🚨I FILE A MOTION TO QUASH A REQUEST FOR PROTECTIVE ORDER IN THE BLAKE LIVELY SAGA🚨

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1. First, I'm going to address this person (who is still getting his false information from a fake LinkedIn profile which has already been confirmed as something that my ex set up (amongst multiple other fake profiles across various platforms nearly a decade ago).

To be clear, NOTHING about my filing was written in any professional capacity whatsoever.

I wrote pro se, from my perspective of someone who has experienced severe, long-term domestic abuse, and someone who felt let down by the way Blake Lively chose to market a film that was intended to help others like me.

I helped others with their filings as a friend, not in any professional capacity.

I'm aware of Brett's own experience and do respect him for speaking openly about it. Not enough men feel that they can and he could really do some good here. However, he appears to be too occupied tearing people like me down when we share our own experiences.

He misrepresents himself as an advocate for women who have experienced trauma at the hands of men - but its appears that he only advocates for women who say the right words and have the right thoughts.

When I advocate for myself and help others to find the strength and words to advocate for themselves (many whom are also DV survivors), it's disappointing to see that he is still focussing on misinformation and hate.

People like this do not represent survivors of domestic violence when then are ignoring the voices of victims they don't agree with.

Finally, I don't need to prove myself to anyone. The skill in my filing, and others, speaks for itself. 2. READ THE FOOTNOTES TOO!

💛I point out that there was a typo in my name on the subpoena request but, in compliance with the Substantial Compliance Test under FRCP 45, I already know that this does not render the subpoena invalid.

The fact that it was not properly served also does provide any assurances as Vanzan was not properly served and I do cover the ongoing effect of that abuse of process further on.

🩷I refer to my concern that contact with Manatt are evasive and misrepresented. I refer to the call @andysignore made and the misrepresentation Esra Hudson made that Andy had committed crime, before clarifying the legal position with some case law to debunk that allegation.

🧡I give notice that I will be arguing both the UK and US law. The UK law is for my benefit but the US law is to make the case to try and have all the social media subpoenas quashed.

🚨STEPHANIE JONES' MOTION TO DISMISS AGAINST WAYFARER'S AMENDED COUNTERCLAIM🚨

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1. I'm just going to do a really short thread here because much of it is the same as previous claims/motions to dismiss/Abel's

There's a few interesting points that I'll add relevant pages for.

The biggest think that struck me is how aggressively Jones is arguing the sexual harassment and smear campaign claims. She's arguing them harder than even Lively.

I know Jones has to because without the sexual harassment and retaliation, she doesn't have a leg to stand on (not that I'm suggesting she particularly does anyway). 2. Lots of delusional chatter from Jones about the subpoena. She still thinks everyone has now agreed that it was a lawful" subpoena.

That's not what I read in the amended counterclaims and I am rather concerned that she is so obviously misleading what Wayfarer (and Abel) said about the subpoena given they only just found out about it.

I am firmly convinced that it was Jones who leaked the subpoena given she is making comments such as, "...after months of cries of phantom subpoenas...". I see no benefit for the Lively's to have leaked it.

I question the rather specific wording Jones makes about giving Wayfarer notice of the subpoena. Whilst she's right that contract does not state she will notify Wayfarer, you'd think she would to further cover herself. I did a separate post on another thought I had: x.com/kiarajade2001/…

Jones then makes a bizarre claim that Wayfarer never state what the confidential information is that she is supposed to have leaked. Under her own agreement, all information about a client is considered "confidential". So if discovery shows she has leaked any (and she has because the subpoena request was so specific) then she has improperly disclosed confidential information.

🚨STEPHANIE JONES MOTION TO DISMISS AGAINST JEN ABEL'S AMENDED COUNTERCLAIM🚨

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1. I will go through Baldoni/Wayfarer's separately and do a separate thread following the same layout as this one.

I have added relevant pages only. The whole filing can be seen here soon: courtlistener.com/docket/6958176… 2. Jones hits the ground running and immediately raises the point that Abel had abandoned numerous claims, including the false imprisonment claim. This is true and fair for Jones to cite to bolster her assertion that Abel's claims are unreliable.

Jones then takes a shot at the new claims Abel makes in her amended counterclaim.

We get mentions of the "subpoena" but there's no pushback surround the assertion that Wayfarer makes about the sham lawsuit used to obtain it. In fact, Jones falsely claims that Abel now agrees that there was a lawful subpoena.

My recollection of the amended counterclaim was that Abel believed the subpoena was anything BUT lawful so it's disingenuous for Jones to make this claim.

