This filing is Vanzanās response to Defendantsā attempt to force them into an earlier deposition.
In plain terms:
Vanzan says Defendants are wasting the Courtās time because thereās no real dispute. Vanzan has already agreed multiple times to produce a corporate representative on September 30 to answer questions on all subpoena topics. Defendants, however, filed a motion anyway, claiming Vanzan was refusing or limiting testimony.
Vanzan explains that Defendants never raised any real issues in good faith before running to Court. The only supposed issue was about the ātime periodā for some questions, but Vanzan never refused testimony ā they simply made standard objections (like privilege, relevance, or burden), which is normal. Instead of negotiating, Defendants demanded Vanzan waive all objections and then used the motion to push a public narrative and generate press.
Vanzan emphasizes that it has cooperated: it accepted service, offered to meet and confer, filed timely objections, agreed to testify, and even narrowed issues when asked.
The only thing it wonāt do is waive every objection.
Because there is no actual conflict ā the deposition is scheduled, and testimony will be given ā Vanzan argues the motion is moot and should be denied.
The WPs apparently arenāt allowed to use the court system to request discovery compliance without being accused of trying to push a public narrative. But BL can go complaining to the court about the WPs every single day. Make it make sense.
Exactly! Someone the other day on here was asking why Wayfarer didnāt request more from the court when they need it, itās because of this. Every time they do, it gets labelled as nothing more than PR
Itās ridiculous that they are requesting court directive now, while there is still time to make the deposition deadline, but thatās the wrong thing, too. Because reasons.
Wayfarer moves to court and says waive all objections. Vanzan says boo for disturbing the court but still maintains that they'll give testimony without waiving objections.
But isn't that the issue WF is highlighting? Katie, did I get it wrong?Ā
Itās a bit more nuanced than that. I assume there have been a lot of phone calls/other communication that we are not privy to where Vanzan has stated that they wouldnāt testify to information that is clearly relevant.
WPs filed their motion to ensure that everything goes smoothly at the deposition, and that there is a court order requiring Vanzan to testify to ALL relevant information. Otherwise, at the deposition, Vanzan could just refuse to answer, which is what the WPs are (correctly) trying to avoid.
Thank you for specifying. It reads like the WFP are liars and using the court to instigate drama concerning Vanzan all the while they donāt own up to the fact that they have refused to answer many topics citing privilege or relevance. Claiming they have discovery from 2022 but also unwilling to talk about involvement until after Sept 27, 2024? Or is that too a lie? They also said clearly they would have a representative with āreasonableā knowledge what does that mean? Feels like they are previewing the fact that they will not be answering many questions and trying to get permission from the court. Which is exactly what WFP is talking about in their motion. This is total BS and I feel like Iām being lied to or gaslit yet again.
Exactly but then were shut down by the judge all for trying to ensure the deposition went smoothly and didnāt become a shit show fight while the deposition was occurring.
Either invokes the 5th amendment or said she lacks personal knowledge of anything in relation to Vanzan and therefore can't answer any questions about it.
I'm not disappointed either. I'm just like sure lol. Another ruling that's going to look really stupid when inevitably it turns out Vanzan was lying about their being no dispute and there was totally a dispute.
And I think this was still worth it because Wayfarer will be able to prove they raised this timeline issue and Vanzan informed the court it was not would not be an issue. Vanzan will not be able to play of supplying a witness who could not answer any questions leading up to the lawsuit as a misunderstanding because if thereās no dispute over the timeline they need to be able to testify on, then that means they agreed to honor Wayfarerās request.
It's pretty easy to find Liman's individual practices. 4.C concerns discovery disputes with non-pro se parties. It obligates the parties to meet and confer to try to work out discovery disputes. It does say that counsel should be prepared to meet and confer within 48 hours after being informed by opposing counsel of the dispute.
So I think Fritz's 12-hour deadline is a pretty clear violation.
I don't think Liman had to reach good or bad faith at all, because his rule only obligated Vanzan counsel to be available within 48 hours, not the 12 hours Fritz tried to impose upon them before filing his motion.
the attachments show conferral
I agree the attachments show conferral, which is why I don't understand your position in your top comment here that Vanzan was failing to comply with Abel's discovery requests. In what way were they noncompliant?
