Justin Baldoni Should Be Stripped Of His Rights! Blake Lively:

Justin Baldoni Should Be Stripped Of His Rights! Blake Lively:

As my people say, the T is Caliente. Hello my friend, it is Perez, the queen of all media, the original influencer, your number one source for everything. It ends with us saga. And this video is a four in. We’re going to get through a lot and it is all juicy. First, did you see Ryan Reynolds on Jimmy Kimmel Live last night? Vanity Viper’s husband was a guest on location from Brooklyn of Kimmel and gave such an awkward and cringe interview. You all know I’m not a prude, but he was cursing up a storm. Reynolds had to be bleeped many times throughout his chat with Kimmel. Why? He knows you don’t curse on broadcast television. He’s trying to be edgy. I don’t get it. His typical stickick of being self-deprecating and mocking his own children was raging. I eat their Halloween candy. And no, Kimmel did not ask anything about the it ends with us saga. Fail. Missed opportunity, Jimmy. But thankfully, it did make me happy to see that across social media in the comments section of clips that Kimmel shared of Reynolds interview, people left many comments about Justin Baldoni. Justice for Justin. He needs justice because the ruin the friendship muse is trying to strip him of his rights. There is a new filing that just hit the docket that is so ludicrous and on brand for team ridicula. Remember Friday night I was up late working hard because team Belon Wayfairer filed a motion for judgment on the pleadings. If you did not watch that video, go watch it. But let me give you a super quick recap. They made so many legally sound arguments, some for the first time that I think are a gamecher. and they basically say, “You got nothing. All of her claims need to be tossed in the garbage.” This motion for judgment on the pleadings is different than summary judgement. And so smart because if the judge denies this, they still get another bite of the apple in the motion for summary judgement. Remember the difference is the motion for judgment on the pleadings just takes into consideration everything that the subpoena superstar has filed. Her complaint, her amended complaint, the second amended complaint and breaks down why it is not legally sound. Motion for summary judgement is similar, but it takes into account everything that they have learned over the past year of litigation, including any evidence that was uncovered in depositions. So now, many days later, Betty Buzzkill and her lawyers are asking for the whole pie. Basically, they say, “We want a delay, but we also want this, or maybe not that.” It’s bold. Let’s get into it. Mikey Mike Gotautle took lead on this one and he says, “Dear Judge Lyman, pursuant to federal rule of civil procedure 12c, plaintiff Blake Lively respectfully requests that the court deny the wayfairer defendants motion for judgment on the pleadings as unttimely without prejudice to the wayfairer defendants raising the arguments therein in motion for summary judgement or at trial. Pause. Let me read to you the law. You can bring a motion for judgment on the pleadings after the pleadings are closed, but early enough not to delay the trial. This means the court will review the complaint, the answer, and any counter claims or third-party complaints and the responsive pleadings have been filed. For a little context, the docket duchess filed her second amended complaint less than two months ago. So, the Baldoni parties last week filing their motion for judgment on the pleadings is not going to delay the trial. The trial is not scheduled to start until March of 2026. But Mikey Mike Gotautib says it’s untimely. lawyers be lawyering. Mr. Gotautle continues saying in the alternative the alternative if her bestie does not deny their motion for judgment on the pleadings without prejudice. than in the alternative. Pursuant to rule 1D of the court’s individual rules and practices, Miss Lively respectfully moves for an extension of time to and including October 27th, 2025 in which to respond to the Wayfairer defendant’s motion. Is this not a response? It seems like a response. He goes on and um it makes it seem like it’s a response, a short one, but it’s a response. And she is looking for an extension of several weeks. Typically, these things you have two weeks to respond. So, if they filed it this past Friday, they would have just before the middle of October to respond. But now they want until the end of October. Ridiculating. Mikey Mike continues, “To be clear, Miss Lively is prepared to respond to each of the Wayfairer defendants arguments at the appropriate time, whether that be at the summary judgment stage or at trial. These people think they can dictate how this court operates because up until now they have. There’s a little footnote here. It says to take just one example. The motion asserts that