may 16, 2023 - Heath Enters Lively's Trailer

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"May 16, 2023: Later that day, Lively texts Baldoni to request another meeting with him and the other producers to discuss wardrobe. Baldoni agrees. After shooting wraps Producer, Sony Executive, Heath, and Baldoni approach Lively’s makeup trailer. Heath knocks on the door and is invited in.

Present in the room are Lively’s nanny, makeup artist, and assistant while Lively is having body
makeup removed—she was not topless, as she claimed in her Complaint. She was either nursing or pumping while fully covered. Lively asks Heath to face the wall while they determine a time to meet with the other producers, who are standing just outside the door. Weeks later, on June 1, 2023, Lively accuses Heath of making eye contact with her while she had asked him to face the wall. While Heath does not remember doing so, he sincerely apologizes if he made momentary eye contact with Lively while conversing, acknowledging that it was possible he may have out of habit. Lively stated that she “didn’t think he was trying to cop a look,” and they moved on.

Heath pleads with Lively to consider having the meeting the next morning to avoid her getting
home too late and losing shoot time the following day. The conversation in Lively’s makeup trailer lasts only a couple of minutes, and they agree to meet with the rest of the producers in her personal trailer. Ten minutes later, they meet and discuss the wardrobe at length. Any suggestion that Heath ‘stared’ at her inappropriately is not only blatantly false but also difficult to believe, especially in such a setting. Furthermore, Lively’s Complaint incorrectly states that Lively intended to speak with the producers about unprofessional behavior on this day. As this timeline shows, the allegedly ‘inappropriate behavior’ Lively describes in her Complaint had not yet occurred, and the conversation concerned only wardrobe and production."

(see page 25)

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