Andersen et al v. Stability AI Ltd. et al

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31 Case No. 23-cv-00201-WHO (LJC)
JOINT STIPULATION AND ORDER REGARDING CASE SCHEDULE
[Counsel listed on signature pages]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
SARAH ANDERSEN, ET AL.,
Individual and Representative Plaintiffs,
v.
STABILITY AI LTD., ET AL.,
Defendants.
Case No. 3:23-cv-00201-WHO
JOINT STIPULATION AND ORDER
REGARDING CASE SCHEDULE
Judge: Hon. William H. Orrick
Case 3:23-cv-00201-WHO Document 623 Filed 07/01/26 Page 1 of 4

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31 Case No. 23-cv-00201-WHO (LJC) 1
JOINT STIPULATION AND ORDER REGARDING CASE SCHEDULE
Pursuant to Local Rules 6-2 and 7-12 and the Court’s April 21, 2026 Order (“Order”) (ECF No.
499), Plaintiffs Sarah Andersen, Karla Ortiz, Grzegorz Rutkowski, Gregory Manchess, Gerald Brom,
Jingna Zhang, Julia Kaye, and Adam Ellis (“Plaintiffs”) and Defendants Runway AI, Inc (“Runway”),
Midjourney, Inc. (“Midjourney”), DeviantArt, Inc. (“DeviantArt”), and Stability AI, Ltd. and Stability AI,
Inc. (“Stability”) (collectively, the “Parties”), by and through their respective counsel, hereby stipulate
and request as follows:
I. CONTENTION INTERROGATORIES
WHEREAS, on April 3, 2026, Stability served contention interrogatories on Plaintiffs, and on
May 18, 2026, Plaintiffs served objections to those interrogatories;
WHEREAS, on April 15, 2026, Midjourney served contention interrogatories on Plaintiffs, and on
May 18, 2026, Plaintiffs served objections to those interrogatories;
WHEREAS, on April 20, 2026, Runway served contention interrogatories on Plaintiffs, and on
May 20, 2026, Plaintiffs served objections to those interrogatories;
WHEREAS, on June 1, 2026, DeviantArt served contention interrogatories on Plaintiffs;
WHEREAS, on June 1, 2026, Plaintiffs served contention interrogatories on Defendants;
WHEREAS, on June 9, 2026, and on June 22, 2026, the Parties met and conferred via video
conference regarding the sufficiency Plaintiffs’ responses and objections to Runway’s contention
interrogatories;
WHEREAS, the current deadline to take depositions of fact witnesses is August 15, 2026;
WHEREAS, the Parties agree that Defendants need not provide substantive responses to
Plaintiffs’ contention interrogatories on their due date (July 1, 2026) and further agree to a deadline of
August 17, 2026, for full and final responses to all contention interrogatories served on both Plaintiffs
and Defendants;
WHEREAS, the Parties agree to a deadline of August 24, 2026, to file any joint letter brief
directed at the sufficiency of a Party’s responses to contention interrogatories.
Case 3:23-cv-00201-WHO Document 623 Filed 07/01/26 Page 2 of 4

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31 Case No. 23-cv-00201-WHO (LJC) 2
JOINT STIPULATION AND ORDER REGARDING CASE SCHEDULE
II. ORDER AT ECF NO. 602
WHEREAS, Magistrate Judge Lisa J. Cisneros issued an Order requiring Plaintiffs to serve
discovery responsive to Defendants’ Joint Request for Production No. 13 and Runway’s Interrogatory
No. 9 (ECF No. 602) by June 30, 2026;
WHEREAS, Plaintiffs have been diligently collecting documents that would be responsive to and
inform these discovery requests;
WHEREAS, on June 30, 2026, the Parties agreed to the following:
• The Parties will stipulate to an amended Interrogatory No. 9 whereby Plaintiffs would
provide income and expense information on a monthly basis where monthly records exist,
on a quarterly basis where only quarterly records exist, and on an annual basis only where
no more granular records exist. Plaintiffs will also produce and cite the supporting records
and identify the period covered; Plaintiffs will not oppose any reasonable requests for
more deposition time if needed as a result of the productions contemplated in this
stipulation and will provide dates occurring before August 15, 2026;
• If Plaintiffs’ productions remain deficient after further production, Defendants may seek
additional productions and supplemental interrogatory responses, including but not limited
to any renewed request for tax returns, and may seek to enforce subpoenas served upon
Edna Chan and/or Andrews McMeel Universal;
• Defendants will extend the deadlines for Plaintiffs to respond to Defendants’ Joint Request
for Production No. 13 and Runway’s Interrogatory No. 9 consistent with the proposed
deadlines set forth in the table below;
NOW, THEREFORE, IT IS HEREBY AGREED and jointly requested by and between the
Parties, through their undersigned counsel, that the Court enter the following case schedule:
Case 3:23-cv-00201-WHO Document 623 Filed 07/01/26 Page 3 of 4

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31 Case No. 23-cv-00201-WHO (LJC) 3
JOINT STIPULATION AND [ORDER REGARDING CASE SCHEDULE
EVENT CURRENT
DEADLINE
[PROPOSED]
DEADLINE
Deadline for Plaintiff Sarah
Andersen to serve documents
responsive to Defendants’ Joint
Request for Production No. 13
June 30, 2026 July 7, 2026
Deadline for Plaintiffs Gregory
Manchess and Karla Ortiz to
serve supplemental responses
to Runway’s Interrogatory No.
9
June 30, 2026 July 7, 2026
Deadline for Plaintiffs Adam
Ellis and Grzegorz Rutkwoski
to serve supplemental
responses to Runway’s
Interrogatory No. 9
June 30, 2026 July 9, 2026
Deadline for Plaintiffs Sarah
Andersen, Julia Kaye, and
Jingna Zhang to serve
supplemental responses to
Runway’s Interrogatory No. 9
June 30, 2026 July 14, 2026
Deadline for Parties to
supplement and/or respond to
contention interrogatories
July 1, 2026 August 17, 2026
Deadline to file any joint letter
brief directed at the sufficiency
of a party’s responses to
contention interrogatories
July 9, 2026 August 24, 2026
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: July 1, 2026 ___________________________________
Honorable Lisa J. Cisneros
United States Magistrate Judge
Case 3:23-cv-00201-WHO Document 623 Filed 07/01/26 Page 4 of 4