Texas Court of Appeals, 15th District, 2025

In re Storable, Inc.; RedNova Labs, Inc. (d/B/A storEDGE); SitelinkSoftware, LLC; Easy Storage Solutions, LLC; Bader Co.; And Property First Group, LP v. the State of Texas

Texas Court of Appeals, 15th District · Decided June 23, 2025

Opinion

ACCEPTED 15-25-00109-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/23/2025 5:08 PM NO. __-__-______-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 6/23/2025 5:08:40 PM CHRISTOPHER A. PRINE Clerk IN RE STORABLE, INC.; REDNOVA LABS, INC. (D/B/A STOREDGE); SITELINK SOFTWARE, LLC; EASY STORAGE SOLUTIONS, LLC; BADER CO.; AND PROPERTY FIRST GROUP, LP Relators.

Relating to Trial Court Cause No. 25-BC03A-0001 In the Third Division of the Texas Business Court SWORN MANDAMUS RECORD

Dale Wainwright State Bar No. 00000049 [email protected] Justin Bernstein State Bar No. 24105462 [email protected] GREENBERG TRAURIG, LLP West 6th Street Suite 2050 Austin, Texas 78701 T: (512) 320-7200 F: (512) 320-7210 COUNSEL FOR RELATORS INDEX TO SWORN MANDAMUS RECORD Exhibit Description Date Pages 1 Docket Sheet N/A 008-046 Plaintiff’s Verified Second Amended 01/28/2025 Petition and Application for A Temporary 2 047-083 Restraining Order, Temporary Injunction, and Permanent Injunction Reporter’s Record Volume 4 of 7 Volumes 02/13/2025 3 from Appeal No. 15-25-00020-CV 084-092 (excerpt) Reporter’s Record Volume 5 of 7 Volumes 02/14/2025 4 from Appeal No. 15-25-00020-CV 093-102 (excerpt) 5 Notice of Appeal 02/25/2025 103-107 Agreed Protective Order and Temporary 02/27/2025 6 108-119 Sealing Order Storable’s Motion to Modify Protective 04/04/2025 7 Order/ Require Disclosure and Request for 120-135 Expedited Consideration Exhibits A-J of Storable’s Motion to Modify 04/04/2025 8 Protective Order/ Require Disclosure and 136-181 Request for Expedited Consideration Plaintiff’s Response to Motion to Modify 04/11/2025 9 182-224 Protective Order and Require Disclosure Order Denying Motion to Modify 04/15/2025 10 225-227 Protective Order Defendants’ Objections and Responses to 04/21/2025 11 Plaintiff SafeLease Insurance Services, 228-245 LLC’s First Merits Request for Production

-2- Defendants’ Amended Answer, Affirmative 05/05/2025 Defenses, Response in Opposition to 12 246-276 Plaintiff’s Application for Temporary Injunction, and Counterclaims Lockelaw PLLC’s Letter to the Court 05/16/2025 277-280 Supplement to Plaintiff’s Verified Second 05/22/2025 Amended Petition and Application for a 14 281-284 Temporary Restraining Order, Temporary Injunction, and Permanent Injunction Arnold & Porter’s Response Letter to 05/23/2025 15 285-289 Lockelaw PLLC’s Letter to the Court Discovery Order [referred to as the 05/28/2025 Production Order in the petition for writ of 290-295 mandamus] Defendants’ Motion for Partial Summary 06/02/2025 Judgment on SafeLease’s Attempted 296-326 Monopolization Claim Declaration of Katherine Ginzburg 06/02/2025 Treistman in Support of Defendants’ Motion for Partial Summary Judgment on 327-694 SafeLease’s Attempted Monopolization Claim Storable’s Emergency Motion for a Partial 06/06/2025 Stay of the June 13, 2025 Court-Ordered 695-704 Production Deadline Storable’s Motion for Reconsideration of 06/06/2025 the Court’s April 15, 2025 Order Denying 705-793 Modification of the Protective Order Storable’s Motion for Partial 06/09/2025 Reconsideration of the May 28, 2025 21 794-862 Discovery Order (including declaration and exhibit to declaration)

-3- Notices of Written Submission and 06/10/2025 22 863-864 Briefing Schedules Plaintiff’s Opposition to Defendants’ 06/12/2025 Motion for Partial Stay of Production 865-960 Deadline Storable’s Reply in Support of Emergency 06/12/2025 Motion for a Partial Stay of the June 13, 961-966 2025 Court-Ordered Production Deadline Order Partially Granting Emergency Stay 06/12/2025 25 967-968 and Additional Relief Plaintiff’s Response to Motion for 06/16/2025 Reconsideration of Order Denying 969-985 Modification of Protective Order Storable’s Motion for Extension of Stay and 06/17/2025 27 986-996 Reply Deadline Plaintiff’s Response to Motion for Partial 06/19/2025 Reconsideration of May 28, 2025 997-1042 Discovery Order Notice of Submission 06/20/2025 1043-1045 Storable’s Reply in Support of its Motion 06/23/2025 for Partial Reconsideration of the May 28, 1046-1070 2025 Discovery Order Plaintiff’s Response to Motion for 06/23/2025 31 1071-1075 Extension of Stay Orders on Motions for Reconsideration; 06/23/2025 32 1076-1079 Other Relief

-4- CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served on counsel of record by using the Court’s CM/ECF system on the 23rd day of June 2025, addressed as follows:

STONE HILTON PLLC Judd E. Stone II State Bar No. 2407670 [email protected] Christopher D. Hilton State Bar No. 24087727 Congress Ave., Austin, Texas 78701 T: (737) 465-7248 YETTER COLEMAN LLP R. Paul Yetter State Bar No. 22154200 [email protected] Susanna R. Allen State Bar No. 24126616 [email protected] Luke A. Schamel State Bar No. 24106403 [email protected] Shannon N. Smith State Bar No. 24110378 [email protected] Main Street, Suite 4100 Houston, Texas 77002 T: (713) 632-8000 COUNSEL FOR REAL PARTY

-5- I also certify that a copy of the foregoing document was served by email on Respondent on the 23rd day of June 2025, addressed as follows:

Honorable Melissa Andrews Third Division of the Texas Business Court Herman Marion Sweatt Courthouse Courtroom 421 1000 Guadalupe St. Austin, Texas 78701 [email protected]

/s/ Dale Wainwright Dale Wainwright

-6- re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

https://research.txcourts.gov/CourtRecordsSearch/ViewCasePrint/7c3dd6b992cc448397adba060cc864e6 008 Case Information SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink Software, LLC,Easy Storage Solutions, LLC,Bader Co.,Property First Group, LP 25-BC03A-0001 Location Business Court 3a Case Category Civil - Other Civil Case Type Tortious Interference Case Filed Date 1/29/2025 Judge Andrews, Melissa Davis Case Status Open (Active)

Parties □7 Type Name Nickname/Alias Attorneys Plaintiff SafeLease Insurance Services LLC Adam Locke, Alexander Dvorscak, Christopher Hilton, Julia Risley, Luke Schamel, Mr Judd Stone, II, Mr R. Paul Yetter, Shannon Smith, Susanna Allen Appellant Storable, Inc. Andrew Bergman, John Holler, Justice Dale Wainwright, Lakshmi Kumar, Mikaila Skaroff, Mr Neil Kenton Alexander, JR, Ms Elizabeth Eoff, Ms Jonna Summers, Ms Katherine G.

Treistman, Ray Torgerson Appellant RedNova Labs, Inc. Andrew Bergman, John Holler, Justice Dale Wainwright, Lakshmi Kumar, Mikaila Skaroff, Mr Neil Kenton Alexander, JR, Ms Elizabeth Eoff, Ms Jonna Summers, Ms Katherine G.

Treistman, Ray Torgerson Appellant SiteLink Software, LLC Andrew Bergman, John Holler, Justice Dale Wainwright, Lakshmi Kumar, Mikaila Skaroff, Mr Neil Kenton Alexander, JR, Ms Elizabeth Eoff, Ms Jonna Summers, Ms Katherine G.