Jones also states that Abel's counterclaims do not support any allegations that Jonesworks "hacked" Abel, but again, this is not what was being alleged. I will cover this is more detail later.

🚨LESLIE SLOANE'S MOTION TO DISMISS AGAINST WAYFARER🚨

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1. Firstly, to calm anxiety, this is completely standard part of the process. One party feels the other party is not being responsive and has asked the Judge to intervene. It's normal and we will see a lot of this over the next year in various forms.

The letter specifically requests Wayfarer be compelled to respond to Interrogatories 3, 4, 5 & 7 and produce documents in response to request 32 only. I am going to focus on these but I have some comments about a few of the other requests. I will deal with the footnote in BLUE on the next page.

I was not privy to any of the discussions between the lawyers so I'm looking at this as a stand alone motion and on the face of it, the points, she's making, if she's representing the communications truthfully, is that prima facie, her comments are fair.

However, there is another side to this and the history of this case tells me that Wayfarer will likely respond with a letter which say something along the lines of....

"Your Honour, the Sloane Parties are bilingual. They speak English and Rubbish and on this occasion, they are talking in their second language."

I am exaggerating and clearly no representative of Wayfarer will actually say this. This is the kind of scene I play in my head for amusement when I read these filings.

The letter suggest that Sloane's concerns are reasonable. However, when I got into the detail of the requests themselves, they are anything but reasonable.

The points in YELLOW are her points. Wayfarer have the burden of proving their claims against Sloane. They do need to identify the statements and where, when and whom they were said to. Sloane needs this information to know what she's defending herself from.

I would say this regardless of who the party is. If Wayfarer can't produce this information, then Sloane will likely defeat the defamation claim at trial, if she's not dismissed for any reason beforehand.

I don't believe that Freedman would bring this case against Sloane if he did not even have a case to begin with.

I also don't think that see's Sloane off the hook entirely either as there is still questions about her involvement of the Vanzan lawsuit and the call to Melissa Nathan when Stephanie Jones seized Jen Abel's device.

I want to see Wayfarer's response but I do have a theory about why they are reluctant to comply with some of these Interrogatories and Sloane's letter confirms that Wayfarer have cited Local Rule 33.3.


2. FOOTNOTE RE DAILY MAIL

First, let me just correct an oversight by Sloane. She has erroneously referenced Paragraph 16 when she should have referenced Paragraph 15.

It is hard to see these screenshots so I advise going to the exhibit directly (Exhibit C of Sloane's motion) or going to the Wayfarer's California lawsuit against New York Times (which is what Exhibit C is).

But I will quote here for your information....

James from Daily Mail to Melissa Nathan: "She said the whole cast hits Justin this has nothing to do with Blake and now she's saying that Blake was sexually assaulted. Why wouldn't she say anything about that then?" ["hits", I believe is a typo and should read "hates"]

James from Daily Mail later on to Bryan Freedman: "I had many conversations with her about Blake and never once did she say anything about sexual assault. I had a three-way call with her and Melissa and she never said anything about then either."

It kind of appears that James maybe fibbed and caused trouble because he definitely told Melissa Nathan that (someone who is implied to be Sloane mentioned sexual assault.

Later on, again, he denies to Bryan Freedman that a person, who is implied to be Sloane, said anything about sexual assault.

I don't know whether James is talking about the same person on both occasions, or just lying, but discovery will get to the bottom of this.

Sloane is right to point out the discrepancy and question it.

🚨JED WALLACE'S AMENDED COMPLAINT AGAINST BLAKE LIVELY🚨

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1. To address the elephant in the room - no it does not mention the Vanzan, Inc lawsuit or subpoena.

It does better and, whilst not naming her, it refers to @colonelkurtz99 epic protest at SXSW with her rainbow-coloured, glittery sign (highlighted in 💚).

I'm only going over brief points that I either think are well made or are new information. I've left out the jurisdiction arguments because I've covered them to death - spoiler alert: they want Texas.

Firstly, I found it interesting that Lively and Megan Twohey had referenced Wallace's lawsuit against Paramount Pictures. I'm not even sure what relevance that would have to any of Lively's allegations.

Wallace makes a point of echoing Wayfarer's assertion that Reynolds and Sloane are dragons, I mean agents, of Lively's in the footnote.

Then Wallace alleges that Lively retained Wallace's former lawyer from the Paramount Pictures case to try and litigate against him in this case.


2. Wallace alleges that Lively dismissed her claim in Texas because Bryan Freedman told her to at the hearing in New York on 3rd February 2025. I've read that transcript and that is not true, as Charles Babcock also states.

