Blake Lively v. Wayfarer Studios Second Amended Complaint
on July 31, 2025
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on July 31, 2025
L-R Justin Baldoni and Blake Lively in "It Ends With Us" romance montage.
The "second amended complaint of Blake Lively v. Wayfarer" refers to an updated legal document filed July 30th by Blake Lively in her ongoing case against Wayfarer Studios and Justin Baldoni. The complaint is specifically focused on claims defamation.
In the amended complaint against Wayfarer, Blake Lively added allegations that two other actresses on the set of "It Ends With Us" felt uncomfortable due to Baldoni's behavior and were willing to testify about their experiences. The complaint also includes details about a female cast member reporting her concerns about Baldoni's behavior to Sony and a producer in May 2023, and another actress confiding in Lively about feeling uncomfortable on set. Additionally, the complaint adds a defamation claim related to comments made by Wayfarer Studios and Baldoni's attorney, Bryan Freedman.
Testimony from other actresses:
Lively's complaint includes claims that two other actresses on the set of "It Ends With Us" felt uncomfortable due to Baldoni's actions and are prepared to testify about their experiences.
Details of other women's complaints:
The complaint details a May 2023 incident where a female cast member reported her concerns about Baldoni's behavior to Sony and a producer. It also mentions another actress confiding in Lively about feeling uncomfortable on set.
Defamation claim:
The complaint includes a new cause of action for defamation, alleging that Baldoni's attorney, Bryan Freedman, made defamatory statements about Lively in the media. This refers to defendants Wayfarer, Baldoni, and Heath, through their agents, including Bryan Freedman, intentionally made false statements of fact and false statements that conveyed a false meaning that are reasonably understood to state and imply that Ms. Lively fabricated claims of harassment and filed false claims of harassment with the Civil Rights Department of the State of California and with this Court.
Below is a breakdown of the issues that make the legal claims of Lively more understandable.
Baldoni had no reason to believe that the 'sexual harassment' would have been revealed. Note that the allegations were not publicized until December of 2024 when the infamous NY Times article was published. Why were the PR executives and Street Relations trying to cover up something that had seemingly been resolved before the second round of filming? The texts reveal some very unflattering information about Justin Baldoni and Wayfarer as creatives and business people. The overall filming experience was very unprofessional and shoddy. As evidenced by the following:
Bizarre on set behavior by Baldoni and Jamie Heath. As noted in 'Exhibit A' provided by Wayfarer, Baldoni is trying to film scenes on a boat to avoid the noise made by picketers when it could be scrubbed out in post-production. A bizarre post abuse nude scene in the shower involving Lively. Because of this there appears to be truth to some very unusual and unnecessary work arounds, it lends credibility to Lively's claims of an uncomfortable work environment. Also, the showing of a naked birthing video is unnecessary for a 3 time mother especially for a hospital birth that was nothing like the one shown to her.
The petty and sloppy handling of 'ending' Joneworks' contract. The contract was neither cancelled or rescinded even though the company claimed to have cause to do so. As of today, there is no explanation of the omission of this basic business matter's resolution.
The suit references Baldoni's efforts at a campaign against Lively's character. Lively provides receipts regarding Baldoni's campaign against her.
"On August 5, 2024, Mr. Baldoni set the narrative for the social media campaign, sending Ms. Abel a screenshot of a thread on X that had accused another female celebrity of bullying women. Mr. Baldoni stated, “this is what we would need.”"
The strange and tonally confused end product. The movie ends poorly with a confusing naming of the newborn daughter after the dead brother of the abuser and a visit to the father's grave. The movie seems unfinished, poorly written and doesn't address restraining orders, custody in abuse cases or security issues essential to a discussion of domestic violence. IEWU comes across as a romance novel trying to purloin gravitas from the weighty issue of intimate partner violence.
The unnecessary firing of the first assistant director (AD). It is characterized as being Blake's fault but is not her doing. Baldoni appears to be creating the idea that Lively is difficult but it was unclear what she and the unnamed female 1st AD were even arguing about. If Baldoni 'agonized' over firing the first director, detailing the reason is important to his claims but he is shockingly vague. His assertions about having to fire the AD are not supported.
His supposed nice guy approach is not supported by his poor business leadership and insentient handling of labor issues. There is more evidence of posturing based on optics, this excerpt from 'Exhibit A' of messages about the post firing sympathy play detail a weak and inconstant leader trying to soften an unnecessary blow dealt solely by him.
