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][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]

Actually, you're totally misreading the declaration.  "The Requests" as they are defined in the declaration are narrowed to include a limited set of [b]7 particular document requests[/b] from that first set of RFPs Wayfarer issues (including the 2 Swift requests and 5 requests dealing with harassment, Sony, WME, and damages).  [b]Since that first set of RFPs included at least 109 doc requests, it is certainly a mistatement to say that Wayfarer has "yet to receive a single document responsive to their First Request for Documents from Lively" as you have done above when all that declaration is actually saying is that Wayfarer hasn't received anything responsive to those 7 particular requests yet from Lively[/b].  Check the declaration again -- what you have said is not what it says.  [/quote]

And this is one rare case where I'm going to throw the whole "a real lawyer would know to check the definitions" before making such a gross overstatement etc, which you have thrown so much at me, right back on to you.[/quote]

Perhaps you should check and see what those requests cover.  Sexual harassment, retaliation, economic damages, communications with Sony — in other words, the entire substantive part of her case.[/quote]

I mean, it seems like a lot of the retaliation evidence is going to come from the Baldoni parties and/or from the texts from VanZan that Lively has already produced.  Actually, if if Lively already produced all of the VanZan texts in her first 2K doc production then I would take issue with Wayfarer's claim that she hasn't produced anything about retaliation, because there were certainly communications about the smear campaign in those communications.

I won't go back and forth with you on this anymore.  I still think it was a big miss for you to claim Lively hadn't produced anything responsive to the entire 130 point First RFP when in fact all it said was she hadn't produced anything responsive to 7 particular requests on that RFP (and I'm not sure that would be an accurate characterization given what we know about the VanZan production).  You completely misinterpreted and misrepresented the declaration.[/quote]

Read the email chain.[/quote]

Between the two, it’s clear nothing of substance has been produced.  
[/quote]

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