Treistman, Ray Torgerson Appellant Easy Storage Solutions, LLC Andrew Bergman, John Holler, Justice Dale Wainwright, Lakshmi Kumar, Mikaila Skaroff, Mr Neil Kenton Alexander, JR, Ms Elizabeth Eoff, Ms Jonna Summers, Ms Katherine G.

Treistman, Ray Torgerson Appellant Bader Co. Andrew Bergman, John Holler, Justice Dale Wainwright, Justin Bernstein, Lakshmi Kumar, Mikaila Skaroff, Mr Neil Kenton Alexander, JR, Ms Elizabeth Eoff, Ms Jonna Summers, Ms Katherine G. Treistman, Ray Torgerson Appellant Property First Group, LP Andrew Bergman, John Holler, Justice Dale Wainwright, Justin Bernstein, Lakshmi Kumar, Mikaila Skaroff, Mr Neil Kenton Alexander, JR, Ms Elizabeth Eoff, Ms Jonna Summers, Ms Katherine G. Treistman, Ray Torgerson

Hearings □

Date/Time Hearing Type Judge Location Result 2/11/2025 09:00 AM Temporary Injunction Hearing Andrews, Melissa Davis Heman Marion Sweatt Held Courthouse - Hearing Room

1 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date/Time Hearing Type Judge Location Result 009 2/13/2025 09:00 AM Temporary Injunction Hearing Andrews, Melissa Davis Heman Marion Sweatt Held Courthouse - Hearing Room 2/14/2025 09:00 AM Temporary Injunction Hearing Andrews, Melissa Davis Heman Marion Sweatt Held Courthouse - Hearing Room 2/18/2025 02:00 PM Temporary Injunction Hearing Andrews, Melissa Davis Virtual/Video Hearing Held 3/13/2025 09:00 AM Scheduling Conference Andrews, Melissa Davis Virtual/Video Hearing Held 4/10/2025 10:00 AM Other Hearing Andrews, Melissa Davis Virtual/Video Hearing 6/2/2025 10:00 AM Other Hearing Andrews, Melissa Davis Virtual/Video Hearing Held 7/1/2025 09:00 AM Motion for Summary Andrews, Melissa Davis Heman Marion Sweatt Judgment Courthouse - Hearing Room 6/12/2026 09:00 AM Pre-Trial Conference Andrews, Melissa Davis 6/23/2026 09:00 AM Pre-Trial Hearing Andrews, Melissa Davis 6/30/2026 09:00 AM Bench Trial Andrews, Melissa Davis Heman Marion Sweatt Courthouse - Hearing Room

Events D

Date Event Type Comments Documents 1/29/2025 Filing Case Information Sheet Business Court Case Information Sheet.pdf 1/29/2025 Filing Transfer (County Use Exhibit A - Appendix & Exhibit A - Appendix & Travis County Records.pdf Only) Travis County Records 1/29/2025 Filing Notice of Removal to Notice of Removal To Notice of Removal To Business Court.pdf Business Court Business Court 1/29/2025 Filing New Cases Filed (OCA) No Documents © 1/30/2025 Filing Application Plaintiff's Emergency Plaintiff's Emergency Application For Temporary Restraining Application For Order, Temporary Injunction, and In The.pdf Temporary Restraining Order, Temporary Injunction, and In The Alternative, Motion For Recondsideration 1/30/2025 Filing Protective Order Proposed Temporary Proposed Temporary Restraining Order and Order Setting Restraining Order and Hearing For Temporary Injunction.pdf Order Setting Hearing For Temporary Injunction 1/30/2025 Filing Appearance of Counsel Notice of Appearance.pdf 1/30/2025 Filing Notice of Hearing Notice of Hearing - TRO Notice of Hearing - TRO.pdf 1/30/2025 Filing Objection Defendants' Objection to Defs' Obj to Removal and Request for Hearing.pdf, Ex. A - Removal and Request for Email Ruling.pdf Hearing 1/30/2025 Filing Protective Order Proposed Temporary Proposed Temporary Restraining Order and Order Setting Restraining Order and Hearing for Temporary Injunction.pdf Order Setting Hearing for Temporary Injunction 1/31/2025 Filing Protective Order Proposed Order Denying Proposed Order Denying Application for Emg TRO.pdf, Plaintiff's Emergency Transmittal Letter to Business Court and Proposed Order Application for Temporary Attached.pdf Restraining Order 1/31/2025 Filing Objection Defendants' Objections to Defendants' Objections to January 30 Proposed Order.pdf Plaintiff's January 30 Proposed Order 1/31/2025 Filing Notice of Hearing Notice of Hearing.pdf 1/31/2025 Filing Order Order Denying Order Denying Application for Temporary Restraining Application for Temporary Order.pdf Restraining Order

2 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 010 1/31/2025 Filing Motions - All Other Defendants' Motion to Motion to Remand.pdf, Proposed Order Granting Motion To Remand Remand.pdf 1/31/2025 Filing Notice of Hearing Notice of Hearing on Notice of Hearing on Motion to Remand.pdf Motion to Remand 2/3/2025 Filing Letter from Attorney Court Welcome Letter Welcome Letter.pdf 2/3/2025 Filing Certificate of Court Appointment of Deputy Appointment of Deputy Court Reporter and Statement.pdf Reporter Official Court Reporter and Statement 2/4/2025 Filing Motions - All Other Plaintiff's Emergency Plaintiff's Emergency Motion For Expedited Discovery & Entry Motion for Expedited of Discovery Control Plan.pdf Discovery and Entry of Discovery Control Plan 2/4/2025 Filing Order Order Setting Briefing Order Setting Briefing Schedule and Hearing on Motion to Schedule and Hearing Remand.pdf 2/4/2025 Filing Notice of Court Notice of Court Order.pdf Proceeding 2/4/2025 Filing Order Expedited Discovery Expedited Discovery Order.pdf Order 2/7/2025 Filing Protective Order Proposed Order Denying Proposed Order Denying Motion to Remand.pdf Motion to Remand 2/7/2025 Filing Answer/Response Plaintiff's Opposition to Plaintiff's Opposition to Defendants' Motion to Remand.pdf Defendants' Motion to Remand 2/10/2025 Filing Witness List Plaintiff's Witness List Plaintiff's Witness List for TI Hearing (Incl Expert Discl) - REDACTED.pdf 2/10/2025 Filing Brief Plaintiff's Hearing Brief Plaintiff's Hearing Brief on Texas Antitrust Law.pdf On Texas Antitrust Law 2/10/2025 Filing Answer/Response Defendants' Reply Defendants' Reply Supporting Motion to Remand.pdf Supporting Motion to Remand 2/10/2025 Filing Brief Plaintiff's Hearing Brief on Plaintiff's Hearing Brief on Reconsideration.pdf Reconsideration 2/10/2025 Filing Answer/Response Plaintiff's Original Answer Plaintiff's Answer and Special Exceptions to Defendants' and Special Exceptions to Counterclaims.pdf Defendants' Counterclaims 2/10/2025 Filing Letter from Attorney Plaintiff's Discovery Letter Plaintiff's Discovery Letter.pdf 2/10/2025 Filing Opinion Order & Opinion Denying Order & Opinion Denying Defendants' Motion to Remand.pdf Motion to Remand 2/10/2025 Filing Notice of Court Notice of Court Order.pdf Proceeding 2/10/2025 Filing Letter from Attorney Response to Discovery Ex. A - 2025-02-07 Plaintiff's Response to Def..pdf, Ex. B - Letter to Court 2025-01-12 Plaintiff's Objections to D.pdf, Response to Discovery Letter.pdf 2/11/2025 Hearing Temporary Injunction - - Hearing 2/11/2025 Filing Letter from Attorney Plaintiff's Discovery Plaintiff's Discovery Response Letter.pdf Response Letter 2/13/2025 Hearing Temporary Injunction - - Hearing 2/13/2025 Filing Certificate of Court Appointment of Deputy Appointment of Court Reporter Form.pdf Reporter Official Court Reporter and Statement 2/14/2025 Hearing Temporary Injunction - - Hearing 2/14/2025 Filing Notice of Hearing Notice of Hearing Notice of Hearing - TI Closing Arguments.pdf

