Andersen et al v. Stability AI Ltd. et al

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28 Case No. 23-cv-00201-WHO (LJC)
SECOND STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR PLAINTIFFS TO PRODUCE TO RUNWAY
MATERIALS CONTAINING THIRD-PARTY DESIGNATED INFORMATION
[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)
SECOND STIPULATED ORDER FOR
ENLARGEMENT OF TIME FOR
PLAINTIFFS TO PRODUCE TO RUNWAY
MATERIALS CONTAINING THIRD-
PARTY DESIGNATED INFORMATION
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 417 Filed 02/17/26 Page 1 of 5

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Case No. 23-cv-00201-WHO (LJC) 	1
SECOND STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR PLAINTIFFS TO PRODUCE TO RUNWAY
MATERIALS CONTAINING THIRD-PARTY DESIGNATED INFORMATION
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, on January 30, Plaintiffs wrote to counsel for Runway requesting its agreement to a 14-
day extension on the deadline to produce In re Google Materials because much of it contains information
designated as confidential by third parties to this Action;
WHEREAS, Runway agreed to a two-week extension, to February 18, 2026, on the deadline for
production of materials designated confidential in In re Google, in order to allow those designating parties
to seek protective orders, in accordance with the protective orders in both this Action and In re Google, but
this agreement does not include those materials that were not designated confidential;
WHEREAS, the Court granted the Parties’ Stipulation for Enlargement of Time for Plaintiffs to
Produce to Runway Materials Containing Third-Party Designated Information (ECF No. 411);
WHEREAS, Plaintiffs have begun complying with the Court’s Order (ECF No. 403) by serving
certain expert reports and written discovery responses that do not contain third-party confidential
information to Runway;
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, Plaintiffs have been working diligently with designating parties through a multi-step
process to identify and redact confidential information in the remaining In re Google Materials in an effort
to resolve confidentiality issues without the need for Court intervention;
Case 3:23-cv-00201-WHO Document 417 Filed 02/17/26 Page 2 of 5

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Case No. 23-cv-00201-WHO (LJC) 	2
SECOND STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR PLAINTIFFS TO PRODUCE TO RUNWAY
MATERIALS CONTAINING THIRD-PARTY DESIGNATED INFORMATION
WHEREAS, Plaintiffs have advised Runway that additional time is needed for the Parties and
designating parties to address confidentiality issues, and that designating parties have expressed concern
regarding the current February 18, 2026, deadline;
WHEREAS, on February 11, Plaintiffs wrote counsel for Runway requesting its agreement to a
further extension on the current February 18, 2026, deadline to produce In re Google Materials containing
confidential information, and for designating parties to seek protective orders, to March 10, 2026;
WHEREAS, Runway agrees to extend to March 10, 2026, the deadline for production of materials
designated confidential in In re Google, 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, but this
agreement does not include those materials that were not designated confidential;
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 Plaintiffs’ deadline to produce In re Google Materials that contain
third-party designated information, and the designating parties’ deadline to seek protective orders with
respect to their confidential information, shall be extended to March 10, 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.
Case 3:23-cv-00201-WHO Document 417 Filed 02/17/26 Page 3 of 5

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Case No. 23-cv-00201-WHO (LJC) 	3
SECOND STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR PLAINTIFFS TO PRODUCE TO RUNWAY
MATERIALS CONTAINING THIRD-PARTY DESIGNATED INFORMATION
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: ___________________________________
MAGISTRATE JUDGE
LISA J. CISNEROS
Dated: February 13, 2026
Dated: February 13, 2016
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)
JOSEPH SAVERI LAW FIRM, LLP
601 California Street, Suite 1505
San Francisco, CA 94108
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
By: 	/s/ Paven Malhotra
Paven Malhotra
David J. Silbert (SBN 173128)
Paven Malhotra (SBN 258429)
Bailey Heaps (SBN 295870)
Julia L. Greenberg (SBN 333864)
Paul H. von Autenried (SBN 335917)
633 Battery Street
San Francisco, CA 94111-1809
February 17, 2026
Case 3:23-cv-00201-WHO Document 417 Filed 02/17/26 Page 4 of 5

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Case No. 23-cv-00201-WHO (LJC) 	4
SECOND STIPULATED ORDER FOR ENLARGEMENT OF TIME FOR PLAINTIFFS TO PRODUCE TO RUNWAY
MATERIALS CONTAINING THIRD-PARTY DESIGNATED INFORMATION
KEKER, VAN NEST & PETERS LLP
Telephone: (415) 391-5400
Email: dsilbert@keker.com
pmalhotra@keker.com
bheaps@keker.com
jgreenberg@keker.com
pvonautenried@keker.com
Counsel for Defendant Runway AI, Inc.
ATTESTATION PURSUANT TO CIVIL L.R. 5-1
The filer attests that the other signatories listed, on whose behalf the filing is also submitted,
are registered CM/ECF filers and concur in the filing’s content and have authorized the filing.
Dated: February 13, 2026 	/s/ Joseph R. Saveri
Joseph R. Saveri
Case 3:23-cv-00201-WHO Document 417 Filed 02/17/26 Page 5 of 5