Wallace had already notified the court of this order on his dismissal from the NY litigation on July 16, here:

Link to filed document by BL here:

BL's notice repeats what JW's notice stated, that the dismissal was without prejudice. They add that they can refile until July 30. Her notice also cites case law alleged to support her position that lack of 'jurisdiction' of JW in NY has no bearing on whether TX has jurisdiction over her in this case.

She also describes the dismissal of the WP NY suit against her as well as the reasons for said dismissal.

Once again, the footnotes don't disappoint. Whether or not BL's previous filings requested transferring the case to a CA court, she asks for it here, in footnote 2:

"In the NY Litigation, Wallace submitted testimony that he “considered the impact of [his] work to be in California” and that he was “doing business and providing [his] services to individuals in California.” SDNY Dkt. 142-1, Dkt. 26-14 ¶ 28. In this case, Plaintiffs have admitted that the statements at issue “emanated in California.” Dkt. 29 at 11. If the court believes that personal jurisdiction and venue are proper in California, where Street was incorporated when this case began, it can transfer this case to the Central District of California sua sponte."

TAG's response to Friday's motion filed by Esra Hudson to de-designate the AEO response to Interrogatories is unopposed. TAG agreed to de-designate.

In this agreement to make their contact list public, TAG states that only ONE of the subpoenaed cc was on the Interrogatory list. In other words, TAG was responsible for only one of the more than 36 cc who are in the process of filing MTQ.

The docket is linked on the right. Attached to Fritz's declaration are three exhibits, which are unredacted subpoenas to Google, TikTok and X.

Link to Declaration of Kevin Fritz:

Link to TAG's response to Motion to De-designate AEO Interrogatories:

gov.uscourts.nysd.635782.69.0.pdf

"The Vanzan Subpoena opened the door for Lively to obtain the documents Jones extracted from Abel’s phone without notice to Abel or the Wayfarer Parties against whom Lively intended to use the information. Lively produced at least some of the information during discovery, confirming that the sham Vanzan Action was successful in facilitating the transfer of Abel’s data to Lively prior to the filing of Lively’s claims against Abel and the Wayfarer Parties. Lively’s lawyers have publicly acknowledged and defended the sham Vanzan Action and Subpoena, declaring that “There is nothing untoward here—just conscientious and thorough investigation” and characterizing the Vanzan Action and Subpoena as “common tools ... that are entirely lawful and appropriate for pursuing claims and uncovering the identity of unknown perpetrators of unlawful activities.” Garofalo Decl., ¶ 6, Ex. E, pp. 4-5. Arguing the ends should justify the means, Lively’s lawyers admitted the Vanzan Action and Subpoena enabled them to access Abel’s “text messages.” Id. at p. 5. Such tactics are hardly common or appropriate where, as here, the lawsuit is a sham, the subpoena is intended to obtain information irrelevant to the proceeding in which it issued and, most egregiously, the purpose of the Subpoena was either to obtain privileged and confidential information without notice to Abel or to cover up Jones’ prior disclosure of Abel’s confidential and privileged information to Lively before the Subpoena was even served. Abel remains in the dark as to whether Jones actually produced documents in response to the Vanzan Subpoena or whether the Vanzan Subpoena was merely a smokescreen to conceal Jones’ prior disclosure of Abel’s information – the conduct at the core of Abel’s claims.

Abel has now subpoenaed Vanzan for documents relating to the Vanzan Subpoena and release of Abel’s stolen information to Lively. Abel’s original Subpoena included eleven categories. During the meet and confer process, Abel agreed to withdraw six of the original requests (Nos. 2, 3, 5-8) and substantially narrow the remaining five requests (Nos. 1, 4 and 9-11). Garofalo Decl., ¶ 7. Vanzan has rebuffed this overture and refused to produce any of the requested documents. Id., ¶ 8. Abel now seeks an order compelling the production of documents responsive to five of the eleven requests set forth in the Subpoena. Of those five requests (request numbers 1, 4, and 9-11), Abel now moves to compel the following documents: (1) a copy of the Vanzan Subpoena served on Jones in the sham Vanzan Action (a subset of request 10); (2) the documents Jones produced in response to the Vanzan Subpoena (a subset of Subpoena request 11); (3) communications between Vanzan and Jones (and/or their respective counsel) about the Vanzan Action (a subset of request 9); (4) documents sufficient to show Vanzan’s organizational structure (request 1); and (5) documents sufficient to identify Vanzan’s shareholders (a subset of request 4)."

Declaration in Support of Motion: gov.uscourts.nysd.635782.70.0.pdf

Exhibit A (Subpoena of Vanzan): gov.uscourts.nysd.635782.70.1.pdf

Exhibit B (the Summons with complaint): gov.uscourts.nysd.635782.70.2.pdf

Exhibit C (voluntary continuance without prejudice): gov.uscourts.nysd.635782.70.3.pdf

Exhibit D (process of summons): gov.uscourts.nysd.635782.70.4.pdf

Exhibit E (Deadline article): gov.uscourts.nysd.635782.70.5.pdf

Document 27: Liner Freedman Taitelman + Cooley, LLP (“LFTC”) responds to the Court’s July 10, 2025 order to show cause “why the motion to quash should not be decided based on the joint stipulation submitted in the Central District of California”

Link:

Document 26: Jason Sunshine of Liner Freedman Taitelman + Cooley LLP, with offices located at 1801 Century Park West, 5th Floor, Los Angeles, California 90067, hereby appears on behalf of movant LINER FREEDMAN TAITELMAN + COOLEY, LLP.

Link:

Document 25: Plaintiff Blake Lively writes in response to the Court’s order to show cause issued on July 10, 2025 as to “why the motion to quash should not be decided based on the joint stipulation submitted in the Central District of California.” See ECF No. 24. Ms. Lively respectfully submits that it would be appropriate for this Court to decide the motion to quash on the basis of the joint stipulation submitted in the Central District of California, which is fully briefed and ready for this Court’s decision.

Link:

Document 24: ORDER: The parties shall show cause by 5:00 p.m. on July 14, 2025, why the motion to quash should not be decided based on the joint stipulation submitted in the Central District of California.

Link:

Filing 23: STATEMENT OF RELATEDNESS. The letter argues why the newly filed case is relevant to the current case. Filed on behalf of Ms. Lively.

Link:

Document 22: NOTICE OF APPEARANCE by Michael Gottlieb on behalf of Blake Lively.
Link: Must purchase on PACER

Document 21: CASE TRANSFERRED IN from the United States District Court - District of California Central; Case Number: 2:25-mc-00053. Original file certified copy of transfer order and docket entries received. 

Link:

Document 20: MEMORANDUM DECISION AND ORDER TRANSFERRING MOTION TO QUASH TO THE SOUTHERN DISTRICT OF NEW YORK by Magistrate Judge A. Joel Richlin transferring case to Southern District of New York.

Link:

Document 19: ORDER by Judge Michelle Williams Court: granting 17 Non-Resident Attorney Kristin Bender APPLICATION to Appear Pro Hac Vice on behalf of Respondent Blake Lively, designating Sarah Moses as local counsel. THERE IS NO PDF ASSOCIATED WITH THIS ENTRY(aus) [Transferred from California Central on 7/7/2025.

Link: Must buy on PACER

Document 18: MINUTES OF INFORMAL DISCOVERY VIDEOCONFERENCE held before Magistrate Judge A. Joel Richlin. On July 3, 2025, the Court held an informal discovery conference to discuss the pending motion to quash subpoena. After discussing the motion with the parties, the Court advised that a ruling would be forthcoming.

Link: Must buy on PACER

Document 17: APPLICATION of Non-Resident Attorney Kristin Bender to Appear Pro Hac Vice on behalf of Respondent Blake Lively (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-40014967) filed by Respondent Blake Lively. (Attachments: # 1 Proposed Order) (Moses, Sarah) [Transferred from California Central on 7/7/2025.] 

Link: Must buy on PACER

Document 16: MOTION RE: INFORMAL DISCOVERY DISPUTE - Video Conference is set for 7/3/2025 at 11:00 AM before Magistrate Judge A. Joel Richlin. [See document for details.] (san) [Transferred from California Central on 7/7/2025.] (Entered: 07/01/2025)

Link: Must buy on PACER

Document 15: UPPLEMENT to MISC - Motion Related to Subpoena from Another District, 1 filed by Movant Liner Freedman Taitelman Cooley, LLP. (Garofalo, Ellyn) [Transferred from California Central on 7/7/2025.] 
Link: Must buy PACER

Document 14: NOTICE OF LODGING filed re Deficiency in Attorney Case Opening - optional html form 4 (Attachments: # 1 Proposed Order)(Garofalo, Ellyn) [Transferred from California Central on 7/7/2025.]

Link: Must buy on PACER

Document 13: ORDER SCHEDULING INFORMAL DISCOVERY CONFERENCE BY VIDEO by Magistrate Judge A. Joel Richlin. 7 In an effort to address this dispute in the most efficient manner possible, the Court schedules an informal discovery conference by video for Thursday July 3, 2025 at 11:00 a.m. The Courtroom Deputy Clerk will email a link to the parties to join the videoconference. The purpose of the informal discovery conference is to discuss the dispute, the parties' respective positions, and possible next steps to resolve the dispute.

Link: Must buy on PACER

Document 12: Notice of Appearance or Withdrawal of Counsel: for attorney Sarah Emily Moses counsel for Respondent Blake Lively. Adding Sarah E. Moses as counsel of record for Blake Lively for the reason indicated in the G-123 Notice. Filed by Respondent Blake Lively. (Attorney Sarah Emily Moses added to party Blake Lively.

Link: Must buy on PACER

Document 11: Notice of Appearance or Withdrawal of Counsel: for attorney Stephanie Anne Roeser counsel for Respondent Blake Lively. Adding Stephanie A. Roeser as counsel of record for Blake Lively for the reason indicated in the G-123 Notice. Filed by Respondent Blake Lively.