3 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 011 2/18/2025 Filing Brief Defendants' Bench Brief Defendants' Bench Brief on the Court's Authority.pdf on the Court's Authority to Compel Parties to Enter into Contract, Set Price Terms, and Permit Free- Riding 2/18/2025 Filing Brief Requested Bench Brief Requested Bench Brief.pdf 2/18/2025 Filing Brief Plaintiff's Post-Hearing Plaintiff's Post-Hearig Breif.pdf Brief on Legal Issues 2/18/2025 Filing Motions - All Other Motion to Exclude or Motion to Exclude or Disregard Opinions of Dr. Williams On Disregard Opinions of Dr. The Ground That They Are Unreliable & Con.pdf Williams on the Ground that they are Unreliable and Constitute No Evidence 2/18/2025 Filing Protective Order API Access Proposed TI Proposed TI Order.pdf Order 2/18/2025 Filing Protective Order AU Access Proposed TI Proposed TI Order.pdf Order 2/18/2025 Filing Protective Order Order Denying Plaintiff's Proposed Order Denying Plaintiff's Application.pdf Application for Temporary Injunction 2/18/2025 Hearing Temporary Injunction - - Hearing 2/19/2025 Filing Protective Order Proposed Order Granting Propopsed Order Granting Temporary Injunction.pdf Temporary Injunction 2/19/2025 Filing ISCOI Order Granting Order Granting Plaintiff's Application for Temporary Temporary Injunction Injunction.pdf 2/20/2025 Filing Bond Cash Bond Cash Bond Form.pdf 2/20/2025 Filing Protective Order Proposed Agreed 2025-02-20 Agreed Protective Order_Business Court.pdf Protective Order 2/21/2025 Service Writ - - 2/21/2025 Filing Writ of Injunction Storable, Inc. Writ of Temporary Injunction.pdf 2/21/2025 Filing Letter from Attorney Letter to Court Regarding Letter to Ct re Bond.pdf Bond 2/21/2025 Filing Motions - All Other Objections to temporary 2025-02-21 Objections to temporary injunction order and injunction order and motion to reconsider.pdf motion to reconsider 2/21/2025 Filing Protective Order Proposed Order Granting Proposed Order Granting Motion To Reconsider.pdf Defendants' Motion To Exclude and Reconsider 2/24/2025 Filing Answer/Response Plaintiff's Response to Plaintiff's Resp. to Mot. to Reconsider TI Order.pdf, Proposed Motion to Reconsider TI Order Denying Mot. to Reconsider TI Order.pdf Order with Proposed Order attached 2/25/2025 Filing Notice Defs Notice of 2025-02-25 Notice of Submission.pdf Submission 2/25/2025 Filing Notice of Appeal Defendants' Notice of 2025-02-25 Notice of Appeal.pdf Appeal 2/25/2025 Filing Request Request for Reporter's 2025-02-25 Request for Reporter's Record D. Goree.pdf Record - D. Goree 2/25/2025 Filing Request Request for Reporter's 2025-02-25 Request for Reporter's Record K. Kidd.pdf Record - K.Kidd 2/25/2025 Filing Request Defs' Request for Clerk's 2025-02-25 Request for Clerk's Record.pdf Records 2/26/2025 Filing Request Request for Reporter's 2025-02-26 Request for Reporter's Record L. Schnoor.pdf Record L. Schnoor 2/27/2025 Filing Correspondence - From 15th Court of Correspondence From 15th Court of Appeals.pdf Received Appeals

4 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 012 2/27/2025 Filing Notice of Hearing Notice of Hearing - Notice of Hearing - Sealing.pdf Sealing Motion 2/27/2025 Filing Notice of Hearing Notice of Scheduling Notice of Scheduling Conference.pdf Conference 2/27/2025 Filing Order Agreed Protective Order Agreed Protective Order and Temporary Sealing Order.pdf & Temporary Sealing Order 2/27/2025 Filing Request Request for Reporter's Request for Reporter's Record J. Simon.pdf Record J. Simon 2/27/2025 Filing Notice of Court e Service Reciept Notice of Court Proceeding.pdf Proceeding 2/28/2025 Filing Correspondence - Sent Invoice - Cost of Invoice.pdf Preparation of Clerk's Record 2/28/2025 Filing Letter from Attorney Payment for Clerk's Clerk's Record Invoice.pdf Record $1003.00 3/3/2025 Filing Request Designation of Reporter's Designation of Reporter's Records.pdf Records 3/4/2025 Filing Correspondence - From 15th Court of Correspondence - Received.pdf Received Appeals re: Court Reporter's Extension 3/5/2025 Filing Ody - Motion - Dismiss Plaintiff's Corporate Plaintiff's Corporate Disclosure Statement.pdf Disclosure Statement 3/5/2025 Filing Protective Order Proposed Scheduling 2025.03.05 - Proposed Sch. Order (Final).pdf Order 3/5/2025 Filing Ody - Motion - Dismiss Defendants' Corporate Defendants' Corporate Disclosure Statement.pdf Disclosure Statement 3/6/2025 Filing Notice of Hearing Amended Notice of Amended Notice of Hearing Sealing.pdf Hearing - Sealing Motion 3/6/2025 Filing Notice of Court EService Receipt Notice of Court Proceeding.pdf Proceeding 3/7/2025 Filing Appearance of Counsel Notice of Attorney Notice of Appearance by Katherine G. Treistman and Andrew Appearance by Katherine D. Bergman.pdf G. Treistman and Andrew D. Bergman for Defendants Storable, Inc., RedNova Labs, Inc. d/b/a StorEDGE, Sitelink Software, LLC, Easy Storage Solutions, LLC, Bader Co., and Property First Group, LP 3/7/2025 Filing Order Amended Temporary Amended Temporary Sealing Order.pdf Sealing Order 3/7/2025 Filing Answer/Response Supplement to Plaintiff's 2025-03-07 25-BC03A-0001 Plaintiff's Supp. Resp. to Mtn to Response to Objections Reconsider TI Order.pdf, Exhibit A - 2025.02.27 - Storable to Injunction and Motion Defends Platform Integrity.pdf to Reconsider 3/10/2025 Filing Correspondence - From 15th Court of Letter From 15th Court of Appeals re: Clerk's Record Filed.pdf Received Appeals re: Clerk's Record Filed 3/10/2025 Filing Notice of Court Receipt Eserve Temp Eserve Temp Sealing Order.pdf Proceeding Sealing Order 3/10/2025 Filing Answer/Response Storables Reply Reply supporting objections to temporary injunction order and Supporting Objections to motion to reconsider.pdf Temporary Injunction Order, Motion to Rule On Exclusion of Opinions of Dr. Williams, and Motion to Reconsider Based on Objections and Exclusion 3/11/2025 Filing Order Order on Post-TI Motions Order on Post-TI Motions.pdf

