JOINT STIPULATION

Pursuant to Dkt. No. 2443, Plaintiffs and Defendants Uber Technologies, Inc., Rasier, LLC, and Rasier-CA, LLC (collectively, “Defendants”) (jointly, “the parties”), respectfully submit this Joint Stipulation regarding production of new material responsive to TAR process.

I. Production of Documents after TAR Process

With respect to the documents which the Parties now agree are responsive after the Court’s order at Dkt. No. 2443,

1. Defendants will substantially complete production of all documents deemed responsive as a result of agreements made by the Parties during the TAR negotiations[1] (to the extent these documents have not already been produced pursuant to Dkt. 2009-1) as well as documents deemed responsive by the Court’s order at Dkt. No. 2443, to the extent Defendants do not assert privilege over those documents or otherwise assert those documents are protected from disclosure, by April 11, 2024.

2. These documents will be produced to Plaintiffs pursuant to Dkt. No. 524, and all subsequent orders and/or stipulations agreed to by the Parties related to the production of ESI.

IT IS SO ORDERED.