This matter having come before the Court by stipulation of plaintiff, DRAKE PETROLEUM, INC., and defendant, BRYANT TACONIC CORP., for the entry of a protective order pursuant to CPLR 3103(a), limiting the review, copying, dissemination and filing of confidential and/or proprietary documents and information to be produced by either party and their respective counsel or by any non-party in the course of discovery in this matter to the extent set forth below; and the parties, by, between and among their respective counsel, having stipulated and agreed to the terms set forth herein, and good cause having been shown;

This Stipulation is being entered into to facilitate the production, exchange and discovery of documents and information that the parties agree merit confidential treatment (hereinafter the “Documents” or “Testimony”).

In the event that the Producing party does not seek a conference with the Court within five (5) days of the request to declassify, the documents or materials shall no longer be treated as Confidential Information.

Before any disclosure of Confidential Information is made to an expert witness or consultant pursuant to paragraph 5(c) hereof, counsel for the Receiving party shall provide the expert’s written agreement, in the form of Exhibit A attached hereto, to comply with and be bound by its terms.

This Stipulation may be changed by further order of this Court, and is without prejudice to the rights of a party to move for relief from any of its provisions, or to seek or agree to different or additional protection for any particular material or information.

WHEREAS, on July 22, 2021, the Court entered the parties’ stipulation concerning discovery in lieu of conducting a compliance conference (Dkt No. 107); and WHEREAS, on September 17, 2021, Plaintiff filed an Amended Complaint with leave of Court; and

WHEREAS, the parties are completing certain discovery associated with the expanded claims in the Amended Complaint; and WHEREAS, the parties have submitted this compliance stipulation pursuant to the Court’s COVID-19 Procedures (Dkt No. 119).

IT IS HEREBY STIPULATED by and between counsel for the parties in the above- captioned matter that: 1.

Grunberg shall supplement its document production by November 5, 2021; 2.

Plaintiff shall file a Note of Issue on or before February 11, 2022; and 4.

The Parties hereby· expressly submit to the nonexclusive personal jurisdiction of the Supreme Court located in the State of New York, Westchester County, with regard to any dispute arising under or in connection with this ...

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