Magee v. The Walt Disney Company

Background

Defendants moved to stay, or pause, discovery under Federal Rule of Civil Procedure 26(c) while their motion for judgment on the pleadings was pending. Plaintiff’s proposed discovery included requests to five individuals and third-party discovery from Sony, Universal, Google, Spotify, and Apple.

Court’s Reasoning

The court explained that it may stay discovery during a pending dismissal motion when there is good cause. Courts consider whether the defendant has made a strong showing that the claims may lack merit, how broad and burdensome the discovery would be, and whether a stay would unfairly harm the opposing party.

The court found that Defendants had presented substantial arguments for dismissing many, if not all, of the claims, including the argument that Plaintiff had released his claims against Defendants. The court also found that responding to the requested discovery would likely be burdensome. Resolving the pending motion could significantly narrow or eliminate the issues in the case, so continuing discovery could waste the parties’ resources and impose an undue burden on Defendants. Finally, the court found no unfair prejudice to Plaintiff because the motion for judgment on the pleadings had already been filed and the stay was expected to be brief.

Disposition

Magistrate Judge Stewart D. Aaron granted Defendants’ motion. Discovery in the action was stayed pending the court’s disposition of the pending motion for judgment on the pleadings. The opinion did not decide that motion or resolve whether Plaintiff’s claims were released.