Contract analysis

I. INTRODUCTION Plaintiff Cascade Retail Holdings Inc. ("CRH" or "Plaintiff"), by and through its undersigned counsel Calderwood & Harkness LLP, respectfully moves this Court pursuant to Court of Chancery Rules 65(b) and 65(d) for an Order dissolving the Temporary Restraining Order (the "TRO") entered on March 7, 2025 in this action and discharging the injunction bond posted in connection therewith. On March 7, 2025,

II. PROCEDURAL BACKGROUND A. Filing of the Verified Complaint and TRO Motion On March 5, 2025, CRH filed a Verified Complaint (Dkt. No. 1) and a Motion for Temporary Restraining Order and Preliminary Injunction (Dkt. No. 2) in this Court, together with supporting declarations, exhibits, and a memorandum of law. The Verified Complaint asserted five counts arising from what CRH alleged was a coordinated scheme by the I

III. THE CONSENT ORDER SUPERSEDES THE TRO A. The Modified Restrictive Covenant Terms Replace the TRO Restraints The TRO entered on March 7, 2025 imposed a blanket prohibition on all eight Individual Defendants from commencing employment in any merchandising role at Verdana. While this blanket restraint was appropriate and necessary at the time it was entered — when CRH had just discovered the coordinated departures a

IV. DISCHARGE OF THE INJUNCTION BOND In connection with the TRO entered on March 7, 2025, and as required by Court of Chancery Rule 65(c), CRH posted an injunction bond in the amount of $2,500,000 through Broadview Surety Corp. (Bond No. BSC-2025-TRO-04419, issued from Broadview's office at 175 Water Street, Suite 2400, New York, NY 10038). The bond was filed with the Court on March 7, 2025 (Dkt. No. 9) and has remai

V. CONSENT OF THE PARTIES This Motion is made with the full consent of all parties to this action. Undersigned counsel for CRH has conferred with counsel for all Defendants and has confirmed that no party opposes the relief sought herein. Specifically, Catherine Nygaard, Esquire, of Whitfield, Nygaard & Doyle LLP, 1000 North Market Street, Suite 1500, Wilmington, Delaware 19801, counsel of record for all eight Indivi

VI. PROPOSED ORDER A Proposed Order Dissolving the Temporary Restraining Order and Discharging the Injunction Bond is submitted herewith as Exhibit 2 for the Court's consideration. The Proposed Order provides that:

1. The Temporary Restraining Order entered on March 7, 2025 (Dkt. No. 8) is dissolved, effective upon entry of the Consent Order Incorporating Modified Restrictive Covenants filed concurrently herewith.

2. Injunction Bond No. BSC-2025-TRO-04419, in the amount of $2,500,000, posted by Plaintiff Cascade Retail Holdings Inc. through Broadview Surety Corp. (175 Water Street, Suite 2400, New York, NY 10038), is discharged and released.

3. Broadview Surety Corp. is authorized and directed to release Cascade Retail Holdings Inc. from any further obligations arising under Bond No. BSC-2025-TRO-04419.

4. The Order is without prejudice to the rights of any party under the Consent Order Incorporating Modified Restrictive Covenants entered concurrently herewith.

VII. CONCLUSION For the foregoing reasons, Plaintiff Cascade Retail Holdings Inc. respectfully requests that this Court enter the Proposed Order attached hereto as Exhibit 2:

1. Dissolving the Temporary Restraining Order entered on March 7, 2025 (Dkt. No. 8), effective upon entry of the Consent Order Incorporating Modified Restrictive Covenants filed concurrently herewith;

2. Discharging and releasing Injunction Bond No. BSC-2025-TRO-04419 in the amount of $2,500,000 posted by Plaintiff through Broadview Surety Corp.; and

3. Granting such other and further relief as this Court deems just and proper. CALDERWOOD & HARKNESS LLP By: ________ Bernard Crawford (Del. Bar No. 5218) 1301 K Street NW, Suite 1200 Washington, DC 20005 Telephone: (202) 555-7100 Facsimile: (202) 555-7101 bcrawford@calderwoodharkness.com Renata Vasquez (Del. Bar No. 6034) 601 South Figueroa Street, Suite 4200 Los Angeles, CA 90017 Telephone: (213) 555-4800 Facsimile

1. Non-Opposition to Dissolution of the TRO. The undersigned, on behalf of their respective clients, do not oppose the dissolution of the Temporary Restraining Order entered by this Court on March 7, 2025 (Dkt. No. 8), effective upon entry of the Consent Order Incorporating Modified Restrictive Covenants filed concurrently herewith.

2. Non-Opposition to Discharge of Injunction Bond. The undersigned, on behalf of their respective clients, do not oppose the discharge and release of Injunction Bond No. BSC-2025-TRO-04419, in the amount of $2,500,000, posted by Plaintiff Cascade Retail Holdings Inc. through Broadview Surety Corp. No party has asserted or intends to assert any claim against the bond or against Broadview Surety Corp. in connection the

3. Consent Order Supersedes TRO. The undersigned, on behalf of their respective clients, confirm that the Consent Order Incorporating Modified Restrictive Covenants, filed concurrently herewith, supersedes and replaces in their entirety the restraints imposed by the Temporary Restraining Order entered on March 7, 2025 and the Consent Interim Order entered on March 21, 2025. WHITFIELD, NYGAARD & DOYLE LLP By: ________

1. The Temporary Restraining Order entered on March 7, 2025 (Dkt. No. 8) is hereby DISSOLVED, effective as of the date of entry of this Order.

2. Injunction Bond No. BSC-2025-TRO-04419, in the amount of Two Million Five Hundred Thousand Dollars ($2,500,000), posted by Plaintiff Cascade Retail Holdings Inc. through Broadview Surety Corp. (175 Water Street, Suite 2400, New York, NY 10038), is hereby DISCHARGED and RELEASED.

3. Broadview Surety Corp. is authorized and directed to release Cascade Retail Holdings Inc. from any and all further obligations arising under Bond No. BSC-2025-TRO-04419, and the Clerk of this Court is directed to release the bond from the Court's records.

4. This Order is without prejudice to the rights of any party under the Consent Order Incorporating Modified Restrictive Covenants entered concurrently herewith, which retains this Court's jurisdiction for enforcement purposes for the duration of the modified restrictive covenant periods set forth therein. SO ORDERED. ________________________________________ Vice Chancellor Margaret T. Zhao Date: ________