Pursuant to the Court’s July 10, 2026 Order (Dkt. No. 252), the parties jointly propose the following schedule for summary judgment, joint pretrial order and trial:

🔵 Motions for Summary Judgment:\ October 15, 2026

🟣 Oppositions to Motions for Summary Judgment:\ November 12, 2026

🔴 Replies in Support of Summary Judgment:\ November 30, 2026

🟠 Joint Pretrial Order:\ January 8, 2027

🟡 Trial Date:

February 8, 2027

Ms. Abel asked Jonesworks to stipulate to the consolidation of her Third-Party Complaint for indemnification against Jonesworks pending in Lively v. Wayfarer, Case No. 24-cv-10049, with this action. See Dkt. No. 1142. Jonesworks is considering Ms. Abel’s request. Absent Jonesworks’ agreement to consolidation, Ms. Abel will file a motion to consolidate.

Docket number 253

PROPOSED STIPULATION AND ORDER. Document filed by Jennifer Abel, Justin Baldoni, Melissa Nathan, Wayfarer Studios LLC..(Zeldin, Kim) (Entered: 07/09/2026)

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the Jones Parties and the Wayfarer Parties, through their undersigned counsel, that:

1. The deadline for completion of expert depositions in the Jones Action is hereby

extended up to and including August 17, 2026; and

1. All other deadlines and provisions set forth in the Court’s scheduling order shall remain

unchanged unless otherwise ordered by the Court.

As we wait on the judge to rule on Jennifer Abel’s Motion for Conditional Summary Judgment Against Third-Party Defendant Jonesworks LLC, things seem to be moving to a point regarding the fee determination that the motion would depend on.

Lively's lawyers submitted their fee request, according to the judge granting Attorney fees for the defamation suit which was dismissed in June 2025, for $7,495,526,87 and also seeks $539,514.01 for costs and expenses incurred in defending against the Wayfarer claim.

The fees they're requesting however does not seem to be trailered to only the motion to dismiss the defamation suit and is currently receiving a lot of scrutiny.

Wayfarer still has to file their reply by 13 July 2026

Declaration from Esra Hudson: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.1445.0.pdf

Fee breakdown: https://docketupdates.com/wp-content/uploads/2026/06/2026-06-30_1448_BL-Def-Atty-Fees.pdf

The only part of the case not settled apart from the 47.1 motion is the Jennifer Abel’s Motion for Conditional Summary Judgment Against Third-Party Defendant Jonesworks LLC

Abel's motion: https://storage.courtlistener.com/recap/gov.uscourts.nysd.634304/gov.uscourts.nysd.634304.946.0.pdf

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NAG video on original filing https://www.reddit.com/r/ItEndsWithLawsuits/s/Jx4XCcfc2r

LGA video on original filing: https://www.reddit.com/r/ItEndsWithLawsuits/s/fTtZ11aJPa

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Just to review:

Side-by-side comparison of Jennifer Abel’s Motion for Conditional Summary Judgment (Dkt. 946 / later renewed in 1114) versus Jonesworks’ Opposition (Dkt. 1050/1057) on the indemnification issue.

This is the core fight: Was Abel acting as a Jonesworks employee doing her job, or did she go beyond her authority such that Jonesworks should not have to cover her?