Lively's causes of action
FIRST CAUSE OF ACTION
(Sexual Harassment in Violation of Title VII – 42 U.S.C. § 2000e-2(a)(1)) Against It Ends With Us Movie LLC and Wayfarer
SECOND CAUSE OF ACTION
(Retaliation in Violation of Title VII – 42 U.S.C. § 2000e-3) Against It Ends With Us Movie LLC and Wayfarer
THIRD CAUSE OF ACTION
(Sexual Harassment in Violation of FEHA – Cal. Gov. Code, § 12940) Against It Ends With Us Movie LLC, Wayfarer, Baldoni, and Heath
FOURTH CAUSE OF ACTION
(Retaliation in Violation of FEHA – Cal. Gov. Code, § 12940) Against It Ends With Us Movie LLC and Wayfarer
FIFTH CAUSE OF ACTION
(Retaliation in Violation of the California Labor Code – Cal. Labor Code, § 1102.5) Against It Ends With Us Movie LLC and Wayfarer
SIXTH CAUSE OF ACTION
(Failure to Investigate, Prevent, and/or Remedy Harassment in Violation of FEHA – Cal. Gov. Code., § 12940) Against It Ends With Us Movie LLC and Wayfarer
SEVENTH CAUSE OF ACTION
(Aiding and Abetting Harassment and Retaliation in Violation of the FEHA – Cal. Gov. Code, § 12940(i)) Against Nathan, TAG, Abel, Wallace, and Street Relations
EIGHTH CAUSE OF ACTION
(Breach of Contract – Actor Loanout Agreement) Against It Ends With Us Movie LLC and Wayfarer
NINTH CAUSE OF ACTION
(Breach of Contract – Contract Rider Agreement) Against It Ends With Us Movie LLC and Wayfarer
TENTH CAUSE OF ACTION
(Intentional Infliction of Emotional Distress) Against Wayfarer, It Ends With Us Movie LLC, Baldoni, Heath, Sarowitz, Nathan, TAG, and Abel
ELEVENTH CAUSE OF ACTION
(Negligence Infliction of Emotional Distress) Against Wayfarer, Baldoni, and Heath
TWELFTH CAUSE OF ACTION
(False Light Invasion of Privacy – California Const., Art. I, § 1) Against Wayfarer, Baldoni, Heath, Nathan, TAG, and Abel
THIRTEENTH CAUSE OF ACTION
(Sexual Harassment in Violation of California Civil Code – Civ. Code, § 51.9) Against Baldoni and Heath
FOURTEENTH CAUSE OF ACTION
(Defamation/Defamation Per Se) Against Wayfarer, Baldoni, and Heath
Wayfarer's team came up with the marketing gimmick of Lily Bloom pop-up shops that were immersive experiences themed around the movie "It Ends With Us," featuring floral arrangements and exclusive events. They offered visitors unique photo opportunities, giveaways, and a chance to engage with the film's aesthetic from July 19 to August 11, 2024, in Los Angeles and New York.
According to the marketing plan, the pop ups would provide access to resources and safe houses for domestic violence victims. They also sought to partner with the non-profit “NO MORE,” which raises awareness and acts to end domestic and sexual violence. This bizarre idea should have left victim aid to law enforcement. The floral shop / domestic violence resource mashup is problematic at best, ridiculous in its ambition and goals at worst.
The New York pop-up collaborated with Starbright Floral Design to create the "Betty Blooms Floral Collection," which included limited-edition flower arrangements inspired by Lively's beverage brands, Betty Buzz and Betty Booze.
These pop-up shops aimed to create a unique blend of floral artistry and film promotion, enhancing the audience's connection to the movie. The pop-up shops associated with "It Ends With Us" have been criticized for prioritizing marketing over raising awareness about domestic violence, failing to effectively support the cause. While they aimed to promote the film, they did not significantly contribute to meaningful discussions or resources for domestic violence awareness. Below are some articles critical of the portrayal of domestic violence by IEWU.
https://www.huffpost.com/entry/it-ends-with-us-abuse_n_66c8ac09e4b0b61af203aa98
https://news.northeastern.edu/2024/08/13/it-ends-with-us-domestic-violence/
https://timesdelphic.com/81624/commentary/it-ends-with-us-florally-starts-controversy/
The overall glossing over of the domestic violence in the film and the bizarrely insensate depiction were incongruent with how victims of domestic violence should process and respond to their situations. A therapist provides a breakdown of the tonal and writing problems with the film's weighty subject matter.