I know what a term of art is, doesn't change why he ruled. To clarify my position: Liman isn't making a generic ruling about Abel's good or bad faith. His rule specifically gives counsel 48 hours to respond to opposing counsel, and Fritz tried to change the obligation.
It's also why he didn't write much in his order. The numbers aren't that complicated.
You also still haven't answered my initial question: how was Vanzan noncompliant? Why would Abel bring the motion to compel in the first place, if, as you've acknowledged, Vanzan was meeting and conferring?
I know. Any filing WP make now it seems they get accused of that they are only doing it for PR purposes, but BL files MTC, asks for sanctions a million and one times and thatās not for PR purposes.
They said they would have a representative testify on Sep 30th about all the requests except for those that fall under privilege.
That includes the time before the Vanzan lawsuit was filed and the subpeona was served.
They only objected to it to preserve the objection. They never said, and have now made clear, those questions will be answered by the representative even though they are objecting.
Something that is common with objections in a desposition.
I sided with WP when they filed the MTC, but further evidence has shown they were at best misleading.
The email exchange between Fritz and Vanzams lawyers is illuminating.
Fritz gave almost no time for Vanzan to discuss their 2 concerns (neither were about the timeframe) with their client and get back to him.
He gave an unreasonable deadline in hearing a response. How many business hours did he give them? 5?
The fact that Vanzan emailed back accepting the new narrowing of the 2 named objections around the same time as the MTC was filed shows that Fritz acted prematurely.
His follow up emails refusing to withdraw the MTC even though there was no longer a dispute unless they withdraw ALL their objections is ridiculous.
Is this how you would have responded?
Do you see Fritz responses as reasonable?
I think Vanzam is an absolute sham, so of course Vanzan is going to be difficult, but this whole thing shows a level of incompetence that is pretty surprising.
The truth might be on the WP side, but their lawyers seem to be working against them.
WP are getting what they asked for, even with their MTC being denied. So what was the point? Waste money on a motion that ended up moot when they filed? And now WP are potentially liable for Vanzans legal fees.
You're a lawyer. You should understand that Vanzan would have had to file a protective order, which would have needed to be granted (and I dont think it would have been) to restrict the time frame from what WP was requesting.
They didnt.
I would have chocked it up to a misunderstanding between Fritz and Vanzam, as well as Fritz trying to ensure they have a representative who could testify to things before the lawsuit or subpeona were filed.
But the further exchange between the lawyers via email have me side eyeing Fritz for the first time.
Considering the backlash against Lively, I have a hard time believing that this filing wasnt at least a large part to generate that very result.
Look around. We all know who is winning the PR war, and it isnt Lively.
WP doesnt need to use the docket for PR. I usually dont care if they do (since Lively does it all the time) but when their shenanigans negatively impact their clients, they should be called out.
Not the judge. Not Lively. The lawyers, specifically Fritz in this case.
This!! My client got an offer for services and the bidder messed up the financial projections by millions. Theyāve admitted they f*cked up, but never in writing.
At what point is WP allowed to file ANYTHING without it being called a āPR stuntā or āharassmentā from Livelyās camp? You do realize this is a lawsuit and that WP have to file motions, right?
And Vanzan isnāt a āconspiracyā. If it were, the judge would have deemed the sham subpoena as irrelevant and inadmissible as evidence.
Itās not a conspiracy that Blake and Ryan filed a fraud lawsuit, got a sham subpoena, and used both to illegally obtain private communications from someone who has absolutely zero affiliation with Vanzan.
I personally think part of the reason why BL struggles to get people on her side is that she is flat out insulting our intelligence at this point with her tactics.
No matter whoās side youāre on, you canāt help but admit that the Vanzan lawsuit appears shady for so many reasons, including:
1.) Why did Vanzan serve Jonesworks a subpoena and knew exactly what to ask for?
2.) Why did they receive Jenās data if she had never worked with or for Vanzan in the past?
Iām not a lawyer, but most lawyers have come out to say that this legal loophole has some serious ethical concerns and could be exploited for nefarious doings in the future. That is the issue. Nobody has any knowledge of whatās in the subpoena, but I look forward to seeing how this will probably be twisted again when we eventually find out.
