Extract to table

WHEREAS, in the course of discovery, the parties anticipate producing documents and information that contain confidential, proprietary, and commercially sensitive information, including but not limited to BRB's internal credit files, Special Assets Group memoranda, credit committee minutes, internal strategy documents, loan-loss reserve classifications, collateral appraisals, and financial information of Triton Harbor Industries, LLC and its principals; WHEREAS, the approximate universe of documents under review for production by BRB comprises approximately 34,000 documents, including electronically stored information, and Triton Harbor will be producing its own financial records, communications with Mercer Tidwell & Associates LLC (its restructuring advisor), and related documents; WHEREAS, the parties, by and through their respective counsel, have conferred in good faith and have agreed to the terms of this Stipulated Protective Order (the "Order") to facilitate the free exchange of discovery materials while protecting the legitimate confidentiality interests of both parties and relevant non-parties; WHEREAS, this Order is entered pursuant to CPLR § 3103(a) and the applicable Rules of the Commercial Division of the Supreme Court of the State of New York; NOW, THEREFORE, the Court, having reviewed the parties' stipulation and the representations of counsel, and finding good cause to enter this Order for the protection of confidential and proprietary information, hereby SO ORDERS as follows: SECTION 1: DEFINITIONS As used in this Order, the following terms shall have the meanings set forth below: 1

4 "Confidential" shall mean the first tier of protection under this Order

5 "Highly Confidential — Attorneys' Eyes Only" ("HC-AEO") shall mean the second and highest tier of protection under this Order

6 "Qualified Person" shall mean a person authorized to receive discovery Material designated as Confidential or HC-AEO, as specified in Sections 4 and 5 of this Order, respectively

7 "Counsel of Record" shall mean: (a) For BRB: Calderwood & Harkness LLP, including attorneys Linda Osei, Esq

Each designation of Confidential or HC-AEO must be made in good faith and on a document-by-document or category-by-category basis, consistent with the standards set forth in Sections 1