Blake Lively is suing her It Ends With Us co-star Justin Baldoni for sexual harassment and a campaign to “destroy” her reputation, months after the release of their box office hit.
The 37-year-old plays Lily Bloom in the film based on the TikTok sensation, It Ends With Us, a novel by Colleen Hoover. Baldoni, who directed the film, stars as Ryle Kincaid, her abusive partner.
Rumours of an on-set feud had been percolating online, as the pair appeared to avoid each other during the film’s promotional tour. Lively was called out for a “tone-deaf” approach to the movie, as some felt she failed to treat its heavy subject matter with the appropriate solemnity.
However, the lawsuit also alleges that fan backlash was part of a carefully orchestrated effort by Baldoni’s PR team, whose lawyers have counter-alleged that Lively’s lawsuit is likewise an attempt to “fix her negative reputation”.
Baldoni is a married father-of-two and has positioned himself as an avid supporter of women’s rights, adding further fuel to the controversy. He has since had an award for being an “ally to women” rescinded.
The actor and director is suing The New York Times for $250m, and he is countersuing Lively and her husband Ryan Reynolds for allegedly attempting to “destroy” his reputation and career.
January 2023 – Casting for It Ends With Us is announced
After the success of Hoover’s bestseller, Baldoni optioned the story for a film adaptation through his company, Wayfarer Studios, in January 2019. Lively was cast as the lead in the film in January 2023, with Baldoni starring alongside her.
Hoover was excited by the prospect of both as she wrote on Instagram at the time, “Our Lily is going to be played by Blake Lively – Blake Lively y’all! She’s my dream Lily. And then when I first met Justin Baldoni, who is directing the film for us, I immediately wanted him to be Ryle. I just thought that he had what it takes to play that character. And the good news is, he’s going to be Ryle – so we have our Ryle and our Lily.”
May 2023 – Filming is halted amid strikes
Filming began in Hoboken, New Jersey in May 2023, but was halted shortly thereafter because of the Hollywood Writers and Actors Guild strikes. It remained on pause at the time of the SAG-AFTRA strikes in July. Shooting resumed in January 2024.
Watch Apple TV+ free for 7 days
New subscribers only. £8.99/mo. after free trial. Plan auto-renews until cancelled
Watch Apple TV+ free for 7 days
New subscribers only. £8.99/mo. after free trial. Plan auto-renews until cancelled
9 August 2024 – It Ends With Us is released, Baldoni praises Lively
The film was released in August, with Baldoni praising Lively as “strong, funny and intelligent — all the things you want from a female heroine”. He added, “There wasn’t a part of this production that she didn’t touch and have an influence on. And everything she put her hands on and her mind to, she made better.”
It goes on to be a box office success, grossing a worldwide total of $351m (£291m).
13 August – Feud rumours circulate as Lively and Baldoni avoid each other, director hires Johnny Depp’s crisis management PR firm
Rumours of a feud start circulating on social media as Baldoni and Lively avoid each other during the film’s promotion. Internet sleuths notice that the stars do not follow each other on social media, with many of the film’s cast following Lively but not Baldoni. Hoover also notably keeps her distance from Baldoni.
TMZ alleged that the cause of the rife was a result of “fat-shaming”, inappropriate comments and Baldoni kissing for too long during scenes. There had also been rumours online that the rift had been caused by Lively and her Deadpool and Wolverine husband, Ryan Reynolds, being too involved with the film.
Baldoni hires crisis management and PR professional Melissa Nathan, whose previous clients include Johnny Depp, Drake and Travis Scott, according to Deadline. Nathan represented Depp during his successful defamation trial against Amber Heard, which occurred during rumours of an organised social media campaign against her.
15 August – Lively faces backlash for ‘tone deaf’ marketing
Lively, known for her upbeat demeanour and comedic rapport with husband Ryan Reynolds, begins to face backlash online for a “tone deaf” approach to the movie’s marketing.
Criticism focused on Lively promoting her new haircare line during her movie tour, encouraging cinemagoers to “bring their florals” in an echo of the “wear pink” trend around Barbie last year, and for avoiding explicit mention of domestic violence.
Hundreds of social media critics flooded Lively’s comments, suggesting that she had misread the room. Commercial tie-ins promoting the film have also raised eyebrows, including the actor’s themed cocktails. One is called the “Ryle You Wait” and is named after a character in the film who throws Bloom down the stairs.
