Reply to Blake Lively- Jason Baldoni and NYT

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[quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous][quote=Anonymous]Well, Lively has moved to file a reply in the case management plan motion, noting among other things that it now seems to be Freedman who is attempting to delay Lively's deposition even though Lively stands ready to have the dep on July 17.  Gottlieb does note security issues from having the dep at defendants offices, and also files the Vin Diesel affidavit as an exhibit in expressing concern about recent "unprofessional and physically aggressive deposition tactics by Mr. Freedman."

"In that same correspondence, the Wayfarer Parties also refused to agree that Ms. Lively’s deposition be held at her counsel’s office to ensure that appropriate security measures could be in place under the supervision of her counsel. This is particularly concerning given the high-profile nature of this case, the substantial public and media interest, Ms. Lively’s right to personal safety and the protections of the Court’s Protective Order, especially in light of Mr. Freedman’s previous threats to “live stream” and “sell tickets to” Ms. Lively’s deposition, as well as recent allegations, detailed in recent filings in Los Angeles Superior Court, of unprofessional and physically aggressive deposition tactics by Mr. Freedman. See Ex. B.

Lively also notes a major problem in here with the film that was provided, explaining that the sound isn't synched to the picture (!!!), effectively making it largely worthless.  Kind of feels like Liner Freedman planned this tbh.

Motion:  https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.401.0.pdf

Bender declaration:  https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.402.0.pdf

Exhibit A:  Email exchange where Liner Freedman appears to sua sponte postpone Lively's deposition, and insist on its original location, but agrees to provide film by 7/11.

Vin Diesel pleading filed here as Exhibit B to Lively pleading (see, it was relevant to this case after all lol):  https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.402.2.pdf[/quote]

And Liman has already very quickly issued an Order in response, referencing Lively's letter filed today and requiring all parties to show cause by Friday, July 11, why he should not issue an order requiring that:

All document production by parties and nonparties shall be completed by July 25, 2025.  (Third-party subpoenas shall require production no later than July 25, 2025.)
     Motions to compel regarding document production shall be filed by no later than August 1, 2025.
     Depositions shall be completed by September 30, 2025. All fact discovery shall be completed by September 30, 2025.

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.403.0.pdf[/quote]

Thank you for posting the updates/links.

I read it to mean the video has no audio at all, which is very obnoxious.

Do you all think the parties will come to an agreement on Lively's deposition setting, or will it end up in front of the judge?[/quote]

Yes, you were right about there being no audio at all, I was wrong about the synching whoops.

Good question about the setting.  I honestly think that maybe there was a typo in the Baldoni atty's email and that they are saying that not all film (with audio) will be produced by July 11 (therefore necessitating rescheduling of the dep), but I could be completely wrong.  If so, maybe that wards off the location question for a bit.

If not, I suspect Gottlieb will push the issue to Liman because I don't think Freedman will give in, and I actually think Gottlieb may lose here.  They aren't really supposed to have the home court advantage for the dep, even with security concerns (and asking for the names of who would be attending, an entire week in advance, is legit unfair of Gottlieb imho.  The attendees is not really security info you need an entire week in advance, that's really info gathering for strategy imo).  But Gottlieb had Freedman's crazy behavior from the Vin Diesel encounter to back up his security concerns with, as well as Freedman's MSG comments, so he had some leverage to ask for the location change.

It's also weird because Vin Diesel himself was asking for a location change for his own dep, so it wouldn't be held at opposing counsel's offices, for his own "security concerns" lol.  And in that case, on 7/1, the judge actually did side with Diesel and require that dep to occur at Freedman's offices instead of the usual custom of having it at the offices of the counsel affirmatively taking the dep.  So it's entirely possible Liman will do the same thing here and side with Gottlieb (though I doubt he'd require the names a week in advance).  It's all really just a snake eating its own tail, and completely ironic in that way.

Hope it is appropriate to provide this commentary here, since it's the exact same issue arising in the Baldoni case here and the filing about it was actually filed in the Baldoni case.[/quote]

It’s inappropriate. You already started another thread that no one cared about to discuss this. [/quote]

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