Reply to Blake Lively- Jason Baldoni and NYT

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[quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous]Baldoni had better not come back in July and say they need another deposition with Lively when they’ve only produced 750 docs collectively so far amongst all their parties.  That’s astoundingly bad. [/quote]

It sounds like all Blake has done is turn over the Wayfarer texts she got from Jones.  Given she’s the plaintiff, that’s not great.[/quote]

To be fair, the email notes she was making another production the next day, which would have happened by now.[/quote]

Note also that the 2K docs are what Lively alone had produced, which even by itself outnumbered by several times what all of the Wayfarer parties put together had produced. Where are all of the texts and emails?  This is pretty ridiculous.

(Not engaging with sock puppet delusion lady anymore, except to say you guys can never admit you’ve been wrong)[/quote]

Apparently you can’t either, because Lively’s production of the Jones production is nothing to brag about and yet you continue to tout it.[/quote]

Lively has made at least one more production since that 2K production, and even not including that additional production, Lively’s one production alone is still nearly four times as many docs as Baldoni, Heath, Sarowitz, Wallace, and Wayfarer all put together lol.  This also isn't counting any docs that Reynolds and Sloane produced.[/quote]

Again, WF's Counsel submitted a declaration today saying they have yet to receive a single document responsive to their First Request for Documents from Lively.  Guess Gottlieb et al was too busy drafting Motions for Sanctions.[/quote]

It's a really bad look to be so behind in document production as the plaintiff, especially when one's counsel have been bombing the Court with all types of motions, including discovery motions.  In essence, all Lively's team has done is sent over the WF defendants copies of their own texts.[/quote]

I would take accusations from both sides that the other is "behind" in production with a grain of salt[b]. First of all, the discovery deadline has not passed -- parties will often wait until the last minute and then dump a bunch of docs. And that's allowed, for the most part.[/b] Second, both parties have likely requested documents that don't exist or which the other side will argue aren't relevant. This is also standard. Like if Baldoni's request for documents asked that Blake provide all documents where she talks about trying to steal the movie and her intentions to make up some SH allegations to do so, it's likely she has not produced those because they don't exist. Likewise, we know Blake is asking for documents where Baldoni/Wayfarer/Freedman conspire with content creators to smear Blake. Those may also not exist. So saying your opponent has "failed" to produce documents doesn't always mean they are dragging their feet. It can can mean there is nothing responsive, or that the party is in the process of objecting to the request. Both sides are doing this.

None of this matters in the end. Honestly, at this point, I don't think the bickering is going to be that determinative unless/until we get to summary judgment and agreed stipulations before trial. The back and forth over discovery will largely be small potatoes.[/quote]

The bolded is why I'm surprised her depo is scheduled for June 23rd. She's kind of a drama queen and apparently likes to come up with last emergencies and delays, but it would really behoove her to show up on time for that. [/quote]

It is totally Freedman's decision to take Lively's deposition this early, before doc production is even substantially complete, even though Liman has said only one deposition of each witness will be allowed.  To me, this is another reckless decision by him done for its performative value and for headlines, which actually risks giving up valuable legal gains he could have made if he waited for all the docs.  This is on Freedman.[/quote]

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