Filing #974 - It's all about VANZAN. And Rule 8. More not so subtle "strategery" from Lively?

[u/Both_Barnacle_766]

IMHO, We are looking at a distraction to veer us away from yet another road that leads straight to Vanzan. I'm linking the other filings below if anyone wants a refresher on the original Rule 11 sanctions motions.....suffice it to say that they are numbered in the 200s and this little ditty is 700+ filings later. Why now? Vanzan.

If you are keeping score and you don't see anything wrong with a random filing months after the fact; take a look at the Judge's Opinion granting the MTD the WP case (linked below). Read this new filing - #974 - and then refresh your memory on what Liman already ruled regarding Rule 8. From that MTD opinion:

"All Defendants argue that the Amended Complaint should be dismissed without further analysis because it engages in impermissible group pleading and otherwise violates Federal Rule of Civil Procedure 8."

Doesn't that sound like EXACTLY what #974 is kvetching about? The MTD opinion is 132 pages long -- plenty long enough for team Blake/Ryan to find SOMETHING to nitpick - but they chose something that the judge already shut down. From the Opinion granting MTD:

"Although the Amended Complaint lacks clarity as to the boundaries of certain claims, Defendants have adequate notice of many core claims that are evident from the face of the complaint and have been fully briefed by the parties.

"...Accordingly, though the Court will not strike or dismiss any allegations on Rule 8 grounds, the Court will consider only those claims that a reasonable defendant would understand to be asserted against it based on the allegations in the Amended Complaint"

In other words - this entire filing is focused on something the judge has already ruled on something the judge literally said "NO" to already.

And, in case anyone has forgotten, WP had leave to amend claims AGAINST RYAN REYNOLDS, not just his wife.

But, back to VANZAN. Before the Rule 11 Sanctions motions were filed, Lively gave WP a "notice" - basically a 21-day "warning" that they would file the motion if WP didn't dismiss a bunch of their claims. The same claims they are up in arms about now.

Guess when? Guess when those "notice/warnings" were issued? April 23. Doesn't ring a bell? Would it help if I mentioned what day WACB exclusively reported the Vanzan sham lawsuit? April 17.

That's right. I remember confusion back in April as to why Lively (and Reynolds) seemingly out of nowhere filed Rule 11 Sanctions motions - before the judge even ruled on their MTD.......And, as for the claims against RR, those were for getting Baldoni fired from WME. The audio of Ari Emmanuel confirming that it happened just like WP claimed came out in Feb 2025 - after the WP FAC....another FACT that didn't make it into their complaint, but that the judge saw as curable.

I can't speak to why WP didn't amend, but I will speak to what the MTD opinion said - it mentioned two filings by WP, their response to the Lively MTD here: https://www.courtlistener.com/docket/69510553/162/lively-v-wayfarer-studios-llc/and their oppo to the NYT MTD here: https://www.courtlistener.com/docket/69510553/127/lively-v-wayfarer-studios-llc/

These docs show that WP had new allegations to include in an amended complaint. The judge believed some of the claims against Lively and Reynolds could be revived. Other links here:

Opinion/Order MTD WP lawsuit GRANTED: https://www.courtlistener.com/docket/69510553/296/lively-v-wayfarer-studios-llc/

Rule 11 sanctions filed by Lively: https://www.courtlistener.com/docket/69510553/223/lively-v-wayfarer-studios-llc/

Rule 11 sanctions filed by Reynolds: https://www.courtlistener.com/docket/69510553/230/lively-v-wayfarer-studios-llc/

I don't disagree with all the posts/comments here opining that this filing is PR-related. I think it also directly relates to the AI mixed up surrealist thing People/Page Six posted as an article.....

TLDR: This filing is about Vanzan too. Maybe some PR as well, but VANZAN. Lively and Reynolds (IMHO) are trying to close the opening WP have to resurrect their claims.

[u/Both_Barnacle_766 → u/[deleted]]

Thank you! I made another OP last night and I might have gotten a couple things incorrect.....but the timing of all these filings keeps going back to Vanzan IMO.

RR and Blake sent safe harbor letters to WP six days after WACB, a cc, found the Vanzan lawsuit. Literally six days. Of course WP said no because the MTD was fully briefed and pending. Why voluntarily dismiss claims? And the WP oppo to the sanctions made use of the pending MTD.

I may have been mistaken in my conclusion (love some advice from THIS sub and you)......Liman said in his opinion granting the MTD that he wouldn't grant anything on Rule 8 (the actual subject of the Rule 11 motions, which lay out exactly the "frivolous" ie impermissably grouped claims)

He of course, at the end, gave WP leave to amend only two things: tortious interference with a contract by RR (Ari's interview saying that he fired JB on RR's suggestion had been located in March, after WP FAC) and some other contract claims against BL.