The we have the reference to our hero @colonelkurtz99 (not by name) and her little protest of Lively at SXSW in 💚. I'd like to take this opportunity to that colonel for representing us on that day.

Babcock makes a good point that Lively should have foreseen the devastation that her allegations, and the lumping in of all the Parties, would have caused to Wallace.

Then there is a dig which goes to jurisdiction where Wallace confirms that Book Bonanza was help in Texas with it's Texan author and the movie was first publicly shown in Texas. As a stand alone jurisdiction argument, it's not strong but it is a cherry on top of many other stronger arguments.

🚨VANZAN AND SUBPOENA AMENDMENTS TO JEN ABEL'S COUNTERCLAIM AGAINST STEPHANIE JONES🚨

1. This will just be a very short thread as everything was the same as the original counterclaim, bar the addition of comments about the Vanzan lawsuit and the subpoena.

The Wayfarer counterclaim is the same so I won't duplicate it.

The big take away, Freedman is absolutely pissed!

I've added highlighted pages:
💛for general comments
🩷is for Freedman snark
💚is for Freedman snark directed at Ryan Reynolds
💙is for really disturbing information 2. "In contrast with Abel, who was loyal, trusted and even-tempered while working around the clock through the crisis, Jones was a walking disaster whose self-absorption, disloyalty and insubordination had become a significant headache."

Freedman does not hold back in his scathing assessment of Jones in contrast to Abel.

"On information and belief, Jones stewed in resentment and indignity..." 😂😂 It took me some time to stop laughing at this line. Freedman is essentially painting Jones as a bitter person who exploited the phone data as revenge for Abel and Wayfarer cutting ties.

We then get into the accusations that Jones shared the communications with Sloane, Lively and Reynolds. This was my theory I posted on last week before the news about the Vanzan lawsuit dropped: x.com/kiarajade2001/…

"Devoid of any scruples concerning the unlawful means by which Jones obtained the communications and desperate for a scapegoat for Lively's bad press, the Lively Parties likely saw an opportunity."

Then in green, Reynolds does not escape the stinging assessment in this filing, with his own words being used against him to take a shot at Lively. "Abel and others in Wayfarer's circle held Lively in deep disdain..."🤣 Oof!

Freedman then goes through in detail the events of the Vanzan lawsuit and the sham subpoena. He accuses the New York Times of also being in on this underhand plan

"However, for different reasons, the Lively Parties, on one hand , and Jones and Jonesworks , on the other hand, needed to create a veneer of legitimacy. The Lively Parties likely anticipated - or were told directly - that the New York Times would not traffic in stolen communications under these circumstances and needed the colour of the law. Jones and Jonesworks, for their part, wanted to insulate themselves from legal exposure to Wayfarer for breaches of confidentiality."

Again, this was also something I posted on last week: x.com/kiarajade2001/…

🚨THE NEW SUBPOENAGATE THEORY🚨

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1. Firstly, credit to Without A Crystal Ball for her work on this story. It was really interesting to go through and she did a good job in finding it. Here video can be seen here: youtu.be/6w3thoBr0yo?si…

When this all came out, it was the middle of the night for me so I hadn't looked in to it in any depth. Now, I've had an hours sleep, I've gone back and had a look at the documents. I've got a lot of thoughts. Post 4 is worth a good read.

I will begin by saying that I'm 99.99999% sure that Wayfarer's legal team already know about this and have done for weeks.

I will say that I have always maintained that a subpoena came from a filing somewhere. I never believed that lawyers would have just created one off a Word template or anything like that.

I'll also say that I'm not convinced that, even if this is all true (because that hasn't been established yet to us), I don't currently feel like this is going to be fatal to Blake Lively's case. It could be, but I feel that if it was, Freedman would have already filed a motion to quash. I would if it was me. It could affect some of Lively's claims but I cannot say this with certainty because there is still so much that is unknown.

Also, Freedman would have an obligation under ABA Model Rule 8.3 to report the law firm for the alleged misconduct. That would certainly be Lively's attorneys but could also be Jonesworks', Sloane's and NYT's lawyers if any or all, knew of, and were complicit with the alleged misconduct. Again, I'm not saying there has been any, but if it turns out there has, there is now an obligation on Wayfarer's legal team to report it.

I've had a look at the document and added colour-coded highlights on some points of interest, but I'm going to start with VANZAN INC. 2. VANZAN. INC

Credit to @Serenitygal2 here for her informative thread: x.com/Serenitygal2/s…

I won't go into everything here as she's done a wonderful job so I recommend looking at her thread if you want a deeper dive on this aspect. I'll lightly cover some things here for background context.

