of the State of New York, reached an agreement on a process for expert discovery in the above- captioned action; IT IS HEREBY STIPULATED AND AGREED, by and between the Parties, as follows:

Notwithstanding any provision of law to the contrary, including CPLR 3101, Commercial Division Rule 13(c), or any other potentially applicable provision, case law, or rule, discovery (including disclosure at any hearing or trial) shall not be permitted into the following, except to the limited extent that an expert identifies in their report any of the foregoing materials or communications as facts or data relied upon in forming the expert’s opinions: (a) Drafts of reports, disclosures, declarations, affidavits, work product, workpapers, worksheets, notes, memoranda, outlines, non-final calculations, modeling, or other preliminary, intermediate, or draft materials, or supporting materials, including materials, studies, charts, documents, or exhibits, regardless of form, prepared or provided by or for the expert, the Parties or their counsel, or the expert’s staff, supporting firm,

Notes or other documents prepared or provided by or for the expert or the expert’s staff, supporting firm, consultants, or persons working under the expert’s supervision; or

Notwithstanding anything to the contrary herein, it is understood and agreed that all Parties reserve their right to object to any question, as appropriate.

Nothing herein shall constitute a waiver of privilege or work product claim or limit or waive any Party’s right to object for any reason to the admission of any other Party’s expert’s reports or opinions (in whole or in part) into evidence or to the qualification of any person to serve as an expert witness.

• The deadline to complete fact discovery is extended to February 7, 2025.

• Affirmative expert reports shall be served by March 14, 2025.

• Rebuttal reports shall be served by April 18, 2025.

• The note of issue deadline is extended to May 23, 2025.

• The parties shall submit a joint status update by May 19, 2025.