Following the criticism, Lively shared a message to her Instagram stories on Tuesday (13 August) writing: “One in 4 women aged 18 and older in the US alone have been the victim of severe physical violence by an intimate partner in their lifetime.”
Her co-star Brandon Sklenar defends Lively amidst what he calls the “disheartening” backlash, after a clip of an interview with the two of them also goes viral.
15 August – Interview with journalist Kjersti Flaa resurfaces
Amid the criticism surrounding Lively, a Norwegian journalist, Kjersti Flaa, posted a clip of a 2016 interview with the actor, which made her “want to quit” her job.
The sit-down was in promotion of Lively’s film Café Society, directed by Woody Allen. Lively was accompanied by her co-star Parker Posey.
Sharing the clip to YouTube, Flaa titled the video: “The Blake Lively interview that made me want to quit my job.”
Flaa began the interview by congratulating the actor on her “little bump” after which Lively sarcastically responded: “Congrats on your little bump.”
Speaking about the film, the journalist said she found it “visually amazing” and asked whether Lively and Posey enjoyed the fashion, which played a big role in a film set in the 1930s.
Lively is then seen ignoring Flaa, and instead turns to Posey to says: “Everyone wants to talk about the clothes, but I wonder if they would ask the men about the clothes.”
9 December – Baldoni awarded at Vital Voices event celebrating men who ‘elevate women’
Baldoni was awarded a 2024 Voices of Solidarity Award from Vital Voices, a non-profit organization dedicated to ending sexual and domestic violence. The star-studded event was dedicated to celebrating men who “elevate women, combat gender-based violence and promote gender equality worldwide.”
21 December – Lively files bombshell lawsuit against Baldoni alleging sexual harassment
In the lawsuit, obtained by TMZ, Lively claims Baldoni exhibited behaviour that caused her “severe emotional distress”.
The lawsuit states there was a meeting attended by individuals including Lively, her husband Ryan Reynolds, Baldoni and their lawyers, to address The Age of Adeline star’s claims, per TMZ.
Lively had a number requirements in order for her to work on the film that – according to the lawsuit cited by the outlet – included “no more showing nude videos or images of women to Blake, no more mention of Baldoni’s alleged previous ‘pornography addiction,’ no more discussions about sexual conquests in front of Blake and others, no further mentions of cast and crew’s genitalia, no more inquiries about Blake’s weight, and no further mention of Blake’s dead father.”
Additionally, “no more adding of sex scenes, oral sex or on camera climaxing by BL outside the scope of the script BL approved when signing onto the project,” were other requirements included in the lawsuit, according to TMZ.
Per the outlet, the lawsuit says that the distributors of the film, Sony Pictures, approved Lively’s requests. However, the actor claims in the filing that Baldoni then began a campaign to “destroy” her reputation in response.
Baldoni’s lawyer, Bryan Freeman, told TMZ that Lively’s lawsuit had been filed in order to “fix her negative reputation”.
He added to the outlet that the A Simple Favour star’s allegations are “false, outrageous and intentionally salacious with an intent to publicly hurt.”
The lawyer added that Lively had caused issues on the film set by “threatening to not [show] up to set, threatening to not promote the film, ultimately leading to its demise during release.”
22 December – New York Times investigation alleges PR campaign orchestrated to ‘bury’ Lively
Private messages obtained by The New York Times appear to show an intentional attempt to “bury” Lively.
The battle over creative control was pitched as an idea for talking points during the press campaign, but Baldoni is said to have wanted more, as he said “Not sure I’m feeling the protection I felt on the call”, following a conversation according to the report.
“You know we can bury anyone,” Baldoni’s PR Nathan is alleged to have said, per The New York Times.
Baldoni is said to have sent examples of a viral social media thread accusing another celebrity of bullying writing, “This is what we would need.”
The Times alleged, “Ms Nathan soon floated proposals to hire contractors to dominate social media through ‘full social account takedowns,’ by starting ‘threads of theories’ and generally working to ‘change narrative.’
“‘All of this will be most importantly untraceable,’ she wrote.”
When approached by The Times, Flaa denies that she was involved in an organised smear campaign against Lively. Addressing the situation further in a new YouTube video, Flaa said that she would “never take money to jeopardize my integrity as a journalist.”
