
Happy Fourth of July 🇺🇸
Have fun and stay safe ❤️

Have fun and stay safe ❤️
With these news outlets and Baldoni supporters saying Blake and Ryan ran away from NYC because of the Taylor Swift celebration and using this as proof they aren’t friends. Anyone with two brain cells should realize that a) Swift and Kelce already married in a smaller ceremony elsewhere, and b) the event BL and RR were attending for their daughter was at 8 AM just 4 hours upstate!!! Like parents can do things with their kids in the morning and then make it to events in the evening!!! This shouldn’t bother me as much as it does. I just want PROOF that they are invited and attending so I can shove it down peoples throats who’ve been using it as a tool to crap on Blake!!! 😤
According to the Federal Judicial Center website, "The D.C., First, Second, Seventh, and Tenth Circuits require contemporaneous fee records, and may substantially reduce or even deny a fee award in their absence."
Crucially for this case, the Second Circuit has determined that computer reconstructions of contemporaneous records, typewritten transcriptions of original entries, or typed listings of hours printed from computer records are fully adequate to satisfy the rule—provided they are based on entries made contemporaneously as the work was completed.
This is exactly what Lively’s legal team did. In her sworn declaration, attorney fee expert Diana Kantner states that she reviewed and analyzed the invoice spreadsheets provided to her by counsel, which perfectly reflect the same information in the monthly invoices prepared for Ms. Lively.
Procedurally, this is all that is required to file a fee motion. The actual raw, redacted invoices do not need to be produced upfront unless the fees are formally disputed or requested by the judge.
So why would Lively hire a third-party fee expert to do this?
It’s a classic "damned if you do, damned if you don't" strategic scenario, but hiring an outside expert is a total no-brainer:
An outside expert provides a layer of professional objectivity that carries significantly more weight with the Court. The Wayfarer camp is having a meltdown and will undoubtedly attack how the data was filtered, but Lively’s counsel can simply point to Diana Kantner's independent credentials and let her data speak for itself.
Blake's incredible legal team!
Esra Hudson declaration: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.0.pdf
Michael Gottlieb declaration: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1447.0.pdf
Peer firm data: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1447.2.pdf
Stephanie Roeser: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.2.pdf
Matthew F. Bruno: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.3.pdf
Sarah E. Moses: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.4.pdf
Katelyn Climaco: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.5.pdf
Diana Kantner is a Vice President at KCIC, a consulting firm specializing in dispute resolution support, litigation consulting, and expert testimony. She has more than 20 years of professional experience handling complex insurance claims, economic and financial analyses, damage quantification, and allocation modeling. Prior to joining KCIC, she spent over a decade as a managing director at The Claro Group and served as a director of financial management for Northwestern University’s Feinberg School of Medicine.
Diana's declaration: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1448.0_1.pdf
Diana's C.V: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1448.1_1.pdf
Diana Kantner was hired to examine and analyse the billings of the two law firms hired by Lively, Manatt, Phelps, and Phillips LLP and Wilkie, Farr, and Gallagher LLP.
Summary of fees and costs: https://www.courtlistener.com/docket/69510553/1448/2/lively-v-wayfarer-studios-llc/
Look at April 5th, 2025, Melissa Taustine billed $15,555.00 for 12.2 hours in a single day for researching and drafting the Rule 11 sanctions for the Wayfarer Parties.
Introduction.
Esra points out that Wayfarer's lawsuit was a "gross misuse of the legal system," that it was never meant to win in court. It's purpose was to retaliate against Blake by falsely branding her a liar, intimidating witnesses and media and discouraging others from speaking out. She states the Wayfarer Parties have since admitted Blake's claims were "protected activity" that deserved "to be heard." Esra did not hold back, "The Wayfarer Parties employed scorched earth tactics designed to drain Lively's resources, including a near daily press campaign promoting their sham lawsuit, propounding expansive and irrelevant discovery demands, obstructing discovery directed at them and affiliated third parties, and forcing Lively to seek frequent relief from the court to reign in their abusive docket filings." YIKES!
Relevant Background.
Esra lays it all out here, that Wayfarer's lawsuit was nothing more than a malicious, multi-million dollar PR stunt rather than a lawsuit.
She calls Wayfarer's complaint filed on January 16th 2024 an "unhinged rant," filled with no conceivable legal purpose other than to falsely brand her a liar.
The Smear Campaign Website, was to sensationalise the case and destroy her image. She points to the unsealed signal messages where the Wayfarer Party was gloating about the website launch.
The court consolidated Wayfarer's suit and Lively's affirmative lawsuit into a single action due to the common legal issues. Lively filed 15 motions to compel during the discovery process, as she was met with "extreme resistance" at every turn.
Wayfarer failed to produce necessary files, improperly hid behind attorney-client privilege, and straight up destroyed relevant evidence (resulting in a motion for spoliation sanctions).
Wayfarer used the public docket to smear Blake and her attorney's, drawing a warning from the court "that future misuse may be met with sanctions."
The Wayfarer Parties lawsuit was dismissed in it's entirety by the court in June 2025, slamming it for a severe "lack of clarity," and relying on "dramatised allegations."