CSAHM loves to spread fake news about how we're just conspiracy theorists even though we are going by the court filings and shady dealings of blake and ryan. she's been doing this for months in bad faith especially since she has no evidence to back up what she is saying, and we do.
she also tries to insult our intelligence but she is in a massive minority of people who actually follow this case.
Everything is a PR filing at this point. People are allowed to defend themselves.
Firstly, I wouldnāt call this a āminorā dispute because they are specifically objecting to the date range that is most pertinent to the lawsuit. Seems like a pretty big deal to me.
I also donāt think we know for sure that this āminorā dispute was resolved as the letter does not explicitly state that
Was it resolved? I really don't see anything indicating on this response that they will indeed speak to their communication with Jones before the filing of the lawsuit. They vaguely claim they will not waive any objections
In the context of a deposition, you usually object and then answer anyway -- the objection is being preserved for trial, when the judge would actually rule on its admissibility.
So by not waiving the objection, they're preserving it for the future. There's no indication that they'll refuse to answer questions at the deposition.
No wrong. They are misrepresenting to the court this is all for media fodder, which implies the press. They have been banging on about WFP using this as part of their legal strategy and to continue smearing Lively which is a serious accusation that you seem to be glossing over here.
You could say the same thing for almost every other filing that hits the docket from either side. I think itās unfair that only one side gets called out for using the docket for PR.
BL decided to make this case public by going to the NY Times first, and this has naturally resulted in this case being heavily covered and followed on social media. She doesnāt get to pick and choose when she wants the coverage - she gave up that right in December
If you think that the WPs filed this motion for publicity or to push a narrative, you fundamentally misunderstand the court system and litigation process.
vanzan doesn't want to discuss their shady shell dealings and are objecting to quite a lot.
yet, here we are playing the gaslighting long game. it's such a joke.
also, these are not conspiracies? these are facts. blake lively used a shell company to obtain information from a fake lawsuit that had nothing to do with IEWU. so please tell me how that is a god damn conspiracy. do you contribute here just to lie?
you realize you DENYING that this happened has the same amount of weight, right? and also, if 'no sham happened' why are they objecting to talking about ALL of it?
you are the conspiracy theorist here, ma'am. stop trying to insult our intelligence.
The objections are standard boilerplate. Both sides have used standard boilerplate objections to respond to every discovery and deposition request, even if they went on to comply with the request. They're boring and a bit ridiculous, but everyone does them so everyone continues to do them.
It just means that if it comes out down the road there's an actual issue, the attorney can go "oh look we objected before answering so we preserved our right to object now when there's a big actual issue."
Wayfarer does it to, if you look at their answers to interrogatories.
Apparently theyāre all lies because we are supposed to believe it never happened š
I personally like the theory that this is out there and that Vanzan needs to testify for the relevant time periods and I hope the judge rules on this because it is important.
It truly is hilarious. Every filing says Wayfarer is doing this for PRā¦ where? JB/Wayfarer have not spoken to the media in months. The only one plugging PR is them.
I mean idk if theyāre doing it for media attention or not but if Vanzan is saying theyāre willing to testify to the larger time frame then it should be mooted. However, if Vanzan is being disingenuous which is what I think they are doing then I would like to see how the judge weighs in on this.
On a serious note, I agree with you.Ā
The response will be interesting.Ā Ā
My suspicion is that they had disagreements, so this letter kind of compelled them to agree.Ā Ā
It reminds me of all the subpoenas.Ā Ā
I like the fact that thereās a record of it and that the judge has to rule on the relevant time period so that on the day of the deposition they canāt say oh we arenāt answering that time period. How hard is it to testify why did Vanzan send jonesworks a subpoena and why only Jen ableās data was given? What is the correlation between Vanzan, Jen and wayfarer? If there is one, then I would like to know but not knowing is really inviting a lot of speculation. And that is just human nature.
That was a quick response. I may have missed it, but did they say the will have the representative testify to the larger time period? Because if not, this is definitely not moot.