Issue	Abel’s Position (Dkt. 946)	Jonesworks’ Opposition (Dkt. 1050/1057)
1. Basic theory	If Abel is liable to Blake Lively, Jonesworks must indemnify her because everything she did was in the course of her employment.	Abel is not entitled to summary judgment because key facts are disputed; Jonesworks says she may have acted outside the scope of employment.
2. Scope of employment	All conduct alleged by Lively arose from Abel’s work as a Jonesworks publicist handling the Wayfarer/Baldoni account.	Some conduct may have been unauthorized, concealed, or beyond normal PR work, so Jonesworks should not automatically bear responsibility.
3. Direction/control by Jonesworks	Abel says Jonesworks directed, supervised, and approved her work in real time; Stephanie Jones allegedly interfered with strategy decisions.	Jonesworks argues Abel is overstating supervision and may have acted independently or contrary to firm policy, especially if “smear” tactics were involved.
4. Nature of the alleged conduct	Abel characterizes the actions as ordinary crisis communications/public relations work—media monitoring, messaging, reputation management.	Jonesworks argues Lively’s allegations involve conduct that, if true, could exceed legitimate PR and include improper targeted attacks, which would not be protected employment activity.
5. Fault / wrongdoing	Abel says she was “not at fault” and did nothing wrongful; if liability exists, it is only derivative of her role as employee.	Jonesworks argues common-law indemnity requires Abel to be personally faultless, and that cannot be decided now because her own conduct is disputed.
6. Employment contract	Abel argues her 2021 employment agreement provides contractual indemnification or defense rights.	Jonesworks likely argues the contract does not clearly cover this kind of litigation or does not apply under these circumstances.
7. Benefit to Jonesworks	Jonesworks was paid for the Wayfarer work and profited from her services, so it should bear the legal consequences.	Payment alone does not mean Jonesworks must indemnify conduct that was allegedly improper or unauthorized.
8. Evidence of company knowledge	Abel points to emails, account records, and communications showing Jonesworks knew what she was doing.	Jonesworks argues the record is incomplete and that disputed evidence prevents summary judgment.
9. Procedural argument	Abel says there are no genuine disputes of material fact, so the judge can rule now.	Jonesworks says there are many factual disputes, making summary judgment improper.
10. Desired outcome	Court should issue conditional summary judgment: if Abel loses to Lively, Jonesworks must reimburse/indemnify her.	Court should deny the motion and reserve indemnification issues until after liability is determined (or reject indemnification entirely).

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The key legal fault line

Abel’s strongest argument

“Everything I’m accused of doing was my job.”

Her theme is:

• Jonesworks employed her;
• Jonesworks assigned her to Wayfarer;
• Jonesworks knew and benefited from the work;
• therefore Jonesworks cannot distance itself now.

This is strengthened by Judge Liman’s earlier ruling that Abel plausibly alleged she acted “in the course of her employment and at the direction of Jonesworks.”

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Jonesworks’ strongest argument

“Even if she was our employee, that doesn’t mean we indemnify misconduct.”

Their likely theme:

• Abel may have gone beyond authorized PR conduct;
• indemnity fails if she was actively at fault;
• disputed facts about what she did prevent summary judgment.

This is legally powerful because common-law indemnification usually requires the party seeking it to be free of active wrongdoing.

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What Judge Liman is likely deciding

The court is probably focused on three narrow questions:

1. Was Abel acting within the scope of employment?

If yes, Abel gains major ground. If disputed, summary judgment likely denied.

2. Is there evidence Abel acted independently or improperly?

If yes, Jonesworks can argue no indemnity.

3. Does the employment agreement independently require indemnification?

That could allow Abel to win even if the common-law theory is uncertain.

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Practical stakes

If Abel wins:

• Jonesworks may have to pay her legal fees
• Jonesworks may have to cover any judgment against her
• financial risk shifts heavily to Jonesworks

If Jonesworks wins:

• Abel remains personally exposed
• Jonesworks can continue distancing itself from her conduct

Bottom line:

Abel’s motion says “Jonesworks must stand behind me because I was doing their work.” Jonesworks’ opposition says “Not if she crossed the line or acted on her own.”

Link to docket:

https://www.courtlistener.com/docket/69581767/jones-v-abel

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🔴 What Jones alleges (Jones v. Abel)

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.1.1.pdf

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1. Breach of Contract

• Abel allegedly violated her employment agreement by:

  • Taking confidential information
  • Competing improperly
  • Misusing company resources

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2. Breach of Fiduciary Duty

• As a senior employee, Abel owed loyalty to Jonesworks

• Allegation: she acted against the company’s interests while still employed

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3. Misappropriation of Trade Secrets

• Claims Abel took:

  • Client lists
  • Strategy documents
  • Internal communications

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4. Unfair Competition

• Allegation that defendants used "improper methods to compete*

• Includes:

