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.

• The deadline to complete fact discovery is extended to January 31, 2025.

• Affirmative expert reports shall be served by March 7, 2025.

• Rebuttal reports shall be served by April 11, 2025.

• The note of issue deadline is extended to May 16, 2025.

• The parties shall submit a joint status update by January 29, 2025.

The following e-filed documents, listed by NYSCEF document number (Motion 009) 140, 141, 142, 143 were read on this motion to/for

It is ORDERED that the motion for leave to appear pro hac vice is granted and Erin Marie Choi, Esq. is permitted to appear and to participate in this action on behalf of defendant; and it is further ORDERED that she shall at all times during this action be associated with counsel who is a member in good standing of the Bar of the State of New York and is attorney of record for the aforesaid party; and it is further ORDERED that all pleadings, briefs, and other papers filed with the court shall be signed by the attorney of record, who shall be responsible for such papers and for the conduct of this action; and it is further ORDERED that, pursuant to Section 520.11 of the Rules of the Court of Appeals and Section 602.2 of the Rules of the Appellate Division, First Department, the attorney hereby admitted pro hac vice shall be familiar with and abide by the standards of professional conduct imposed upon members of the New York Bar, including the rules of the courts governing the conduct of attorneys and the Rules of Professional Conduct; and it is further

Page 1 of 2 ORDERED that she shall be subject to the jurisdiction of the courts of the State of New York with respect to any acts occurring during the course of her participation in this matter; and it is further ORDERED that said counsel shall notify the court immediately of any matter or event in this or any other jurisdiction that affects her standing as a member of the bar.

Motion Seq.

No. _____ ORDERED that the motion for leave to appear pro hac vice is granted and Erin Marie Choi Esq. is permitted to appear and to participate in this action on behalf of the Defendant; and it is further ORDERED that she shall at all times during this action be associated with counsel who is a member in good standing of the Bar of the State of New York and is attorney of record for the aforesaid party; and it is further ORDERED that all pleadings, briefs, and other papers filed with the court shall be signed by the attorney of record, who shall be responsible for such papers and for the conduct of this action; and it is further

that, pursuant to Section 520.11 of the Rules of the Court of Appeals and Section 602.2 of the Rules of the Appellate Division, First Department, the attorney hereby admitted pro hac vice shall be familiar with and abide by the standards of professional conduct imposed upon members of the New York Bar, including the rules of the courts governing the conduct of attorneys and the Rules of Professional Conduct; and it is further ORDERED that she shall be subject to the jurisdiction of the courts of the State of New York with respect to any acts occurring during the course of her participation in this matter; and it is further ORDERED that said counsel shall notify the court immediately of any matter or event in this or any other jurisdiction that affects her standing as a member of the bar.

Dated: _________________

• The deadline to complete fact discovery is extended to January 18, 2025.

• Affirmative expert reports shall be served by February 21, 2025.

• Expert depositions shall be completed by April 25, 2025.

• The note of issue deadline is extended to May 2, 2025.

• The parties shall submit a joint status update by January 16, 2025.

• The deadline to substantially complete productions is September 26, 2024.

• The deadline to complete fact discovery is December 5, 2024.

• Affirmative expert reports shall be served by January 9, 2025.

• Rebuttal reports shall be served by February 13, 2025.

• The parties shall submit a joint status update by October 31, 2024.