Miss Lively has failed to exhaust her administrative remedies against it ends with us movie. But the burden of pleading and proving Title 7 exhaustion lies with defendants and operates as an affirmative defense. Not only does that render this argument inappropriate for resolution on a defendant’s rule 12 motion, it ends with US movie did not even raise this affirmative defense in its answer. Maybe they were waiting for this haha gotcha which they dropped on Friday. Also, I don’t believe Jack that these people say because I experienced this firsthand in their filings. They misrepresented the law. I don’t know how lawyers are allowed to lie in legal papers. It’s mindblowing. Mike continues, “In other words, not only did It Ends With Us movie for judgment on the pleadings based on an affirmative defense it had not pleaded, but because of that failure, Miss Lively would be entitled to judgment on this particular defense, not it ends with us movie.” In any event, and further demonstrating the wastefulness of the wayfairer defendant’s motion, Miss Lively amended her CRD complaint and received right to sue letters with respect to it ends with us movie during the pendency of this action. How does that make it okay? She had already sued. She got a right to sue letter after she already sued. It ends with us movie. Ow. Grotesque gutl continues. As is well established in this district that is sufficient. the same district that allowed the Vanzan sham subpoena. It goes on. The Wayfairer defendant’s decision to sit on these supposedly meritorious arguments for nearly nine months means that briefing and adjudicating them now would only lead to duplicative briefing and waste judicial resources and would force Miss Lively and the court to bear the burden of the wayfairer defendants delay. There was no delay. They were within the law and the rules of civil procedure to bring this motion when they did. Tellingly, they continue, although each of the wayfairer defendants arguments has been available to them since the outset of the case, and although their council eluded to the possibility of a motion for judgment on the pleadings on the record at the conference held on July 30th, 2025. They warned you this was a possibility in July. You had every ability to prepare for this possibility and you didn’t. And now you’re boohooing about it now. Now they’re boohooing, hoohooing, and saying the Wayfairer defendants waited to file their motion until the response deadline would fall on the last day for depositions in this case. Knowing full well that because of their own discovery deficiencies, Miss Lively’s council would be preparing for and taking the depositions of four of the defendants during that period. They literally just said, “Oh, we can’t, your honor. We’re going to take all our time and submit this at the very last minute.” Well, guess what? You have these multinational ginormous law firms working on your team. Submit your response by the end of this week, next week. Don’t take till the very last day. That’s on you. Meanwhile, they continue to moan. By the time the Wayfair defendants motion is fully briefed, the deadline for summary judgement motions will be only days away. Meaning that each of the factbound challenges to the pleadings raised in the motion will be overtaken by the record evidence at the summary judgement stage. The question at this stage of the case is not what the pleadings allege, but what the evidence shows. Okay, I’m team truth. That is the most compelling thing Mike has said probably in months. And he continues, “The appropriate means of answering that question is through a motion for summary judgement.” Her lap dog, Lyman, is probably going to give them what they want. Spoiler alert. But they continue. Meanwhile, to the extent the motion raises purely legal issues that would not be affected by the summary judgment evidence, such as some procedural things, the Wayfairer defendants will suffer no prejudice from a few weeks additional delay in briefing those issues. Make an exception for us, not for them. We deserve it. Miss Lively filed her initial complaint on December 31st, 2024 and her amended complaint on February 18th, 2025. Each of the Wayfairer defendants answered the amended complaint on March 20th. In response to the court’s order granting Jed Wallace and Street Relations motion to dismiss, Miss Lively filed her second amended complaint on July 30th, 2025. All right, it was exactly two months ago. I thought it was on the 31st of July. I was off by a day. Once again, each of the Wayfairer defendants filed answers this time on August 13th. At the outset of this case, the court expedited the initial pre-trial conference and asked the parties to submit a case management plan with deadlines that would enable trial to occur on March 6, 2026 at 9:30 a.m. Even with the handful of modifications that the court has