Cameron v. Winter
- Vargas
- 1:25-cv-00210
- U.S. District Court · Southern District of New York
- 3
In Cameron v. Winter, Judge Vargas denied Winter’s motion to partially stay discovery while her motion to dismiss remained pending.
Margaret Winter’s request to pause discovery concerning the alleged fiduciary-duty claims was denied; discovery was not partially stayed.
What happened
In Cameron v. Winter, Margaret Winter asked the court to pause discovery about the plaintiffs’ alleged fiduciary-duty claims while her motion to dismiss was pending. She argued that those claims should be litigated in the Delaware Court of Chancery.
The court found that Winter had not shown good cause for a partial stay. It concluded that her arguments mainly concerned where the case should be heard, that the discovery requests did not appear unusually burdensome, and that a stay was generally an exception rather than the rule.
Judge Vargas denied Winter’s Motion to Partially Stay Discovery and directed the clerk to terminate the motion from the docket.
The detailed version
- Cameron v. Winter · No. 1:25-cv-00210
- Vargas
- June 4, 2025
Background
Margaret Winter filed a motion to dismiss. Among other arguments, she contended that the claim concerning an alleged breach of fiduciary duty should be dismissed under the doctrine of forum non conveniens and litigated in the Delaware Court of Chancery. Forum non conveniens is a doctrine that allows a court to decline to hear a case when another forum is more appropriate.
Winter separately moved to partially stay discovery. She distinguished between claims involving breach of contract and declaratory judgment, on one hand, and claims involving alleged breaches of fiduciary duty, on the other. She sought to pause discovery relating to the fiduciary-duty claims, which she described as broader and more fact-intensive.
Court’s analysis
The court explained that filing a motion to dismiss does not automatically stop discovery. Under Federal Rule of Civil Procedure 26(c)(1), a court may stay discovery for good cause, and the party requesting the stay bears the burden of showing good cause.
The court considered three factors: whether the defendant strongly showed that the plaintiff’s claim was unmeritorious, the scope and burden of the discovery, and the risk of unfair prejudice to the party opposing the stay.
The court found no good cause for a partial stay. First, it stated that most of Winter’s arguments concerned the forum where the case would be decided, rather than whether the case belonged in court at all, so a stay would only postpone discovery. Second, the court found that Winter had not adequately explained why discovery would be particularly burdensome; the three requests for production she identified appeared consistent with common practice and limited in time and scope. Third, the court noted that a discovery stay is the exception rather than the rule in the district.
Disposition
Judge Jeannette A. Vargas denied Defendant’s Motion to Partially Stay Discovery. The clerk was directed to terminate ECF No. 23. The opinion addressed the request to stay discovery; it did not rule on the pending motion to dismiss.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.