5 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 013 3/11/2025 Filing ISCOI Amended Order Granting Amended Order Granting Temporary Injunction.pdf Temporary Injunction 3/11/2025 Filing Notice of Court Eserve Receipt of Order Notice of Court Proceeding.pdf Proceeding on Post TI Motions 3/11/2025 Filing Notice of Court Eserve Receipt for Notice of Court Proceeding.pdf Proceeding Amended TI Order 3/11/2025 Filing Motion Defendant's Motion for Defendant's Motion for Clarification.pdf Clarification 3/12/2025 Filing Protective Order Defendant's Motion for Proposed Order Granting Defendants' Motion for Clarification Clarification.pdf 3/12/2025 Filing Notice Notice of Hearing By Notice of Hearing By Submission on Motion for Submission on Motion for Clarification.pdf Clarification 3/12/2025 Filing Notice Notice of Submission - Notice of Submission - Motion for Clarification.pdf Motion for Clarification 3/13/2025 Hearing Scheduling Conference - - 3/13/2025 Filing Notice of Court Eserve Receipt of Notice Notice of Court Proceeding- Eserve Notice of Submission.pdf Proceeding of Written Submissions 3/13/2025 Filing Notice Amended Notice of Amended Notice of Submission.pdf Submission 3/13/2025 Filing Notice of Court Eserve Amended Notice Notice of Court Proceeding-Eserve Amended Notice of Proceeding of Submission Submission.pdf 3/14/2025 Filing Special/Other Scheduling Order Scheduling Order.pdf 3/14/2025 Filing Protective Order Proposed ESI Protocol 2025-03-14 Proposed ESI Protocol Order.pdf Order 3/19/2025 Filing Answer/Response Plaintiff's Response to Plaintiff's Response to Motion to Clarify TI Order.pdf Motion for Clarification 3/19/2025 Filing Motion Plaintiff's Motion to Plaintiff's Motion to Release and Substitute Bond.pdf, Release Cash Bond and Proposed Order Releasing and Substituting Bond.pdf Substitute with Surety Bond 3/19/2025 Filing Bond SafeLease Surety Bond Surety Bond - SafeLease.pdf 3/20/2025 Filing Notice Notice of Written Notice of Submission - Motion to Release.pdf Submission - Motion to Release 3/24/2025 Filing Answer/Response Storable's Reply in Storable's Reply in Support of Motion for Clarification.pdf Support of Motion for Claification 3/24/2025 Filing Order Order on Motion for Order on Motion for Clarification.pdf Clarification 3/24/2025 Filing Appearance of Counsel Notice of Appearance of Notice of Appearance of Adam T. Locke for Plaintiff SafeLease Adam T. Locke for Insurance Services LLC.pdf Plaintiff SafeLease Insurance Services LLC 3/25/2025 Filing Answer/Response Storable's Response in Storable's Response in Opposition to Plaintiff's Motion to Opposition to Plaintiff's Release Cash Bond.pdf Motion to Release Cash Bond and Substitute with Surety Bond 3/25/2025 Filing Letter from Attorney Letter re Protective Order Letter re Protective Order & Sealed Records + Ex. A.pdf & Sealed Records + Ex. A 3/25/2025 Filing Exhibit List Receipt of Exhibits Receipt of Exhibits.pdf 3/25/2025 Filing Motions - All Other Plaintiff's Unopposed 2025-03-25 Motion for Perm Seal (final).pdf, 2025-03-25 Motion for Permanent Proposed Order Perm. Seal.pdf Sealing Order 3/26/2025 Filing Protective Order Proposed Permanent Proposed Permanent Sealing Order.pdf Sealing Order

6 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 014 3/26/2025 Filing Notice of Hearing Public Notice of Hearing 2025-03-26 Public Notice Hearing on Perm Seal.pdf on Plaintiff's Unopposed Motion for Permanent Sealing Order 3/26/2025 Filing Protective Order Denying Plaintiff's Motion Proposed Order Denying Plaintiff's Motion to Release Cash to Release Cash Bond Bond and Substitute with Surety Bond.pdf and Substitute with Surety Bond 3/26/2025 Filing Motion Defendants' Rule 76A Defendants' Rule 76A Motion to Seal Court Reco.pdf, Motion to Seal Court Proposed Order.pdf Records 3/26/2025 Filing Notice of Appeal Amended Notice of Amended Notice of Appeal by Storable.pdf Appeal by Storable 3/26/2025 Filing Notice Notice of Rule 76A Notice of Rule 76A Motion to Seal Court Record.pdf Motion to Seal Court Records 3/27/2025 Filing Request Defendant's Request for Defendant's Request for Preparation of First Supplemental Preparation of First Clerk's Record.pdf Supplemental Clerk's Record 3/27/2025 Filing Return of Service Verified Public Notice of Verified Public Notice Hearing on Perm Seal.pdf Hearing 3/27/2025 Filing Service Return Officer's Return of Officer's Return of Service of Notice of Rule.pdf Service of Notice of Rule 76A Motion to Seal Court Records 3/27/2025 Filing Notice 2025-03-27 Verified 2025-03-27 Verified Public Notice Hearing on Perm Seal.pdf Public Notice of Hearing (Mtn to Seal) 3/27/2025 Filing Answer/Response Plaintiff's Reply in Plaintiff's Reply in Support of its Motion to Release Cash Bond Support of its Motion to and Sub with Surety Bond.pdf Release Cash Bond and Sub with Surety Bond 3/28/2025 Filing Motion Storable's Unopposed Proposed Order Granting Storable's Motion for Leave to File Motion for Leave to File a Sur-Reply.pdf, Storable's Sur-Reply in Opposition to Plaintiff's Sur-Reply Motion to Release Cash Bond.pdf, Storable's Unopposed Motion for Leave to File a Sur-Reply.pdf 3/28/2025 Filing Correspondence - Payment for Invoice - Supplemental Clerks Record.pdf Received Supplemental Clerk's Record $181.00 3/28/2025 Filing Protective Order Proposed Order Granting Proposed Order Granting Storable's Motion for Leave to File Unopposed Motion for Sur-Reply.pdf Leave to File a Sur-Reply 3/31/2025 Filing Correspondence - From 15th Court of Notice From 15th Court of Appeals - Supplemental Clerk's Received Appeals - Supplemental Record Filed.pdf Clerk's Record Filed 3/31/2025 Filing Order Denying Motion to Order Denying Motion to Substitute Bond.pdf Substitute Bond 4/3/2025 Filing Motion Mikaila Skaroff's Mikaila Skaroff's Unopposed Motion for Pro Hac Vice Unopposed Motion for Admission.pdf, Proposed Order Granting Unopposed Motion of Pro Hac Vice Admission Mikaila Skaroff to Appear Pro Hac Vice.pdf and Proposed Order 4/3/2025 Filing Motion Motion of Katherine G. Motion of Katherine G. Treistman Requesting Admission of Treistman Requesting Mikaila Skaroff to Appear Pro Hac Vice.pdf Admission of Mikaila Skaroff to Appear Pro Hac Vice 4/3/2025 Filing Order Order Granting Motion to Order Granting Skaroff PHV Motion.pdf Appear Pro Hac Vice- Signed

7 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 015 4/3/2025 Filing Answer/Response Response in Opposition 2025.04.03 Response in Opposition to Defendants' Motion to to Defendants' Motion to Seal_Redacted.pdf, 2025-04-03 Proposed Order Partially Seal Denying Sealing.pdf 4/4/2025 Filing Protective Order Proposed Order Partially Proposed Order Partially Denying Sealing.pdf Denying Sealing 4/4/2025 Filing MODIFY Storable's Motion to 2025-04-04 Proposed Order Granting Storable's Motion to Modify Protective Order - Modify Protective Order.pdf, EX A - Excerpt of Feb. 11, 2025 Require Disclosure and TI Transcript.pdf, EX B - Excerpt of Jan. 16, 2025 TI Request for Expedited Hearing.pdf, EX C - SafeLease Press Release re Adam Locke Consideration (Jul. 20, 2022).pdf, EX D - Agreed Protective Order and Temporary Sealing Order (Feb. 27, 2025).pdf, EX E - 2025-04-04 A. Bergman Declaration (Signed).pdf, EX F - 2025-03-25 - K. Treistman Letter to P. Yetter.pdf, EX G - A.

Locke Letter to K. Treistman (Mar. 26, 2025).pdf, EX H - A.