22 December – Baldoni dropped by talent agency
Baldoni, previously represented by the WME agency, parted ways with the actor following Lively’s lawsuit, per The Hollywood Reporter.
Lively – who is also repped by WME along with her husband, Ryan Reynolds – accused Baldoni of sexual harassment and alleged the actor had launched a campaign to “destroy” her reputation.
23 December – Hollywood stars come out in support of Lively
Colleen Hoover, Gwyneth Paltrow, America Ferrera, Amy Schumer, and Paul Feig share messages supporting Lively and stand with her in the aftermath of the allegations being made public. Lively’s sister and actor Robyn also weighed in as she wrote, “FINALLY, Justice for my sister Blake Lively”.
In a statement, Lively said, “I hope that my legal action helps pull back the curtain on these sinister retaliatory tactics to harm people who speak up about misconduct and helps protect others who may be targeted.”
See the full list of celebrities supporting Lively here.
23 December – Baldoni’s lawyers respond to sexual harassment lawsuit
Bryan Freedman said in a statement, “Audiences found Lively’s own actions, interviews and marketing during the promotional tour distasteful, and responded organically to that which the media themselves picked up on”, according to People.
He defended the PR company involved saying, “TAG PR operated as any other crisis management firm would when hired by a client experiencing threats by two extremely powerful people with unlimited resources.”
23 December – Lively unable to make Saturday Night Live appearance due to lawsuit
In the Gossip Girl alum’s complaint, her lawyer claimed she was unable to continue with other work because of the backlash she was receiving as a result of Baldoni’s campaign.
This purportedly included the opportunity to host the season 50 premiere of SNL on September 28, 2024, which was instead hosted by Jean Smart. The Independent has contacted NBC for comment.
24 December – Baldoni has Award for being ‘ally to women’ rescinded
In a statement shared on their social media and website, Vital Voices stated that the lawsuit, which “alleges abhorrent conduct” stands “contrary to the values of Vital Voices”.
“The communications among Mr Baldoni and his publicists included in the lawsuit – and the PR effort they indicate – are, alone, contrary to the values of Vital Voices and the spirit of the Award.
“We have notified Mr Baldoni that we have rescinded this award.”
24 December – Lively and Baldoni’s It Ends With Us co-star addresses lawsuit claims
Brandon Sklenar, who plays Lively’s teenage love interest in It Ends With Us, shared a link to her lawsuit and captioned the Instagram post: “FOR THE LOVE OF GOD READ THIS,” adding a red heart emoji while also tagging Lively.
24 December – Baldoni’s podcast co-host leaves show amid lawsuit
Journalist and author Liz Plank, longtime co-host of The Man Enough Podcast, announced her departure following allegations of misconduct leveled against co-host Justin Baldoni by his It Ends with Us co-star Blake Lively.
“As this chapter closes for me, I remain committed to the values we’ve built together,” Plank said. “We all deserve better, and I know that together, we can create it.
25 December – Baldoni’s former publicist sues him over breach of contract
Stephanie Jones files a lawsuit against Baldoni for breach of contract, linking her dismissal to the alleged smear campaign against Baldoni’s It Ends With Us co-star Blake Lively.
27 December – Ryan Reynolds hints at difficult time in first post since feud became public
Lively said negative press also affected her husband, Deadpool actor Reynolds, whom she married in 2012, and their four children.
While Reynolds has not addressed the furore directly, he hinted at a difficult time in the post, which saw him appear in character as the Marvel antihero for a short clip that co-starred Wonder Woman actor Lynda Carter.
In the caption, he suggested that recent experiences had eaten away at him, calling it a time where he “really didn’t feel like putting the suit on”.
31 December – Baldoni’s lawyer hints they will file ‘explosive’ countersuit
The Daily Mail reported that “an explosive counter lawsuit will be filed by Baldoni” on January 2. The publication reported that the legal document, which Baldoni’s attorney Bryan Freedman has been preparing, claims Lively’s Vision PR team was responsible for smears against Baldoni, not the other way round.
Freedman told Deadline that he could not confirm when the lawsuit would be filed, but that it would contain some surprises.
“I am not going to speak to when or how many lawsuits we are filing but when we file our first lawsuit, it is going to shock everyone who has been manipulated into believing a demonstrably false narrative,” the lawyer said. “I will be supported by real evidence and tell the true story.”