So the company was reinstated on September 23rd 2023 following 10 years of inactivity. Blake Reynolds (Lively's legal married name) is named as the CEO, CFO and Company Secretary. Blake is listed as a CEO on the company from 2021.

My own thought process is questioning whether this is really Blake who has reactivated this company. The company name starts with Van which is common knowledge that Ryan's social media accounts have Vancity as his name, a nod to his place of birth in Canada. Additionally, Ryan Reynolds is known for using alternative names for some projects - such as Gordon Reynolds. That is just a speculative thought on my part and there is nothing to confirm this.

Some people have noted the date of reactivation is during the WGA strikes, and about six weeks before the Return to Productions was sent to Wayfarer. That is true but at this moment, I don't see it as meaning anything significant. The reason I say this is because if we are assuming this lawsuit was filed for the purpose of obtaining an improper subpoena for the texts on Jen Abel's phone, it makes no sense why this company was be reactivated nearly a year before any alleged smear campaign would have taken place. Jen Abel's phone had not jet been confiscated. Stephanie Jones had not made Leslie Sloane aware of the text messages. So, I think this is just coincidental for now but it may become relevant when more information is made available.

The company has no known ties or affiliations with the Wayfarer Parties. Lively subcontracted her acting services under a different company, BlakeL. Inc., so there is no obvious reason for Vanzan. Inc to initiate legal proceedings against them.

🚨LET'S TALK ABOUT THE MYSTERY SUBPOENA BLAKE LIVELY ALLEGEDLY SERVED ON STEPHANIE JONES🚨

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1. I am getting a HUGE amount of questions about this subpoena so I think it's best to look at the processes behind civil subpoena's and explain from there why this subpoena has so many legal commentators perplexed.

I going do this as a thread to break up the information so please read all the pages. I'll put in links to any legislation I use so you can go check that out for yourself.

I'll stay with New York and California as they are the relevant states here. 2. So The starting point for subpoenas, especially where production of documents is concerned, is that there needs to be notice given, and a copy provided, to all parties, BEFORE serving it on the individual/company it is directed at. This also applies to pre-litigation subpoenas.

In this case:

📌Parties: Wayfarer, Abel, Nathan and Wallace (he was included in the CRD)

📌Directed at: Jones and/or Jonesworks

The reason this is important is because producing information is subject to due process. You can't just take a subpoena and ask for anything. Even FOIA requests are scrutinised for any exceptions or necessary redactions.

In this case, although the device was company owned, the phone number attached to it was personal as well as being used for the business, and Jones was well aware of that. She cannot just hand out personal data that belongs to Abel. Equally, there are clauses in the contract between Jonesworks and Wayfarer that confidentiality will be maintained and information destroyed upon the cessation of the contract.

Put simply, Jones had a duty of care to both her former employee and former clients.

And that means that they should have been notified of the subpoena request in advance so they could have lodged their objections before it was served and complied with.

What does the law say for New York and California on this?...

🚨JED WALLACE REPLIES TO LIVELY'S RESPONSE TO HIS MOTION TO DISMISS🚨

1. I really liked this filing. It was well written, well argued and contained some very snarky clap backs. I genuinely felt that Wallace's legal team really care about him and believe in his case, and that is always good to see.

I am planning to briefly summarise most of the highlighted points (I went nuts with the highlighter just because I liked so much of it but I'm not covering everything here). I will also link my satirical mock argument thread, at the end, that I did for Lively's response.

I will add all the pages as they all have some degree of colour-coded highlighting. The colours are:

💛YELLOW - general good points
💙BLUE - good legal points
🩷PINK - good snarky points
🎓where I'll do a separate post explaining legal points 2. Introduction

This sets out the theme of Wallace's arguments. I refers heavily to jurisdiction which is essential to Wallace because if Lively successfully argues California law applies, she has already argued a case in the Texas lawsuit against him that she believes that s.47.1 would apply because her claims are built on the foundation that of her sexual harassment allegations. I'm not convinced it would apply to Wallace but I can't be sure because the law is new and hasn't really been tested.

Wallace argues that Lively's arguments of conspiracy theory jurisdiction 🎓 are not recognised by Texas (where he is resident) and, although they are recognised by Second Circuit Federal courts, it should not apply in this case because Lively cannot even provide evidence of a conspiracy. The case she cites also only applies where jurisdiction is not contested, which is not the case for Wallace. Wallace refers to New York's 'long-arm statute'🎓but also argues that does not apply to him.

He refers to Lively's assertion that the court should disregard his sworn declaration and then goes on to argue that Lively has failed to allege any allegations against, any evidence of where or when the conspiracy is alleged to have occurred or when Wallace is alleged to have joined it, or how it supports New York as the correct jurisdiction.

