Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Read the production letter, which specifically says she gave the metadata that was provided. The docs from Jonesworks were missing metadata as received. How many times do you need to be pointed back at the production letter?

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

It’s legit for her to ask for the metadata. Obviously.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Garofalo just blew through all her credibility with her misrepresentations and obfuscations in that filing. Hope the headline (which lasted a few hours before the counter-headlines of “They already have it!” took over) was worth it.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Facts have not been established yet to confirm Vanzan=Blake. So why should Liman accept that docs produced from Blake would be the same as produced from Vanzan? There’s a reason Garofalo is requesting info on Vanzan’s structure.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Read the production letter. The information is right there. They already have it.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Liman doesn’t want guesses or assumptions, only facts uncovered via discovery to the proper parties. You should know that by now.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Lively’s production letter explains that she produced the docs in exactly the same form they were received from Jones, and that as received from Jones, the docs were missing certain metadata:

“Ms. Lively’s forthcoming production contains a reproduction of documents that Ms. Lively received in response to a subpoena duces tecum to Jonesworks, LLC, dated October 1, 2024 (the 'Subpoena'), together with a copy of the Subpoena. Ms. Lively is reproducing the documents responsive to the Subpoena ('Jonesworks Documents') as she received them. For example, the Jonesworks Documents were produced to Ms. Lively without certain attachments and without the metadata contemplated in the subsequently negotiated Joint Stipulation on the Protocol for Discovery of Electronically-Stored Information and Hard Copy Documents, dated May 13, 2025 (Dkt. No. 212; 'ESI Stipulation'). While Ms. Lively’s forthcoming production reflects all metadata fields contemplated in the ESI Stipulation, certain of the fields are not populated because the Jonesworks Documents lacked corresponding metadata. And certain attachments are missing because the Jonesworks Documents did not include them."

Frankly this production letter does make it sound like there is no other version of these docs via VanZan — the docs produced by Lively in May were exactly as received by Jones. It’s right there in the letter. Not sure how much clearer that could be stated.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Blake has been asking everyone, including third parties, for the same documents.

Further, the texts produced by Lively to WF has no metadata which is weird since Jones had the phone the texts were on and allegedly was given the entire phone,

Anonymous wrote:I think the MTC would be reasonable closer to the discovery deadline — they are entitled to get the dupe docs from both parties — but the day after the ESI was entered and asking for docs it already has (so doesn’t need early on in discovery for any particular reason) without acknowledging the same is bad strategy. I think non lawyers probably don’t realize just how shady a MTC is at a point in time where the docs probably could not have been physically produced pursuant to the newly agreed ESI. I think they run the risk of annoying Liman when they could have waited just a few weeks. This has to be all about affecting the news cycle (maybe they were the ones holding out on the ESI and just agreed in order to file this, in fact) and not about the substance. Hopefully it doesn’t backfire.

Anonymous wrote:Lively has requested the same documents from probably a dozen parties, and the judge has granted her motions to compel despite that.