Reply to Blake Lively- Jason Baldoni and NYT

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[quote=Anonymous]From Lively's request to de-designate TAG's disclosure of CCs as AEO:

After TAG was ordered to respond to the Interrogatories (see Dkt. No. 355), TAG supplemented its responses, identifying a number of individuals who have spoken publicly about Ms. Lively and this lawsuit, apparently at the behest of TAG and the other Wayfarer Defendants. See Roeser Decl., Ex. 1. Despite the factual nature of this information, TAG unilaterally designated its responses as confidential and “Attorneys’ Eyes Only,” thus obscuring TAG as the source of this information, and allowing the Wayfarer Defendants to once again recast Ms. Lively as the aggressor in pursuing subsequent discovery (which is exactly what has transpired)."

And:

"Moreover, these mis-designations are having very real impacts. For example, if Ms. Lively
issues subpoenas related to individuals identified in TAG’s Interrogatory Responses to marshal evidence about their involvement in the “smear campaign,” she will be hindered in her ability to meet and confer or respond to questions, and will be unable to explain to such subpoenaed parties that the discovery directed towards them is based in part on the fact that TAG identified them. Content creators who have been the subject of discovery have already painted Ms. Lively as the the aggressor in this lawsuit and have drawn a false equivalency between her discovery efforts and the Wayfarer Parties’ alleged smear campaign. One subpoenaed content creator even went so far as to record a call with a receptionist from Ms. Lively’s attorney’s office without express consent and then posted the recording on YouTube. 4 See Popcorned Planet, ITS REAL!? We Called Blake Lively’s Lawyers - THEY LIED TO US!?, YouTube (July 11, 2025), https://www.youtube.com/watch app=desktop&v=Rzen-Sa8e40&feature=youtu.be. This content creator further used the recording to make false, inflammatory remarks about Ms. Lively and her counsel, and is seeking to fundraise based on the recording and his remarks. See id. The bottom line is that the concern about being hamstrung in being able to tie her discovery to the Wayfarer Parties’ discovery responses further exacerbates public backlash against Ms. Lively, which she should not have to endure when there is no conceivable privacy interest that TAG and others are protecting."[/quote]

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