Anonymous wrote:The Lively letter specifically invokes Liman’s individual rules 1.C and 4.C which relate respectively to letter motions and discovery disputes. It doesn’t just make the judge aware of the dispute in another court, it goes on to set forth all the basis for all of Lively’s objections to the subpoena. Pursuant to Liman’s own rules, any party not in agreement with arguments put forth in a letter filed pursuant to his Rule 1.C should so inform the Court within 2 days. https://nysd.uscourts.gov/sites/default/files/practice_documents/LJL%20Liman%20Individual%20Practices%20in%20Civil%20Cases_updated%209.26.24.pdf

Anonymous wrote:

Anonymous wrote:Let’s just go right to Freedman’s letter. He specifically states his filing is responsive and wants to address the contention that the DC subpoena is not seeking relevant info. I’m not going to argue about the plain language of his filing:

We write in response to the letter filed by Plaintiff/Consolidated Defendant Blake Lively (“Ms.
Lively”) and Consolidated Defendant Ryan Reynolds (together, the “Lively Defendants”)
regarding their requested intervention in an action in the United States District Court for the
District of Columbia seeking to quash the Wayfarer Parties’ subpoena (the “Subpoena”) to
Venable LLP (“Venable”) (Dkt. 213).
. . . .
However, the Lively Defendants’
insistence that the Subpoena seeks irrelevant information is wrong. The Subpoena aims to obtain
discovery relating to witness tampering and evidence spoliation.

No. Just answer my question about your familiarity with letters like Governski’s. It will let me know whether you know what you’re talking about.

Anonymous wrote:

Anonymous wrote:Let’s just go right to Freedman’s letter. He specifically states his filing is responsive and wants to address the contention that the DC subpoena is not seeking relevant info. I’m not going to argue about the plain language of his filing:

We write in response to the letter filed by Plaintiff/Consolidated Defendant Blake Lively (“Ms.
Lively”) and Consolidated Defendant Ryan Reynolds (together, the “Lively Defendants”)
regarding their requested intervention in an action in the United States District Court for the
District of Columbia seeking to quash the Wayfarer Parties’ subpoena (the “Subpoena”) to
Venable LLP (“Venable”) (Dkt. 213).
. . . .
However, the Lively Defendants’
insistence that the Subpoena seeks irrelevant information is wrong. The Subpoena aims to obtain
discovery relating to witness tampering and evidence spoliation.

No. Just answer my question about your familiarity with letters like Governski’s. It will let me know whether you know what you’re talking about.

Anonymous wrote:Let’s just go right to Freedman’s letter. He specifically states his filing is responsive and wants to address the contention that the DC subpoena is not seeking relevant info. I’m not going to argue about the plain language of his filing:

We write in response to the letter filed by Plaintiff/Consolidated Defendant Blake Lively (“Ms.
Lively”) and Consolidated Defendant Ryan Reynolds (together, the “Lively Defendants”)
regarding their requested intervention in an action in the United States District Court for the
District of Columbia seeking to quash the Wayfarer Parties’ subpoena (the “Subpoena”) to
Venable LLP (“Venable”) (Dkt. 213).
. . . .
However, the Lively Defendants’
insistence that the Subpoena seeks irrelevant information is wrong. The Subpoena aims to obtain
discovery relating to witness tampering and evidence spoliation.

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

It doesn’t matter if the notice of intervention letter was appropriate or not, Freedman was still responding to it. The fact that you have argued this point incorrectly for several pages doesn’t give value, sorry, and the fact that you don’t understand this speaks volumes.

Posters stop responding to you because you repeat the same, usually incorrect, point ad nauseam, not because you have a good point.

But I haven’t argued it incorrectly. I am right that it’s Freedman’s lol “response” that was totally out of line and not the routine letter from Governski that preceded it. That is why Judge Liman struck every single thing Freedman filed in response to Governski’s letter but not Governski’s letter itself.

I’m involved in a case right now where two such notification letters have been filed with the judge by one party. In neither case did the non-filing party file a response. That is the norm.