Wallace then makes two further great arguments,

1. Blake Lively chose not to add him to this lawsuit when she filed (NY lawsuit) and only added him after he filed against her in Texas. I made this point in my thread on her response that this was a ridiculous argument.

2. FEHA does not apply to Wallace as he is not Lively's employer and her merely citing her allegations against Wayfarer do not evidence that Wallace had any knowledge of them.

🚨RYAN REYNOLDS REPLIES TO WAYFARERS RESPONSE TO HIS MOTION TO DISMISS🚨

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1. This was nothing short of an exhausting, mental agility test.

✅Tongue-twister sentences
✅Lack of proper research
✅Lack of cases cited to backup claims
✅Less shade than the original 12(b)(6) motion contained
✅Some arguments made that actually support Wayfarer

I'll add (only) the relevant, highlighted pages and do a separate education post on a doctrine referred to. There will be less posts within this thread but the individual posts will be longer.

I won't be covering all claims individually, unless there's something worth talking about in them, as they just repeat similar arguments to the defamation claim.

Please do read Post 3 - my heart and soul went into that one.

My summary analysis is, I don't think Ryan Reynolds is getting dismissed at this stage (not that I ever did think he would). 2. INTRODUCTION

The tone from the outset is similar to the tone in his original motion to dismiss - 'a toddler having a tantrum'.

Reynolds has piqued my interest in claiming that Wayfarer have made "a number of fatal concessions". I am now curious because I don't recall anyone, including myself, commenting on them if they were in Wayfarer's response to the motion to dismiss.

Reynolds argument that the claim should fail because damages are not stated is stupid. Damages are a matter for the jury to determine. This is not a legal argument for the Judge.

Reynolds also claims that Wayfarer, Baldoni and Heath were the only parties to state a claim against him, completely disregarding the small group pleading that Wayfarer made in their response to his motion. Also, as part of Wayfarer, Steve Sarowitz is co-founder and main financier.

Wayfarer have argued that all members of the Wayfarer Parties (which would also be relevant for Jed Wallace but is not argued here on his behalf) have been harmed by the collaboration and conspiring done by the Lively Parties, in conjunction with Jones and the NYTimes. Wayfarer have therefore, alleged several claims against Reynolds on behalf of all member of it's group.

THE FAC FAILS TO STATE A CLAIM FOR DEFAMATION

Reynolds quite arrogantly tells the Judge that there's no need to even consider choice of law as his motion should be dismissed - he does this for every cause of action so I won't bother repeating it.

Sidenote: When I re-read the original motion to dismiss from Reynolds, I noticed something I didn't spot originally. The podcast Reynolds refers to, on page 13, was the episode with @jaimecamil [channelling my inner, and very dramatic, 'Rogelio' voice]: "How dare he!" - forgive the digression, I am a big fan of Jaime Camil and saw an opportunity to use a Rogelio GIF in a desperate effort to make this filing even slightly interesting😂

In the original 12(b)(6), Reynolds concedes that California law should apply to Wayfarer and Lively's claims, here he is arguing that it should not apply to the claim against him.

Here, Reynolds make an argument which can only be described as 'unintelligible'. "But to the extent that such an analysis is required, New York law applies to each claim asserted against Mr. Reynolds. The Wayfarer Parties concede this (via silence) as to all but the defamation claim: as they acknowledge, the analysis must be conducted separately for each individual claim, but they respond to Mr. Reynolds' choice-of-law arguments only with respect to the definition claim." - what even is this supposed to mean? I know what they're saying he means, but it is worded so poorly. It sounds like they're saying Wayfarer, said, "nothing" and "everything" at the same time.

If I had to make an educated guess, I do believe that Liman will apply California law on, at minimum, most of the claims and most of the parties, if not all. But I cannot conclusively state what someone else will do, just what I think they are most likely to do. Both Wayfarer and Lively have asserted California law applies, so we'll see.

Reynolds does argue that Wayfarer failed to adequately state the details of the defamation claim, whilst simultaneously complaining that the additional information they have provided about Danny Greenberg is not in the FAC and should not have been added.

x.com/kiarajade2001/…

🚨BLAKE LIVELY'S RESPONSE TO JED WALLACE'S LAWSUIT IN TEXAS🚨

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1. I've had a look at Blake Lively's response to Jed Wallace's lawsuit he filed against her in Texas.

I'm going to go with uploading relevant, highlighted pages.

I've not got much to say on legislation or cases as it's rather threadbare in terms of law I was expecting to see, or repetitive of claims she has made against Wayfarer.

