Reply to Blake Lively- Jason Baldoni and NYT

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[quote=Anonymous]The content creator ROG response was unsealed.

https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.451.1.pdf
INTERROGATORY NO. 5, AS INSTRUCTED BY THE COURT:
Identify all Content Creators with whom You have communicated in any manner,
concerning Ms. Lively, Mr. Reynolds, the CRD Complaint, the Actions, the Lively/Reynolds
Companies, or the Digital Campaign from May 1, 2024 to present.
RESPONSE TO INTERROGATORY NO. 5, AS INSTRUCTED BY THE COURT:
Responding Party incorporates by reference its general objections as if fully set forth in
response to this Interrogatory. Responding Party objects to this Interrogatory to the extent it is not
proportional to the needs of the case or relevant to the claim or defense of any party. Responding
Party further objects to this Interrogatory on the grounds that it is overbroad. Responding Party
further objects to this Interrogatory on the grounds that it is vague as to “communicated.”
Responding Party further objects to this Interrogatory on the grounds that it assumes the existence
of a purported Digital Campaign. Responding Party further objects to this Interrogatory to the
extent that it exceeds the scope of Local Civil Rule 33.3(a).
Subject to and without waiving the foregoing objections, Responding Party responds:

ATTORNEYS’ EYES ONLY PURSUANT TO PROTECTIVE ORDER
BILLY BUSH
ANDY SIGNORE (“Popcorned Planet”)
CANDACE OWENS
PEREZ HILTON[/quote]

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