Everything Blake Lively Claims in Complaint Against Justin Baldoni: Unwanted Kissing, Watching Her Naked and Smear Campaign

Blake Lively has accused Justin Baldoni of inappropriate behavior on the set of It Ends with Us and sued him for sexual harassment and a subsequent smear campaign.

Months after rumors of a feud between the costars swirled online, Lively, 37, alleges in a newly filed complaint that Baldoni, 40 — who also directed the film — exhibited “disturbing” and “unprofessional” behavior on set and, after filming wrapped, deployed an extensive retaliatory smear campaign against her.

The complaint was filed against not only Baldoni but also the film’s lead producer, Jamey Heath, as well as Baldoni’s production company, Wayfarer Studios, and its co-founder Steve Sarowitz. It was also filed against Jed Wallace, Melissa Nathan and Jennifer Abel, each of whom are named in the alleged effort to tarnish Lively’s reputation earlier this year.

Bryan Freedman, Baldoni’s lawyer, told PEOPLE in a statement that Lively’s complaint was to “fix her negative reputation.” He also said that her allegations are “false, outrageous and intentionally salacious with an intent to publicly hurt.”

Freedman also alleged that Lively caused issues during the filming of the movie, including “threatening to not show up to set, threatening to not promote the film, ultimately leading to its demise during release.”

Baldoni added ‘gratuitous sexual content’ after Lively signed onto the film, the complaint alleges

Lively’s allegations date back to before the adaptation of the Colleen Hoover novel began filming — and before a meeting was held to put safeguards in place where Baldoni and Heath were concerned. Among her claims are that prior to shooting, Baldoni “inserted improvised gratuitous sexual content and/or scenes involving nudity into the film (including for an underage character) in highly unsettling ways.”

These changes and additions — which included “a scene in which Ms. Lively was to orgasm on-camera” and a “detailed scene” of the younger version of Lively’s character, Lily Bloom, losing her virginity that was not in the novel — were added without the actress’ consent after she signed on to the film, according to the complaint.

When Lively “objected to these additions, Mr. Baldoni insisted he had added them because he was making the film ‘through the female gaze,’ ” the complaint alleges.

Though he ultimately agreed to remove the scenes, the director allegedly tried to keep one in which Lily and Baldoni’s character, Ryle Kincaid, orgasm on their wedding night, which he said was “important to him because he and his partner climax simultaneously during intercourse.”

He also “intrusively asked” Lively whether she and her husband (the actress is married to Ryan Reynolds) also “climax simultaneously during intercourse,” a matter Lively found “invasive” and declined to discuss with him, according to the complaint.

Baldoni ‘improvised’ kisses and inquired about Lively’s sex life, according to the complaint

During the intimate scenes that made it into the final script, Baldoni also “improvised physical intimacy that had not been rehearsed, choreographed or discussed with Ms. Lively, with no intimacy coordinator involved,” the complaint alleges.

One such improvisation, the complaint claims, occurred when Baldoni “discreetly bit and sucked on Ms. Lively’s lower lip during a scene in which he improvised numerous kisses on each take,” a scene he “insisted” on shooting “over and over again.”

During another scene, a slow dance between Lily and Ryle that required no sound, Baldoni, speaking as himself, “leaned forward and slowly dragged his lips from her ear and down her neck as he said, ‘it smells so good,’ ” the complaint alleges.

Baldoni “was caressing Ms. Lively with his mouth in a way that had nothing to do with their roles,” the complaint alleges, adding that when Lively later objected to his behavior, Baldoni responded by telling her, “I’m not even attracted to you.”

Following a meeting between Lively, Baldoni, producers and Ryan Reynolds in January 2024, Wayfarer Studios agreed an intimacy coordinator would be on set “for all scenes involving nudity and/or simulated sex” and there would be “no more improvising of kissing,” according to the complaint.

The complaint claims Baldoni and Heath shared their own ‘personal sexual experiences’ without consent

“Disturbing” behavior like this continued into filming, according to the complaint, which alleges that both Baldoni and Heath shared their own “personal sexual experiences” and, at times, pressured Lively to reciprocate.

During the scene in which Lily gives birth, Baldoni and Heath “suddenly pressured Ms. Lively to simulate full nudity, despite no mention of nudity for this scene in the script, her contract, or in previous creative discussions,” the complaint alleges.

The birth scene, for which Lively was “was mostly nude with her legs spread wide in stirrups and only a small piece of fabric covering her genitalia,” was also “utterly lacking in standard industry protections,” the complaint claims.

The complaint also alleges that Heath showed both Lively and her on-set assistant a graphic and “fully nude” video of his wife giving birth — which Lively initially thought was “pornography” — without consent. It also alleges that the two men “invaded” Lively’s privacy by repeatedly entering her trailer unannounced while she was undressed.

When Lively tried to meet with Heath to discuss Baldoni’s “unprofessional behavior” on the second day of filming, the complaint alleges, he “arrived unannounced” at Lively’s makeup trailer while she was “topless and having body makeup removed by makeup artists.”

After Lively said they could meet “once she was clothed,” he insisted she allow him to enter, and she “reluctantly agreed, but asked that Mr. Heath keep his back turned,” but allegedly noticed minutes later that the producer “was staring directly at her while she was topless.”