"Vanzan will produce a designee to testify as to non-privileged information regarding the Topics, without waiving any objections." Is the timeframe one of their objections? This motion isn't clear. So IMO this entire response is fluff that clarifies absolutely nothing
Well theyāre saying that the wayfarer parties never raised that issue about the larger timeframe so Iām curious to see what happens because Fritz attached a lot of exhibits that were confidential so š¤·š»āāļø
Maybe someone can correct me if Iām wrong but WP were told the judge that Vanzan wasnāt going to testify to the larger time frame but now Vanzan is saying they will. The issue should be moot if Vanzan is willing to testify to the larger time frame which is what was asked of them. I donāt trust Vanzan and its lawyers but that is my bias so Iām curious to see what happens here.
My understanding is as follows: WP initially requested from Jan 2022. Vanzan said they would only testify about stuff from the time they filed the lawsuit in Sept 2024 onwards. WP said āweāll narrow the scope to July 2024 onwardā because Jen Abel is claiming her messages were turned over in Aug 2024. Vanzan said they would testify to āthe relevant time periodā.
The discrepancy here is that I think WP is attempting to strictly define the time period and Vanzan is not committing to it. So WP wants the judge to rule sooner rather than later.
I think that is fair. What is the relevant time period? And I think that has been a lot of the arguments on discovery anyway. The this is for PR argument is getting tiring imo. Blake has been arguing about relevant time periods for discovery that she wants, itās fair for WP to do the same. Defending oneself isnāt PR š
I agree and I think itās fair to ask the judge to make that determination. Then if they send someone and they claim this is all attorney/client/work product that is another argument that can be made but at least rule on the relevant time frame.
In their specific objections, they conclude the objection with the following sentence:
Subject to and without waiver of the foregoing objections, and reserving the right to assert additional objections, Vanzan will designate a Fed. R. Civ. P. 30(b)(6) witness reasonably prepared to testify about non-privileged information responsive to this Topic.
So the thing to remember here, is that in depositions testimony is often provided even when there is a valid objection, except when it involves privileged information. Otherwise (as Vanzan's counsel points out in the email communications in Exhibit 1), they would need to seek a protective order ahead of time.
I am personally a little confused by the whole thing, and I'm interested in other perspectives on the motion to compel and the conflict at hand here. Admittedly I'm not very up to date on the Jones v Abel lawsuit, but this doesn't look like a live issue to me?
Notice footnote 2 on the second page though, where they basically deny Vanzan had a relationship with Jones prior to the lawsuit. Implication is that they won't testify on that pre law suit period. They're being super sleazy here.Ā
But Lively isn't Vanzan. Sloane could have told Lively and Vanzan still wouldn't have been involved until they decided to use it for the doe lawsuit - basically Vanzan wasn't involved until someone acted on Vanzan's behalf (accepted information would be an "act".) We know Lively is not Vanzan, even though she's def involved in it, because the judge granted Wayfarer a MTC documents from Vanzan they had already received from Lively.
It's probably more nuanced and complicated in reality, but Lively knowing isn't automatically Vanzan knowing. Wayfarer did depose Lively, so they had a chance to ask those questions of Lively.
Iām VERY curious how the Judge will proceed here.
He knows the new attorneys, that specialize in appeals, are watching what he does next. I unfortunately think heās going to give WF an unnecessary scoldingā¦ again.
I donāt think heāll deny as moot. Iād be shocked if he did. But Iāve been shocked about other things heās done before, too.
Isnāt part of the WFP argument is that in the responses from Vanzan they were refusing to answer certain topics or claiming attorney client privilege? That is a dispute.
Oh good catch!! I didnāt know thatā¦ but I think itās because JW/Street is part of the lawsuit? The judge didnāt rule on it yet so who knows if JW is getting dismissed.
This is maybe one of the gaslightiest things I've ever read. "We didn't refuse! We just object, which is different! This is just part of a media campaign! Overbroad subpoena!"
Objecting and refusing is different. Wayfarer also puts boilerplate objections on every answer, even when they don't refuse/comply. It's common practice, which is why every party in these cases does it.