You seem to have missed our points, above, or maybe are just being deliberately obtuse. Freedman knew the sanctions motions were coming in SDNY, so he took the opportunity of the Governski letter to make a Taylor Swift headline, knowing full well that a response to a routine notification letter like Governski’s was not needed, and certainly knowing that a response making extortion accusations would be out of line. He did it anyway and the judge spanked him.

DP. Agree with the bolded but also hate to admit it was pretty clever of BF.

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

Also, I am going to say this once and not argue about it for pages. Freedman interpreted the notice of intervention as an attempt to induce Liman to exercise jurisdiction, whether correctly or not, which Liman has the discretion to do. He therefore set forth why he had issued the subpoena, in case Liman decided to exercise jurisdiction and quickly ruled. For this reason, some litigators are of the view that Liman’s striking his letter was not the proper judicial response. In any case, Freedman did get what he wanted, Liman did not exercise jurisdiction.

That is such a misreading of Governski’s letter that I question whether you are an actual lawyer.

Ah yes, the old when wrong on facts, go with insults.

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

It doesn’t matter if the notice of intervention letter was appropriate or not, Freedman was still responding to it. The fact that you have argued this point incorrectly for several pages doesn’t give value, sorry, and the fact that you don’t understand this speaks volumes.

Posters stop responding to you because you repeat the same, usually incorrect, point ad nauseam, not because you have a good point.

But I haven’t argued it incorrectly. I am right that it’s Freedman’s lol “response” that was totally out of line and not the routine letter from Governski that preceded it. That is why Judge Liman struck every single thing Freedman filed in response to Governski’s letter but not Governski’s letter itself.

I’m involved in a case right now where two such notification letters have been filed with the judge by one party. In neither case did the non-filing party file a response. That is the norm.

You seem to have missed our points, above, or maybe are just being deliberately obtuse. Freedman knew the sanctions motions were coming in SDNY, so he took the opportunity of the Governski letter to make a Taylor Swift headline, knowing full well that a response to a routine notification letter like Governski’s was not needed, and certainly knowing that a response making extortion accusations would be out of line. He did it anyway and the judge spanked him.

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

It doesn’t matter if the notice of intervention letter was appropriate or not, Freedman was still responding to it. The fact that you have argued this point incorrectly for several pages doesn’t give value, sorry, and the fact that you don’t understand this speaks volumes.

Posters stop responding to you because you repeat the same, usually incorrect, point ad nauseam, not because you have a good point.

But I haven’t argued it incorrectly. I am right that it’s Freedman’s lol “response” that was totally out of line and not the routine letter from Governski that preceded it. That is why Judge Liman struck every single thing Freedman filed in response to Governski’s letter but not Governski’s letter itself.

I’m involved in a case right now where two such notification letters have been filed with the judge by one party. In neither case did the non-filing party file a response. That is the norm.

You seem to have missed our points, above, or maybe are just being deliberately obtuse. Freedman knew the sanctions motions were coming in SDNY, so he took the opportunity of the Governski letter to make a Taylor Swift headline, knowing full well that a response to a routine notification letter like Governski’s was not needed, and certainly knowing that a response making extortion accusations would be out of line. He did it anyway and the judge spanked him.

Anonymous wrote:

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

Also, I am going to say this once and not argue about it for pages. Freedman interpreted the notice of intervention as an attempt to induce Liman to exercise jurisdiction, whether correctly or not, which Liman has the discretion to do. He therefore set forth why he had issued the subpoena, in case Liman decided to exercise jurisdiction and quickly ruled. For this reason, some litigators are of the view that Liman’s striking his letter was not the proper judicial response. In any case, Freedman did get what he wanted, Liman did not exercise jurisdiction.

That is such a misreading of Governski’s letter that I question whether you are an actual lawyer.