1 January – Baldoni sues The New York Times for $250m, claims Reynolds ‘aggressively berated’ him
Baldoni and nine other plaintiffs including publicists Melissa Nathan and Jennifer Abel brought a $250m lawsuit against the newspaper alleging libel and false-light invasion of privacy.
The suit, which has been seen by The Independent, was filed in Los Angeles Superior Court and claims that the Times reporting “‘cherry-picked’ and altered communications stripped of necessary context and deliberately spliced to mislead.”
He claims he was “aggressively berated” by Reynolds after Baldoni, who suffers from back problems, asked Lively how much she weighed before he lifted her, “to ensure he could safely perform the lift without injury.”
1 January – Lively officially sues Baldoni
The Hollywood star, 37, initially filed a legal complaint in December that detailed the claims against her co-star and director, with whom she had been rumoured to have clashed while shooting the adaptation of Colleen Hoover’s best-selling 2016 novel.
In the lawsuit filed on 1 January in New York federal court, Lively accused Baldoni and his PR team of organising a sophisticated scheme to undermine her reputation, in retaliation for speaking up about alleged misconduct on set.
2 January –New York Times and Baldoni’s lawyers respond
In a statement to The Independent, a New York Times spokesperson said: “The role of an independent news organization is to follow the facts where they lead.
“Our story was meticulously and responsibly reported. It was based on a review of thousands of pages of original documents, including the text messages and emails that we quote accurately and at length in the article. To date, Wayfarer Studios, Mr. Baldoni, the other subjects of the article and their representatives have not pointed to a single error. We published their full statement in response to the allegations in the article as well.
“We plan to vigorously defend against the lawsuit.”
In a separate statement, Baldoni’s attorney Bryan Freedman told The Independent: “In this vicious smear campaign fully orchestrated by Blake Lively and her team, the New York Times cowered to the wants and whims of two powerful ‘untouchable’ Hollywood elites, disregarding journalistic practices and ethics once befitting of the revered publication by using doctored and manipulated texts and intentionally omitting texts which dispute their chosen PR narrative.
“In doing so, they pre-determined the outcome of their story, and aided and abetted their own devastating PR smear campaign designed to revitalize Lively’s self-induced floundering public image and counter the organic groundswell of criticism amongst the online public. The irony is rich.
“Make no mistake however, as we all unite to take down the NY Times by no longer allowing them to deceive the public, we will continue this campaign of authenticity by also suing those individuals who have abused their power to try and destroy the lives of my clients. While their side embraces partial truths, we embrace the full truth – and have all of the communications to back it. The public will decide for themselves as they did when this first began.”
17 January – Baldoni countersues Lively and Reynolds for $400m
After weeks of threatening to countersue Lively and Reynolds, Baldoni finally filed a $400m lawsuit against the couple for allegedly attempting to “destroy” his reputation and career.
In the suit, Baldoni accused Lively and Reynolds of civil extortion, defamation, false light invasion of privacy, breach of implied covenant of good faith and fair dealing, intentional interference with contractual relations, intentional interference with prospective economic advantage, and negligent interference with prospective economic advantage.
“This lawsuit is a legal action based on an overwhelming amount of untampered evidence detailing Blake Lively and her team’s duplicitous attempt to destroy Justin Baldoni, his team and their respective companies by disseminating grossly edited, unsubstantiated, new and doctored information to the media,” Baldoni’s lawyer, Bryan Freedman, shared in a statement with The Independent.
“It is clear based on our own all out willingness to provide all complete text messages, emails, video footage and other documentary evidence that was shared between the parties in real time, that this is a battle she will not win and will certainly regret. Blake Lively was either severely misled by her team or intentionally and knowingly misrepresented the truth.”
When reached for comment, Lively’s legal team told The Independent that Baldoni’s lawsuit was “another chapter in the abuser playbook”.
“This is an age-old story: A woman speaks up with concrete evidence of sexual harassment and retaliation and the abuser attempts to turn the tables on the victim. This is what experts call DARVO. Deny. Attack. Reverse Victim Offender,” they said.
21 January – Baldoni releases ‘damning’ video and Lively hits back
In an attempt to prove Baldoni’s innocence, his legal team released a seven-minute-long video showing Lively and Baldoni’s interaction while shooting a dance scene in the film.
