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Judge Denies Blake Lively’s Sanctions Motion Against Justin Baldoni’s Lawyer

Judge Lewis J. Liman denied Blake Lively’s sanctions motion against Bryan Freedman. The decision was not a gag order and left a key attorney-rule question unresolved.
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Judge Lewis J. Liman denied Blake Lively’s motion for sanctions against Bryan Freedman, a lawyer for the Wayfarer parties, on March 13, 2026. The ruling did not impose a gag order or decide the underlying allegations in the dispute. Liman said Lively had not shown that Freedman’s challenged statements, made eight to eleven months before the then-scheduled trial, were substantially likely to prejudice proceedings. The judge left unresolved whether the statements qualified for a safe harbor under New York’s attorney-conduct rule.

What the judge decided

Lively’s motion sought sanctions under New York Rule of Professional Conduct 3.6 and Federal Rule of Civil Procedure 16(f), according to E-Discovery LLC’s report of the decision. Liman denied it. The report quotes the order: “Accordingly, the motion is DENIED.”

The judge’s stated reason was the lack of a required showing of likely prejudice from the timing and effect of the challenged statements. As quoted in the report, Liman wrote: “Assuming without deciding that Freedman’s statements were not protected by the safe harbor provision in Rule 3.6(d), Plaintiff has not shown that those statements, given when they were made, are substantially likely to prejudice any adjudicative proceedings in this case.”

That qualification matters: the court assumed for purposes of its analysis that the safe harbor might not apply, but did not decide the issue. The ruling therefore is not a finding that the statements violated Rule 3.6, nor a final determination about whether they fell within the rule’s safe harbor.

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Was this a gag-order ruling?

No. “Motion to silence” is headline shorthand, not a precise description of the relief counsel said they wanted. At a February 3, 2025 hearing, Lively and Ryan Reynolds’ lawyer Michael Gottlieb said they were not asking for a gag order against Freedman. He described the request as asking the court to adopt professional-conduct rules governing lawyers’ statements outside court, according to ABC News’ account of the case timeline.

The hearing and the later ruling were separate procedural moments. The 2025 conference addressed proposed rules and publicity; the March 2026 decision denied a sanctions motion based on the later challenged statements. The March decision did not bar Baldoni’s team or its lawyers from speaking.

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How the February 2025 hearing differed from the 2026 decision

Date What was discussed What the judge did or said
February 3, 2025 Counsel discussed applying attorney-conduct rules to statements outside court amid concerns about publicity. ABC News reported that Liman criticized a factual narrative attached to a website and said sanctions were possible in that separate context. He also said a trial date could be moved if media coverage made a fair proceeding untenable.
March 13, 2026 Lively sought sanctions against Freedman under Rule 3.6 and Rule 16(f). Liman denied the motion, finding the showing of likely prejudice insufficient and leaving the Rule 3.6(d) safe-harbor question undecided.

ABC News reported Liman’s February 2025 remark about the website attachment: “The law is pretty clear — you can’t just attach a factual narrative.” That hearing comment was not the rationale for the later denial of sanctions.

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Where the motion fits in the wider dispute

The legal conflict followed Lively’s December 2024 complaint concerning alleged conduct during production of It Ends with Us, according to ABC News. Baldoni denied wrongdoing. In January 2025, Baldoni and associated plaintiffs brought claims against Lively, Reynolds, and others. Those claims and denials are party positions, not findings made in the March 2026 sanctions ruling.

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The motion concerned publicity and lawyer conduct, not whether the underlying harassment or retaliation allegations were true. A later federal-court opinion recounts that the Wayfarer action was dismissed in June 2025, with final judgment entered October 31, 2025; it also says the related Lively action settled in May 2026. Those later procedural developments are distinct from Liman’s March ruling.

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