Link: Must buy on PACER

Document 10: NOTICE of Related Case(s) filed by Respondent Blake Lively. Related Case(s): 2:25-mc-00055- WLH-SK (the Related Case), pending in the Central District of California

Link: Must buy on PACER

Document 9: NOTICE of Interested Parties filed by Respondent Blake Lively

Link: Must buy on PACER

Document 8: Notice of Pendency of Other Actions or Proceedings filed by Respondent Blake Lively. (Attachments: # 1 Exhibit A)(Hudson, Esra) 

Link: Must buy on PACER

Document 7: SUPPLEMENT to MISC - Motion Related to Subpoena from Another District, 1 filed by Respondent Blake Lively. (Attachments: # 1 Proposed Order)(Hudson, Esra)

Link: Must buy on PACER

Document 6: (IN CHAMBERS) ORDER REFERRING MOTION TO QUASH SUBPOENA (DKT. 1 ) TO MAGISTRATE JUDGE A. JOEL RICHLIN by Judge Michelle Williams Court: The Court has reviewed the matter and refers the matter to Magistrate Judge A. Joel Richlin for his determination. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (tj) TEXT ONLY ENTRY [Transferred from California Central on 7/7/2025.]

Link: Must buy on PACER

Document 5: NOTICE OF HEARING on MOTION RELATED TO A SUBPOENA FROM ANOTHER DISTRICT by Clerk of Court. Counsel is hereby notified that the MISC - Motion Related to Subpoena from Another District, 1 is set for hearing. Motion set for hearing on 7/11/2025 at 01:30 PM before Judge Michelle Williams Court. 

Link: Must buy on PACER

Document 4: NOTICE OF DEFICIENCIES in Attorney Case Opening RE: MISC - Motion Related to Subpoena from Another District, 1 . The following error(s) was found: The Proposed Order is Missing

Link: Must buy on PACER

Document 3: NOTICE OF ASSIGNMENT to District Judge Michelle Williams Court and Magistrate Judge A. Joel Richlin.

Link: Must buy on PACER

Document 2: Notice of Appearance or Withdrawal of Counsel: for attorney Esra Acikalin Hudson counsel for Respondent Blake Lively. Adding Esra A. Hudson as counsel of record for Blake Lively for the reason indicated in the G-123 Notice. Filed by Defendant Blake Lively. (Attorney Esra Acikalin Hudson added to party Blake Lively.

Link: Must buy on PACER

Document 1: MOTION RELATED TO A SUBPOENA FROM ANOTHER DISTRICT Receipt No: ACACDC-39905720 - Fee: $52, filed by Movant Liner Freedman Taitelman Cooley, LLP.

Link:

Lively’s legal team filed a motion for a protective order asking for two major things regarding her deposition set for July 17th:

1. Move where it will occur or take place

2. Force Wayfarer to disclose the identities of those who will attend

They argue this is necessary because:

Defendants have not denied that their intent is to manufacture a harassing publicity stunt by requiring Ms. Lively to parade through paparazzi, or by inviting unknown attendees to the deposition, including members of the media or social media influencers, or any other number of abusive tactics.

Defendants’ failure to acknowledge the real security and privacy risks ignores that they have engaged in retaliatory harassment that has extended into the litigation itself, including by defense counsel’s repeated and personal attempts to turn Ms. Lively’s deposition into a media event. 

Lively’s legal team cites Bryan Freedman’s numerous statements about Lively’s deposition as support for the idea that Wayfarer intend to turn Lively’s deposition into a media circus.

They also cite they have taken precautions to have the deposition done at a different location and have already made arrangements to ensure the safety of Lively and others due to the high profile nature of the case and the inherent security issues that arise as a result.

Kristin Bender’s Declaration:

Exhibit A:

Judge Liman grants the Motion to Dismiss for Jed Wallace without prejudice.

Link:

(This may be one of the last times we use this flair).

As many may have heard elsewhere, Justin Baldoni and Wayfarer - the two remaining parties with claims to replead against Blake Lively and Ryan Reynolds - declined to file a Second Amended Complaint by yesterday’s deadline. This complaint had been invited by Judge Liman to replead contract breach clauses relating to Lively’s Loan Out Agreement and to replead the intentional interference claim involving Baldoni’s WME agreement.

Based on Judge Liman’s Rules of Court, it also appears that the deadline for appealing the Order on the Motion to Dismiss also passed yesterday (at least a deadline for providing notice of intent to appeal to the court). Judge Liman may have set the deadline for both choices (amend or appeal) to the same day.

Given the fact that It Ends With Us generated over $100 million in profits for Wayfarer, and by extension its owners Sarowitz and Baldoni, it would have been extremely difficult for the parties to prove damages on these two contract breach claims. It appears that the Wayfarers will now solely focus on defending themselves against (1) damages and legal fees demands, like the one Sloane filed yesterday, and (2) Lively’s remaining and many SH, defamation, retaliation, and conspiracy claims. Discovery (what can be produced, what questions can be asked in depos) will all be scoped back accordingly.

Given all of this, Wayfarer v. Lively as a case will be CLOSED.

There will still be a lot to discuss - Jones v. Abel kicked off electronic discovery yesterday, a Judge was assigned to the case in Los Angeles to navigate discovery issues there, we will see resolution on the Motions to Compel, legal fees motions, and ultimately Motions for Summary Judgment from Lively. We might be closer to staying on Judge Liman’s trial schedule as well.

A few differnet documents were unsealed today via court order. These two documents linked below are objections and responses to Lively’s interrogatories.

TAG’s Objections and Responses:

Wayfarer’s Objections and Responses:

WP filed a motion to compel financial computations of damages incurred by BL due to retaliation over SH allegations on set. BL's attorneys filed their motion to oppose providing this information

Parties are currently filing back and forth over the Vanzan subpoena. Individual posts on each filing are already available on this sub, but we wanted to compile one master post showing all the filings so far, as well as a summary on what's happening.

These filings are happening on the Jones v. Abel docket that can be found here:

Motion to Compel

Abel filed a motion to compel Vanzan to produce the subpoena and documents produced as a result of the subpoena. These were not filed by Freedman but by Ellyn Garofalo:

Declaration in support of motion:

Exhibit A:

Exhibit B:

Exhibit C:

Exhibit D:

Exhibit E:

Responses to Motion To Compel

In response to this motion to compel, there are two responses from two separate law firms or entities. The first is from Esra Hudson, one of Lively's lawyers:

The second response is from Jon Fetterolf, a law who appears to be representing Vanzan directly:

Declaration in Opposition to Motion:

Exhibit 1:

Exhibit 2:

Summary

This isn't an exhaustive summary, but a brief synopsis of what is happening with these filings and the subpoena itself.

Abel's motion to compel suggests or implies that they have still never received the Vanzan subpoena. This subpoena has been a talking point because it was issued to Jones by Vanzan, a company associated with Reynolds and Lively, months before the CRD complaint was filed.

This subpoena led to Jones turning over text messages from Abel's phone to the Lively parties, that were then used as evidence in her CRD and her complaint in her lawsuit.

Freedman has long since suggested they have not seen this subpoena, and that it's use is not proper, ethical, or even legal. However, there is no specific law or rule of ethics that Freedman has been able to point to that would make this subpoena not valid.

Abel's request for the subpoena is being met by two responses. One from Esra Hudson, who says that they already have the subpoena and have had it for several weeks. They also produced all documents they were given by Jones. All of this was given to the Wayfarer parties on May 16th.

Vanzan is not represented by Esra Hudson, but a different legal team that filed their own response. In their response, they reiterate that Abel already has the subpoena and has had it for weeks. They also raise issues about some of Abel's additional requests, and state that they have no relevance to any claims. They also point out that Abel is seeking from Vanzan information that should not be sought from them, but from Jones since Jones is a party and Vanzan is not.

Both Hudson and Vanzan cite that Abel is using the docket for PR purposes, because they used their motion to compel to imply they don't have documents that were produced to them in May. At the end of their response, Vanzan offers to produce its articles of incorporation and written consents of the board of directors to share it's officers and stakeholders, but states Abel needs to seek any communications with Jones from Jones.

Freedman's law firm filed a motion to quash a subpoena sent to them to procure communications between the firm and media outlets.

The California judge ultimately ruled that this motion to quash would be transferred back to SDNY since the subpoena is connected to the ongoing litigation there. Part of the ruling remarks on a ruling from the California court on the motion to quash as potentially interfering with Liman's management of the case so far. They also cite there is essentially no burden on LFTC to have the motion to compel ruled on in SDNY, and that they do not even respond to Lively's transfer arguments at all.

Motion to Compel:

Judge's Ruling:

After the case against her was dismissed (June 9), Blake Lively's publicist Leslie Sloan filed a motion for attorney's fees. Wayfarer responded, and today Sloan filed her reply.

Included in this motion is an email string between Daily mail reporter James Vitushka, Brian Freedman and Melissa Nathan.

The tech platforms have a pretty strong reputation for not complying with subpoenas for user data so I’m surprised that Google may even be leaning comply unless the CC object. At first I thought their email notice may have been a template email that they send so people take it seriously, but they wouldn’t actually comply unless it was literally a life or death issue. Any lawyers have experience or perspective on this?

This post is not about whether the subpoenas are justified or evil or whatever. There’s a lot of posts about that already. Just asking about the legal circumstance.

WP were ordered to respond by 5 pm. today (Sunday) to BL's motion for a protective order regarding issues with her deposition - namely the location and the list of WP attendees.

BL wants to be deposed at her attorney's offices; WP want her deposed in their offices.

BL claimed that WP intend to turn her depo into a media circus.

WP answer BL's question regarding who will be at the depo from WP (albeit vaguely); stating that WP attorneys and maybe one or more WP will attend (in other words, no media and no content creators, as she mentioned in her motion for protective order).