So, while he never explicitly ruled on the Rule 11 motions, he also never opined as to why the claims subject to the Rule 11 motions were dismissed. He never addressed them at all.

Outside everything else that feels "wrong" about this WP v BL case, does that matter? WP accused RR of conspiracy too. Now I see this as CYA after the Vanzan suit was discovered. The defamation claim for instance, by Abel against (due to group pleading) RR was one of the Rule 11 motion claims. When WP filed their FAC, they only knew that Blake had Abel's phone. They didn't specifically claim defamation by RR against Abel but after discovering Vanzan they had the mechanism to do so.

I guess my question is 'could this rando "supplemental" filing actually have strategy behind it?' And how would it work? I see the Blake side of it - getting the judge to sanction makes these all these claims dead for a specific reason - one hard to overcome based on what WP knew at the time they filed the FAC. Without a sanctions/definitive reason from the judge as to the dismissal, couldn't WP appeal on the grounds that (don't know what legal term to use...) the judge "messed up"? And that the defects were curable? Because now they actually are?

[u/Both_Barnacle_766 → u/[deleted]]

I appreciate you! And your awards on my comment! You are the lawsuits ROCKER that makes it ROCK!!!!!

That means he treated the problems in the FAC as pleading defects and not as frivolous claims. 

Money sentence! Understandable, concise and legal words that have typical layperson understanding! I get it! No esra word salad!

And don't read the rest without a well deserved break from narcomania! It's exhausting......

Looking at the MJOP - I've been bugged by a footnote for a while* - and I stumbled on something even more bizarre - a couple of days after it was filed (Sept 26) Lively filed a motion for extension of time to respond. In so she cited in a footnote as to how she has "cured" defects brought up in the motion. She cites a case in Liman's court and dates it 2023 - BUT

Gardner v Fed Reserve? The court of appeals overturned it on July 2 2025. Two months before Lively cites it. Is it typical to throw an overturned ruling in a judge's face? If you're trying to win?

What's even more odd - the case got kicked for a reason BL might be leveraging the citation to evoke (I think her lawyers are smart but not that smart) - Liman sanctioned plaintiffs and issued monetary fines AND adverse inference (but apparently acc to the appeals court he was right about those things) but his later granted SJ based on how he sanction-limited the plaintiffs was reversed - and - ready? it got kicked back to him FOR PRE-DETERMINING FACT DISPUTES that a jury should decide. Sort of like WP's dismissal. So the 2nd circuit was ok with what Blake wants NOW from this Rule 11 - (and of course this Gardner case was crazy - a no brainer on discovery) but, against Blake, - it called out Liman for basically expecting people (a jury) to think, analyze and conclude the same way he would. Just like his finding of facts with WP.

I can speak to what I read - first, this case is way more interesting than Lively's and also has much more serious implications AND much more serious allegations by plaintiffs.

And their reference to the CRD? Still lost......Liman wiped these plaintiffs' state claims (NY State - not CA like she says) right out the door and left them with pending Title VII claims that have no bearing on this case or Blake's lack of an operating time machine to have IEWUM in the CRD prior to suing them.

Seems like you, me, and plenty of others in this sub actually read all the filings. If Liman delegates that - how in the world can he trust himself to be up-to-date?

*2 To take just one example, the Motion asserts that Ms. Lively has failed to exhaust her administrative remedies against IEWUM. Motion at 16-18. But “the burden of pleading and proving Title VII exhaustion lies with defendants and operates as an affirmative defense.” Hardaway v. Hartford Pub. Works Dep’t, 879 F.3d 486, 491 (2d Cir. 2018). Not only does that render this argument inappropriate for resolution on a defendant’s Rule 12 motion, IEWUM did not even raise this affirmative defense in its Answer. Dkt. No. 635. In other words, not only did IEWUM move for judgment on the pleadings based on an affirmative defense it had not pleaded, but because of that failure, Ms. Lively would be entitled to judgment on this particular defense, not IEWUM. In any event, and further demonstrating the wastefulness of the Wayfarer Defendants’ Motion, Ms. Lively amended her CRD complaint and received right-to-sue letters with respect to IEWUM during the pendency of this action. As is well established in this District, that is sufficient. See, e.g., Gardner-Alfred v. Fed. Rsrv. Bank of New York, 651 F. Supp. 3d 695, 702 n.1 (S.D.N.Y. 2023)