There is a lot of what appears to be pettiness in it and will spend most of my time on that because I was always told that writing down my feelings is helpful.

[Is there any truth in that @LethalLauren904 😅] 2. The first issue that really angered me. The complete reframing of the birth scene (which has been described as having added "unscripted nudity". It completely deviates from the phrase "nearly nude", which is how Lively frames scene in her CRD and NY lawsuit - and she's even walked that back in her motion to dismiss against Wayfarer.

There is appears to be a new reference to unscripted nudity that I don't recall seeing anywhere and we have to assume it refers to Lively because it doesn't say that it refers to any other cast member and Lively is the one complaining of retaliation.

She has, again, mischaracterised poor Adam Mondschein's role as being a pervy mate of Baldoni who was only brought on to stare at her upgraded to "nude" lady garden.

She's doing this for sensationalism and to hammer why she believes she was sexually harassed. In this lawsuit, she does not have Wayfarer as a party to bring the receipts to rebut her statements and she knows fine well Wallace cannot speak to the truth of them as he was not on set at any point.

She is clearly hoping to be dismissed before this gets to discovery. I hope it's not and Wayfarer are brought in as witnesses to take apart these lies.

🚨WAYFARER'S RESPONSE TO BLAKE LIVELY'S MOTION TO DISMISS🚨

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(This could be long as I feel like there's a lot to say - sorry about that!)

⚠️Serious amount of fangirling throughout. Regardless of who people support in this case, it is undeniable that pure magic has gone into crafting these legal arguments.

1. "The First Amended Complaint contains hundreds of pages rife with factual detail about Lively’s calculated efforts first to extort and manipulate the Wayfarer Parties into ceding total control over the film It Ends With Us and then to defame and scapegoat them when her plan backfired."

The first paragraph has a shift in tone. Wayfarer sound completely over all this nonsense now and, rather pissed off.

They go on to say, "Lively asks the Court to find that she is immune from any culpability for her wrongful acts, and instead it is the Wayfarer Parties who must be punished for daring to exercise their constitutional right to seek a remedy from the Court for her lies."

I'm getting a sense of genuine anger at attempts by Lively to wriggle out of having her case heard and evidence tested at a trial, in favour by exploiting privileges that would see her achieve the same result without facing any scrutiny... and I don't blame them because that's exactly what she's doing.

When I read statements in Lively's motion to dismiss using phrases such as, "In an epic self-own, the Wayfarer Parties have created more liability for themselves by their malicious efforts to sue Ms. Lively "into oblivion".", I felt there was less of a tone I would have expected from a genuine victim of sexual harassment and more of a "Haha, your move sucker!" vibe and it did not sit right with me.

It looks like Wayfarer felt the same. 2. 'Lively Is Liable for Statements Made by the Sloane Parties and Reynolds Under the Principles of Agency and the Doctrine of Respondeat Superior' (and her own statements)

This was a magnificent argument that Lively may not have anticipated coming.

Wayfarer start by asserting the principle of agency to hold Lively vicariously liable for defamatory statements by Sloane and Lively. Sloane is clearly acting in capacity as an agent of Lively due to her role as Lively's publicist - that is an obvious connection to make. However, Freedman also argues that Reynolds also acted in an agency capacity for Lively and cites her own designation of the role of "representative" for him, which she did in the 17/20/30-point document and his agency of her in the statements he made to WME. What an "epic self-own".

[Hypothetically: Baldoni could also argue the same for Ari Emanuel statements to Freakonomics if he chose to - which currently, he has not]

The doctrine of Respondeat Superior holds employers (in this case, "Khaleesi") responsible for defamatory statements made by their employees (in this case, the "dragons") in the course of their employment. This is the case even if the "Mother of Dragons" was not aware of, and/or did not sanction, the statements, and make the point, "Not only did Lively not immediately terminate the agency relationships or retract or clarify their statements, she doubled and tripled down, ratifying them and making them her own."

Wayfarer also make a brief, standard argument that Lively is responsible for her own statements.

🚨SATIRICAL MOCK MINI ARGUMENT FOR JED WALLACE AGAINST LIVELY🚨

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1. This is humour with GIF's and satire only and not intended to be serious or formal. Not all points will be covered because they are just so ridiculous.

I am also only covering Lively's allegations which relate specifically to Jed Wallace. So this shouldn't take too long because I'm not even certain Lively knows what she's accusing him of. 2. INTRODUCTION AND SUMMARY OF ARGUMENT

"In this case, despite Mr. Wallace's boasts about his clandestine abilities, he and his company got caught: even without discovery, the facts available to Ms. Lively already show that Mr. Wallace and Street Relations joined and actively participated in the conspiracy to "bury" Ms. Lively and destroy her reputation for speaking up about sexual harassment."

