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on October 1, 2024, in accordance with the Court's directive that the parties establish a confidentiality protocol governing the production and use of discovery materials in this Action; and WHEREAS, the parties wish to establish a framework for the designation, handling, and protection of confidential information produced in discovery that balances the parties' legitimate interests in protecting confidential and proprietary information with the need for the efficient prosecution and defense of the claims and counterclaims in this Action; NOW, THEREFORE, the parties, through their respective counsel, hereby stipulate and agree as follows, subject to the approval and "So Ordered" endorsement of the Court: Right-click to update Table of Contents ARTICLE 1: DEFINITIONS As used in this Stipulation, the following terms shall have the meanings set forth below: 1

1 "Action" shall mean the matter captioned Meridian Infrastructure Partners LLC v

3 "Receiving Party" shall mean any party or parties that receive discovery Material from a Producing Party in connection with the Action

8 "Qualified Person" shall mean any individual who is authorized under this Stipulation to access Confidential or AEO discovery Material, as specified in Articles 3 and 4, respectively

10 "Coverage Counsel" shall mean Pemberton Fox LLP, 600 Third Avenue, 15th Floor, New York, New York 10016 (contact partner: Rachel Solomons, Esq

In the event that either party engages a different or additional e-discovery vendor during the course of this Action, such vendor shall be subject to the terms of this Stipulation and shall execute the Acknowledgment and Agreement to Be Bound prior to receiving access to any Confidential or AEO discovery Material