Blake Lively accuses It Ends With Us director Justin Baldoni of ...

According to the complaint, the parties reviewed a list of 30 demands by the Gossip Girl actor, including to stop showing images or videos of nude women to Lively and her employees, describing their genitalia to Lively, and Baldoni and Heath mentioning their alleged previous “pornography addiction” to Lively.

It further specified, “No more improvising of kissing” and “No more entering, attempting to enter, interrupting, pressuring or asking [Lively] to enter her trailer ... by Mr Heath or Mr Baldoni while she is nude”.

Lively also would no longer be asked for scenes involving nudity that exceeds what was formally agreed to, the complaint stated.

While the parties agreed to the demands, the complaint said, what later followed was “social manipulation” to “destroy” Lively’s reputation.

According to the complaint, Wayfarer co-founder, co-chairman and leading financier Steve Sarowitz was “prepared to spend $100 million [$176.8m] to ruin the lives” of Lively and her family.

“With that backing, Mr Baldoni and his Wayfarer associates embarked on a sophisticated press ... and digital plan in retaliation for Ms Lively exercising her legallyprotected right to speak up about ... their misconduct on the set, with the additional objective of intimidating her and anyone else from revealing in public what actually occurred.”

Additionally, the complaint alleged Baldoni “abruptly pivoted” from the film’s marketing plan - focusing on the message of resilience and hope - and used domestic violence “survivor content” to protect his public image.

The complaint contained many text messages between two women hired by Baldoni as part of his PR team: crisis management expert Melissa Nathan, who previously represented Johnny Depp, and publicist Jennifer Abel.

In one message, Abel expressed to Nathan that Baldoni, ”wants to feel like [Lively] can be buried”, to which Nathan replied: “you know we can bury anyone”.

“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 New York Times.

Baldoni’s lawyer Bryan Freedman responded with a statement to the New York Times, saying: “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”.

Freedman said it was “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”.

“These claims are completely false, outrageous and intentionally salacious with an intent to publicly hurt and rehash a narrative in the media.”

The complaint comes amid months of rumours of a feud brewing between Baldoni and Lively, who did not jointly publicly promote It Ends With Us - a film adaptation of the romance novel by Colleen Hoover depicting domestic violence and emotional abuse.

The film was also criticised for having romanticised domestic violence. In response, Baldoni said that critics were “absolutely entitled to that opinion”.

He told the Associated Press at the time: “If anybody has had that real-life experience, I can imagine how hard it would be to imagine their experience being in a romance novel. To them, I would just offer that we were very intentional in the making of this movie.”