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Sarah Andersen and DeviantArt dispute custodians

The parties in Andersen v. Stability AI have raised a discovery dispute with Magistrate Judge Cisneros.

Plaintiffs’ Position: Plaintiffs respectfully seek an order requiring DA to designate four
key percipient witnesses as custodians: (1) Niran Lamay (Product Lead); (2) Nikolay Surovenko
(Machine Learning Engineer); (3) Robert Woolfson (Head of Data); and (4) Sasha Lerner (Vice
President of Engineering), for a total number of eight DA custodians.

DeviantArt’s Position: Plaintiffs’ request to add additional custodians should be denied because three of the four new individuals did not work on DreamUp design, training, development, commercialization, or any other aspects relevant to the claim against DA, and the fourth is duplicative and cumulative of information already possessed by existing custodians. Further, Plaintiffs’ claim that DA’s custodians lacked day-to-day involvement in DreamUp is untrue and refuted by the very documents Plaintiffs cite, which show extensive input from the existing custodians.

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