Locke Email to K. Treistman (Mar. 28, 2025)_Redacted.pdf, EX I - 2025-03-31 - K. Treistman Letter to A. Locke.pdf, EX J - A. Locke Letter to K. Treistman (Apr. 2, 2025).pdf, Storable's Motion to Modify Protective Order.pdf 4/7/2025 Filing PO Granting Storable's Granting Storable's Motion to Modify Protective Order Require Motion to Modify Disclosure and Request for Expedited C.pdf Protective Order Require Disclosure and Request for Expedited Consideration 4/7/2025 Filing NOT Notice of Written 2025-04-07 Notice of Written Submission on Storable's Motion Submission on Storable's to Modify Protective Order.pdf Motion to Modify Protective Order - Require Disclosure and Request for Expedited Consideration 4/7/2025 Filing NOT Court's Notice of Court's Notice of Submission - Motion to Modify with Briefing Submission - Motion to Deadlines.pdf Modify 4/7/2025 Filing M Plaintiff's Unopposed Plaintiff's Unopposed Revised Motion to Release Cash Bond Revised Motion to and Substitute with Surety Bond.pdf, Proposed Order Release Cash Bond and Releasing and Substituting Bond.pdf Substitute with Surety Bond 4/7/2025 Filing ORD Order Granting Motion to Order Granting Motion to Release Cash Bond.pdf Release Cash Bond and Substitute with Surety Bond 4/7/2025 Filing BOND Temporary Injunction 2025.04.03 - Bond.pdf Bond 4/9/2025 Filing ACR Storable's First Ex. B Revised.pdf, Ex. C Slipsheet.pdf, Ex. D Slipsheet.pdf, Supplement to Its Rule Ex. E Slipsheet.pdf, Ex. F Slipsheet.pdf, Ex. G Declaration of 76A Motion to Seal Court Neil Verma.pdf, Proposed Permanent Sealing Order.pdf, Records Storable's First Supplement to Its Rule 76A Motion to Seal Court Records.pdf 4/10/2025 Hearing Other Hearing - - 4/11/2025 Filing ACR Plaintiff's Response to 2025-04-11 Proposed Order Denying Motion to Modify PO.pdf, Motion to Modify Plaintiff's Response to Motion to Modify Protective Order and Protective Order and Require Disclosure.pdf Require Disclosure 4/11/2025 Filing PO Proposed Order Denying Proposed Order Denying Defendants' Motion to Modify the Defendants' Motion to Protective Order and to Require Disclosure.pdf Modify the Protective Order and to Require Disclosure 4/14/2025 Filing ORD Permanent Sealing Permanent Sealing Order-Signed.pdf Order-Signed

8 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 016 4/14/2025 Filing ACR Storable's Reply in Exhibit K.pdf, Exhibit L - Excerpt of P's Second Merits Support of Its Motion to RFPs.pdf, Second Proposed Order Granting Storable's Motion Modify Protective Order to Modify PO (Apr. 14, 2025).pdf, Storable's Reply in Support and to Require Disclosure of Its Motion to Modify Protective Order and to Require Disclosure.pdf 4/15/2025 Filing ORD Order Denying Motion to Order Denying Motion to Modify Protective Order.pdf Modify Protective Order 4/21/2025 Filing REQ Plaintiff's Request to Plaintiff's Request to Supplement Clerk's Record.pdf Supplement Clerk's Record 4/23/2025 Filing REQ Corrected Request to Corrected Request to Supplement Reporter's Record.pdf Supplement Reporter's Record 5/5/2025 Filing AMEND Defendants' Amended Defendants' Amended Answer, Affirmative Defenses, Answer, Affirmative Response in Opposition.pdf Defenses, Response in Opposition to Plaintiff's Application for Temporary Injunction, and Counterclaims 5/9/2025 Filing MOTAO Defendants' Unopposed Defendants' Unopposed Rule 76a Motion to Seal Portions of Rule 76a Motion to Seal Apr. 10 Transcript.pdf, Ex. A - List of Transcript Excerpts.pdf, Portions of Apr. 10 Ex. B (Temp. Seal COVER SHEET ONLY).pdf, Ex. C - NV Transcript Declaration.pdf, Ex. D - Copy of StorEDGE TOS.pdf, Proposed Permanent Sealing Order.pdf 5/12/2025 Filing VL Vacation Letter for Ms. Vacation Letter for Ms. Treistman.pdf Treistman 5/12/2025 Filing M Plaintiff's Motion for Plaintiff's Motion for Access to Sealed Reporter's Record.pdf, Access to Sealed Proposed order granting access to record.pdf Reporter's Record and Proposed Order 5/14/2025 Filing ORD Order Granting Motion for Order Granting Motion for Access.pdf Access 5/16/2025 Filing LTR Letter Summarizing Letter Summarizing Discovery Dispute Under Local Rule Discovery Dispute Under 4(d).pdf Local Rule 4(d) 5/20/2025 Filing RETS Public Notice of Hearing Return of Service Public Notice of Hearing on Defendants' on Defendants' Unopposed Rule 76a Motion to Seal.pdf Unopposed Rule 76a Motion to Seal 5/22/2025 Filing AMEND Supplement to Plaintiff's Supplement to Plaintiff's Verified Second Amended Petition Verified Second Amended and Application for TRO, TI and PI.pdf Petition and Application for TRO, TI and PI 5/23/2025 Filing ACR Storable's Response to Storable's Response to SafeLease's Discovery Dispute Letter SafeLease's Discovery (May 23, 2025).pdf Dispute Letter 5/28/2025 Filing CORR-R Correspondence Letter Correspondence From 15th Court of Appeals.pdf from 15th Court of Appeals 5/28/2025 Filing ORD Discovery Order Discovery Order.pdf 5/29/2025 Filing NOT Plaintiff's Notice to Plaintiff's Notice to Defendants of Subpoena to EQT.pdf Defendants of Subpoena to EQT 5/29/2025 Filing NOT Plaintiff's Notice to Plaintiff's Notice to Defendants of Subpoena to Cove Hill.pdf Defendants of Subpoena to Cove Hill 5/29/2025 Filing MOTAO Motion of Katherine G. Motion of Katherine G. Treistman Requesting Admission of Treistman Requesting John Holler to Appear Pro Hac Vice.pdf Admission of John Holler to Appear Pro Hac Vice

9 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 017 5/29/2025 Filing MOTAO John Holler's Unopposed John Holler's Unopposed Motion for Pro Hac Vice Motion for Pro Hac Vice Admission.pdf, Proposed Order Granting Unopposed Motion of Admission John Holler to Appear Pro Hac Vice.pdf 5/29/2025 Filing RETS Re: Notice of Intent To Return of Service of Notice of Intent To Seek Production of Seek Production of Documents From Non-Party Subpoena on EQT.pdf Documents From Non- Party Subpoena on EQT IX GP LLC 5/30/2025 Filing RETS Re: Notice of Intent To Re: Notice of Intent To Seek Production of Documents From Seek Production of Non-Party Subpoena to Cove Hill Partners L.pdf Documents From Non- Party Subpoena to Cove Hill Partners L.P. 5/30/2025 Filing AOC Notice of Appearance Notice of Appearance Julia Risley.pdf Julia Risley 6/2/2025 Hearing Other Hearing - - 6/2/2025 Filing ORD Sealing Order Permanent Sealing Order.pdf 6/2/2025 Filing ORD Order Granting John Order Granting John Holler's Unopposed Motion to Appear Pro Holler's Unopposed Hac Vice.pdf Motion to Appear Pro Hac Vice 6/2/2025 Filing ATCH Part 2 of 2 of Declaration Part 2 of 2 of Declaration of Katherine Ginzburg Treistman in of Katherine Ginzburg Support of Defendants' Motion for Part.pdf Treistman in Support of Defendants' Motion for Partial Summary Judgment 6/2/2025 Filing PO Proposed Order Granting Proposed Order Granting Defendants Motion for Partial Defendants Motion for Summary Judgment on SafeLeases Attempted Monop.pdf Partial Summary Judgment on SafeLeases Attempted Monopolization Claim 6/2/2025 Filing M Defendants' Motion for Defendants' Motion for Partial Summary Judgment on Partial Summary SafeLease's Attempted Monopolization Claim.pdf, Part 1 of 2 Judgment on SafeLease's of Declaration of Katherine Ginzburg Treistman in Support.pdf Attempted Monopolization Claim 6/5/2025 Filing NOH Notice of Hearing - Notice of Hearing - Motion for Partial Summary Judgment.pdf Motion for Partial Summary Judgment 6/6/2025 Filing M Storable's Unopposed Storable's Unopposed Motion for a Temporary Sealing Motion for a Temporary Order.pdf Sealing Order 6/6/2025 Filing PO Proposed Order Granting Proposed Order Granting Storable's Unopposed Motion for a Storable's Unopposed Temporary Sealing Order.pdf Motion for a Temporary Sealing Order 6/6/2025 Filing M Storable's Emergency Storable's Emergency Motion for a Partial Stay of the June 13, Motion for a Partial Stay 2025 Court-Ordered Production Deadlin.pdf of the June 13, 2025 Court-Ordered Production Deadline 6/6/2025 Filing PO Proposed Order Granting Proposed Order Granting Defendants' Emergency Motion for a Storable's Emergency Partial Stay.pdf Motion for a Partial Stay 6/6/2025 Filing M Storable's Motion for Storable's Motion for Reconsideration of the Court's April 15, Reconsideration of the 2025 Order Denying Modification of th.pdf Court's April 15, 2025 Order Denying Modification of the Protective Order