Ms. Lively has failed to state any facts that point to any actions taken by Mr. Wallace to discredit or "bury" Ms. Lively beyond questionably obtained text messages which Ms. Lively either knew, at the time she obtained them, mischaracterise their context to bend to her narrative but did not care, or, she did not know but should be aware now given the contents of Wayfarers FAC.

Either way, none of the evidence available supports Ms. Lively's allegations. Even if there was truth in Ms. Lively's allegation regarding a retaliatory campaign, which is disputed, Mr. Wallace has no motive for participating in any action with the intend to retaliate for speaking up about sexual harassment. Mr. Wallace has not been accused of sexual harassment, despite Ms. Lively's efforts to recklessly tarnish him with the same brush in her CRD.

🚨Deep dive of Colleen Hoover🚨

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1. Colleen Hoover is a controversial author who is known for writing books that include domestic violence themes but marketing them as romance novels.

To date, she has written over 25 books since her first novel was written in 2011/12.

Her 2016 novel, It End's With Us was the first of her books to be adapted into a film. Justin Baldoni liked the book and wanted to produce a film that spoke to people who have experienced domestic abuse. He partnered with domestic abuse charity 'No More' to try to capture domestic abuse with authenticity and signpost resources to people who need them. 2. Hoover proudly originates from Texas, where she still lives to this day.

She is married to her husband Heath and they have 3 children together.

🚨BLAKE LIVELY'S MOTION TO DISMISS🚨

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1. Well, if you thought her husband's filing was aggressive, buckle up!

Some of the arguments are decent arguments in terms of applicable law but the language is unnecessarily aggressive.

It's a long thread that has taken me 4 hours to read, look up case laws and statutes, make highlights and then type. I've attached the pages I have highlighted and tried to keep them in order but check the page number at the bottom.

I will try to cover point's according the pages I've attached to the thread where I can.

So the introduction gets off to an aggressive start referring to the Wayfarer's lawsuit against her as "vengeful" and "rambling".

She reasserts that her claims are for sexual harassment and retaliation for speaking out about it. She claims that Wayfarer's own lawsuit constitutes further retaliation. She cites California's sexual harassment privilege for this - I disagree, Wayfarer is entitled to defend themselves and test her claims in court. The sexual harassment privilege would apply to frivolous or vexatious lawsuits not defensive lawsuits. Wayfarer's lawsuit has a lot of evidence which successfully refutes her claim and casts doubts on her allegations. It is therefore not frivolous or vexatious.

She refers to Wayfarer's correct assertion that California law applies as an "epic self-own" claiming that if she is successful, she is entitled to claim attorney's fees, treble damages and punitive damages. She's right but again, I don't think she'll be necessarily successful, however that is a decision for Judge Liman.

Firstly, she argues that Wayfarer have failed to be specific with regards to defamatory or false light statements. Then she alleges that her statements relate to her claims of sexual harassment which are privileged in California and are time barred due to being outside of the one year statute of limitations - not sure I agree. For instance, Wayfarer claim that the sexual based allegations were never raised or complained about until the meeting in January 2024. The 17 point document she keeps referring to does not state the claims of sexual harassment and is more requests that were considered reasonable and acceptable.

Then she states that Wayfarer are claiming that she is both powerful and influential whilst simultaneously fabricating sexual harassment claims to leverage control of the movie - I believe both can be true and if Reynolds and Lively have a reputation of acquiring their power through manipulation and bullying, then Wayfarer are not wrong. Additionally, Wayfarer suggested her power and influence come from her associations (something Khaleesi herself stated to Baldoni). During the period when her "concerns" occurred, her husband was in England filming.

Then she claims Wayfarer have not alleged what property or money she is supposed to acquired through extortion - hard disagree! She got a PGA credit, her friends clothes and music were used and marketed, her own hair care and drinks brands tied to the movie and got free markets courtesy of Wayfarer and her husbands marketing brand took over the marketing. That is a lot of revenue generated for both Lively and Reynolds, but also their friends.


2. Lively makes several misrepresented claims that Wayfarer admitted to her claims...

Baldoni said her appearance was failing to meet audience expectations - he said the wardrobe not her personal appearance and the feedback on social media confirmed that. He was in fact relaying Sony's concerns.

At some point in May or June, a simulated nude scene was filmed without an intimacy coordinator present - I believe she is referring to either a scene she herself wrote or a scene with young Lily. SAG-AFTRA rules recommend intimacy coordinators for specific scenes but do not enforce their use. If this is regarding scene with Lively, then signing her nudity rider would have set out conditions she agreed to. If the scene was filmed with another actress, then that actress had her own nudity rider and expressed no discomfort at the time or after.

