Reply to Blake Lively- Jason Baldoni and NYT

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[quote=Anonymous]Baldoni has filed a response to Lively's motion for a protective order against the Swift subpoena requesting documents, saying basically Lively is required to submit these docs and they're still responsive re her garden variety emotional distress claims.  Letter also notes that no [b]"communications between Ms. Lively and Ms. Swift"[/b]  have been provided to the Wayfarer parties.  Baldoni is narrowing down the to/from parties here to focus on the fact that the communications required by the subpoena involve Swift and Lively only (not the attorneys, etc).  Baldoni is saying these communications are still relevant because Lively claimed Swift was with her through the project the whole way and because communications after various incidents occurred could reflect Lively's level of distress/non-distress.

Attached declaration also claims Lively refused to properly meet and confer before filing its motion for protective order.  The declaration also says Lively's attorneys haven't responded to some other doc requests from the first set of RFPs, and has just promised to provide those docs (besides the Swift docs) before the substantial completion date of July 1.

The email chain with the parties correspondence is revealing as always and notes the following:  
* [b]Lively's deposition is scheduled for Monday, June 23[/b] - less than a week away!
* Doc production status:  Baldoni's attorney Fritz complained that as of 6/12, Lively had produced only documents obtained through her company VanZan, to which Lively responded they are making rolling productions and have already produced docs from Sony and WME).  Then Lively's attorneys recounted doc production history so far reflecting that Lively had produced 3 or 4 times as many docs as Baldoni has so far:   "This is the first time that you have raised a concern with the pace of Ms. Lively’s productions, and the Wayfarer Parties have only made two voluntarily productions, or three including the compelled production. Ms. Lively has also produced [b][u]2,832 documents[/u][/b], and all of the Wayfarer Parties collectively have produced only [b][u]754 documents[/u][/b] (including those that were compelled). In any event, Ms. Lively intends to make her next production tomorrow (6/13), and to make regular rolling productions thereafter that will satisfy substantial completion obligations by July 1."

Baldoni Opposition:  https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.351.0.pdf

Declaration:  https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.0.pdf

Email chain:  https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.352.4.pdf

Fritz for Baldoni also filed an Opposition to Lively's motion to compel interrogatory responses involving the content providers and etc. they share information with:

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.353.0.pdf[/quote]

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