The clip revealed their conversation was mostly professional, with the unedited footage showing the moment, previously highlighted by Lively, that saw Baldoni kiss her neck while commenting on Lively’s scent. In the clip, Baldoni said Lively “smells good” in response to concerns she was getting spray tan on him.
Following the clip’s release, Lively swiftly shared her own statement in response to the unedited footage released by Baldoni’s production company Wayfarer and his lawyer Bryan Freedman, calling it “damning” evidence supporting her allegations.
“Justin Baldoni and his lawyer may hope that this latest stunt will get ahead of the damaging evidence against him, but the video itself is damning,” Lively’s legal team told MailOnline, who obtained the video.
According to Lively’s legal team, “every frame of the released footage corroborates, to the letter, what” the actor “described” in her original complaint.
Addressing the contents of the clip, Lively’s team said the actor was uncomfortable during the filming of these scenes due to Baldoni “attempting to kiss her, kissing her forehead, rubbing his face and mouth against her neck, flicking her lip with his thumb, caressing her, telling her how good she smells, and talking with her out of character”.
“Every moment of this was improvised by Mr Baldoni with no discussion or consent in advance and no intimacy coordinator present. Mr Baldoni was not only Ms Lively’s co-star, but the director, the head of studio and Ms Lively’s boss,” they added.
25 January – Baldoni’s sister breaks silence to praise his ‘dedication to truth’
Baldoni’s younger sister, Sara, shared her first Instagram post in over a year to celebrate the actor’s 41st birthday.
“Happy birthday JB,” she wrote in the caption. “I love you and I celebrate you – the man you are, the love you embody, the strength of your connection to God, the essence of your being, your dedication to truth, to service and to love – today and all days.”
Sara added: “I am so proud to call you my big brother and annoyingly squeeze the hell out of you until the end of time.”
Her post came days after Baldoni’s wife, Emily, also broke her Instagram silence to honor the Jane the Virgin alum on his January 24 birthday.
“Happy birthday my love. Celebrating the man, husband, and father that you are. I’d choose you again and again,” Emily wrote alongside a photo of them and their two children on a beach.
27 January – Baldoni apologises to Lively in leaked voice memo
In a leaked voice memo that Baldoni allegedly sent to Lively during the production of the movie, he can be heard apologising to his co-star.
The nearly seven-minute-long audio message is believed to have been sent after Baldoni questioned changes Lively made to a rooftop scene – months before their explosive lawsuit.
Baldoni’s response to the edits Lively had made to a pivotal scene in the movie led the upset actor to express her disappointment with Baldoni, for which he said he was “really sorry”.
“Man, reading the second part of your message, my heart sank and I’m really sorry. I, for sure, fell short and you worked really hard on that,” Baldoni said in the voice note.
“I feel really grateful that you feel safe enough to tell me that that’s how you feel and share that with me. And I’m really sorry. I f***ed up. That is a fail on my part.”
In the message, which Baldoni said was sent at 2am, he said he is “far from perfect”, adding: “I’m a very flawed man, as my wife will attest. But I will always apologise and then find my way back to centre. That is one thing I can assure you of. And I’m sorry I made you feel that way – that must have felt terrible.”
28 January – Trial date set
Within hours of the audio message’s release, New York federal judge Lewis J. Liman informed both parties to prepare for a March 9, 2026 trial.
He also moved an initial conference from mid-February to early February and told lawyers to be prepared to address complaints about pretrial publicity and attorney conduct.
Liman took the actions after Lively’s lawyers claimed in a filing on Monday (January 27) that an attorney for Baldoni was trying to taint potential jurors over lawsuits the actors have filed against each other.
30 January – Lively and Reynolds ask for Baldoni’s lawsuit to be dismissed
The couple’s attorneys filed a notice on January 30 stating that they will seek to dismiss Baldoni’s counter lawsuit. This is in compliance with Judge Lewis Liman’s order, which outlined how the case will proceed.
The judge had reportedly asked for a letter that would “indicate in one sentence the Defendant’s intent to make a motion to dismiss”. Liman will later set a deadline for when to file the motion.
Following the judge’s instruction, lawyer Michael J Gottlieb said: “The Lively-Reynolds Parties intend to move to dismiss Plaintiffs’ complaint.”
Leslie Sloane, who is a publicist for Lively and Reynolds and was also named as a defendant in Baldoni’s lawsuit, submitted a similar statement to the court on January 29.