WP also present information regarding the safety and security of their offices, as well as secure, private, ingress and egress.

The judge has ordered a meeting next week regarding the scheduling for this case.

Lively filed a two page letter last week to connect Jed Wallace to Nathan, Abel, and the activities of the smear campaign. This evening Jed Wallace filed his response to this letter.

Jed Wallace’s response:

Wayfarer counsel filed a Letter in response to the July 9th Motion to amend the date of discovery to July 25th. They agree to the changes.

Michael Gottlieb, Lively's attorney, filed a Letter in response to the same Motion seeking clarification that "the July 25 deadline is without prejudice to the issuance of (1) additional written party discovery until August 29, and (2) additional third-party document subpoenas until the close of fact discovery on September 30."

"The intent of this proposal was to ensure that any documents trailing behind the “substantial completion” deadline be fully produced in advance of depositions. This proposal would accomplish the aim of fully completing party document discovery except for any to-be-issued written discovery, and also is intended, as the Court acknowledged, to allow the parties to resolve document deficiencies for all such completed productions by August 1, 2025."

"September 30 as a date for production is necessary to ensure that, for requests for production, parties do not simply serve objections on September 30. To the extent parties find requests objectionable, they may serve objections in advance of September 30 to allow for sufficient time for party conferrals. In addition, to the extent that good cause arises to issue limited additional discovery based on deposition testimony between August 29 and September 30, Ms. Lively proposes that the parties seek approval to propound such discovery from the Court upon a showing of good cause."

"Ms. Lively therefore submits it would be appropriate for the Court so-order both the July 25 and August 29 dates laid out above, to require timely production of all party document discovery issued (comprising the vast majority of all party document discovery), while also allowing the parties to complete any final written discovery requests arising from the parties’ July 1 productions and with the benefit of any additional discovery that may be obtained from third parties or depositions through August 29."

"Ms. Lively respectfully submits that the Court’s July 25 deadline for third-party productions should apply to all noticed subpoenas in order to facilitate those productions, without prejudice to additional third-party document discovery through the close of fact discovery on September 30 (for which production is required 14 days after service)."

Lively's attorney stated that although Lively has been pursuing third-party documentation and had issued 60 document subpoenas, she has yet to get enough information prior to depositions.

They included this footnote specifically about Perez Hilton:

"Ms. Lively has drawn the distinction between noticed subpoenas and served subpoenas as she intends to imminently file motions for alternative service at least as to: Cynthia Barnes-Slater, Dervla Mcneice, and Perez Hilton (Mario Lavandeira). Counsel for the Wayfarer Parties “do not represent these individuals and therefore have no authority to accept service on their behaves [sic].” Declaration of Kristin E. Bender (“Bender Decl.”) ¶¶ 8, 9, Exhibit A. The Wayfarer Parties’ counsel made similar representations that they did not represent third party Matthew Mitchell—going so far as to even require this Court to rule on a motion for alternate service as to that third party. See Bender Decl. ¶¶ 3–6; see ECF No. 356. Yet after the Court issued its order approving alternative service, counsel revealed that they do represent Mr. Mitchell. Bender Decl. ¶ 6. It appears that Mr. Freedman currently represents at least Mr. Hilton (Lavandeira), yet has not responded to requests for service to be accepted on his behalf. See, e.g., Perez Hilton (@theperezhilton), INSTAGRAM, Blake Lively subpoenaed me? My response:, at 2:24 – 2:32 (July 4, 2025), (Perez Hilton: “I have not been served with anything yet. And I also have not communicated with my lawyer, Bryan Freedman, about this ….”); Perez Hilton (@theperezhilton), INSTAGRAM, I just scored a win in my legal battle against Blake Lively!!!!, at 2:30 – 2:54 (July 10, 2025), (Hilton taunting that he has not been served and will not be accounted for under this Court’s proposed schedule for July 25). If the Court wishes the July 25 deadline for third-party production to apply only for served (not merely noticed) subpoenas, Ms. Lively respectfully seeks that the Court additionally require a deadline for production of 14 days for any subpoenas that have been noticed but not yet served."

Kristin E. Bender's:

Declaration in Support (non-motion):

Exhibit A - Correspondence:

Kassidy O'Connell has outed herself as the anonymous YouTuber and has written a letter to Judge Liman threatening to take legal action as she feels her First Amendment Rights have been violated.

She attached "Exhibit A (The contents of the complaint we’re drafting against attorney Esra Hudson to the State Bar of California)"

She outlines what she feels are the problems with the subpoena and how it harms her.

She attached another "Exhibit A: (The e-mail that accompanied my copy of the subpoena that was finally delivered to me at 2:23 PM, July 14, 2025)".

"Exhibit B: (Ms. Lively’s dkt 410 page 3 stating her intentions to serve more such subpoenas)".

"Exhibit C: (A copy of my subpoena finally received on July 15, 2025 at 2:23 PM)".

"Exhibit D: (Listing Ryan Reynolds as a party though he was dismissed from the lawsuit)".

"Exhibit E: (Transcript from Andy Signore’s phone call to Manatt Phelps & Phillips, LLP)".

"Exhibit F: (File from Jones v Meta Opposing her Motion to Compel)".

"Exhibit G: (Instructions for domesticating a New York subpoena to California)".

gov.uscourts.nysd.634304.445.0.pdf

I have tried googling about this, not much success.

So if some information in a trial is designated Attorneys Eyes Only (AEO), just how do attorneys use this during a trial?

They can't ask questions that would lead to an answer from the AEO info can they if it is protected info?

Would it be where like the courtroom is emptied so only attorneys and a witness and the jury/judge can hear testimony?

Right now I am thinking of Jed Wallace's client info and any resulting findings. But I know other things in this case are also getting the AEO designation (can't remember what all right now).

After today’s hearing, Blake Lively’s deposition has been continued until July 31.

Link:

Attorney Kevin Fritz submitted a letter today to "respectfully request that the Court preliminarily seal Exhibits A, B, C, and D to the Wayfarer Parties’ Motion to Compel, filed contemporaneously herewith".

Exhibit A is Blake Lively’s Amended Initial Disclosures.

Exhibit B is Ms. Lively’s Responses and Objections to the Wayfarer Parties’ First Set of Requests for Production of Documents.

Exhibit C is Ms. Lively’s Responses and Objections to the Wayfarer Parties’ First Set of Interrogatories.

Exhibit D is Ms. Lively’s Responses and Objections to Wayfarer Studios LLC’s Fourth Set of Requests or Production Documents.

In accordance with Rule 4.b of Attachment A, the Wayfarer Parties respectfully request that the Court not rule on this letter-motion to seal for one week, so that the parties can meet and confer, and Ms. Lively may file a motion for continued sealing if she so chooses.

Link:

A week or so ago Lively filed a motion to compel against two TAG employees who had failed to turn over documents after going back and forth with their legal teams to narrow the scope of subpoenas sent tot hem.

In response to the motion to compel, a hearing was scheduled, and the motion to compel was granted as a result.

This letter from the TAG employees is asking for additional time to comply with the subpoenas. They cite delays such as engaging with the e-vendor, and setting up time to turn over documents, as well as the holiday weekend as being reasons they were are not able to comply by the court’s deadline.

In emails exchanged with Lively’s lawyers, they suggest a date of July 16th for the extension. Lively‘s lawyers said they would agree to July 14th, as Lively’s deposition is set for the 17th and they would need time to review documents the TAG employees would be turning over.

In this letter from TAG to the court, they are asking for a deadline of July 18th.

Main Document:

Declaration in Support of Motion:

Attachment 1:

Attachment 2:

So Kassidy motion filing appearing on the docket. But let’s break down what that actually means.

A docket number simply indicates that a document has been officially received and entered into the court’s record, it does not mean the judge has reviewed, approved, ruled or stamped on it.

Court clerks assign docket numbers in the order documents are filed, regardless of their content or merit. Many people confuse this administrative step with a legal victory, but judicial approval or stamp only comes when the judge issues a separate order, which will appear as its own docket entry. So while seeing a motion listed as, say, entry #445 confirms it was submitted, it doesn’t mean the court has taken any action on it or a judge has stamped it.

So with Wayfarer side no longer having any lawsuits against Lively, if she were to just drop the lawsuit, would Justin have any options?

Is there any way to say you do not want the lawsuit dropped, you want your day in court?

I am just thinking she could drop it. Blake and Ryan are going on about their lives, Wayfarer suits all gone now, Blake got her story out to everyone, she could drop it and move on. She and Ryan will be fine.

Justin also got his side of the story out there. Her accusations would still be there, he won't have had his day in court to defend against them. But Wayfarer could still carry on, do you think? I would guess Justin could just do more behind the scenes things than acting. But then any media interviewing him would always bring up the accusations and I assume he would be allowed to talk about them, he'd still be defending it in press, hanging over his head, etc.

I just think Blake and Ryan feel they have won a lot at this point, may decide to forego the stress and costs and that they will be fine, with their acting jobs and side businesses.

The Clerk’s Office has notified the Court that it has received a motion from the

anonymous owner of a certain Youtube account to quash a subpoena issued to Google seeking

information regarding that Youtube account. The motion is captioned with the case number of

this action. It was submitted anonymously by email to the pro se filing office and does not

contain information identifying the movant.

Parties in federal court generally must identify themselves by name, unless a court has

determined that the party’s interest in anonymity outweighs the public interest in disclosure and

any prejudice to the opposing party. The Court will not entertain the motion to quash unless it is

either de-anonymized or accompanied by a motion requesting leave to proceed anonymously in

this Court and explaining why the movant’s interest in anonymity outweighs the public interest

in disclosure and any prejudice to the opposing party. 

Link:

My understanding is there won’t be cameras because it’s a federal court case. I’m so curious and invested after all this that I do kinda wish it would be broadcasted, but it’s probably a good thing that it won’t be.

