Andersen et al v. Stability AI Ltd. et al

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Case No. 23-cv-00201-WHO (LJC)
THIRD STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR THIRD PARTIES
TO SEEK PROTECTIVE ORDERS REGARDING MATERIALS PRODUCED TO RUNWAY
[Counsel listed on signature pages]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
SARAH ANDERSEN, et al.,
Plaintiffs,
v.
STABILITY AI LTD., et al.,
Defendants.
Case No. 23-CV-00201-WHO (LJC)
THIRD STIPULATED ORDER FOR
ENLARGEMENT OF TIME FOR THIRD
PARTIES TO SEEK PROTECTIVE
ORDERS REGARDING MATERIALS
PRODUCED TO RUNWAY
Dept: 2; 17th Floor
Judge: Hon. William H. Orrick
Date Filed: January 13, 2023
Trial Date: April 5, 2027
Case 3:23-cv-00201-WHO Document 441 Filed 03/11/26 Page 1 of 6

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Case No. 23-cv-00201-WHO (LJC) 1
THIRD STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR THIRD PARTIES
TO SEEK PROTECTIVE ORDERS REGARDING MATERIALS PRODUCED TO RUNWAY
Pursuant to Local Rules 6-2 and 7-12, Plaintiffs Sarah Andersen, Karla Ortiz, Grzegorz Rutkowski,
Gregory Manchess, Gerald Brom, Jingna Zhang, Julia Kaye, and Adam Ellis (“Plaintiffs”) and Defendant
Runway AI, Inc. (“Runway”) (collectively, the “Parties”), by and through their respective counsel, hereby
stipulate and request as follows:
WHEREAS, on January 28, 2026, the Court issued an order requiring Plaintiffs to produce to
Runway: (1) final expert reports Plaintiffs Andersen and Zhang served in In re Google, (2) Plaintiffs
Andersen and Zhang’s deposition transcripts from In re Google, and (3) the written discovery responses
served by Plaintiffs Andersen and Zhang in In re Google (“In re Google Materials”), no later than February
4, 2026. ECF No. 403;
WHEREAS, many of the In re Google Materials contain information designated confidential by
third parties to this Action;
WHEREAS, Runway has told Plaintiffs that, in an effort to avoid Court intervention, it is willing to
accept redactions to In re Google Materials that contain third-party confidential information, reserving all
rights to challenge the scope of such redactions;
WHEREAS, after two stipulated extensions of time (ECF Nos. 410, 417), the deadline for production
of materials designated confidential in In re Google was extended to March 10, 2026, in order to allow those
designating parties sufficient time to seek protective orders, in accordance with the protective orders in both
this Action and In re Google;
WHEREAS, since the issuance of the Order, Plaintiffs have worked diligently with designating
parties through a multi-step process to identify and redact confidential information in the In re Google
Materials in an effort to resolve confidentiality issues without the need for Court intervention;
WHEREAS, Plaintiffs began producing In re Google Materials to Runway, on a rolling basis upon
receipt of appropriate approval and/or redactions from interested third parties on February 4, 2026;
WHEREAS, Plaintiffs’ most recent production was Plaintiff Andersen’s deposition transcript, with
confidentiality designations, on March 6, 2026;
WHEREAS, Plaintiffs’ productions of In re Google Materials are not yet complete;
Case 3:23-cv-00201-WHO Document 441 Filed 03/11/26 Page 2 of 6