Because the claims were so egregiously baseless, Blake served the Wayfarer team with Rule 11 Safe Harbor letters, demanding they withdraw them. When they refused to defend the merits of their claims, the court granted Blake's Rule 11 motion on the 27th March, 2026. Judge Liman concluded their was "no conceivable basis" for five of the seven claims and formally reprimanded Wayfarer's "high priced" lawyers for pushing claims that were "legally frivolous and factually baseless." This will forever be my favourite quote!!
Argument
1. Blake is seeking $8,035,040.88 in fees and costs for her successful litigation defense. This figure represents the expenses incurred and work performed by Blake's counsel to that end, specifically, the fees and costs related to (i) motion practice associated with Wayfarer's lawsuit including, but not limited to, the prevailing MTD, Rule 11 motion, and motions to compel; (ii) work performed associated with the consolidated action as a whole, including discovery through deadline for the Wayfarer Parties to amend their pleading that was relevant to both actions; and (iii) Lively's 47.1 motion, including this application.
2. Based on the provided legal documents, the excerpt argues that under California Civil Code Section 47.1, the apportionment of defense costs by individual claim is not permitted because the statute applies broadly to the successful defense of "the litigation" as a whole. Because Lively successfully secured the dismissal with prejudice of all claims brought against her in the Wayfarer Action, she is entitled to full recovery of her attorney's fees and costs, including those incurred while preparing the fee motion. Furthermore, because the legal work between her defense in the Wayfarer Action and her prosecution of the Lively Action is "inextricably intertwined," no apportionment is legally required. Ultimately, counsel for Lively assert that the requested attorney's fees totaling $7,495,526.87 are reasonable under the "lodestar method" applied by California courts.
Esra argues that the requested attorney's fees are entirely justified based on the reasonableness of both the hourly rates and the hours billed. First, it asserts that the hourly rates are standard for the market and aligned with the counsel's specialised experience; the fact that Lively actually paid these fees serves as strong judicial evidence of their reasonableness. Second, they maintain that courts should defer to the professional judgment of the winning lawyers regarding hours expended, especially given the novel, high-quality, and complex nature of the Employment and First Amendment issues that required hiring two specialised law firms. Finally, the requested total of $7,495,526.87 is presented as an eminently reasonable amount because Lively achieved a complete victory, the recently enacted Section 47.1 required extensive research with little prior precedent, and the defense faced aggressive discovery without a stay alongside the litigation of Rule 12 motions.
Conclusion
Lively respectfully requests the court award her reasonable attorney's fees of $7,495,526.87 and costs in the amount of $539,526.01.
Monday's filing is likely to be one of the most significant remaining public filing's in the litigation because it will put an actual dollar amount on the fee award the court has already determined Blake is entitled to recover. The only real question left is how much.
What we can expect to see:
Blake's attorneys will likely ask for a specific amount, which will be broken down into attorney's fees, litigation costs, and potentially fees on fees (time spent litigating the motion itself), if they contend those are recoverable under California Law.
Detailed billing records
I expect some information to be redacted to preserve attorney-client privilege and work product but to support the request they will likely need, attorney declarations, billing summaries, hourly rates, hours worked, and expense records.
An argument about the scope of recoverable fees
Judge Liman specifically noted that the parties would need to address apportionment, in other words, which legal work was performed defending the dismissed defamation claims versus work on claims that are not fee shifting. He indicated that fees on common issues may be recoverable where the work cannot be reasonably separated.
Blake's team will likely argue that much of the discovery overlapped, many motions addressed multiple claims simultaneously, separating every billing entry would be artificial, and California fee shifting allows recovery for intertwined work.
I am not a lawyer so i couldn't possibly guess how much it will be, but i am confident its going to be 7 figures and not $200,000 like many on the other side are claiming. I'm also wondering if Lively will ask for recovery through the date of settlement, or also seek fees incurred after settlement litigating the §47.1 issue itself.Judge Liman left room for further briefing on the proper measure of fees, so her memorandum may address whether those post-dismissal and post-settlement efforts are compensable under California's fee-shifting principles. That could have a meaningful impact on the final award.
Brief: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1446.0.pdf
Exhibit 7: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.7.pdf
Exhibit 6: storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.6.pdf
There are more filings but they are not available yet.
She really suits glasses 😍
Those following this lawsuit are aware that there has been a legal aspect to the case and a PR aspect. Sometimes, it’s been hard to separate the two.
I want to highlight on particular example of the social media manipulation surrounding the lawsuit. I have seen multiple posts and comments about Ryan Reynolds’ alleged involvement in a stunt person’s death on the set of a film he was involved with. It’s an incredibly sad situation as I’ve seen it reported and so I hope any comments here will reflect that.
I revisited Justin Baldoni’s deposition this week and I noticed that he raised an issue about a stunt person dying on set. I can’t think of a reason for him to raise that issue except that he was instructed to raise it by his team because it fed into the PR aspect.
I’ve shared the relevant page in Justin Baldoni’s deposition. Let me know if you see what I see (or not).
I am obsessed with these photos, especially the first one 😍
I hope you all have a lovely weekend! ❤️
Good to see, hope this continues!