I’ve learned all about complaints and motions and prayers for relief yada yada, but I realized I don’t really know the basics of how actual court works beyond what I saw on Law & Order SVU lol

Are reporters allowed in the courtroom? Are transcripts released every day, or does that not happen until afterwards? Will we get those courtroom sketches of people on the stand??

One more question for the lawyerly folks while I have you, if you would be so kind. They’re doing discovery now. Can they submit anything they want that they’ve obtained through discovery as evidence? I assume the other side can object cuz they always can lol. And then will anything submitted as evidence be publicly available?

Oops, two questions 😅 sorryyyyy thank you ❤️

The motion for a protective order is denied. Judge Liman ruled that Wallace’s clients’ identities could least to information relevant to the case. Judge Liman states that if Wallace did participate in digital campaigns that have harmed the reputation of third parties, it would be “done here as Lively alleges”. If Wallace wants to protect his clients, he will have to file for an Attorney’s Eyes Only (AEO) protective order.

Link:

Another unsealed document. Exhibit A for 300. This was filed under seal but was unsealed today.

DEFENDANT’S UNOPPOSED MOTION FOR LEAVE TO FILE REPLY IN EXCESS OF 10 PAGES

Brief - Defendant's Reply in Support of Motion to Dismiss

• Venue is Wrong: Ms. Lively argues the case should not be in Texas because the key events happened elsewhere (mainly in California), and the plaintiffs’ connection to Texas is weak or recent.

• Duplicate Lawsuit: There’s already a nearly identical case (the “NY Litigation”) that was dismissed with prejudice, and the same issues are being re-argued here. Courts avoid “duplicate lawsuits.”

• No Legal Basis for Defamation: Plaintiffs didn’t clearly show what specific false statements were made or that the statements were actually defamatory.

• Protected Speech: The statements in question were made in the context of an official complaint (the CRD Complaint) and are protected under California’s legal privileges (like litigation privilege and fair report privilege).

• No Jurisdiction Over Ms. Lively: Texas courts don’t have the legal authority to judge Ms. Lively because she didn’t direct her actions toward Texas, and a prior unrelated petition doesn’t change that.

• Failure to Prove Harm: Plaintiffs did not convincingly show that Ms. Lively’s statements actually caused them reputational or financial damage.

• Request for Case Dismissal: Ms. Lively is asking the Texas court to throw out the case permanently and make plaintiffs pay her legal fees.

*The additional documents attached to this filing will be posted as a comment under this post when they are made available.

Main Doc:

Exhibit A:

DECLARATION OF MAXWELL BREED IN OPPOSITION TO BLAKE LIVELY’S MOTION TO COMPEL

Exhibit 1: Bender April 3, 2025 Email

Exhibit 2 - Bender April 18, 2025 Email

Exhibit 3 - Roeser May 6, 2025 Email

Exhibit 4 - Pohlman May 8, 2025 Email

Exhibit 5 - Bender May 20, 2025 Email

Exhibit 6 - Bender May 30, 2025 Email

Exhibit 7 - Breed June 2, 2025 Email

Exhibit 8 - Bender June 3, 2025 Email

Exhibit 9 - Breed June 3, 2025 Email

The lawyers for Katherine Case and Breanna Butler Koslow are saying that Lively's team are too broad, overly demanding, not fair to nonparties (people not directly involved in the lawsuit), and asking for a tight deadline (June 27th, 2025).

• Case and Butler Koslow worked at the PR firm during the time of interest but aren’t mentioned in the lawsuit.

• They agreed to work with Lively’s team and suggested ways to limit what documents to provide.

• There were several calls and emails between both sides to narrow down what’s needed and who would pay for the technical work to gather the documents.

They disagree about:

• How far back in time to search for documents (they suggest July 1 to December 21, 2024).

• Whether they need to search group text messages that include people already involved in the lawsuit.

• How quickly they need to provide the documents—Lively’s team wants them fast, but their lawyer says that’s unreasonable.

They're saying they were rushed, Lively's attorneys stopped negotiating and filed their court motion instead. They're asking the judge to:

• Deny Lively’s motion entirely, or at least limit it based on what was previously agreed.

• Give them a reasonable amount of time (at least 21 days) to provide documents.

• Don’t force them to search through private group texts unless truly necessary.

Another unsealed document. This one if for Lively's objections to interrogatories from Wayfarer.

Email communications between Wayfarer and Jed Wallace regarding his work and cost, as well as a W9 tax form discussion. Personal information has been redacted from this copy.

Link at right. Also, JB's cross-motion to compel, DENIED. BL's request to file a reply to JB's motion in opposition to the protective order and the cross motion to compel: GRANTED

"LEWIS J. LIMAN, United States District Judge:

Blake Lively (“Lively”) moves for leave to serve third party Matthew Mitchell (“Mitchell”) by alternative means pursuant to Federal Rules of Civil Procedure 4(e)(1), 4(e)(2), and 45, and New York Civil Practice Law and Rules 308(1)–(5). Dkt. No. 330. The motion is granted.

Mitchell was a senior Vice President at Jonesworks, Baldoni and Wayfarer’s public relations firm. Dkt. No. 331 at 1. The Wayfarer Parties have stated that he was involved in handling the public relations “crisis” Baldoni and Wayfarer faced around the time of the release of It Ends With Us. Dkt. No. 50 ¶ 232. Lively sought to serve Mitchell with a Rule 45 subpoena via a process server beginning on May 5, 2025. Dkt. No. 331 at 1. The process server attempted service at Mitchell’s last known address on eight separate occasions, at various times, by various means. Dkt. No. 332-3. Neighbors stated they were unfamiliar with Mitchell and did not know if he lived at that address. Id. Lively’s counsel attempted to call a telephone number the Wayfarer Parties provided for Mitchell, and the outgoing voicemail message indicated that the number was associated with Mitchell. Dkt. No. 332 ¶ 3.

Federal Rule of Civil Procedure 45 states that “[s]erving a subpoena requires delivering a copy to the named person.” Fed. R. Civ. P. 45(b)(1). However, courts have authorized alternative service when a party has “demonstrate[d] a prior diligent attempt to personally serve.” Kenyon v. Simon & Schuster, Inc., 2016 WL 5930265, at *3 (S.D.N.Y. Oct. 11, 2016); JPMorgan Chase Bank, N.A. v. IDW Grp., LLC, 2009 WL 1313259, at *2–3 (S.D.N.Y. May 11, 2009); Sec. & Exch. Comm’n v. Pence, 322 F.R.D. 450, 454 (S.D.N.Y. 2017). Here, the affidavit of the process server describing the eight attempts to serve Mitchell at his last known residence establishes that personal service is impracticable. Dkt. No. 332-3; see Pence, 322 F.R.D. at 454 (“Courts have ordered substituted service of subpoenas after far fewer attempts at personal service have failed.”).

Alternative service must be reasonably calculated to ensure the witness actually receives the subpoena. See Kenyon, 2016 WL 5930265, at *3; IDW Grp., 2009 WL 1313259, at *2–3 (“[T]he proposed alternative service methods are reasonably calculated to provide [the recipient] with timely notice of her obligation to appear at a deposition.”); Freeman v. Giuliani, 2024 WL 5054913, at *2 (S.D.N.Y. Dec. 10, 2024) (“[A]lternative forms of service may be used, as long as they are calculated to provide timely actual notice.” (quoting Tube City IMS, LLC v. Anza Cap. Partners, LLC, 2014 WL 6361746, at *2 (S.D.N.Y. Nov. 14, 2014))); see also In re Three Arrows Cap., Ltd., 647 B.R. 440, 450 (Bankr. S.D.N.Y. 2022) (“The Court does not find it to be controversial that Rule 4 cases applying the ‘reasonably calculated’ standard, which is a due process requirement, can be instructive in the Rule 45 context.”). Here, Lively possesses a telephone number for Mitchell, and there is evidence that it is in fact Mitchell’s number. Lively also notes that Mitchell’s publicly available LinkedIn page has been updated since his departure from Jonesworks. Dkt. No. 331 at 3. Courts have held that service via social media is a permissible form of alternative service under similar circumstances. See In re Bibox Grp. Holdings Ltd. Secs. Litig., 2020 WL 4586819, at *2 (S.D.N.Y. Aug. 10, 2020); Kumar v. Alhunaif, 2023 WL 8527671, at *5 (S.D.N.Y. Dec. 8, 2023); In re Three Arrows Cap., 647 B.R. at 456 (noting that the decision to authorize service is “informed by the fact that the [movants] included facts showing recent and actual use” of relevant accounts)."

At the same time, social media service is usually used “as a ‘backstop’ for service by other means,” such as email, mail, or publication, rather than a standalone method of service. Kumar, 2023 WL 8527671, at *5 (quoting Doe v. Hyassat, 337 F.R.D. 12, 15–16 (S.D.N.Y. 2020)). Lively states that nail-and-mail service under CPLR 308(4) is less likely to provide Mitchell with actual notice than electronic service, and the requirement to follow that provision of the CPLR would create undue delay. Dkt. No. 331 at 4. But Lively does not provide any reason why she should not, in addition to serving Mitchell by LinkedIn and notifying him of service by telephone, also affix the subpoena to the door of Mitchell’s residence and mail it to him at that residence. 1 Adding this more traditional method of service will ensure that service is “calculated to provide timely actual notice.” Tube City IMS, 2014 WL 6361746, at *2.

Accordingly, the Court directs that the following will be deemed proper service on Mitchell for the duration of this litigation:

1. Affixing the relevant document to the door of Mitchell’s last known residence;

2. Mailing the relevant document to Mitchell’s last known residence;

3. Sending a copy of the document to Mitchell via LinkedIn; and,

4. Attempting to contact Mitchell at the telephone number provided by the Wayfarer Parties and, if he does not answer, leaving a voicemail stating that he has been served with the relevant document at his residence, by mail, and by LinkedIn message.