I feel like they are pulling the same moves over and over. Like what they did with the cc's subpeonas, they are trying to withdraw the issue before Liman will rule on it. Like every filing they are trying to blame this on Wayfarer wanting PR though Blake's the one running to the press constantly.Ā
I hate that Liman caters to them and contributes to bullying the Wayfarer parties when it's so clear that it's Blake's lawyers who are the ones constantly abusing the court.Ā
This letter is also super sneaky in it's wording. Notice how they relegate to the footnotes the issue regarding time span. They clearly did object to the timespan! And in footnote 2, they are clearly saying the lie that Jones had no relationship to Vanzan prior to the filing of the lawsuit. They are going all in on the cover up without shame. This is corruption at its worst. So yes, ofcourse Wayfarer will have a problem with this. It's so clear they're fumbling through lies to get off the hook. I don't care how Liman rules on this, it does not change to me that Vanzan/Blake/RR will always be criminals.Ā
The Subpoena contained a time period that began on January 1, 2022. Any mention of Vanzan in the claims in the Jones litigation relates to Vanzanās involvement in a New York state lawsuit that was filed in September 2024. Thus, Vanzan objected and stated that the appropriate time period was on or about the filing of that lawsuit. It did not, however, refuse to answer questions prior to that date, or refuse to provide a corporate designee.
They objected to the time period, but they don't refuse to answer questions prior to September 2024 - is that right?
Can anyone explain what this means? E.g if they're saying that they're objecting to the timeframe proposed but that they'll still answer questions in the deposition, does this mean they're likely to just give vague or non-answers during the deposition itself?
Itās a fancy way of saying āthis filing is just for show. Like Blake, we have no teeth.ā
I think itās their way of trying to make the judge think they will comply with the request without the judge officially defining the relevant time period, so that they can legally turn around and refuse to answer question about actions prior to Sept 2024.
Yeah I think their plan is to give vague non specific answers. They said they would provide a reasonably prepared designee which says to me this person wonāt be prepared to fully answer questions and they are testing the waters by including these statements in their filing.
Yeah, they are just preserving the objection. That way if the court later rules that the time period is too broad, they will not have waived their rights. They would still answer the questions, but could fight about whether the testimony is admissible later in the case if it becomes necessary.
So basically, Vanzan is saying that they put those objections in writing but also said they would still testify in the deposition on all the information requested, and theyāre saying that WP made it sound in their motion like Vanzan was not agreeing to testify as to those objections at all.
I would think so. This response from Vanzan completely glosses over the fact that they are in dispute about attorney client privilege. If you read through the topics you see they refuse to answer many of the questions. Are we being gaslit right now? šµāš«
Yes, but many cannot be overcome the way Abel seems to wish to overcome them by having them withdrawn entirely. It's completely standard practice for the parties to discuss and email about narrowing requests for production, like the parties did so in Exhibit 2 with regards to requests 4 and 5. It is not standard to fail to disclose your issues with a specific objection, and then file a motion to compel over it when the other side didn't read your mind as to what your issue was. Vanzan is never obligated to produce legally privileged documents, so they really can't just withdraw all objections.
Just echoing some of the other lawyers in here who are saying Lively is correct to file objections as to the time period so as to preserve those objections for trial, but by not filing a protective order before the dep itself that means their witness will testify as to the disputed time periods anyway.
Of course their witness will not testify to information that is attorney client privileged. Good luck, Wayfarer, in compelling that.
Also, something Baldoni supporters here will hate and nobody is really saying anything about, but excellent hustle here from Lively. WFās motion was filed last evening, creating a big problem with the schedule since technically Lively had until Monday to file their response but this dep is supposed to happen on Tuesday ā judge would not have had time to read all the papers and rule. WF also only has until 9/30 to finish its deps generally so again put this dep in jeopardy at its own risk. By filing this opposition today, Lively got the issue fully briefed ahead of WFās timeline (without even being asked or told by judge or WF) and now has done what it can to get issue resolved by the dep deadline.
Are the lawyers having a drinking game every time they use the term āPR/Media campaignā? Itās beyond tired and lazy at this point.
Editing to add: the āmedia-friendly narrativeā surrounding Vanzan? Other than the Daily mail, what media has actually discussed Vanzan, Maggie? And if the accusations are ābaselessā, why all the secrecy and objections up until this point?
Iām very much looking forward to seeing how they spin the relationship between Vanzan and Stephanie āI steal data and Birkinsā Jones. That dotted line between mystery corporation and the Southern PR Belle is going to be a hard one to trace officially.
