Andersen et al v. Stability AI Ltd. et al

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Case No.: 3:23-cv-00201-WHO
STIPULATION AND ORDER EXTENDING DEADLINE TO FILE JOINT LETTER BRIEF
REGARDING STABILITY SOURCE CODE AND RFP, SET FIVE
[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
STIPULATION AND ORDER EXTENDING
DEADLINE TO FILE JOINT LETTER
BRIEF REGARDING STABILITY
SOURCE CODE AND REQUEST FOR
PRODUCTION, SET FIVE
Case 3:23-cv-00201-WHO Document 576 Filed 05/29/26 Page 1 of 3

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Case No.: 3:23-cv-00201-WHO 	1
STIPULATION AND ORDER EXTENDING DEADLINE TO FILE JOINT LETTER BRIEF
REGARDING STABILITY SOURCE CODE AND RFP, SET FIVE
Plaintiffs Sarah Andersen, Karla Ortiz, Grzegorz Rutkowski, Gregory Manchess, Gerald Brom,
Jingna Zhang, Julia Kaye, and Adam Ellis (“Plaintiffs”) and Defendants Stability AI Ltd. and Stability AI,
Inc. (collectively, “Stability AI”), by and through their respective counsel, hereby stipulate and agree as
follows:
WHEREAS, on May 7, 2026, Plaintiffs and all Defendants filed a Joint Status Report stating
Plaintiffs and Stability AI were meeting and conferring regarding inspection of Stability AI Source Code
and Stability AI’s Objections and Responses to Plaintiffs’ Requests for Production, Set Five. ECF No. 543
at 5;
WHEREAS, on May 14, 2026, the Court ordered Plaintiffs and Stability to continue to meet and
confer on these matters and, if resolution is not reached, to file joint letter briefs regarding these disputes
by May 28, 2026. ECF No. 555;
WHEREAS, the Parties are negotiating in good faith to resolve their current disputes about the
Source Code Inspection and Stability’s Objections and Responses to Request for Production, Set Five;
WHEREAS, on May 26, 2026, the Parties agreed to extend the deadline to file a joint letter brief
with the Court regarding these disputes to June 5, 2026, in an effort to resolve them without Court
intervention;
WHEREAS, an extension to the deadline to file a joint letter brief regarding Source Code Inspection
and the Objections and Responses to Plaintiffs’ Requests for Production, Set Five would have no other
effect on the current schedule of the case;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the Parties,
through their undersigned counsel, as follows:
1. 	The deadline for filing a Joint Letter Brief regarding inspection of Stability AI Source Code and
Stability AI’s Objections and Responses to Plaintiffs’ Requests for Production, Set Five is
extended from May 28, 2026 to June 5, 2026.
2. 	The Parties shall meet and confer in good faith regarding these disputes on or before June 2,
2026.
Case 3:23-cv-00201-WHO Document 576 Filed 05/29/26 Page 2 of 3

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Case No.: 3:23-cv-00201-WHO 	2
STIPULATION AND ORDER EXTENDING DEADLINE TO FILE JOINT LETTER BRIEF
REGARDING STABILITY SOURCE CODE AND RFP, SET FIVE
3. 	Nothing in this Stipulation shall be construed as a waiver of either Party’s rights or positions
regarding the scope, completeness, or sufficiency of Stability AI’s document productions, or
any other issue in this litigation.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: May 29, 2026
The Honorable Lisa J. Cisneros
United States Magistrate Judge
Case 3:23-cv-00201-WHO Document 576 Filed 05/29/26 Page 3 of 3