The motion for alternative service is GRANTED as described herein.

Proof of service shall be filed in accordance with Federal Rule of Civil Procedure 45(b)(4). The Clerk of Court is respectfully directed to close Dkt. No. 330.

SO ORDERED."

Judge Liman rules on Ms. Lively/Mr. Reynold's (Lively Parties) Motion to Compel in regards to content creators. The motion is granted in part and denied in part.

Lively and Reynolds seek to compel responses to three interrogatories.

1. The first interrogatory (the “Account Interrogatory”) states:

Identify any email account from May 1, 2024 to date, in which any third party,

including but not limited to Content Creators or the media, had access for the

purpose of communicating information of any kind, including messaging, talking

points, guidelines, scripts, or other information, regarding Ms. Lively, Mr.

Reynolds, the Digital Campaign, the CRD Complaint, or the Actions. This motion is denied. The wording of the interrogatory is sufficiently specific to enable a targeted response by the Wayfarer Parties.

However, Reynolds is not entitled to responses to this interrogatory because he is not a party.

2. The second interrogatory: “Reporter Interrogatory”) states:

Identify all reporters and news or media outlets of any kind with whom You have

communicated in any manner, concerning Ms. Lively, Mr. Reynolds, the CRD

Complaint, the Actions, or the Lively/Reynolds Companies. This motion is granted. The Wayfarer Parties

have provided no justification for withholding the responses of Nathan and Abel regarding the

period between June 15, 2024, and December 21, 2024, and in fact agreed to provide such

responses. Dkt. No. 311 at 3. 

3. The third interrogatory (the “Content Creator Interrogatory”) states:

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. The motion is granted as the Content Creator Interrogatory propounded by Lively to

TAG. Defined as stated above, the interrogatory is not “hopelessly vague” or unduly

burdensome.

Link to full docket:

Ms. Lively's legal team is asking Judge Liman permission to file a short response to the Wayfarer Parties' opposition and cross-motion that they filed in response to Ms. Lively's request for a protective order. Correspondence/Exhibits are included.

Link:

Stephanie Jones opened a new docket to file motions to compel against Pinterest and Meta. This docket has several filings, but because we've been a bit behind on posting them all we decided to make a master post to share what's been happening on this docket so far. We've added the link for this docket to our sidebar, and are including it here:

Below are the major filings that have hit the docket so far.

Motion to Compel - Case Opening:

This has sixteen exhibits, please see Courtlistener link to docket above to view the attachments. The link below is just the Main Document:

Pinterest's Opposition to Motion to Compel:

Meta's Opposition to Motion to Compel:

Jones Response in Support of Motion to Compel / Brief:

This has five attachments, please see Courtlistener link to docket above to view the attachments. The link below is just for the Main Document.

Lively submitted a request to reply to Wayfarer response on the extenstion. Gottlieb calls out continued non-receipt of discovery, including film footage and non-reciept of tracking number as well as a few other issues with discovery. He also calls out that Lively is prepared to sit for depo - provided she has footage with sufficient time to review.

Interestingly, in the emails Lively teams point out they need video by 7/11 or they will not sit for Depo. Wayfarer response "accepted the proposal to move the deposition" and stated the videos would be recieved by 7/11. I'm not sure if that is intentional or not, or if it was based upon the deadline given to respond.

They also cited safety concerns for Lively and want depo held at their office, not Freedman's based upon recent unprofessional actions of Freedman (which a request for sanction has been submitted).

Edit: synopsis is not complete. Just wanted to get this up here.

Request to Reply:

Reply:

Declaration:

Emails:

Exhibit B/Request for Sanctions:

The Wayfarer Parties have responded to the Lively Parties request to amend the case management plan and schedule. Kevin Fritz writes that the Wayfarer Parties partially oppose the request to amend the case management plan and scheduling order. Fritz argues that a schedule may only be modified for good cause and with the judge's consent and that "party seeking an extension should demonstrate that it exercised diligence in conducting discovery by describing what discovery it conducted in the time period originally scheduled and that there are circumstances that were not foreseen at the time of the order sought to be modified nor the party's fault that give rise to the request for the extension." Fritz alleges that Lively and Jones have not been diligent in scheduling depositions except for TAG which was ultimately canceled. Fritz argues that the motion should be denied, except to the extent that it seeks to extend the deposition deadline to September 30, 2025.

Links:

Letter:

Declaration of Kevin Fritz:

Exhibit A (Lively Notice of Deposition):

Exhibit B (Emails re Deposition):

Exhibit C (Notice of Deposition Lively):

Exhibit D (Notice of Deposition Jones):

Blake Lively (“Lively”) moves to compel Wayfarer Studios LLC and It Ends With Us

Movie LLC (together, the “Wayfarer Entities”) to produce materials responsive to Lively’s

Fourth Set of Requests for Production. Dkt. No. 228; see Dkt. No. 239. The Wayfarer Entities

have opposed the motion. Dkt. Nos. 233, 320. The motion is denied.

This is regarding Lively's motion to review Wayfarer's documentation for the third party investigation that was conducted. Judge Liman ruled that the documents are protected under “attorney-client communications or attorney work product.” This does mean that Mr. Baldoni will not be able to use these documents in their defense. The link to the docket is below.

Link:

Hello! This is my first post on this sub. If it’s off topic or inappropriate please let me know. I want to preface that I’m not trying to spread conspiracy theories about the judge or spread misinformation. I wanted to post here instead of the other sub because I want to avoid a frenzy of attacks on the judge.

But I think the judge might have a very good working relationship with Gottleib. A lot of judges have lawyers they work well with and lawyers have preferred judges they like better. Blake’s lawyers are incredibly talented and strategic. Is it possible or a thing that lawyers are able to strategize to get a certain judge appointed to a case? Which in and of itself isn’t unethical or illegal. So not accusing Blake’s lawyers or the judge of being corrupt. Lawyers are allowed to like certain judges.

I read a comment saying that in NY federal court, the clerks assign cases to the judges and there are ways to request a certain judge, but obviously I’m not sure about that.

One thing I was curious about is if hypothetically if a lawyer could look into a judges docket to see when a good time to file a case would be to increase the chances of getting the judge assigned. Thank you!

A new docket related to this case went live today. Here is the docket:

So far it looks like the first filing that has been submitted is in relation to subpoenas sent to Freedman’s law firm by the Lively parties. These subpoenas are seeking information from the law firm concerning communications between them and content creators among other things.

Freedman is moving to quash these subpoenas, and the first filing notes a meeting on July 10th in California Court.

Main Document:

Attachment 1:

Declaration of Amir Kaltgrad:

Exhibit B:

Declaration of Kristin Bender:

Affidavit Certificate of Service:

"As an initial matter, the Motion is notable for what Abel omits from it. Abel fails to inform the Court that she abandoned the meet and confer process. Counsel for Abel and non-party Vanzan conferred regarding the Subpoena on May 27, 2025.1. See Declaration of Jon R. Fetterolf, dated June 26, 2025 (“Fetterolf Decl.”) at ¶ 5. During that conference and in a follow-up email, Vanzan highlighted its various objections to the subpoena. See Fetterolf Decl., Ex. 1 at 1-2. Nevertheless, to resolve the dispute without the Court’s involvement, Vanzan offered to produce two of the items that Abel now seeks, specifically the Doe subpoena served on Stephanie Jones in the New York litigation and the documents produced by Ms. Jones in response (Request Nos. 10 and 11).2 Vanzan confirmed this proposed solution via email on May 30, 2025 and offered to further confer. See id. Counsel for Vanzan did not receive a response to this email even though, by that time, Abel had already received production of the subpoena and responsive documents over a week before that. See ECF No. 71. Three weeks later, Abel filed the instant Motion without any notice to Vanzan, obscuring the fact that she already had the documents in her possession. 3 See Fetterolf Decl. at 7-8."

Declaration in Opposition to Motion:

Exhibit 1 - May 2025 Counsel Email Correspondence:

Exhibit 2 - May 16, 2025 Vanzan Objections and Responses to Abel Subpoena:

Attorney Kevin Fritz filed a Motion to Compel on behalf of Wayfarer Parties today. The motion requests that Ms. Lively provide a computation of her alleged damages, the theory under which she seeks damages, and the documents supporting the computation within 7 days.

Fritz argues that:

Ms. Lively must comply with Rule 26(a)(1)(A)(iii): Rule 26 requires parties to provide: “a computation of each category of damages claimed by the disclosing party--who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered.

Ms. Lively Must Respond to the Damages Interrogatory: The Damages Interrogatory, as narrowed by the Wayfarer Parties, is limited to requesting a computation of Ms. Lively’s alleged damages (Fritz Decl., ¶ 9), which complies with Local Civil Rule 33.3(a). Ms. Lively refuses to respond to the Damages Interrogatory on the grounds that the information sought is the subject of expert discovery. Ms. Lively is obligated to respond to the Damages Interrogatory based upon the information presently available to her and she can supplement her response, as appropriate, after expert discovery.

Ms. Lively Must Produce Documents Responsive to the Damages Requests: Federal Rule of Civil Procedure 26(b)(1) provides that parties “may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense. “Relevancy” under Rule 26 is to be “construed broadly to encompass any matter that bears on, or that reasonably could lead to other matter[s] that could bear on, any issue that is or may be in the case". Ms. Lively’s Amended Complaint alleges that she suffered “substantial losses in earnings, equity, and … other economic losses and also alleges that her businesses – Blake Brown, Betty Buzz and Betty Booze – have been damaged. The Wayfarer Parties’ Document Request No. 56 seeks: “All documents and communications relating to [Ms. Lively’s] claims for damages.

Link:

Abel had requested several sets of documents from Vanzan, who obtained her cellphone data through a subpeona to Stephanie Jones.

