Moore v. Johnson & Johnson, 1:24-cv-06405

Plaintiff Lauren Moore filed an employment discrimination lawsuit against Johnson & Johnson and individual defendants after her termination, alleging race-based discrimination.
She asserts claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law.
Defendants moved to dismiss, arguing improper venue for Title VII claims, failure to state a claim under NYSHRL/NYCHRL, and lack of personal jurisdiction.
While the motion to dismiss was pending, Defendants filed two motions to stay discovery.
Both parties had already engaged in significant discovery, exchanging thousands of documents.
The Court considered whether to stay further discovery until the motion to dismiss was resolved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Stay of discovery during motion to dismiss	Stay would prejudice Moore due to fading memories and witness relocation.	Discovery should be stayed due to the burden and potential case dismissal.	Stay granted; discovery paused
Strength of motion to dismiss	Plaintiff maintains claims are viable and should be heard.	Motion to dismiss presents strong defenses that could dispose of case.	Court found motion potentially dispositive
Burden of ongoing discovery	Plaintiff accepts discovery burden due to case importance.	Defendants face substantial burden with continuing discovery.	Court found burden weighs for stay
Prejudice from delay	Delay harms plaintiff’s ability to seek redress and secure evidence.	Limited prejudice due to prior discovery already completed.	Court: Burden outweighs prejudice

Spencer Trask Software & Info. Servs., LLC v. RPost Int’l Ltd., 206 F.R.D. 367 (S.D.N.Y. 2002) (stay of discovery granted where motion to dismiss could resolve most or all claims)
Negrete v. Citibank N.A., 2015 WL 8207466 (S.D.N.Y. 2015) (granting stay where motion to dismiss had substantial arguments for dismissal)