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Case No. 23-cv-00201-WHO (LJC) 2
THIRD STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR THIRD PARTIES
TO SEEK PROTECTIVE ORDERS REGARDING MATERIALS PRODUCED TO RUNWAY
WHEREAS, Runway requires additional time to determine whether it will challenge the scope of
the redactions in the In re Google Materials, including those in materials that Plaintiffs have not yet
produced;
WHEREAS, Runway agrees to a two-week extension, to March 24, 2026, on the deadline for
designating parties to seek protective orders, in accordance with the protective orders in both this Action
and In re Google, in order to allow sufficient time for both Runway to consider the redactions and the
designating third parties to seek protective orders, if necessary;
WHEREAS, to date, there have been minimal time modifications in the case by stipulation or Court
order;1 and
WHEREAS, an extension to the deadline for Defendants’ response to the Motion would have no
effect on the current schedule for the case.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the Parties,
through their undersigned counsel, that the deadline for designating parties’ to seek protective orders with
respect to their confidential information in the In re Google Materials, shall be extended to March 24,
2026.
1 See Dkts. 28 & 29, 39 & 40, 60 & 63, 92 & 95, 137 & 138, 152 & 153, 242 & 243, 254 & 255, 270 &
273, 295 & 296, 310 & 312, 311 & 313, 315 & 317, 399 & 401, 410, 411, 416, 432, 433, 435, & 439.
Case 3:23-cv-00201-WHO Document 441 Filed 03/11/26 Page 3 of 6

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Case No. 23-cv-00201-WHO (LJC) 3
THIRD STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR THIRD PARTIES
TO SEEK PROTECTIVE ORDERS REGARDING MATERIALS PRODUCED TO RUNWAY
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: March 11, 2026 ___________________________________
The Honorable Lisa J. Cisneros
United States Magistrate Judge
Dated: March 9, 2026 By: /s/ Joseph R. Saveri
Joseph R. Saveri
Joseph R. Saveri (SBN 130064)
Cadio Zirpoli (SBN 179108)
Christopher K.L. Young (SBN 318371)
Elissa A. Buchanan (SBN 249996)
Evan Creutz (SBN 349728)
Holden Benon (SBN 325847)
Aaron Cera (SBN 351163)
Alexander Zeng (SBN 360220)
SAVERI LAW FIRM, LLP
550 California Street, Suite 910
San Francisco, CA 94104
Telephone: (415) 500-6800
Facsimile: (415) 395-9940
Email: jsaveri@saverilawfirm.com
Email: czirpoli@saverilawfirm.com
Email: cyoung@saverilawfirm.com
Email: ebuchanan@saverilawfirm.com
Email: hbenon@saverilawfirm.com
Email: acera@saverilawfirm.com
Email: azeng@saverilawfirm.com
Matthew Butterick (SBN 250953)
1920 Hillhurst Avenue, 406
Los Angeles, CA 90027
Telephone: (323) 968-2632
Facsimile: (415) 395-9940
Email: mb@buttericklaw.com
Counsel for Individual and Representative Plaintiffs
and the Proposed Class
Case 3:23-cv-00201-WHO Document 441 Filed 03/11/26 Page 4 of 6

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Case No. 23-cv-00201-WHO (LJC) 4
THIRD STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR THIRD PARTIES
TO SEEK PROTECTIVE ORDERS REGARDING MATERIALS PRODUCED TO RUNWAY
Dated: March 9, 2026 By: /s/ Paven Malhotra
Paven Malhotra
Paven Malhotra (SBN 258429)
David J. Silbert (SBN 173128)
Bailey Heaps (SBN 295870)
Julia L. Greenberg (SBN 333864)
Paul H. von Autenried (SBN 335917)
633 Battery Street
San Francisco, CA 94111-1809
KEKER, VAN NEST & PETERS LLP
Telephone: (415) 391-5400
pmalhotra@keker.com
dsilbert@keker.com
bheaps@keker.com
jgreenberg@keker.com
pvonautenried@keker.com
Counsel for Defendant Runway AI, Inc.
Case 3:23-cv-00201-WHO Document 441 Filed 03/11/26 Page 5 of 6

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Case No. 23-cv-00201-WHO (LJC) 5
THIRD STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR THIRD PARTIES
TO SEEK PROTECTIVE ORDERS REGARDING MATERIALS PRODUCED TO RUNWAY
ATTESTATION PURSUANT TO CIVIL L.R. 5-1
I, Joseph R. Saveri, am the ECF User whose ID and password are being used to file this document.
In compliance with N.D. Cal. Civil L.R. 5-1(i)(3), I hereby attest that the concurrence in the filing of this
document has been obtained from the other signatory.
Dated: March 9, 2026 /s/ Joseph R. Saveri
Joseph R. Saveri
Case 3:23-cv-00201-WHO Document 441 Filed 03/11/26 Page 6 of 6