Through motions, Vanzan had already agreed to provide all the documents EXCEPT communications between Vanzan and Jones. The judge GRANTED the motion to compel these communications. The judge denied as moot the rest of the motion because Vanzan already agreed to produce them.

 (646) 453-4442 and using Conference ID# 358639322

Would love to get some lawyer opinions about this hearing. They are discussing how the time during Blake Lively's deposition will be allocated between the Wayfarer lawyers and the Wallace lawyers and how to include Wallace in the deposition in case Lively amends. They are now in recess until 6:15.

"Pursuant to the Court’s June 16, 2025 Order, we write on behalf of Plaintiff Blake Lively and Defendant Ryan Reynolds (the “Lively-Reynolds Parties”) to advise the Court as to whether the Wayfarer Parties’ supplemental interrogatory responses render any portion of Plaintiffs’ pending Motion to Compel (ECF No. 295) (the “Motion”) moot. The short answer is “no.”

On June 13, 2025, certain of the Wayfarer Parties1 (The Agency Group PR LLC (“TAG”), It Ends With Us Movie LLC (“IEWU LLC”), Justin Baldoni, Steve Sarowitz, Jamey Heath, and Wayfarer Studio LLC (“Wayfarer”)) served supplemental interrogatory responses (collectively, the “Supplemental Responses”). Those Supplemental Responses, however, do not resolve the Motion. As a preliminary matter, Defendants Jennifer Abel and Melissa Nathan failed to serve any supplemental responses to any of the interrogatories at issue, and, as such, the Motion remains wholly unresolved as to each of them. The interrogatories at issue are directed at the alleged media and social media retaliation campaign against Ms. Lively and her family. As such, the responses of Ms. Abel and Ms. Nathan—whose texts to each other are among the key evidence supporting the allegations regarding that claim2 —regarding which reporters and “Content Creators” they have communicated with are plainly relevant and critical evidence in the case.

The Supplemental Responses also fail to resolve the Motion as to TAG, IEWU LLC, Mr. Baldoni, Mr. Sarowitz, Mr. Heath, and Wayfarer for the following reasons:

Email Accounts Provided to Third Parties: The Motion seeks that this Court compel each Wayfarer Defendant (other than IEWU) to identify all email accounts (since May 1, 2024) that were made accessible to third parties—such as through login credentials, shared folder access, or any other means of access—for purposes of communicating about Ms. Lively, Mr. Reynolds, the CRD Complaint, or the Digital Campaign. In their Opposition, the Wayfarer Parties agreed to respond only as to TAG, and only as to a specific type of access, i.e., providing third parties with “login credentials” to such email accounts. The Wayfarer Parties then said they “never engaged in [the] alleged clandestine communications.” ECF No. 311.

Consistent with their representation, only TAG supplemented its response to this interrogatory with a one-word answer that did not identify any email accounts. There are two problems with this response. First, TAG’s response does not clarify whether it includes all email accounts as to which it provided any form of “access” to third parties, or if it includes only email accounts in which it provided “login credentials” to third parties. Based on the Opposition, it appears that the response is only as to “login credentials,” which is the Wayfarer Parties’ unilaterally imposed interpretation and is not sufficient for all of the reasons set forth in the Motion. Second, the other Wayfarer Parties—Mr. Baldoni, Ms. Nathan, Ms. Abel, Mr. Heath, Mr. Sarowitz, and Wayfarer—have failed to supplement the response to this interrogatory at all. These parties appear to be withholding responses as moot based on the Court’s dismissal of the Wayfarer Parties’ claims asserted against Mr. Reynolds in this action because Mr. Reynolds propounded this interrogatory to the parties other than TAG (which Ms. Lively propounded). However, because the Wayfarer Parties and their counsel have publicly indicated an intent to amend their claims as to Mr. Reynolds on June 23, 3 this discovery remains relevant and essential. Thus, the Lively-Parties continue to seek full, complete, and unambiguous responses to this interrogatory by all parties upon whom it was propounded. (Lively Interrogatory No. 3 as to TAG; Reynolds Interrogatory No. 2 as to Abel, and Nathan, and No. 3 as to Baldoni, Heath, Sarowitz and Wayfarer).

Reporter Communications: The Motion also remains unresolved as to the interrogatory seeking the identities of reporters and media outlets with whom the Wayfarer Parties have communicated about Ms. Lively, Mr. Reynolds, the CRD Complaint, the Consolidated Action, or the Lively/Reynolds Companies. Most notably, as stated above, the two individuals charged with communicating with the press, Ms. Abel and Ms. Nathan, failed to supplement this request at all. While the remaining Wayfarer Parties did supplement their responses to this interrogatory, they unilaterally narrowed the time frame to June 15, 2024 through December 21, 2024. As Ms. Lively alleges that the Wayfarer Parties’ retaliatory smear campaign is ongoing, such narrowing is inappropriate for all of the reasons set forth in the Motion. Indeed, as set forth in the Motion, Ms. Lively has sued the Wayfarer Parties for defamation based primarily on statements made after December 21, 2024. See ECF No. 84. Further, some of the supplemental responses are inexplicably vague in identifying reporters, such as including only the initial for the last name of reporters that appear to be well known to the Wayfarer Parties. There is no reason for any of the Wayfarer Parties to leave it to the Lively-Reynolds Parties to guess as to the full name of specific reporters with whom the Wayfarer Parties were in direct communication. All responses should be full and complete. (Lively Interrogatory No. 1 as to Baldoni, Heath, Sarowitz, IEWU, Wayfarer, and No. 6 as to TAG; Reynolds Interrogatory No. 5 as to Abel and Nathan).4

Content Creators: Finally, the Motion remains unresolved as to the interrogatories seeking the identities of content creators with whom the Wayfarer Parties have communicated regarding Ms. Lively, Mr. Reynolds, or the subject matter of this action. None of the Wayfarer Parties served any supplemental responses at all in response to this interrogatory. (Lively Interrogatory No. 5 as to TAG; Reynolds Interrogatory No. 4 as to Abel, Nathan and Sarowitz, No. 5 as to Heath and Wayfarer, and No. 6 as to Baldoni).

For the reasons set forth in the Motion, the Lively-Reynolds’ Parties respectfully request that the Court grant the Motion in its entirety. We remain available should the Court require any additional information."

*Significant footnote in filing: "1 The Wayfarer Parties served the following supplemental interrogatory responses, which are attached as follows: The Agency Group PR LLC’s Supp. Responses (Ex. 1), It Ends With Us Movie LLC’s Supp. Responses (Ex. 2), Justin Baldoni’s Supp. Responses (Ex. 3), Steve Sarowitz’s Supp. Responses (Ex. 4), Jamey Heath’s Supp. Responses (Ex. 5), and Wayfarer Studio LLC’s Supp. Responses (Ex. 6). Based on their confidential designation, the foregoing exhibits are being filed under seal. 2 As the Court noted in the ruling on Ms. Lively’s Motion to Dismiss: “The CRD complaint and Article contain numerous messages and documents strongly suggesting the Wayfarer Parties did spread negative stories about Lively. Specifically, Abel stated to Nathan that Baldoni ‘wants to feel like she can be buried,’ Nathan responded ‘we can’t send over the work we will or could do because that could get us in a lot of trouble,’ and Nathan provided a ‘Scenario Planning’ document to Baldoni and Wayfarer that included negative statements about Lively as ‘Key Messaging Points.’ Dkt. Nos. 107-1, 106-7. Subsequently, Abel texted Nathan ‘we need to put the social combat plan into motion,’ and Nathan responded to Abel’s text about ‘wanting to plant pieces . . . of how horrible Blake is to work with’ by stating that she had already spoken to an editor at the Daily Mail. Dkt. No. 107-1 at 8. Baldoni texted Abel a social media threat accusing a celebrity of bullying behavior and said ‘[t]his is what we would need,’ texted Nathan and Abel about ‘flipping the narrative’ on Reynolds by ‘using their own words against them,’ Dkt. No. 107-5 ¶¶ 169–170, and circulated a negative TikTok to which a member of Nathan’s team responded that she would ‘let digital know,’ id. ¶ 150. Text messages referenced ‘a shift on social, due largely to Jed and his team’s efforts to shift the narrative towards shining a spotlight on Blake and Ryan,’ Dkt. No. 50 ¶ 286, and ‘boost[ing]’ content that was critical of Lively, Dkt. No. 107-2 at 03:17. In addition, a report from a brand marketing consultant concluded Lively had likely been the target of a ‘multichannel online attack.’ Dkt. No. 107-1 at 12. The Wayfarer Parties’ statements regarding sending negative content to ‘digital’ and Wallace’s attempts to ‘shin[e] a spotlight on Blake and Ryan’ are inexplicable unless the Wayfarer Parties were spreading negative content about Lively, and this impression is reinforced by messages from Baldoni, Abel, and Nathan suggesting this strategy. It is fair to presume that the Wayfarer Parties did what they said that they planned to do. Cf. Mut. Life Ins. Co. of N.Y. v. Hillmon, 145 U.S. 285, 296 (1892); Fed. R. Evid. 803 advisory committee note (1973) (“The rule of Mutual Life Ins. Co. v. Hillmon, allowing evidence of intention as tending to prove the doing of the act intended, is, of course, left undisturbed.”). Those messages are what is contained in the Article and referenced in the Video. A reader of those messages would have little doubt that the Wayfarer Parties engaged in a smear campaign.” ECF No. 296 at 115. 3 Justin Baldoni Lawyer Bryan Freedman Rips Blake Lively For 'False Victory Tour', TMZ (June 10, 2025), (at 1:42–2:45)."

"We represent Defendants Jed Wallace and Street Relations, Inc. Under Local Rule 7.1(e) and the Court’s Individual Practices in Civil Cases 1.C, we write to request the Court allow to keep under seal one exhibit to Ms. Lively’s Response (Dkt. 300) and Lively to file a minimally redacted copy of Exhibit B (Dkt. 301-2). The exhibit contains Mr. Wallace’s cell phone number, which is the only information Wallace and Street propose be redacted. A copy of the proposed redaction is attached. This letter motion is unopposed. See Liman Individual Practices 1.C ¶3."

