WHEREAS, on December 23, 2024, the Court entered the Joint Stipulation and Order Approving Privilege Re-Review Protocol (the “Protocol”) (Dkt. 1092); and

WHEREAS, the Protocol establishes that objections to Special Master determinations are generally to be filed within four court days from the issuance of such determinations;

WHEREAS Epic Games, Inc. (“Epic”) is unable to evaluate or object to Special Master determinations upholding redactions for privilege before Apple Inc. (“Apple”) produces to Epic the document subject to such redactions; and

WHEREAS pursuant to the Protocol, Apple may produce documents to Epic after the fourday objection period has passed;

THEREFORE, IT IS STIPULATED AND AGREED THAT:

1. Notwithstanding the time limits set forth in paragraph 4(a) of the Protocol, the deadline for Epic to object to a Special Master ruling on a redacted document will be four (4) court days from the date of production of such document by Apple to Epic, irrespective of the date of the Special Master’s ruling;

2. Notwithstanding the above, Epic may object on or before March 14, 2025, to any Special Master rulings that (i) were issued on or after February 12, 2025, (ii) upheld Apple’s proposed redactions, and (iii) pertained to documents that Apple produced to Epic on or prior to March 10. 

PURSUANT TO THE FOREGOING STIPULATION AND GOOD CAUSE APPEARING, IT IS SO ORDERED.