granted in the months since, that goal remains in sight. Fact discovery is scheduled to conclude on September 30th, 2025. Today, with a few exceptions, including a handful of fact depositions to be completed by October 10th, 2025, and the production of additional documents withheld on privilege grounds. Expert Discovery is scheduled to conclude on November 14th, 2025. Meanwhile, the current deadline for summary judgement motions is November 5th, 2025. That’s a while from now. Trial remains scheduled to begin on March 9th, 2026. Federal Rule of Civil Procedure 12C provides that a party may move for judgment on the pleadings after the pleadings are closed, but early enough not to delay trial, as has happened here. Generally, a rule 12C motion is considered timely if it is made early enough to delay trial or cause prejudice to the nonmovement. Whether a rule 12c motion is timely is within the sound discretion of the judge, not you, the judge. And you know that judge is biased, corrupt, paid for in her favor. Obviously, in general, if a party engages in excessive delay before moving under rule 12c, the district court may refuse to hear the motion on the ground that its consideration will delay or interfere with the commencement of the trial. Consideration of the motion may still be appropriate, unlike here, if it seems clear that the motion may effectively dispose of the case on the pleadings. But if the pleadings do not resolve all of the factual issues in the case, proceeding with discovery and potentially a trial on the merits would be more appropriate than an attempt at resolution of the case on a rule 12c motion. Courts are unwilling to grant a judgment under rule 12c unless it is clear that the merits of the controversy can be fairly and fully decided in this summary manner. The wayfairer defendants motion is untimely. They argue although all of the arguments raised have been available to the wayfairer defendants since the initial complaint was filed. They did not raise them until September 26, 2025. Measured against the court’s stated goal of managing this case to a March 9th, 2026 trial date. That delay was excessive under rule 12c. Says you, not the judge. You are not the judge. You are not the judge. You and Mike and Ezra and Merrill and everybody else. You are not the judge. The motion primarily raises factbound challenges of the Second Amended complaints allegations. Those arguments are meritless, but as far as the timing of the motion is concerned, they are more importantly all but moot. At this stage of discovery, Miss Lively has uncovered voluminous evidence relevant to all of her claims. That is the biggest joke. They are going to settle because I am pretty confident they don’t have any evidence, but they claim they have volumes of it. Rather than merely defend the sufficiency of the allegations to respond adequately to the motion, Miss Lively would also need to make a profer of the new and more detailed facts in her possession that would entitle her to amend her complaint. Should any of the wayfairer defendants arguments prove successful as to any of the second amended complaints claims, the court would then need to evaluate that evidence under rule 15’s futility standard under rule 12b6’s plausibility standard, construing that evidence in Miss Lively’s favor along with the benefit of reasonable inferences there from. But crucially, that would be the same analysis as the summary judgement stage when if the wayfairer defendants chose to move against any of Miss Lively’s claims or defenses, she would then need to point to record evidence that construed in her favor and drawing reasonable inferences there from would support a reasonable jury’s finding in her favor. Good luck there, babe. You’re going to need it. Considerations of judicial economy and common sense and the goal of holding to a March 2026 trial date. Mike wrote 2025 support conducting that exercise only once. For similar reasons, the First Circuit has observed that the legal standard that would apply to the motion and to any request to amend based on discovery is by its nature a threshold inquiry. And logic strongly suggests that it occur prior to discovery. Logic suggests that, but the rules don’t state that. At this stage of proceedings, after substantial pre-trial discovery has taken place, ignoring the entire paniply of facts developed during discovery makes little sense. The Wayfairer defendant’s motion thus seeks a duplicative exercise that can only have the effect of causing delay. Meanwhile, the Wayfairer defendants will suffer no prejudice from having their present motion evaluated on the basis of the summary judgement evidence rather than the Second Amended complaint allegations. You don’t get to dictate whatever. I’m going to That’s a separate thing. They know how these things work. They have not sought to stay discovery or otherwise