"On behalf of Blake Lively, we write pursuant to Rule 4.b of Attachment A to Your Honor’s Individual Rules to respectfully request that the Court preliminarily seal Exhibits 1 through 6 to Plaintiff Blake Lively and Defendant Ryan Reynolds (the “Lively-Reynolds Parties”) Letter pursuant to the Court’s June 16, 2025 Order, filed contemporaneously herewith. Exhibits 1 through 6 are supplemental interrogatory responses produced by the Wayfarer Parties, which the Wayfarer Parties designated as confidential. In accordance with Rule 4.b of Attachment A, Ms. Lively respectfully requests that the Court not rule on this letter-motion to seal for one week, so that the parties have the opportunity to meet and confer, and the Wayfarer Parties may file a motion for continued sealing if they so choose."

The judge has not yet ruled on the Wallace mption, and requested Lively's team to file a letter addressing the issue of how Wallace is connected to New York.

Lively's team responded today with a two page letter arguing Wallace worked with several individuals based in New York and was a co-conspirator.

"Dear Judge Liman:

As counsel for Wayfarer Studios LLC (“Wayfarer”) and the Wayfarer Third Parties, we submit the following in accordance with the Court’s Order directing a response to Plaintiff Blake Lively’s (“Lively”) June 11th letter (Dkt. 316) demanding immediate compliance with nine (9) third-party subpoenas issued to the Wayfarer Third Parties. (Dkt. 319).

Lively’s letter misrepresents the significant compliance efforts by the Wayfarer Third Parties, who are diligently working to satisfy their discovery obligations. The subpoenas seek a broad range of documents and communications from both professional and personal sources, sometimes covering a period of several years, and numerous topics. Complying with these demands requires a thorough and time-consuming collection and review process across nine (9) custodians, as we have clearly communicated to Lively’s counsel. The Wayfarer Third Parties have not evaded their obligations and are actively working to complete their production. Although we have made good-faith efforts to cooperate with Lively’s counsel, she nonetheless filed her motion, which is unwarranted given the meaningful progress made. 1

As repeatedly discussed with Lively’s counsel—and in the interest of efficiency and minimizing burden and expense—Wayfarer agreed to collect and produce documents on behalf of the Wayfarer Third Parties to the extent those materials are within Wayfarer’s possession, custody, or control. This approach was expressly communicated to Lively’s counsel and never met with objection. To date, Wayfarer has made multiple productions, including email and otherprofessional materials for the subpoenaed custodians. A substantial volume of data has been collected from Wayfarer’s servers, databases, and other repositories, and is being reviewed and produced on a rolling basis, a process that has already begun. We expect to complete production by the July 1, 2025, substantial completion date.

Regarding materials solely within the possession, custody, or control of the Wayfarer Third Parties, all relevant personal devices of the subpoenaed individuals have been forensically collected, where applicable. These substantial data sets are currently undergoing priority review and will be produced, where available, in accordance with the ESI stipulation at Dkt. 212. We expect to complete these productions by June 27, 2025, and in any event no later than July 1, 2025.

Notwithstanding these substantial efforts, Lively continues to seek court intervention, demanding immediate compliance without regard for the realities of the discovery process or the significant progress already made. Court involvement at this stage is unnecessary, particularly in light of the parties’ ongoing communications and the clear record of compliance by Wayfarer and the Wayfarer Third Parties.

For these reasons, and those set forth in the opposition at Dkt. 215, Wayfarer and the Wayfarer Third Parties respectfully request that the Court deny Lively’s motion."

Both filed notice of appearance yesterday in Jones v Abel. Both represent SJ and both were admitted to appear months ago. So, what are they about to do?

Google Umhofer and you'll find an extremely successful career, and much of his success resulted in getting criminal claims mitigated.

Lively's team filed a protective order regarding communications between Lively and Taylor Swift that Wayfarer has continued to ask for.

"Pursuant to Rules 1.C and 4.C of the Court’s Individual Rules and Practices and Federal Rule of Civil Procedure (“Rule”) 26, Blake Lively1 respectfully submits this letter motion for a protective order regarding the Wayfarer Parties’ continuing demands for Ms. Lively’s communications with Taylor Swift (made again yesterday), which they have pursued at the same time they have refused to produce to Ms. Lively the documents they publicly claimed to have received as part of a deal to withdraw their subpoenas to Ms. Swift and her counsel. Good cause exists for this request because it has been the Wayfarer Parties’ tactic since August 2024 to make Ms. Swift and her fan base central to their media strategy against Ms. Lively, which they documented in both their communications and “Scenario Planning Document.” See ECF Nos. 84 ¶ 214, 84-4 at 4. Ms. Swift is not central to Ms. Lively’s claims (unlike dozens of other witnesses she identified who the Wayfarer Parties have largely ignored), and is otherwise irrelevant to the Wayfarer Parties’ claims, which were dismissed on June 9. The Wayfarer Parties should not be permitted to withhold documents from Ms. Lively while demanding her communications with Ms. Swift. Because of this, and because their continued focus on Ms. Swift is a media strategy, not a litigation strategy, Ms. Lively respectfully requests that she be relieved from producing documents responsive to requests numbered 108-109 in the Request for Production served by the Wayfarer Parties on February 21, 2025 (“RFPs 108-109”, Ex. A),2 seeking “all documents and communications relating to and/or reflecting” Ms. Lively’s communications with Taylor Swift “relating to the Film” or “the Action.'"

Lively's team asks to Seal Exhibit A, which is correspondence from Wayfarer marked as "confidential".

I reviewed BL's First Amended Complaint - #84 on the docket. There are 15 Causes of Action. Causes of Action Nine and Ten are in negotiations for dismissal. Of the other 13, I've listed them below, along with the paragraphs that describe the nature of the damages BL has suffered. One paragraph regarding damages is repeated in several causes of action; the ones that differ are listed below by number.

Causes of Action: One, Two, Four, Five, Six, Eight, Nine and Fifteen

Ms. Lively has suffered, and continues to suffer, substantial damages including, but not limited to, severe emotional distress and pain, humiliation, embarrassment, belittlement, frustration, and mental anguish, and is entitled to an award of punitive damages, in an amount to be determined at trial.

THIRD COA (Sexual Harassment in Violation of FEHA – Cal. Gov. Code, § 12940)

Defendants’ unlawful conduct was a substantial factor in causing Ms. Lively to suffer and continue to suffer substantial losses in earnings, equity, and other employment benefits and has incurred other economic losses. See ¶¶ 328–354. 382. Defendants’ unlawful conduct was also a substantial factor in causing Ms. Lively to suffer emotional distress, shame, and embarrassment all to Ms. Lively’s damage in an amount to be proven at time of trial. See ¶¶ 328–354.

SEVENTH COA (Aiding and Abetting Harassment and Retaliation in Violation of the FEHA – Cal. Gov. Code, § 12940(i))

As a direct and proximate result of Defendants’ unlawful discriminatory conduct in violation of FEHA, Plaintiff has suffered, and continues to suffer, harm for which she is entitled to an award of monetary damages, liquidated damages, interest, and other relief.

TWELFTH COA (False Light Invasion of Privacy – California Const., Art. I, § 1)

Ms. Lively sustained harm, including to her business and profession, as well as her reputation. Further, Ms. Lively has suffered, and continues to suffer, from grief and anxiety as a result of the near-overnight change in public sentiment regarding her reputation, work, and brands. As a further direct and proximate result of the said disclosures, Ms. Lively has suffered loss of income and interference with future income.

THIRTEENTH COA (Sexual Harassment in Violation of California Civil Code – Civ. Code, § 51.9)

Ms. Lively has suffered and continues to suffer substantial damages, including, but not limited to, past and future losses in earnings, equity, and other employment benefits and has incurred other economic losses. 458. Ms. Lively has suffered emotional distress, humiliation, shame, and embarrassment all to the [sic] Ms. Lively’s damage in an amount to be proven at time of trial.

FOURTEENTH COA (Defamation/Defamation Per Se)

Ms. Lively has suffered significant general, actual, consequential, and special damages including, without limitation, impairment of reputation and standing in the community and in her profession, personal humiliation, mental anguish and suffering, emotional distress, stress, anxiety, lost earnings, and other pecuniary loss.

The ones I listed separately claim damages over and above the damages caused by emotional distress etc. Did Liman's ruling, specifically as written, deny BL the right to these claims as well? Is there a legal way to distinguish 'mental anguish and suffering' from emotional distress?

Lively's Counsel filed a LETTER MOTION to Compel Katherine Case and Breanna Butler Koslow to produce all relevant, non-privileged materials in response to the Subpoenas.

"Ms. Case is a former and Ms. Koslow is a current employee of The Agency Group PR LLC (“TAG”)—the crisis public relations firm that is alleged to have help launch a retaliatory social manipulation campaign to “destroy” and “bur[y]” Ms. Lively on behalf of Mr. Baldoni, Mr. Heath, and Wayfarer Studios, LLC (with the other Defendants in the Lively Action, the “Wayfarer Parties”). ECF No. 84 ¶¶ 29–37. Ms. Case and Ms. Koslow accepted service of the Subpoenas through counsel on March 3, 2025. Ex. C at 21. The nearly identical Subpoenas had a compliance date of March 20, 2025, and contained thirteen requests for productions (“Requests”) seeking Ms. Case and Ms. Koslow’s documents and communications from May 1, 2024, through present regarding Ms. Lively, Mr. Reynolds, the various Defendants, the digital campaign, and limited phone records. See Exs. A, B. On March 17, 2025, Ms. Case and Ms. Koslow served their responses and objections (“R&Os”) to the Subpoenas. See Bender Decl. ¶ 4, Exs. D, E.