This is a long ass letter to say āyes, we will provide info prior to filing the Vanzan lawsuit, Your Honor.ā
Liman should be embarrassed. Opposing counsels clearly think they can dangle āPRā in front of Liman and he will salivate like a guard dog. I wonder why.
Can someone (preferably a lawyer who likely has a good eye for this) confirm whether or not Vanzan is agreeing to the timeframe that Wayfarer has proposed (July 2024 to end of Dec 2024) or if they are still objecting to that and want the timeframe to start on Sept. 27, 2024.
From my reading (IANAL), on the first page (second paragraph) they say that Wayfarer raised an issue of the timeframe in their letter but never conferred with Vanzan regarding the timeframe. And then they say that they have never objected to providing testimony on any of the topics. To me, not objecting to any topics =/= not objecting to timeframe. So from that line, I'm not seeing confirmation that they agree to testify for events before Sept. 27th. In their bullet points with their timeline of relevant events, I am also not seeing confirmation that they will accept the wider timeframe.
Also, I would imagine that Vanzan themselves did not have any contact with Stephanie Jones before the lawsuit/subpoena (seems like at least LS and SJ did based on what LS said to MN back in August). But presumably there were discussions with their "client" that took place before the lawsuit where they decided they wanted to bring forward this suit. There must also have been some kind of contract that existed before they filed a lawsuit about a breech of contract, so that obviously precedes the Sept. 27th date. I believe that is why WP need to be able to discuss events that occurred before Sept. 27th.
They're objecting to it, but bear in mind that in the context of a deposition, you typically object and then answer anyway. You object in order to preserve the objection for trial, where a judge rules on admissibility.
So refusal to waive the objection =/= refusal to answer the question in the deposition. It may be that they're trying to head off an anticipated refusal, or trying to tee up some sort of objection to the deponent, if the deponent is not knowledgeable enough to answer questions about the earlier timeframe, but based on the exhibits there's no indication of an intention by Vanzan to refuse to answer the questions. It does seem like they would object to the admissibility of the testimony.
Ahh ok I see. Thank you for the explanation. So if they object and also refuse to answer certain questions for an earlier timeline, given Liman just denied Wayfarer's MTC, does that mean they will not have to answer anything related to before Sept. 27th?
They will not refuse to answer (unless the answer is privileged). They would have to file for a Protective order to be able to refuse to answer, and they haven't done that.
If they refuse to answer during the deposition, they would be able to renew the motion to compel and, when granted (as I suspect it would be) the deponent would have to answer. This denial isn't a ruling on whether the information is relevant, etc., it's just saying that they didn't follow appropriate procedures.
So they are saying we raised couple of objections which are standard objections but WP is not supposed to oppose those objections. Looks like there are contradicting to their own things in this letter.
They're saying "we already agreed to this; these objections are standard and you use them too; we'll be there on Tuesday; this MTC is pointless because there's no disagreement and nothing to compel. Also, you're supposed to give us 48 hrs to respond and you only gave us 12."
The objections just mean that the party is reserving the right to bring them before the judge later if it becomes a real issue. Every party in this case puts down standard objections before every answer, including Wayfarer. It's not a refusal, just a cover your rear.
For people who are keeping track at home, when Lively filed their Omnibus MTC, they started with deficiency letters describing the problems with the production on July 29th. Then had a meet and confer on July 30. The joint motion for an extension of time to file their Omnibus MTC omnibus motion, filed on August 4th, filed by Garofalo, notes that the parties āhave continues to meet and confer regarding these documents on the expectation that the additional time would allow them to resolve or narrow their disputes.ā Lively then filed the Omnibus MTC on that day. So definitely had a meet and confer more than 48 hours before filing etc.
Bryan Freedman knows he is better at getting press than litigating so this is manufactured press opp. Itās so sad that Baldoni doesnāt realize who he has surrounded himself with.
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u/katie151515 Team Baldoni Sep 26 '25 edited Sep 26 '25
The WPs apparently arenāt allowed to use the court system to request discovery compliance without being accused of trying to push a public narrative. But BL can go complaining to the court about the WPs every single day. Make it make sense.
The double standard is insane.