• MEC shall complete its production of all documents subject to the May 17, 2024 order (Dkt. 241) no later than July 26, 2024, and MEC shall make rolling productions each Friday leading to that date, including this Friday, July 12, 2024.

• The deadline to complete fact depositions is extended to September 13, 2024.

• The fact discovery and note of issue deadline is extended to October 4, 2024.

• The parties shall submit their next joint status update by August 7, 2024.

It is ORDERED that the June 21, 2024 order (Dkt. 244) is amended only to the extent that the search terms shall be finalized by June 28, 2024, and the production shall be completed by July 12, 2024.

• MEC need not collect documents from four additional custodians, but shall promptly run Peloton's proposed search terms on the current custodians, provide hit reports, and ultimately review whatever search terms Peloton selects provided the hit count is within the 4,000 cap.

The search terms shall be finalized by June 27, 2024, and the production shall be completed by July 11, 2024.

• MEC shall be permitted to remotely depose Mr. Chu, Ms. Johnson, and Ms. McCormick for an additional hour each.

• MEC shall be permitted to remotely depose Mr. Adee for an additional 30 minutes.

• The parties are reminded that relevance objections are impermissible at depositions.

• The deadline to complete fact depositions is extended to July 15, 2024.

• The fact discovery and note of issue deadline is extended to August 5, 2024.

• MEC shall produce: (1) the documents regarding its actual and avoided costs that it withheld pending the outcome of Peloton’s prior motion to compel, except that it need not produce irrelevant documents such as long-term credit agreements; (2) additional documents sufficient to show the amounts of its actual and avoided costs; and (3) internal communications regarding such costs by reviewing ESI based on search terms to be provided by Peloton, provided that such searches shall have a deduplicated hit count cap of 4,000.

• The parties shall e-file and email the court their next joint update by May 22, 2024.

It is premature to rule on any of the issues raised in the parties' May 8 update letters, and they shall continue to meet confer about those issues.

By May 15, 2024, the parties shall e-file and email the court a joint letter addressing all issues on which the parties have reached an impasse and require a ruling.

However, the parties should not address matters that are not in dispute, disputes on which an impasse has not been reached, and disputes on which they are not yet seeking a ruling.

Rather, they should merely note that there are further issues about which they are conferring and request to provide a further update the following week.

It is SO ORDERED.