10 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 018 6/6/2025 Filing PO Proposed Order Granting Proposed Order Granting Storable's Motion for Storable's Motion for Reconsideration of the Court's April 15, 2025 Order.pdf Reconsideration of the Court's April 15, 2025 Order Denying Modification of the Protective Order 6/9/2025 Filing ORD Order Granting Order Granting Temporary Sealing Motion.pdf Temporary Sealing Motion 6/9/2025 Filing M Storable's Motion for Storable's Motion for Partial Reconsideration of the May 28, Partial Reconsideration of 2025 Discovery Order.pdf the May 28, 2025 Discovery Order 6/9/2025 Filing PO Proposed Order Granting Proposed Order Granting Storable's Motion for Partial Storable's Motion for Reconsideration.pdf Partial Reconsideration of the May 28, 2025 Discovery Order 6/10/2025 Filing OTH RETURN OF SERVICE P336508_001.pdf 6/10/2025 Filing NOT Notice of Written Notice of Written Submission and Briefing Deadlines.pdf Submission and Briefing Deadlines 6/10/2025 Filing CLRKREC Second Supplemental 2nd Supplemental Clerk's Record.pdf Clerk's Record 6/11/2025 Filing CORR-R From 15th Court of Correspondence - Received.pdf Appeals 6/11/2025 Filing RETS Return of Service for Return of Service for Subpoena, exhibit a, B, witness fee for Subpoena, exhibit a, B, Cove Hill Partners L.P.pdf witness fee for Cove Hill Partners L.P 6/11/2025 Filing CORR-R From 15th Court of Correspondence - Received From 15th Court of Appeals.pdf Appeals 6/12/2025 Filing PO Proposed Order Denying 2025-06-12 Proposed Order Denying Motion to Stay.pdf Motion to Stay 6/12/2025 Filing ACR SafeLease Opposition to 2025.06.12 - SafeLease Response to Motion to Stay Defendants' Motion for Discovery Order -.pdf partial stay of Production deadline 6/12/2025 Filing ORD Order Partially granting Order Partially granting Emergency Saty and additional Emergency Saty and Relief.pdf additional Relief 6/12/2025 Filing ACR Storables Reply in Defs' Reply re Stay Motion DRAFT(254344243.1).pdf Support of Emergency Motion for a Partial Stay of the June 13, 2025 Court-Ordered Production Deadline 6/16/2025 Filing ACR SafeLease Response to SafeLease Response to Motion to Reconsider April 15 Motion to Reconsider Order.pdf April 15 Order 6/16/2025 Filing PO Proposed Order Denying 2025-06-16 Proposed Order Denying Motion to Reconsider Motion to Reconsider Order Denying Modification of PO.pdf Order Denying Modification of PO 6/17/2025 Filing PO Proposed Order Granting Proposed Order Granting Storable's Motion for Extension.pdf Defendants' Motion for Extension of Stay and MSJ Reply Deadline 6/17/2025 Filing M Defendants' Motion for Defendants' Motion for Extension of Stay and MSJ Reply Extension of Stay and Deadline.pdf MSJ Reply Deadline

11 of 12 6/23/2025, 12:06 PM re:SearchTX - SafeLease Insurance Services LLC vs. Storable, Inc.,RedNova Labs, Inc.,SiteLink So... https://research.txcourts.gov/CourtRecordsSearch/#!/casePrintView/7c3dd6b992cc448397adba060c...

Date Event Type Comments Documents 019 6/18/2025 Filing ORD Order Granting in Part Order Granting in Part Motion for Extension.pdf Motion for Extension 6/19/2025 Filing ACR Storable's Reply in Storable's Reply in Support of its Motion for Reconsideration of Support of its Motion for the Court's April 15, 2025 Order.pdf Reconsideration of the Court's April 15, 2025 Order Denying Modification of the Protective Order 6/19/2025 Filing PO Proposed Order Denying 2025-06-19 Proposed Order Denying Motion to Reconsider Motion to Reconsider Discovery Order.pdf Discovery Order 6/19/2025 Filing ACR SafeLease Response to SafeLease Response to Motion for Partial Reconsideration of Motion for Partial May 28 Order.pdf Reconsideration of May Order 6/20/2025 Filing NOT Notice of Submission - Notice of Submission - Motion for Extension of Stay.pdf Motion for Extension of Stay 6/23/2025 Filing ACR Storable's Reply in 2025-06-23 Defs' Reply re MFR of Discovery Order.pdf Support of its Motion for Partial Reconsideration of the May 28, 2025 Discovery Order 6/23/2025 Filing PO Proposed Order Denying 2025-06-23 Proposed Order Denying Motion for Extension of Motion for Extension of Stay.pdf Stay 6/23/2025 Filing ACR Plaintiff's Response to Plaintiff's Response to Motion for Extension of Stay.pdf Motion for Extension of Stay 6/23/2025 Filing OTH Order on Motions to Order on Motions to Reconsider.pdf Reconsider 7/1/2025 Hearing Motion for Summary - - Judgment 6/12/2026 Hearing Pre-Trial Conference - - 6/23/2026 Hearing Pre-Trial Hearing - - 6/30/2026 Hearing Bench Trial - -

12 of 12 6/23/2025, 12:06 PM

This page intentionally left blank.

047 10:59 PM 1/28/2025 Velva L. Price District Clerk Travis County No. D-1-GN-24-010233 D-1-GN-24-010233 Victoria Benavides SAFELEASE INSURANCE SERVICES § IN THE DISTRICT COURT OF LLC, § § Plaintiff, § v. § TRAVIS COUNTY, TEXAS § STORABLE, INC., et al., § § Defendants. § 345TH JUDICIAL DISTRICT PLAINTIFF’S VERIFIED SECOND AMENDED PETITION AND APPLICATION FOR A TEMPORARY RESTRAINING ORDER, TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Plaintiff SafeLease Insurance Services LLC (“SafeLease”) files this Second Amended Petition and Application for a Temporary Restraining Order, Temporary Injunction, and Permanent Injunction against defendants Storable, Inc.; RedNova Labs, Inc.; SiteLink Software, LLC; Easy Storage Solutions, LLC; Bader Co.; and Property First Group, LP.

NATURE OF THE CASE 1. This action is necessary to prevent a monopoly software provider from using its market power to cripple a low-price competitor in this State in a related market for insurance.

2. Founded and based in this County since 2021, plaintiff SafeLease is a startup that offers low-cost insurance plans through self-storage facilities to protect people who store goods at those facilities. SafeLease’s plans cover tenants at facilities in Texas and elsewhere throughout the United States. Most self-storage companies rely on third-party vendors like SafeLease for these products. With better prices and service, SafeLease has seen steady growth and an enthusiastic response from customers.

3. To administer its policies, SafeLease is required to access the facility management software systems of self-storage facility operator partners. Operators rely on facility management software to run virtually all aspects of their day-to-day operations. Operators give their advance permission to SafeLease to secure access to their software systems and agree to provide, through these software systems, the information SafeLease needs to administer policies.