Baldoni’s team said that they are eager to take Lively’s deposition as soon as possible but claimed that her representatives have indicated that they don’t want his lawyer, Bryan Freedman, to do the deposition due to “unspecified statements made by Mr Freedman”.
1 February – Baldoni launches website with fresh claims about the case
Days before the first court hearing on the case, Baldoni’s team launched a website containing two legal documents about the dispute with Lively. The documents feature an amendment claiming that the New York Times had access to Lively’s lawsuit against him at least 11 days before they published their report. The newspaper said that the filings were “rife with inaccuracies”.
5 February – Lively sued by crisis PR she claimed ‘weaponized a digital army’ against her
Jed Wallace, of crisis PR firm Street Relations, Inc, brings a $7 million defamation lawsuit against Lively alleging that she has no evidence to support her claim that Wallace “weaponized a digital army around the country from New York to Los Angeles to create, seed and promote content that appeared to be authentic on social media platforms and internet chat forums.”
In a statement to The Independent, Lively’s legal team said: “Another day, another state, another nine-figure lawsuit seeking to sue Ms Lively ‘into oblivion’ for speaking out against sexual harassment and retaliation.
“This is not just a publicity stunt—it is transparent retaliation in response to allegations contained within a sexual harassment and retaliation complaint that Ms. Lively filed with the California Civil Rights Department.”
10 February – Baldoni speaks out on ‘intense year’ in old interview filmed months before legal drama ensued
In November 2024, prior to all of the legal drama, Baldoni sat down for an interview on Gent’s Talk podcast, where he opened up about his “intense year.”
“This morning, I sent a text message to my best friend Jamey [Heath] and the president of my company, Tera [Hanks],” he said in the episode, released on February 10, “and I told them that I wasn’t in the best place. I told them that I was exhausted, that I haven’t given myself time to recover or time to heal.”
Baldoni further divulged that he “had an intense year” full of “a lot of material success and a lot of emotional stress.”
“It was very hard on me and my family,” he admitted. “When I checked in with myself I realized that I just haven’t given myself the time to heal from this year.”
13 February – Lively subpoenas Baldoni’s phone records, while It Ends with Us author Colleen Hoover erases actors from Instagram page
Lively’s legal team has reportedly sent subpoenas to the three major US phone companies AT&T, Verizon and T-Mobile, requesting Baldoni’s phone records, according to US Weekly. They have also sought the phone records for Baldoni’s publicists, Jennifer Abel and Melissa Nathan, in an attempt to “expose the full web of individuals” they allege are involved in the smear campaign against Lively.
“Such records will provide critical and irrefutable evidence not only about who, but also about when, where, and how their retaliation plan came together and operated,” Lively’s representative told the publication.
Baldoni’s lawyer, Bryan Freedman, responded to the subpoenas, telling US Weekly that while “subpoenas are an ordinary part of the litigation,” it’s the extent of what Lively’s lawyers are seeking that is “extraordinary.”
“They are asking for every single call, text, data log, and even real-time location information for the past 2.5 years, regardless of the sender, recipient, or subject matter,” he said. “This massive fishing expedition demonstrates that they are desperately seeking any factual basis for their provably false claims. They will find none.”
Meanwhile, as the legal battle continues, It Ends with Us author Colleen Hoover has wiped all mention of Lively and Baldoni from her Instagram page.
Hoover, who quit Instagram last month, returned to the social media platform on Wednesday. Though she still follows Lively, she has deleted all of the photos she had shared with her and Baldoni.
In fact, all references to the It Ends with Us promotional tour, which took place in summer 2024, are gone.
19 February – Lively says other women will testify against Baldoni for making them ‘uncomfortable’
Lively has filed an amended complaint, claiming that she was not the only woman Baldoni made uncomfortable on set.
In the new filing, Lively claims she has corroboration of her original claims, with other women allegedly willing to testify in court against Baldoni.
Though the women are unnamed, the document states that they have “given Ms. Lively permission to share the substance of their communications” and “they will testify and produce responsive documents in the discovery process.”
“The experiences of Ms. Lively and others were documented at the time they occurred starting in May of 2023,” it continues.
“Importantly, and contrary to the entire narrative Defendants have invented, Mr. Baldoni acknowledged the complaints in writing at the time. He knew that women other than Ms. Lively also were uncomfortable and had complained about his behavior.”