suggested that anything about the case schedule should change based on the filing of their motion. By contrast, Miss Lively will suffer significant prejudice from having to file what is effectively an opposition to summary judgement while discovery is still ongoing. It is not that their motion for judgment on the pleadings takes no evidence into consideration. It doesn’t matter what evidence you’ve gotten, alleged evidence you’ve gotten. Indeed, mischievous Michael continues, “The only practical difference between the process for resolving this motion and a summary judgement motion filed at the appropriate time is that to respond to this motion, Miss Lively will have to scramble to amass evidence from a discovery process that is and will be generating new evidence virtually Actually, you don’t have to for this motion. Miss Lively will have to scramble to amass evidence from a discovery process that is and will be generating new evidence virtually every day between now and the response deadline, including depositions of Mr. Baldoni, Mr. Heath and Wayfairer, Mr. Sorrowitz, Miss Nathan, and Mr. Wallace. Not to mention the expert discovery process that will still be ongoing for several weeks thereafter. The court, your sexy and smart honor, I say, accordingly should deny the motion without prejudice to renewal of the arguments raised therein at a later stage or exercise its discretion to hold the motion in obeyance until trial. The what? Totally disregarding the no. In the alternative, Miss Lively respectfully requests that her deadline to respond to the motion be extended to and including October 27th, 2025, 3 days after the deadline to exchange expert rebuttal reports. Unless extended, the current response deadline is October 10th, 2025. Plenty of time from now. This is Miss Lively’s first request for an extension of this deadline. Pursuant to rule 1D of the court’s individual rules and practices, Miss Lively states that the wayfairer defendants oppose the extension but did not provide any reason for the reasons given above. Even if the court is inclined to permit full briefing of this motion in the final days of discovery, such an extension would be warranted. Respectfully submitted. Mikey Mike Gutlid. [Music] Also, Judge Lyman was really busy today. He issued an order with regards to case and Coslo, one former and one current employee of Melissa Nathan, the crisis communications expert. They must hand over some materials by October the 6th. They were previously trying to withhold them on grounds of attorney client privilege. Stephanie Jones got in on some action today as well. His former publicist who wants to depose Jed Wallace is asking the judge to sign off on letting her depose him after the deadline by one day on October the 10th. Modify the existing case management plan. Her bestie signed off on this. The Wayfairer defendants were trying to oppose this and gave some more info about Brian Freriedman’s sons. Ellen Gop said the Wayfairer parties informed Lively that Spencer Freriedman and Jared Freriedman were law clerks assigned to work on this litigation. Okay. Brian Freriedman, as you know, is the lead attorney for Wayfair and his sons were on some of these privileged chats that no other attorneys were present. This could be problematic. Actually, can you be a law clerk without being a lawyer? I don’t know if both or either of Brian Freriedman’s sons have JDs. They also added the Wayfairer parties have also re-reviewed communications involving Jared Freriedman and Spencer Freriedman without attorneys as participants. There are three such documents that were withheld on privilege grounds. All three directly relate to the preparation of legal documents in connection with this litigation with which Jared Freriedman and Spencer Freriedman were instructed by attorneys to assist. So with regards to this, Judge Lyman also ruled today and said she gets her way. An amended categorical privilege log shall be served by October 6, 2025. The court reserves judgment on Lively’s motion pending service of an amended categorical privilege log and the production of those messages that after further review can be produced without waving privilege. So much craziness. You know what I like to do when things get crazy? A little shopping. How about you? Why don’t you buy some of my merch at bypopstuff.com? bypopstuff.com. I have team truth and grab your friends wear your florals plus team Perez and so much more at bypopstuff.com. Also, you need to sign up for our Patreon. 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So much craziness. Let’s get into it all. You know where. See you there in the comments. Superstar.

🗣️ #BlakeLively #JustinBaldoni #TaylorSwift

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Justin Baldoni Should Be Stripped Of His Rights! Blake Lively:

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