Anonymous wrote:

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

Also, I am going to say this once and not argue about it for pages. Freedman interpreted the notice of intervention as an attempt to induce Liman to exercise jurisdiction, whether correctly or not, which Liman has the discretion to do. He therefore set forth why he had issued the subpoena, in case Liman decided to exercise jurisdiction and quickly ruled. For this reason, some litigators are of the view that Liman’s striking his letter was not the proper judicial response. In any case, Freedman did get what he wanted, Liman did not exercise jurisdiction.

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!

It doesn’t matter if the notice of intervention letter was appropriate or not, Freedman was still responding to it. The fact that you have argued this point incorrectly for several pages doesn’t give value, sorry, and the fact that you don’t understand this speaks volumes.

Posters stop responding to you because you repeat the same, usually incorrect, point ad nauseam, not because you have a good point.

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Anonymous wrote:I think the timing of Freedman's docket freakout last week is interesting because he know those Safe Harbor motions were filed 4/23, so he knew full well these sanctions motions were coming today. What did he do in advance of that to make himself some showy headlines, hmm? He launched his Taylor Swift show. I guess having Swift's name still in the headlines takes some of the heat from these sanction motions off him and his firm. Surely this factored into his docket sheet shenanigans calculus: You think you will try to sanction me? Wait until I accuse you of extortion of Taylor Swift!

Meanwhile, Freedman still isn't filing his own motions to compel on anything, including the subpoena. Why is that? I do not understand his reasoning there. Is he just underwater and only filing documents with actual deadlines (and sometimes not even those)?

The Taylor stuff came in response to motions filed by Gottlieb (motion to intervene in DC and letter to Liman).

Freedman *chose* to accuse Gottlieb of extortion in a letter to Liman that he signed and filed on the docket. That was an affirmative choice. Then he made another choice to sign an affidavit swearing to triple hearsay saying the same, and filing it on the docket. He wasn't forced to file these pleadings; he made an affirmative choice. That choice -- and the press furor he created through that choice, which is still being written about today perhaps as much or more as Lively's sanctions motions -- is what I'm talking about above.

My point was one he didn’t affirmatively file anything, he considered it a responsive pleading and it clearly would not have been filed absent the motion to quash.

The only thing Freedman was responding to on Liman's docket was an extremely simple and normal letter notifying the judge of related proceedings in another district. You don't file anything in response to such letters, generally -- I have seen many of them and in zero out of the dozens I've seen has anyone ever filed a letter accusing opposing counsel of extortion, lol.

Freedman choosing to see this as a "responsive" pleading was all hubris combined with his desire to deflect attention from today's sanction motions which he knew full well were coming.

This. He can file a responsive pleading on the DC docket, where the court can actually do something with it. But that would require him to actually respond to the arguments in the motion to quash and motion to intervene. Also, if it's true that he and Venable are collaborating now (I increasingly do not think this is true) they could have together filed a pleading to moot the motion to quash. If Freedman's goal was to get this evidence of this alleged threat/spoiliation, that would actually work toward accomplishing that goal.

But what Freedman was actually after was a media cycle. Which was obvious to everyone including Liman, which is why he quite rapidly did away with it.

“Arlington Mom” and “DC Mom” organically double teaming once again, amazing!

You do stuff like this whenever someone makes a point you don't like. They don't even have to be supporting Lively or attacking Baldoni. Merely pointing out "yeah so Freedman definitely submitted that letter to the court last week for PR reasons knowing the judge would strike it -- it was not a responsive pleading," which is an obvious point that anyone with even a little knowledge of how litigation works would know, immediately gets you labeled as some kind of Lively shill because it's not slavering devotion to JB or Freedman. It's so, so weird and it's the reason this thread has so little real conversation. This is an interesting case it would be fun to debate. But you have decided people are only allowed to have one opinion about anything and will regulate until that's all that's left.

It's soooooo boring.

I agree with this, but hesitate to do so since it will just entice more of the same comments!

Of course you do. Two for two. And that is the true reason there is so little real conversation. The “dynamic” duo of pretend litigators.

At least we post actual substantive analysis of the pleadings and the docket, which for me has been proven over time to be largely correct. Too bad that’s more than I can say for you true Baldoni believers but oh well. Keep trying!