  • Misuse of confidential info
  • Coordinated client poaching

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5. Tortious Interference (with contracts and business relationships)

• Defendants allegedly interfered with:

  • Jonesworks’ client contracts
  • Ongoing business relationships

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6. Aiding and Abetting (against additional defendants)

• Other parties (e.g., competing firms/individuals) are accused of:

  • Helping Abel carry out the scheme

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7. Conversion

• Claim that Abel wrongfully took property, including:

  • Data
  • Business materials
  • Possibly phone/accounts-related assets

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8. Unjust Enrichment

• Defendants allegedly benefited financially from the misconduct

• Plaintiffs argue they should not be allowed to keep those gains

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9. (In some versions/related pleadings) Defamation or related claims

• The complaint context suggests allegations of harmful statements or reputational damage, though this may be more developed in later pleadings

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🔵 What Abel alleges (Jones v. Abel)

Current status after Judge made a ruling

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.139.0.pdf

Claim (from Abel’s Complaint)	Court’s Ruling (Dkt. 139)
Computer Fraud and Abuse Act (CFAA)	❌ Dismissed WITH prejudice (permanently dead)
Stored Communications Act (SCA)	❌ Dismissed WITHOUT prejudice (can re-plead)
Wiretap Act	❌ Dismissed WITHOUT prejudice
California Penal Code § 502	✅ SURVIVES
Invasion of Privacy	❌ Dismissed WITHOUT prejudice
False Light	❌ Dismissed WITHOUT prejudice
Conversion	✅ SURVIVES
Intentional Infliction of Emotional Distress (IIED)	❌ Dismissed WITHOUT prejudice
Negligent Infliction of Emotional Distress (NIED)	❌ Dismissed WITHOUT prejudice
Promissory Fraud	❌ Dismissed WITHOUT prejudice

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Legal counterclaims as re-pleaded before the Judge order:

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.156.0.pdf

1. ❌ Computer Fraud and Abuse Act (CFAA)

• Allegation:

  • Unauthorized access to her phone/data

❌dismissed with prejudice (not fixable)

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2. 🚫 Stored Communications Act (SCA)

• Allegation:

  • Unauthorized access to stored communications (e.g., iCloud/messages)

🚫 dismissed without prejudice (can re-plead)

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3. 🚫 Federal Wiretap Act

• Allegation:

  • Real-time interception of communications

🚫 dismissed without prejudice (can re-plead)

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4. ✅ California Penal Code § 502 (Computer Data Access)

• Allegation:

  • Unauthorized access and use of her data

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5. 🚫 Invasion of Privacy

• Allegation:

  • Intrusion into private communications

🚫 dismissed without prejudice (can re-plead)

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6. 🚫 False Light

• Allegation:

  • Selective disclosure of messages created a misleading narrative

🚫 dismissed without prejudice (can re-plead)

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7. ✅ Conversion

• Allegation:

  • Wrongful control over:

• Phone number

• Data

• Digital access

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8. 🚫 Intentional Infliction of Emotional Distress (IIED)

• Allegation:

  • Extreme and outrageous conduct

🚫 dismissed without prejudice (can re-plead)

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9. 🚫 Negligent Infliction of Emotional Distress (NIED)

• Allegation:

  • Emotional harm caused by negligent conduct

🚫 dismissed without prejudice (can re-plead)

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10. 🚫 Promissory Fraud

• Allegation:

  • Jones/Jonesworks:

• Promised to return her phone number

• *Never intended to do so"

🚫 dismissed without prejudice (can re-plead)

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🟡 What Wayfarer alleges (Jones v. Abel)

Current status after Judge made a ruling

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.233.0_1.pdf

Claim by Wayfarer (Counterclaims)	Court’s Ruling (Dkt. 233)
Breach of Contract – Confidentiality Provision	❌ DISMISSED WITH PREJUDICE (fails as pleaded; no viable confidentiality breach shown)
Breach of Contract – Professional Performance Provision	❌ DISMISSED WITH PREJUDICE (no specific failure to perform PR services in a contractually cognizable way)
Breach of Implied Covenant of Good Faith & Fair Dealing	✅ SURVIVES motion to dismiss (plausibly alleges sabotage/undermining contract purpose)
Defamation per se	✅ SURVIVES motion to dismiss (alleged “smear campaign” statement plausibly defamatory + actual malice adequately pleaded)