Baldoni discussed orgasming with his wife - normally I'd say this was unprofessional but in they were friends and had a comfort in talking to each other.

The homes birth video - she now agrees that the video is not pornography is appears. This appeared to have occurred once in May so I'm not sure why it was necessary to get an agreement for it to not happen again in November as there are no further birth scenes.

Baldoni improvised kissing in scenes - Baldoni denied this and stated that it was actually Lively who improvised kissing scenes, which she confirmed in footnote 16 on page 27 of her first amended complaint.

Heath entered her dressing trailer whilst she was having body make up removed - Wayfarer confirmed that Heath, amongst others, were invited by Lively in her trailer for a scheduled meeting and offered to reschedule.

Baldoni hired a friend to play obstetrician who was in close proximity to her genitalia - well, she has now dropped the "nearly nude" prefix to the genitalia. I don't get her issue with hire for the OBGYN role as the person, Adam Mondschein is a regulated actor as was her sister and Baldoni's wife, who were also given minor roles. OBGYN's are usually nearly genitalia during birth in real life so I'm not sure where she was expecting him to be,. This is an odd statement given she's had 4 children. But the genitals were not nearly nude.

Use of the word sexy - again, this was used to describe a characters look which is what she wrote in a text she wanted. Again, a bizarre claim from and complete reframe of what Wayfarer sain in their complaints.

The comment about Lively's demand that hires being required to come from agencies and not personal connections (Point 16) - I find hypocritical given the links to various Deadpool crew members and Taylor Swift's song being used

The footnotes suggest Lively raised these complaints in May 2023, but Wayfarer confirmed that none of these specific complaints (sexual harassment) were raised to Sony.

Lively makes an effort to fix the issue with the video interview of Megan Twohey. Not very well I might add and I'm not sure why Lively is trying to make a case for NYT in this motion.

🚨RYAN REYNOLDS MOTION TO DISMISS🚨

🧵

1. This one I was half expecting but I'll admit I was still shocked that it's landed. I will post all pages up, 4 pages per post on this thread. It will be a long thread to get all the pages in.

Instead of highlighting the pages, I will just cover the motion overall but the pages attached may not correlate to what I say in the thread. This is because I'm using the thread to get the document out for those who asked for it...

I'll do my best to keep the pages in order but check the number at the bottom of the pages, just incase. I won't include indexes, etc


2. So, straight out the gate, Reynolds is claiming that the only reason he is even a defendant is because "billionaire Steve Sarowitz" (they really don't like the amount of money the guy has!) said he would pay a huge sum to destroy Reynolds and Lively.

My thread about Justin Baldoni 🧵

1. There have been a lot of posts and content around Blake Lively and Ryan Reynolds’ hypocrisy and past interview faux pas. I think now is as good a time as any to shine a light on the man that is Justin Baldoni (I will do a broader Wayfarer thread separately). 2. Baldoni began his acting career in 2004 on the TV programme, The Young and the Restless.

My theory about Ryan Reynolds involvement with IEWU movie

1. When Blake Lively was asked about the writing of the rooftop scene at the movie premiere, she made an unexpected declaration,

"My husband wrote that scene. Nobody knows that but you now".

But Lively didn't stop there. She also proclaimed,

"He works on everything I do and I work on everything he does so his wins, his celebrations are mine and mine are his".

youtu.be/k9IF7hLXDL4?si… 2. This statement initially led to people questioning whether Reynolds had crossed the picket line during the WGA strikes, held from 2nd May 2023 to 27th September 2023, in order to make these script changes.

The amended lawsuit from Baldoni and Wayfarer appears to dispel that theory as the timeline confirms these script changes as occurring in April 2023. Notably, Baldoni is under the impression that it is Lively proposing changes to this scene, not Reynolds.

Thread 🧵: My theory on what happened to the It Ends With Us movie

1. The movie was part of a clear vision by Justin Baldoni to bring a story based on the real life experiences of Colleen Hoover to life.

Baldoni has a well established history of doing projects which raise awareness of important issues to life. Contrary to belief, the subject of those issues are not merely limited to "women's issues". Baldoni previously directed the 2019 Five Feet Apart, which tackled the subject of cystic fibrosis. 2. The purpose of It Ends With Us was to shine a light on domestic violence.

In this film, it was not just an opportunity to help women, it brought attention to men and held them accountable for their behaviour.

In particular, both Ryle and Atlas had both suffered severe childhood trauma but both had very different responses to that trauma.