Counsel for Ms. Lively engaged in a lengthy conferral process with counsel for Ms. Case and Ms. Koslow that began on March 25, 2025, and continued through June 3, 2025. See Bender Decl. ¶¶ 3–15, Ex. C. Over that period, Ms. Lively proposed numerous accommodations to satisfy concerns with any perceived burden and to facilitate prompt production. Specifically, Ms. Lively offered to modify the Requests—to exclude requested communications with certain parties, including Baldoni, Heath, Sarowitz, and Abel, based on a mutual understanding that Ms. Lively would receive the documents directly from the Wayfarer Parties (while reserving rights to later seek them), which has not turned to be the case—and to cover the costs of collecting and hosting data to facilitate production. See Ex. C at 7. In June, when the parties appeared to finally be nearing agreement, counsel for Ms. Case and Ms. Koslow raised objections for the first time to the relevant time period, and asserted a new position as to the Requests. See id. at 1. These late-breaking objections made clear that negotiated compliance would be impossible."

DECLARATION OF KRISTIN E. BENDER IN SUPPORT OF BLAKE LIVELY’S MOTION TO COMPEL:

Exhibit A:

The parties shall show cause by 5:00 p.m. on July 11, 2025, why the Court should not issue an order as follows:

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.

Lively's council will get their request unless Wayfarer council provide a compelling reason to the judge.

I saw this after it started and couldn't join. Anyone here know the topic and able to provide a run down?

Wayfarer hired a third party investigator to conduct an HR investigation in January of 2025. Lively’s team is seeking information related to that investigation, and filed a Motion to Compel.

Wayfarer was requested by the court to respond with a letter today:

Exhibit A:

Exhibit B:

This morning, Judge Liman granted the motion for extension of time for Case and Koslow. Michael Gottlieb submitted a letter yesterday stating that Ms. Lively does not oppose the request for an extension until July 18th with the understanding that all documents that can be produced by July 17th will be produced. "As of this evening, following a meet and confer this afternoon, counsel for Ms. Case and Ms. Koslow have agreed to interim or rolling production(s) prior to July 17, in keeping with their earlier offer...With the understanding that all documents that can feasibly be produced in good faith in advance of July 17 will be produced, Ms. Lively does not oppose Ms. Case and Ms. Koslow’s request for an extension to July 18 for Ms. Case and Ms. Koslow to produce the remainder of documents.

Judge Liman's ruling: Case and Koslow shall make interim or rolling productions prior to July 17, 2025, and shall produce all documents that can feasibly be produced in good faith in advance of July 17, but may produce the remainder of the documents by July 18, 2025. 

Letter from Gottlieb with Judge Liman's ruling:

Original Letter for Motion for Extension of Time for Case & Koslow:

EDIT TO ADD: What date IS being referenced here? Aug 9 was the 'official' premiere. There was a 'showing' at Book Bonanza in June; and apparently 'pre-premiere' showings that are called 'premieres' in press coverage. END EDIT

This 'thought experiment' is based on Blake Lively's sworn statement(s). As far as I can tell, the only filing so far that contains sworn statements by BL is the Rule 202 petition filed in Hays County TX district court, here:

I've reviewed this filing; some paragraphs start with 'on information and belief'. In Texas you can find thousands of people who, on information and belief, claim the Marfa lights are UFOs (UAPs). Therefore, I am only relying on statements presented as fact in this verified (ie sworn) petition.

Paragraph 9: "Starting on the day the Film was released in August 2024, Ms. Lively suddenly became the focus of vitriol and negative commentary on social media and in the press." [emphasis mine]

[Google says that day was August 9, 2024.]

Paragraph 10: "Ms. Lively later learned that the negative public sentiment that was suddenly unleashed against her was the direct and intended result of an intentionally seeded "social media manipulation," "social media mitigation," and "social combat," and public relations scheme that was planned, implemented and funded by Mr. Baldoni, Mr. Heath, Mr. Steve Sarowitz - (Wayfarer's co-founder), and Wayfarer as unlawful retaliation against Ms. Lively for raising concerns about harassing conduct on-set and in violation of multiple contractual agreements, including the Rider non-disparagement provision."[again emphasis mine]

I've heard several different start dates for the smear campaign; the most popular one I've seen times the 'smear campaign' as beginning during pre-release promotions. This sworn statement narrows it down to an exact date, August 9.

Has anyone looked into exactly what changed on August 9? Again, this statement is sworn and specific; by giving an exact date, it tacitly ignores/disregards any negative media prior to August 9. Did the press coverage change after August 9?

Leave to file 2 page letter

Letter outlining that Wayfarer's council are trying to make it look like Lively is not wanting to sit for her deposition, but confirming Lively has not made a request to delay.

Wayfarer have sent incomplete video footage, some harddrives have still not been received and there is no sound included in the footage.

Wayfarer have still failed to produce all communications that they included in their lawsuit and time line A.

Limited prodcution of communications from all parties.

Wayfarer are refusing to allow Livelys deposition to take place at her legal councils office.

Exhibit A - Email chain where council for Livelys lawyers make clear that deposition would go ahead if production was received by 11th July. Wayfarer agree to produce footage by July 11th as requested so that the deposition for Lively can go ahead on the 17th, but inexplicably state that they agree to a postponement of Lively's deposition which was not requested.

Declaration of Kristin E. Bender

Exhibit B - Vin Diesel MTC to sit for Deposition, Showing Bryan Freedman's alleged recent hostile actions during a deposition and also Freedman's law firm insisting for Vin Diesel's safety that his deposition be taken at their law firms offices.

On May 9th, the Lively parties filed a Motion to Compel the Wayfarer parties to turn over documents in response to subpoenas sent to them during the discovery process:

Judge Liman requested the Lively parties inform the court on June 11th whether or not Wayfarer had complied with these subpoenas.

They filed this letter in response to the court:

From the letter:

The issues raised in Ms. Lively’s motion to compel remain outstanding. Ms. Lively served subpoenas on the Wayfarer Third Parties in early March, and agreed to extend the original compliance dates for each of the Wayfarer Third Parties into mid-April. See Dkt. No. 200, at 1. As of this writing, seven weeks after the latest of those extended compliance deadlines, none of the Wayfarer Third Parties—all of whom are represented by counsel for Wayfarer Studios LLC—has produced a single document from his or her individual possession, custody, or control.

In other words, Wayfarer has still not produced any of the requested document, even though in their original response to the motion to compel, they stated they would participate in rolling discovery by the end of the month of May.

The Lively parties asked for the Judge to rule on their Motion to Compel.

I am mostly just guessing off of my basic knowledge, but I do not have a crystal ball into the future or the judge's thoughts on these issues, so if I am wrong, we will see. I am also going off of the fact the judge doesn't seem scared to dismiss in the slightest. I am solely talking about a MTD so we are assuming these allegations are true as alleged. I do not know the facts or evidence supporting any of these claims. This is just after skimming through. Want to know your prediction

Abel

Indemnification - This goes in favor of Abel with fairly high confidence. It doesn't seem Abel acted outside of her role as a publicist for the claims Lively has against her. It seems shady, but there is nothing here that indicates that Jones explicitly told her not to engage in this/that this was not standard crisis PR. She does not have any personal relationship that would cause her to hate Lively personally. She seems to have been doing her job. All the activity alleged in Lively's complaint seem like normal things for a PR agent to do in a crisis. And if not, it's still a fact issue that needs more discovery. Stephanie alleges she was also trying to leave the company and steal confidential information, but that is not what Abel is in court for with Lively.

Invasion of Privacy - It seems that Jones was showing her personal communications to her coworkers. There is that one text from her coworker that seems to back that up.

California Penal Code § 502 (Unauthorized Access to Computer Data) - Abel may edge out if California law applies. This is a close call. This covers unauthorized access to data, including on employer devices.

The rest - These go in favor of Joneswork. The SCA possibly survives but very shaky if it does. They don't allege she logged into her iCloud. It seems like she never logged out her iCloud, which doesn't really constitute hacking, and just handing over the phone will be argued as implied access. There is also no intent to defraud as is the case for some of these. I honestly think the SCA needs for her to have said she logged in after she left. They just do not clearly do that. They said they "hacked" but they don't say how. The reason they wanted to get the subpoena to Edgeworth is to see if Jones asked them to download all contents of Abel's phone including logged in personal accounts or if it just happened that while downloading phone contents, they downloaded even personal data. It'll be necessary to get that to bring these claims.

A claim they didn't include but I would have added/considered is Misappropriation of Confidential Information and Breach of Duty of Loyalty for Abel. If she is alleging her communication was stolen to give to Lively so that she could publish this expose article. It stands to reason that she did that to damage her job prospects/ability to get clients. Think it was a missed opportunity in my opinion and was better than some of the other claims added. Unfair Competition would have also made sense here.

Wayfarer

Breach of Contract - This goes in favor of Wayfarer. Definitely will survive because of the language of the contract that they shouldn't share confidential information.

Defamation Per Se - This goes in favor of Jonesworks. They don't allege what was said, but what they think she said and the judge seems no nonsense on defamation.

What I would have added/considered:

Misappropriation of Confidential Information seems apt here too. Don't know why they don't allege it.

Breach of Fiduciary Duty/Loyalty: She owed them a duty as a publicist not to spread their personal information. Think it would have been helpful to clear up the "confidential" issue. It is a claim of "i should trust you as a publicist"

Wallace

I think he could win his MTD on juridstictional grounds, and if so, all Lively's claims will also be moot since I think that all the remaining claims she has filed against him are all California claims, but someone fact check me on that. The reason being none of the harm happened in California, neither of them live there, and he didn't sign any contract that tied him to California. I think the claims rely on him knowing about the harrassment which they don't allege

It's a really close call but I think he might be going back to Texas, or at the least, New York. I think the judge will wait a while to rule on his though since it seems fragmented discovery is a big concern of his.