Baldoni and Heath displayed a ‘shocking lack of boundaries’ physically and in conversation, the complaint alleges

As filming continued, both Baldoni and Heath exhibited a “shocking lack of boundaries” by entering the actress’s trailer “uninvited” while she was undressed or “vulnerable” — “including when she was breastfeeding her infant child,” the complaint alleges.

Both Baldoni and Heath spoke “often” of their “previous pornography addiction,” and also shared their past sexual relationships in a way that Lively found “disrespectful and disturbing,” the complaint alleges.

In one instance, during a car ride with Lively, her assistant and a driver, the director said he was “sexually abused” by an ex-girlfriend — which he has since spoken about publicly — before allegedly admitting to engaging in sexual conduct without consent in a past relationship.

“Did I always ask for consent? No. Did I always listen when they said no? No,” Baldoni allegedly said during the car ride, which ended with Lively’s driver saying that he did not want her to be left alone with the director in the future.

Baldoni and Heath also “constantly” hugged and touched the It Ends with Us cast and crew and, when Lively — or anyone else — “avoided” the contact, they “would retaliate by becoming irritated, cold and uncollaborative,” the complaint alleges.

At one point, Baldoni also “claimed he could speak to the dead,” telling Lively “on several occasions” that he had spoken to her recently deceased father, according to the complaint.

The complaint alleges Baldoni both sexualized Lively and criticized her appearance

Baldoni “often” referred to women in the workplace as “sexy,” the complaint alleges. In one alleged incident, the director “pressured” Lively to remove her coat to reveal her onesie — which she had partially unzipped to reveal her bra — in a “packed” setting, and told her, “ ‘I think you look sexy’ in a tone that made her feel ogled and exposed.”

In addition to his alleged sexual comments toward Lively, the complaint also alleges that Baldoni “went out of his way to message criticisms of her age and weight,” including voicing worries that she “looked old and unattractive based on paparazzi photos from the set.”

He also “routinely degraded” Lively by “finding back channel ways of criticizing her body and weight,” including calling her trainer — less than four months after she gave birth to her fourth child — behind her back and implying that he “wanted her to lose weight in two weeks,” the complaint alleges.

The complaint also claims that Baldoni and Heath “deliberately withheld” from Lively that she had been exposed to COVID in an on-set outbreak that led to herself and her then-infant child contracting the illness.

A set of protections designed to ‘cease’ Baldoni and Heath’s ‘on-set behavior’ was instituted

Filming for It Ends with Us went on pause during the writers’ strike last year but, before it was set to resume, Lively laid out her complaints about the director and producer — and their “invasive, unwelcome, unprofessional and sexually inappropriate behavior” — during a January 2024 meeting.

The result of the “all hands” meeting, held to address “the hostile work environment that had nearly derailed production” prior to the strike, was a list of 30 protections, including 17 that were “designed to require Wayfarer to cease the on-set behavior of Mr. Baldoni and Mr. Heath,” per the complaint.

Among the protections were “no more improvising of kissing” and “no more personal, physical touching of, or sexual comments by, Mr Baldoni or Mr Heath to be tolerated by [Blake Lively] and/or any of her employees, as well as any female cast or crew without their express consent.”

Upon receiving the list, Wayfarer (which is co-owned by Baldoni) said in part, “Although our perspective differs in many aspects, ensuring a safe environment for all is paramount, irrespective of differing viewpoints. Regarding your outlined requests, we find most of them not only reasonable but also essential for the benefit of all parties involved.”

The complaint alleges that Baldoni instigated a smear campaign against Lively: ‘He wants to feel like she can be buried’

The complaint alleges that ahead of It Ends with Us‘ premiere in August, Baldoni, fearing that Lively would go public with her negative on-set experiences, brought on a team to protect his reputation and turn people against her, as evidenced by private texts and emails included in the complaint.

“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 alleges. “They engaged in the same techniques to bolster Mr. Baldoni’s credibility and suppress any negative content about him.”

In one exchange between Abel, a public relations exec, and Nathan, a crisis management expert, Abel relays Baldoni’s frustration with the team’s initial plans for the alleged smear campaign, according to the exhibits filed with the complaint. “I think you guys need to be tough and show the strength of what you guys can do in these scenarios,” Abel told Nathan of the actor. “He wants to feel like she can be buried.”

“Of course — but you know when we send over documents we can’t send over the work we will or could do because that could get us in a lot of trouble,” Nathan replied. And, in other texts, she allegedly added, “We can’t write we will destroy her,” and, “Imagine if a document saying all the things that he wants ends up in the wrong hands.”

Other texts show Baldoni’s team reveling in their success after shutting down reports of his alleged inappropriate behavior on set, with Nathan saying in October that Baldoni “doesn’t realise how lucky he is right now.”

In his statement, Baldoni’s lawyer Freedman asserted that representatives of Wayfarer Studios “did nothing proactive nor retaliated, and only responded to incoming media inquiries to ensure balanced and factual reporting and monitored social activity. What is pointedly missing from the cherry-picked correspondence is the evidence that there were no proactive measures taken with media or otherwise; just internal scenario planning and private correspondence to strategize which is standard operating procedure with public relations professionals.”

After the complaint was filed, Lively said in a statement to The New York Times, “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.”