4. Defendants are affiliated companies that also offer products and services to the self- storage industry, including facility management software. In fact, with products marketed as storEDGE, SiteLink, and Easy Storage Solutions, defendants have a dominant role in the market for facility management software. Their market share in the relevant market likely exceeds 75%.

Given the central role of these systems to operations of self-storage facilities, defendants’ power over mission-critical software provides them with considerable control and influence across the self-storage industry.

5. Relatedly, defendants offer insurance plans that compete directly with products and services of SafeLease. Defendants aggressively have grown their share of the tenant insurance market through acquisitions of industry leaders. Despite defendants’ efforts to consolidate the tenant insurance market, SafeLease has made considerable inroads, winning customers from defendants with its competitive products. Witnessing SafeLease’s potential and rapid rise, Storable has made overtures to buy SafeLease for years and as recently as late 2024.

6. On December 17, 2024, defendants abruptly went on the attack. They blocked SafeLease’s “authorized user” access to defendants’ storEDGE system, a widely used facility management software, for which customers specifically designate SafeLease as an authorized user.

In so doing, defendants cut off SafeLease’s ability to access critical data to properly service its tenant insurance plans and administer policies for customers covering thousands of storage units.

This action was both sudden and unprompted, as SafeLease has been an authorized user to access customer accounts for years with defendants’ full knowledge.

-2-

7. Notably, these impacted customers are joint customers, as they use defendants’ storEDGE system as well as SafeLease’s insurance products. In January 2025, over 44,000 self- storage units were scheduled to commence or renew coverage under SafeLease insurance plans.

Countless more units would incur claims on existing plans that need to be serviced. SafeLease would be unable to properly service the several thousands of these new or renewed customers and claims on storEDGE systems without access to its customers’ storEDGE systems.

8. Making matters worse, defendants began taking steps to cut off SafeLease’s access to other facility management software products, SiteLink and Easy Storage Solutions. This would impact hundreds of thousands of additional tenants. These actions are unwarranted, threaten the viability of SafeLease’s business, interfere with current and future contracts with customers, and put innocent self-storage operators and tenants at imminent risk of substantial and needless harm.

9. In short, defendants were using dominance in one market (facility management software) to get power over another market (tenant insurance). Their actions were calculated to cripple SafeLease and force customers to switch to defendants’ higher-cost, competing insurance products. This was blatant monopoly leveraging, not legitimate competition.

10. To protect its customers and business, SafeLease filed suit on December 30, 2024, requesting a temporary restraining order, as well as temporary and permanent injunctions, to prevent irreparable harm from defendants’ conduct. The Court granted SafeLease’s request for a temporary restraining order on December 31. Defendants restored SafeLease’s access to their facility management software less than an hour after the TRO became effective. The Court then denied defendants’ request to dissolve the TRO and extended the TRO through January 21, 2025.

-3-

11. For the three weeks the TRO was effective, SafeLease again was able to service the parties’ mutual customers without interruption. However, on January 21, 2025, the day the TRO expired, the Court denied SafeLease’s request for a temporary injunction.

12. Defendants wasted no time in resuming and amplifying their attack. In just hours, they cut off SafeLease’s access not only to storEDGE but also SiteLink and Easy Storage Solutions. The scope of the blocking is massive and exceeds even what SafeLease feared prior to entry of the TRO. Defendants have singled out and targeted SafeLease. Its access has been completely severed, and its customers have no way to grant SafeLease access to the customers’ own critical data in the software. As a result, SafeLease is unable to fully and timely service its customers that use defendants’ facility management software products. This affects over 275,000 tenants at facilities with SafeLease insurance coverage.

13. These new attacks are proof positive of defendants’ anticompetitive scheme to cut off a competitor and to avoid competition on the merits for tenant insurance, ensure higher insurance prices, and eliminate or buy out the only discount insurance competitor in the industry.

Unless restrained, defendants will cause substantial, irreparable harm to self-storage operators and tenants in this State and to SafeLease, which has no choice but to seek injunctive relief from the Court.

DISCOVERY CONTROL PLAN 14. SafeLease intends that this case be conducted under a Level 3 Discovery Control Plain in accordance with TEX. R. CIV. P. 190.4.

PARTIES 15. Plaintiff SafeLease Insurance Services LLC is a Texas limited liability company with its principal place of business in this County at 800 Brazos Street, Suite 320, Austin, Texas

-4-

78701. It provides insurance plans to protect tenants and operators of independent self-storage facilities.

16. Defendant Storable, Inc. is a Delaware corporation with its principal place of business in this County at 11000 N. Mopac Expressway, #300, Austin, Texas 78759. It has appeared and answered. It is a supplier of products and services to the self-storage industry and the corporate parent, directly or indirectly, of the other defendants.

17. Defendant RedNova Labs, Inc. is a Texas foreign for-profit corporation with its principal place of business in this County at 10900 Research Blvd., Suite 160C, Austin, Texas 78759. It has appeared and answered. It is a subsidiary of Storable, Inc. 18. Defendant SiteLink Software, LLC is a North Carolina limited liability company with its principal place of business in this County at 10900 Research Blvd., Suite 160C, Austin, Texas 78759. It has appeared and answered. It is a subsidiary of Storable, Inc. 19. Defendant Easy Storage Solutions, LLC is a Utah limited liability company with its principal place of business in this County at 10900 Research Blvd., Suite 160C, Austin, Texas 78759. It has appeared and answered. It is a subsidiary of Storable, Inc. 20. Defendant Bader Co. is an Indiana corporation with a principal place of business in Indiana. It has appeared and answered. It is a subsidiary of Storable, Inc. 21. Defendant Property First Group, LP is a Pennsylvania limited partnership with its principal place of business in Pennsylvania. It has appeared and answered. It is a subsidiary of Storable, Inc. 22. Defendants RedNova, SiteLink, Easy Storage Solutions, Bader, and Property First are commonly and centrally owned and controlled by Storable, Inc., their parent company. Their

-5- activities are coordinated together by or with Storable, Inc. As such, defendants are a single business enterprise controlled by Storable, Inc., from Austin, Texas.

JURISDICTION AND VENUE 23. Jurisdiction and venue are proper in this Court pursuant to the Texas Constitution, Art. 5, Sec. 8 and TEX. BUS. & COM. CODE § 15.21 and § 15.26. Defendants do substantial business in this County and State.

24. This case could not be filed in and is not removable to federal court. There is no diversity of citizenship between the parties, and no federal claim is raised in this petition. See Am. Airlines, Inc. vs. Sabre Inc., 694 F.3d 539, 543 (5th Cir. 2013).

RELEVANT BACKGROUND A. Self-Storage Industry 25. There are an estimated 52,301 self-storage facilities in the U.S. See SpareFoot, U.S. Self-Storage Indus. Stats. (Oct. 10, 2024), https://www.sparefoot.com/blog/self-storage-industry- statistics/. The industry is largely made up of operators that own/run facilities that lease storage space to businesses and individuals on a temporary basis, usually month-to-month. The industry is valued at $44.3 billion, and it is anticipated to reach nearly $50 billion by 2029. Id. According to the Self Storage Association, 11.1% of U.S. households currently rent a self-storage unit—some 14.6 million households. See The Self-Storage Almanac 2024, Sec. 1, https://digital.modernstorage media.com/almanac/self-storage-almanac-2024db/.

26. Self-storage is big business in Texas. This State has the most self-storage facilities of any state in the country. In 2023, there were 5,564 total storage facilities in Texas, representing more than 10% of all facilities in the nation. Id. (Table 1.4). The amount of rentable self-storage

-6- space in Texas is 256 million square feet. This is one of the highest square feet of rentable space per capita, at 8.70, compared to a national average of 6.32. Id. (Table 1.3).

27. Some self-storage space in the U.S. is owned by large public companies. Four of these companies are real estate investment trusts: Extra Space, Public Storage, CubeSmart, and National Storage Affiliates Trust. The fifth is U-Haul, also a public company. Together, these companies operate 22.5% of self-storage facilities, representing 37.6% of self-storage space by rentable square footage. Id. at Sec. 2. Most or all of these companies have their own insurance programs and proprietary management software.

