Pursuant to Civil Local Rule 37-3, the parties, upon reaching agreement to the terms set 3 forth below, jointly stipulate regarding the deposition of Defendant Elon Musk.

WHEREAS, the fact discovery cut-off in this case is March 31, 2025 (ECF 121 ); WHEREAS, Defendant informed Plaintiffs that he is unavailable to appear for deposition 6 prior to the March 31, 2025 discovery cut-off, but is available to appear for deposition on April 3, 7 2025 in Washington, D.C.; WHEREAS, the parties have met and conferred, and for good cause, subject to the Court's 9 approval below, agreed that (1) Defendant's deposition may be taken on April 3, 2025, after the 10 March 31, 2025 discovery cut-off, and (2) Plaintiffs may file any motion concerning Defendant's 11 deposition after the March 31, 2025 discovery cut-off, while the remaining deadlines in this case 12 would be unaffected.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by the parties hereto, through their undersigned counsel, subject to the approval of the Court: 1) The fact discovery cut-off shall be extended for the limited purpose of taking Defendant's deposition, and for any motion that Plaintiffs may file relating to Defendant's deposition.

2) Defendant's Deposition shall be taken on April 3, 2025, tentatively starting at 9:00 a.m., at a location to be determined in Washington, D.C.

I declare under penalty of perjury under the laws of the United 4 States of America that the foregoing is true and correct.

Regardless, the sealed material is minimally useful “to those monitoring the federal courts.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006) (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)).

By letter at Dkt. No. 352, the parties informed the Court that they had agreed to unseal one of the three categories of document originally covered by the motion.

Defendants continue to seek sealing of the personally identifiable information of third parties in certain materials, and of exhibits 3–9 to the Concannon Declaration at Dkt. No. 347.

Exhibits 3 and 6–9 of the Concannon Declaration are minimally relevant to public understanding of the issues before the Court on the motion to disqualify expert and, in any event, contain confidential business information.

Exhibits 4 and 5 to the Concannon Declaration are contracts containing confidentiality provisions which are central to the issues before the Court on the motion to disqualify expert.

Case No. 4:22-cv-01413-HSG Lead Plaintiff Mark Samarghandi (“Lead Plaintiff”) and Defendants C3.ai, Inc. (“C3”) Thomas M. Siebel, Edward Y. Abbo, David Barter, Lorenzo Simonelli, and Baker Hughes Company (together, the “Defendants,” and with Lead Plaintiff, the “Parties”) hereby stipulate, through their respective counsel of record, subject to approval of the Court, as follows: WHEREAS, on September 27, 2024, Lead Plaintiff filed a motion for leave to file a Third Amended Complaint (ECF No. 181, the “Motion for Leave to Amend”); WHEREAS, on November 12, 2024, Defendants filed their Opposition to Lead Plaintiff’s Motion for Leave to Amend (ECF No. 186); WHEREAS, on December 10, 2024, Lead Plaintiff filed his Reply in Support of the Motion for Leave to Amend (ECF No. 189); WHEREAS, on February 13, 2025, the Court issued an Order Granting Plaintiffs’ Motion for Leave to Amend, Terminating as Moot Defendants’ Motions for Joinders, and Terminating as moot Defendants’ Pending Motions to Dismiss (ECF No. 197, the “MTD Order”); WHEREAS, in the MTD Order, the Court directed Plaintiffs to file their Third Amended Class Action Complaint as a separate docket entry by February 14, 2025 (id. at 5); WHEREAS, in the MTD Order, the Court directed the parties to “meet and confer regarding a briefing schedule for any renewed motion to dismiss, and to file a stipulation and proposed order setting out the agreed-upon briefing schedule and proposed hearing date by February 20, 2025” (id.); WHEREAS, the parties have met and conferred, and all parties consent to the requested relief; IT IS ACCORDINGLY STIPULATED AND AGREED, by and between the undersigned counsel for the parties, subject to Court approval, that:

Plaintiffs shall file their omnibus Opposition to the Motions to Dismiss the Third Amended Class Action Complaint by May 2, 2025.

Defendants shall file their Replies in Support of the Motion to Dismiss the Third Amended Class Action Complaint by June 9, 2025.

Plaintiffs are permitted to file a single, omnibus opposition to Defendants’ motions to dismiss that shall not exceed 60 pages.

5-1(h)(3) I, Reed R. Kathrein, am the ECF User whose identification and password are being used to file the foregoing document.

Pursuant to Civil Local Rule 7-12, the Parties, upon reaching agreement to the terms set forth below, jointly stipulate to resolve their discovery dispute surrounding depositions.

WHEREAS, the parties have met and conferred and, for good cause and based on the complexity and needs of the case, subject to the conditions below, agreed that each side should have leave to take twenty (20) non-expert depositions; THEREFORE IT IS HEREBY STIPULATED AND AGREED, by the Parties hereto, through their undersigned counsel, subject to the approval of the Court, the parties stipulate to the following:

Nothing in this Stipulation shall be interpreted to limit the amount of time the Parties may have by right or under the applicable Federal Rules of Civil Procedure to depose on the record any witness subpoenaed or noticed for deposition or to preclude any Party from cross-noticing the deposition of any person subpoenaed for deposition by the other Party.

Case No. 3:22-CV-05937-CRB February 11, 2025 ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3) I, Tyson C. Redenbarger, attest that concurrence in the filing of this document has been obtained from the other signatories.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Absent any of the elements above, the risk of such a breach is minimal or nonexistent and cannot justify the “drastic remedy” of disqualification.

Defendants nonetheless argue that Barber has a continuing obligation of confidentiality.

(the “Delaware Action”) and state as follows: WHEREAS, the Parties reached an agreement concerning the discoverability in this case of discovery materials exchanged in the Delaware Action (the “Delaware Discovery Materials”) (including with respect to discovery materials that were produced and marked confidential by third parties in the Delaware Action) (the “Agreement”); WHEREAS, on November 8, 2024, the Parties filed a Joint Stipulation and Proposed Order (ECF No. 115) whereby the Parties agreed to be governed by the Agreement attached to that stipulation; WHEREAS, on November 13, 2024, the Court entered such Order (ECF No. 116); WHEREAS, the Agreement provides Defendant will produce “transcripts of and exhibits used during the deposition(s) of the Delaware Defendants” A(1)(c) and “the transcripts of and exhibits used during the depositions of third parties” A(2)(b).

Defendant represents that Twitter will not object to the production of documents it produced or transcripts of and exhibits used during the depositions of its employees and/or board members in the Delaware Action.

Aside from the discovery described in paragraphs A and B (including subparts) above, Plaintiffs agree to refrain from seeking additional document discovery from any party or third party (including Musk, Twitter and X Corp., Tesla, SpaceX, Morgan Stanley, Skadden, X Holdings I, X Holdings II, Space Exploration Technologies Corp., Jared Birchall, Ballard Spar, Quinn Emanuel, McDermott, Antonio Gracias, and Bob Swan) that provided document discovery in the Delaware action that is reproduced in this action, and to refrain from seeking to depose any party or third party (including those identified in the preceding parenthetical) who was deposed in the Delaware Action, so long as such entities and individuals do not object to production to Plaintiffs of all the material identified in A.1-A.2 that was previously provided or produced in the Delaware Action.

Plaintiffs reserve the right to seek interrogatories and requests for admission from Mr. Musk, as permitted under the applicable rules and procedures.

All other terms of the Discovery Agreement remain in force and affect, and shall apply to the production of the audio and video unless otherwise stated herein.