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Blake Lively files amended complaint alleging Justin Baldoni made other women ‘uncomfortable’ on set

The 137-page filing included new allegations of misconduct on set, saying Lively wasn't alone in raising concerns of on-set misconduct more than a year before "It Ends With Us" was edited.
SNL50: The Anniversary Special
Blake Lively at SNL50 in New York City on Sunday.John Nacion / Variety via Getty Images

Blake Lively’s attorneys filed an amended complaint Tuesday against “It Ends With Us” director and actor Justin Baldoni alleging other unnamed witnesses had raised allegations of misconduct on set, support her claims of a retaliation campaign and are willing to testify about it.

In a 137-page filing, Lively’s attorneys, Esra Hudson and Mike Gottlieb, include new assertions of alleged misconduct saying, “Ms. Lively was not alone in raising allegations of on-set misconduct more than a year before the film was edited,” as well as evidence of alleged threats, harassment and intimidation of Lively and others in “defendants’ retaliatory campaign.”

Her attorneys said over that the next weeks they will move to dismiss the lawsuits brought against Lively and her husband.

New allegations

The complaint is filed against Wayfarer Studios; its co-founders, Baldoni and Steve Sarowitz; its CEO, Jamey Heath; Wayfarer’s retained crisis communications specialist, Melissa Nathan; her company, The Agency Group; Wayfarer publicist Jennifer Abel; and others. 

New items in the amended complaint allege that Baldoni made other women on set feel uncomfortable.

In May 2023, a female cast member who wasn’t Lively reported concerns about Baldoni's “unwelcome behavior” to a Sony employee and one of the film’s producers, the filing said. The Sony employee shared the concerns with Wayfarer, and on June 1, 2023, Baldoni responded to the female cast member in writing “acknowledging that he was aware of her concerns, and that adjustments would be made,” the filing alleges.  

The complaint says the “dangerous climate of threats, harassment and intimidation” fueled by the defendants’ “retaliation campaign” required Lively to “alter her personal and professional life” and “take steps to protect innocent bystanders.” The complaint, which doesn’t refer to witnesses by name, says that witnesses have given her permission “to share the substance of their communications in the complaint” and that they will testify and produce responsive documents in the discovery process.  

It also says the social media campaign it alleges Baldoni's camp orchestrated got “dangerously extreme” and resulted in Lively, her family, other cast members and fact witnesses receiving “disturbing threats.” In one instance, a person, whom the complaint doesn’t name but describes as someone known to publicly support Lively, received a written death threat. The filing doesn’t specify whom the threat came from.

The amended complaint adds Jed Wallace, a Texas-based contractor who has described himself as a self-employed “PR consultant” who offers “crisis mitigation services,” as a defendant. It alleges The Agency Group “engaged” Wallace in early 2024 “to design and implement their ‘social combat’ plan.” The complaint says Wallace specializes in executing “untraceable” campaigns on social media platforms “to shape the public perception of his clients.”

Wallace filed a multimillion-dollar lawsuit against Lively this month in federal court in Texas. In his suit he says that he had “nothing to do with” the alleged retaliatory effort against Lively and that the allegations have "caused millions of dollars in reputational harm."

The amended filing also alleges that the Wayfarer investigation into misconduct is a farce. The company launched an investigation into itself last month, hiring an outside investigation counsel. 

“A privileged and confidential internal investigation that is financed and controlled by the same Wayfarer executives who have been sued for sexual harassment and retaliation is not an exercise in transparency, but a sham,” the filing says.

A spokesperson for Lively said Wayfarer chose to devise a plan to retaliate and discredit accusers, rather than thoroughly investigate any claims of sexual harassment when they first surfaced.

Bryan Freedman, who represents Wayfarer Studios and all its representatives, in addition to Baldoni, said in a statement Wednesday: "Our clients have been transparent in providing receipts, real time documents and video showing a completely different story than what has been manipulated and cherry picked to the media."

He called the amended complaint "underwhelming" and "filled with unsubstantial hearsay of unnamed persons who are clearly no longer willing to come forward or publicly support her claims."

"Since documents do not lie and people do, the upcoming depositions of those who initially supported Ms. Lively’s false claims and those who are witnesses to her own behavior will be enlightening. What is truly uncomfortable here is Ms. Lively’s lack of actual evidence," he said.

Freedman previously described Lively’s allegations as “categorically false.”

“These claims are completely false, outrageous and intentionally salacious with an intent to publicly hurt and rehash a narrative in the media,” he said in a statement.

The feud

The amended complaint is part of a monthslong legal feud between Baldoni and Lively following the filming and release of “It Ends With Us,” a movie adaptation of the popular Colleen Hoover novel. 

Lively’s initial complaint, filed with the California Civil Rights Department on Dec. 20, accused Baldoni of sexual harassment during the filming. It also alleged that Baldoni retaliated against Lively after she raised issues about his behavior on the set. In addition to those allegations, Lively claims Baldoni hired a crisis publicity firm to engage in a “social manipulation campaign” to smear her while they were promoting the film.

Such a filing is typically a precursor to a lawsuit. Baldoni has denied those allegations.

On Dec. 31, Baldoni sued in Los Angeles County Superior Court and accused The New York Times of libel for the article it ran on Dec. 21, which laid out Lively’s allegations. The Times has stood by its reporting.

The same day, Lively sued Baldoni in the Southern District of New York. In that suit, Lively alleges that Baldoni, the film’s production company, Wayfarer Studios, and others engaged in “a carefully crafted, coordinated, and resourced retaliatory scheme to silence her, and others, from speaking out.” 

An attorney for Baldoni called the accusations a “vicious smear campaign fully orchestrated by Blake Lively and her team.”

Tension between the stars was initially noticed by fans who followed the film’s premiere and pointed out that Baldoni and Lively never appeared to interact on the red carpet and on media tours. When the suits were filed, they caused a rush of renewed interest on social media.