Director Baldoni’s Lawyers Reprimanded in Blake Lively Case

Lawyers representing Wayfarer Studios, co-founded by actor and director Justin Baldoni, violated legal ethics rules by making some claims that were “legally frivolous and factually baseless” in litigation involving actors Blake Lively and Ryan Reynolds, a federal judge said.

Liner Freedman Taitelman & Cooley LLP and Meister Seelig & Fein were reprimanded for asserting some claims against the actress, her husband—actor Ryan Reynolds—and others in connection with Lively’s allegations that she was sexually harassed on the set of the film “It Ends With Us.”

The complaint claimed, among other things, that Lively and Reynolds had committed civil extortion, defamed Wayfarer and Baldoni, and that Lively had breached duties relating to her contract to make the film with Wayfarer.

Last June, the US District Court for the Southern District of New York granted Lively and Reynolds’ motion to dismiss claims from Wayfarer, Baldoni and several other plaintiffs. The court held, among other things, that the Wayfarer parties failed to state a claim for relief under the California civil extortion statute, because they made no allegations against Reynolds and because Lively’s alleged threats weren’t wrongful and didn’t lead to damages.

The Rule 11 reprimand stems from the civil extortion claim against Lively and Reynolds from Wayfarer, Baldoni, as well as Wayfarer co-founder Steve Sarowitz, Baldoni publicists Melissa Nathan and Jenifer Abel, and It Ends With Us Movie LLC.

What makes that claim “sanctionable” is that the factual allegations don’t support a claim for relief by Sarowitz, Nathan, Abel or IEWUM against Lively or Reynolds, said Judge Lewis J. Liman of the Southern District, as he granted in part Lively and Reynolds’ sanctions motion.

“The four of them simply had no basis to sue Lively or Reynolds for civil extortion,” the judge said in a March 27 order.

Representatives of both law firms didn’t immediately respond to requests for comment.

The Wayfarer parties also alleged intentional interference with contractual relations, intentional interference with prospective economic advantage, and negligent interference with prospective economic advantage, based on “an alleged contract or economic relationship” between them and Hollywood talent agency William Morris Endeavor.

But they haven’t identified “even an arguable basis in law or fact for any Wayfarer Party other than Baldoni and Wayfarer to assert these claims, as no other party was implicated in the contractual relationship,” Liman said.

The Wayfarer parties also claimed that Lively breached the duty of good faith and fair dealing over her contract to appear in the film. Yet there was no “conceivable basis” on which a contractual relationship between Lively and Sarowitz, Nathan, Abel and Wayfarer CEO Jamey Heath could exist, the judge said.

Although Reynolds argued that a defamation claim against him is sanctionable on the “limited basis” that it doesn’t allege that he personally made any defamatory statements to third parties, “a party can be held liable for defamation under New York law on a conspiracy theory,” Liman said. Therefore, Liman denied Reynolds’ sanctions motion as to the defamation claim.

Liman reprimanded the four parties, though he noted he could have imposed monetary sanctions, including attorneys’ fees. He limited the sanctions because there’s no reason to believe the allegations at issue “imposed any great burden on Lively and Reynolds” beyond the burden they faced to address other claims which aren’t sanctionable.

Liner Freedman, Meister Seelig, and Shapiro Arato Bach LLP represent Wayfarer, Sarowitz, Abel, Nathan, and Heath.

Willkie Farr & Gallagher LLP; Manatt, Phelps & Phillips LLP; Haynes & Boone LLP; and Dunn Isaacson Rhee LLP represent Lively. Each of Lively’s firms except Haynes & Boone represents Reynolds.

The case is Lively v. Wayfarer Studios LLC, 2026 BL 108096, S.D.N.Y., No. 1:24-cv-10049, 3/27/26.