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IN THE UNITED STATES DISTRICT som Sours FOR THE WESTERN DISTRICT OF NEW YORK

INDUSTRIAL ACCESS INC. Case No. 22-cv-626 Plaintiff, y JUDGE JOHN L. SINATRA, JR.

PRAETORIAN HOLDINGS GROUP LLC, Defendant. STIPULATED DISMISSAL AND ORDER

Pursuant to Fed. R. Civ. P. 41(a)(1)(a)(ii), and by agreement of all parties herein, Plaintiff Industrial Access, Inc. (“IA”) and Defendant Praetorian Holdings Group LLC (“PHG”) (collectively, the “Parties”) hereby stipulate to the following: 1. The Parties have reached a settlement of this action. 2. The Parties’ settlement has been documented in a certain Confidential Settlement Agreement and Mutual Release (the “Settlement Agreement”), which has been duly executed by IA and PHG. 3. The Parties stipulate and this Court orders that this Court shall and hereby does retain jurisdiction over this action to enforce the terms of the Settlement Agreement. See Kokkonen v. Guardian Life Ins. Co. of Am.,

(1994); and Hendrickson v. United States,

(2d Cir. 2015). 4. The Parties stipulate and this Court orders that, in the event of a default of the Settlement Agreement, this Court may enter a Consent Judgment Entry in accordance with the terms of the Settlement Agreement. 5. IA and PHG hereby dismiss with prejudice and without costs this action and any and all claims that either has asserted against each other in this action, subject to the Court’s

retention of jurisdiction to enforce the terms of the Settlement Agreement and allowing the Parties to submit additional filings to enforce the terms of the Settlement Agreement and any Consent Judgment Entry as agreed to by the Parties. IT IS SO ORDERED, ADJUDGED AND ee | 7 C \ c f \ } 5 \ The-Hon. John L. Sinatra United States District Court Judge UY — - Zo zy AGREED AND CONSENTED TO: Dated: April 17, 2024

/s/Aaron Knights /s/ Jonathon Korinko RUPP PFALZGRAF LLC BENESCH, FRIEDLANDER, COPLAN & Aaron W. Knights, Esq. ARONOFF LLP 1600 Liberty Building Jonathon J. Korinko (Pro Hac Vice) Buffalo, New York 14202 127 Public Square, Suite 4900 (716) 854-3400 Cleveland, OH 44114 [email protected] Tel: (216) 363-4500 Attorneys for Plaintiff Fax: (216) 363-4588 E-mail: [email protected] Attorneys for Defendant

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