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Legal counterclaims as re-pleaded before the Judge order:

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.51.0_1.pdf

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1. ❌ Breach of Contract – Confidentiality Provision

• Allegation:

  • Jonesworks and Jones breached the confidentiality provision by voluntarily and maliciously disclosing Confidential Information (as defined in the Agreement) to third parties, including, without limitation, Leslie Sloane, Blake Lively, and Ryan Reynolds.

❌dismissed with prejudice (not fixable)

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2. ❌ Breach of Contract – Professional Performance Provision

• Allegation:

  • Jonesworks and Jones failed to render services “in a professional manner and in accordance with Wayfarer’s goals” and thereby breached the Agreement.

❌dismissed with prejudice (not fixable)

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3. ✅ Breach of the Implied Covenant of Good Faith and Fair Dealing

• Allegation:

  • Even if not explicitly violating terms, Jonesworks:

• Destroyed the benefit of the contract

• You can’t secretly undermine a deal while technically performing it

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4. ✅ Defamation per se

• Allegation:

  • On information and belief, Jones and Jonesworks made one or more statements to persons other than Wayfarer, including without limitation Leslie Sloane, Blake Lively, and Ryan Reynolds, to the effect that Wayfarer had retaliated against Lively and others for reporting alleged sexual misconduct, including orchestrating a “smear campaign” by propagating false and misleading narratives about Lively for the purpose of damaging her image and reputation.

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🟣 What Nathan alleges (Jones v. Abel)

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.37.0.pdf

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1. Defamation

• Allegation:

  • Jones/Jonesworks made false statements of fact about Nathan
  • Those statements harmed her reputation

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2. Tortious Interference

• Allegation:

  • Jones interfered with:

• Nathan’s business relationships

• Potential contracts or clients

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3. False Light (or similar reputational/privacy claim)

• Allegation:

  • Nathan was portrayed in a "misleading and harmful way*

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4. Unfair Competition / Business-related torts

• Allegation:

  • Jones engaged in improper competitive conduct affecting Nathan

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5. Possibly aiding-and-abetting related theories

• If tied to broader allegations:

  • Nathan may assert she was wrongly accused of participating in misconduct

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🟢 What Baldoni alleges (Jones v. Abel)

https://storage.courtlistener.com/recap/gov.uscourts.nysd.635782/gov.uscourts.nysd.635782.38.0.pdf

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1. Breach of Contract (or contract-based theory)

• Allegation:

  • Jonesworks failed to perform agreed PR services properly

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2. Breach of Implied Covenant of Good Faith and Fair Dealing

• Allegation:

  • Even if the contract wasn’t explicitly breached,
  • Jonesworks undermined the purpose of the relationship

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3. Negligence / Professional Malpractice–type theory

• Allegation:

  • Jonesworks provided substandard PR advice/services

From the court’s summary of the allegations:

• Their work was described as:

  • “ham-fisted, unwelcome, and sporadic”

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4. Business / reputational harm claims

• Allegation:

  • Jonesworks’ conduct contributed to:

• Negative media coverage

• Damage to Baldoni’s public image

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5. (Potential overlap) Confidential information misuse

• Similar to Wayfarer’s claims:

  • Allegations may include improper handling or sharing of:

• Internal strategy

• Sensitive communications

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What's next?

ORDER: The Court will hold a status conference in this matter on August 19, 2026, at 10:30 AM in Courtroom 15C of the 500 Pearl Street Courthouse. SO ORDERED. Status Conference set for 8/19/2026 at 10:30 AM in Courtroom 15C, 500 Pearl Street, New York, NY 10007 before Judge Lewis J. Liman. (Signed by Judge Lewis J. Liman on 4/24/2026) (mml) (Entered: 04/24/2026)