "please identify the defamatory statements you are accusing the defendant of making." They are arguing that it's too early to identify even one example of alleged behavior justifying their entire action against Sloane. That is definitely unusual.

Of course, it's also unusual for a complaint to have such egregious group pleading issues that it would be necessary for a defendant to ask the plaintiff "uh, what specifically are you suing me for" in an interrogatory. So I guess that's why I've never seen it before. Usually the response to a question like this would just be to refer to the portion of the complaint that outlines the defendant's alleged behavior.

And at risk of invoking some kind of seizure in the pro-Baldoni folks, I'll point out that one way to avoid this predicament, where you are suing someone for something but you can't specify what and you have to keep asking for more discovery in the hopes that it will produce for you a specific cause of action, is to file a Doe lawsuit in which to subpoena evidence you believe may give rise to a cause of action, and then use that evidence to file a complaint wherein you may properly plead specific causes of action against specific defendants. [ducks]

As we have repeatedly discussed, Doe cases are only appropriate when defendants are unknown and cannot be named. Which you would know if you were a litigator.

Or even by reading the posts of others here.