The 5 biggest allegations from Blake Lively's complaint against Justin Baldoni

The complaint says she attended an "all hands" meeting with Baldoni, Heath, and others in January to discuss the "hostile work environment that had nearly derailed production of the film." Her husband, Ryan Reynolds, also attended the meeting.

"Ms. Lively was forced to address concerns about Mr. Baldoni and Mr. Heath's misconduct with them directly and began doing so months before filming began," the complaint says. "The concerns she raised were not only for herself but for the other female cast and crew, some of whom had also spoken up."

The meeting resulted in a list of behaviors that Baldoni and Heath agreed to stop, including "showing nude videos or images of women, including the producer's wife, to BL and/or her employees."

Other behaviors the men agreed to cease were mentioning their "previous pornography addiction or BL's lack of pornography consumption" and "descriptions of their genitalia," according to the complaint.

The agreed-upon behaviors were compiled into a document that was shared with Wayfarer Studios, which said it found "most of them not only reasonable but also essential for the benefit of all parties involved," according to the complaint.

Baldoni added improvised sexual content and nude scenes to "It Ends with Us" in "highly unsettling ways," the complaint says, including an on-camera orgasm, without Lively's knowledge or consent.

"When Ms. Lively objected to these additions, Mr. Baldoni insisted he had added them because he was making the film 'through the female gaze,'" according to the complaint. "Although he agreed to remove the scenes, he made a last-ditch attempt to keep one in which the couple orgasm together on their wedding night, which he said was important to him because he and his partner climax simultaneously during intercourse."

"Mr. Baldoni then intrusively asked Ms. Lively whether she and her husband climax simultaneously during intercourse, which Ms. Lively found invasive and refused to discuss," the complaint says.

The complaint also says Baldoni urged Lively to "simulate full nudity" while filming a scene in which her character gives birth, saying it's "not normal" for women to wear their hospital gowns while giving birth. Although Lively disagreed, the complaint says she compromised and agreed to be nude from below the chest down.

Neither Baldoni nor Heath closed the set before filming the scene, according to the complaint, allowing "non-essential crew to pass through while Ms. Lively was mostly nude with her legs spread wide in stirrups and only a small piece of fabric covering her genitalia."

Heath also showed Lively and her assistant a video of his wife giving birth that Lively initially believed was pornography, the complaint says.

"Ms. Lively was alarmed and asked Mr. Heath if his wife knew he was sharing the video, to which he replied, 'She isn't weird about this stuff,' as if Ms. Lively was weird for not welcoming it," the complaint said.

In the complaint, Lively said she and other cast members promoted "It Ends with Us" according to a "Marketing Plan" created by the film's distributor, Sony Pictures Entertainment. That plan encouraged the cast to emphasize her character's "strength and resilience as opposed to describing the film as a story about domestic violence" to avoid talking points that could make the film "feel sad."

Lively said that Baldoni "abruptly pivoted away" from the plan, promoting the domestic violence storyline of the film and what the complaint described as "survivor content."

Consumers criticized Lively's marketing approach during the press tour, which resulted in social media backlash toward her and her brands. Baldoni did not experience the same disapproval from audiences.

"What the public did not know was that Mr. Baldoni and his team did so in an effort to explain why many of the Film's cast and crew had unfollowed Mr. Baldoni on social media and were not appearing with him in public," the complaint said.

In the complaint, Lively said Baldoni's decision to switch marketing strategies was the start of a "multi-tiered plan" using "social manipulation" to ultimately "destroy" her public reputation.

Baldoni hired Melissa Nathan, a crisis communications specialist from The Agency Group PR, on July 31 at the suggestion of his publicist, Jennifer Abel.

"What Ms. Nathan proposed included a practice known as 'Astroturfing,' which has been defined as 'the practice of publishing opinions or comments on the internet, in the media, etc. that appear to come from ordinary members of the public but actually come from a particular company or political group," the complaint said.

The complaint includes screenshots of text messages that Lively's attorneys say are between Abel and Nathan. In one, Abel tells Nathan that Baldoni "wants to feel like she can be buried," in a reference to Lively.

In another one, Baldoni sent Abel a screenshot of a social media post about Hailey Bieber facing bullying allegations in 2023.

"This is what we would need," Baldoni wrote in the text message, according to the complaint.

Baldoni and his team would "feed pieces of this manufactured content to unwitting reporters, making content go viral in order to influence public opinion and thereby cause an organic pile-on," the complaint says.

In the following weeks, news outlets published numerous stories about the "backlash" Lively faced from fans online during the film's press tour.

"To safeguard against the risk of Ms. Lively ever revealing the truth about Mr. Baldoni, the Baldoni-Wayfarer team created, planted, amplified, and boosted content designed to eviscerate Ms. Lively's credibility," the complaint said.

Baldoni was "desperate to suppress any suggestion that he engaged in inappropriate conduct, much less sexually harassing conduct, because it would entirely undermine his carefully curated public image as a feminist ally," the complaint says.

The document referenced a 2018 TED Talk Baldoni gave entitled "Why I'm Done Being 'Man Enough" and other similar content.

"In sum, Mr. Baldoni has crafted a public image of himself as not just an ally, but also a fierce advocate for women," the complaint says. "Contrary to this image, as set forth in detail above, Mr. Baldoni has spent the last several months and significant resources on his goal of wanting to 'bury' and 'destroy' Ms. Lively for raising concerns about his and his CEO's harassing behavior and other disturbing conduct."

Bryan Freedman, an attorney for Baldoni and Wayfarer Studios, said the complaint's claims were "categorically false."

"It is shameful that Ms. Lively and her representatives would make such serious and categorically false accusations against Mr. Baldoni, Wayfarer Studios, and its representatives, as yet another desperate attempt to 'fix' her negative reputation, which was garnered from her own remarks and actions during the campaign for the film; interviews and press activities that were observed publicly, in real time and unedited, which allowed for the internet to generate their own views and opinions," the statement read.

Freedman's statement called the Lively's claims "completely false, outrageous and intentionally salacious with an intent to publicly hurt and rehash a narrative in the media."

The statement said Wayfarer Studios chose to hire Nathan before the film's marketing campaign "due to the multiple demands and threats made by Ms. Lively during production which included her threatening to not show up to set, threatening to not promote the film, ultimately leading to its demise during release, if her demands were not met."

Lively shared a statement with The New York Times, saying, "I hope that my legal action helps pull back the curtain on these sinister retaliatory tactics to harm people who speak up about misconduct and helps protect others who may be targeted."

Lively told the outlet that neither she nor her representatives ever spread negative information about Baldoni or Wayfarer Studios.