28. Most self-storage facilities and square footage are owned and operated by small- and medium-sized businesses or individuals. These independent owners represent 77.5% of self- storage facilities and 62.4% of all rentable square feet. Id. Many of these businesses are mom-and- pop shops. Id. (Chart 2.1). Independent facility owners rely on third-party vendors for their facility management software and tenant insurance plans.

i. Facility Management Software 29. Independent self-storage facilities rely on third-party software to run the day-to- day operations of their businesses. Facility owners subscribe to facility management software, sometimes referred to as FMS, which allows them to track and manage their storage units. This software facilitates core services, such as tracking tenant data, allowing for billings, managing communications, generating financial reports, and servicing tenant insurance policies.

30. Facility management software is an essential tool for owners and their vendors. It is common in the industry for owners to permit vendors to access their facility management software to provide the vendor’s services. These services range from onsite management to remote financial services. For example, owners routinely authorize facility management software access

-7- for an on-site manager (who may run front-of-house) and for access control systems (which operate gate codes). It is also essential for vendors that offer remote or administrative services. For example, an owner may authorize a third-party call center to access its facility management software to follow sales leads or address customer inquiries. Similarly, owners may authorize a bill collection agency to access their facility management software to collect payment data and follow up on delinquent payments. This software is designed to facilitate many services in one place for owner management.

31. Defendants are the largest supplier of facility management software systems to independent self-storage facilities. They offer three such systems: storEDGE, SiteLink, and Easy Storage Solutions. Defendants rolled up the companies that offered these systems under common ownership from 2018-20. See SpareFoot, Tech Firms Combine Under Storable Brand Name To Serve Self-Storage Indus. (Apr. 29, 2024), https://www.sparefoot.com/blog/tech-firms-combine- storable-brand-name-serve-self-storage-industry/; Inside Self Storage, Storable Acquires Self- Storage Software Provider Easy Storage Solutions (June 5, 2020), https://www.insideselfstorage. com/software/storable-acquires-self-storage-software-provider-easy-storage-solutions.

32. According to industry statistics, defendants control some 75% of the U.S. market for facility management software systems for independent self-storage facilities.

33. According to defendants, “more than half of every single storage facility in the United States” uses their facility management software. 2023 State of the Self-Storage Indus., https://www.storable.com/resources/learn/unpacked-webinar-2023-state-of-the-self-storage- industry/. The numbers are even starker considering that the only storage facilities that use third- party facility management software are independent facilities. Some 40,500 facilities in the U.S. are independent self-storage facilities. See The Self-Storage Almanac 2024, Sec. 2 (independent

-8- owners represent 77.5% of self-storage facilities). And nearly 32,000 self-storage facilities used defendants’ facility management software systems as of 2023. See 2023 State of the Self-Storage Indus., supra. Today, defendants advertise that 36,000 self-storage facilities “are currently managed with Storable software.” Storable, About Us, https://www.storable.com/about-us/.

34. SafeLease does not offer facility management software. Rather, its independent self-storage customers rely on their facility management software to facilitate the administration of SafeLease’s tenant insurance plans. Each of these customers expressly authorizes SafeLease to be one of its third-party vendors, to access its facility management software with administrative user credentials, and to use its systems to offer tenant insurance plans. Customers also agree to provide the information SafeLease needs to administer policies through access to their facility management software.

B. Tenant Insurance Plans 35. SafeLease basically offers two types of related insurance products for its independent self-storage customers: tenant insurance and tenant protection.

36. Tenant insurance is produced directly to the tenant by the facility. In most states, the facility operates under a limited lines license, where SafeLease is the designated responsible licensed producer—that is, the overseer for the program. The tenant is directly insured for stored goods, rather than having recourse to the owner-operator of the storage facility.

37. Tenant protection involves the placement of a contractual liability insurance policy with the storage facility owner-operator. The policy covers risk to tenant stored goods on the rental agreement. Under SafeLease’s program, rental agreements are amended so that the standard exculpatory clause (where owners/operators disclaim liability for tenant stored goods) is pared back, and the facility owner-operator instead has limited liability for certain types of loss.

-9-

38. These products are marketed largely as substitutes. Some facility owner-operators prefer conventional tenant insurance, while others choose tenant protection. The coverage levels and cost for the product borne by the tenant and the revenue that can be earned by the facility owner-operator for distribution are comparable.

39. Defendants directly compete with SafeLease on both insurance product lines.

40. In addition to rolling up facility management software system vendors, defendants also acquired various insurance producers and books of business. These include Property First Group LP (StorSmart) and Bader Co. See Inside Self-Storage, Storable Adds Self-Storage Ins. Providers Bader, Storsmart to Stable of Cos. (Sept. 3, 2019), https://www.insideselfstorage.com/in -surance/storable-adds-self-storage-insurance-providers-bader-storsmart-to-stable-of-companies.

Defendants also acquired a large book of insurance business from Sage Insurance in 2021.

41. In short, defendants provide tenant insurance at independent facilities. In addition, they offer an unlicensed, insurance-like “protection plan” program to independent facilities through Easy Storage Solutions facility management software. In total, defendants together control the single largest share of the market for tenant insurance and tenant protection (“tenant insurance”) at independent self-storage facilities.

42. The parties compete in the market for tenant insurance at independent self-storage facilities.

C. SafeLease Access to Customer Accounts 43. SafeLease opened for business in mid-2021 and has grown steadily. It now covers 2576 facilities, representing about 322,000 units with active SafeLease-acquired coverage.

-10-

44. SafeLease currently administers insurance policies/plans through customer facility management software systems. Access to this software is critical to enable SafeLease to effectively administer its customers’ insurance protection and to protect facility owners/operators and tenants.

45. To administer these policies, SafeLease must access facility management software that its self-storage customers use. Given defendants’ dominance in the facility management software market, the vast majority of customer plans that SafeLease administers must be managed through defendants’ software systems. Over 275,000 tenants at nearly 2000 facilities must be administered through defendants’ facility management software: a. storEdge: 83,992 plans (683 facilities) b. SiteLink: 147,233 plans (734 facilities) c. Easy Storage Solutions: 44,681 plans (514 facilities) 46. The remaining policies are administered through third-party facility management software offered by companies other than the defendants, such as Self Storage Manager, Cubby, and WebSelfStorage.

47. Since 2021, for defendants’ storEDGE and SiteLink systems, SafeLease has accessed its customers’ accounts as a designated “Authorized User” on the systems after its customers granted SafeLease such access in accordance with its contracts with those customers.

StorEDGE and SiteLink permit a customer to designate “as many” Authorized Users to access its accounts “as you wish,” according to the terms of service for their facility management software.

a. Sitelink Terms of Use, https://www.storable.com/privacy/sitelink-terms-of-use/ (“4.2. Authorized Users. You may designate and authorize as many Users as you wish under the Agreement.”); and b. storEDGE Terms of Service, https://www.storable.com/privacy/storedge- terms-of-service/ (“4.2. Authorized Users. You may designate and authorize as many Users as you wish under the Agreement.”).

-11-

48. Likewise, SafeLease’s access to defendants’ Easy Storage Solutions (which is a more basic software than storEDGE or SiteLink) only occurs when access is given by defendants at the request of a customer. Access is “locked” otherwise. Easy Storage Solutions customers then must create an Authorized User account for SafeLease. Defendants knew SafeLease was accessing the facility management software on behalf of customers and provided access for it to do so.

49. In SafeLease’s customer contracts, storage facilities are obligated to give SafeLease access to their facility management software for it to administer the relevant insurance policies.

The data within the facility management software—for example, information about a particular facility, its tenants, and its operations—belongs to SafeLease’s customers (not to defendants).

SafeLease’s customers grant SafeLease permission to access this information kept on their facility management software by logging in with a username and password, exactly as the facility owners would log in to access the same information. This is how SafeLease has accessed its customers’ facility management software.

50. The information SafeLease can access is controlled by its facility customers.

SafeLease only accesses the information that is necessary to carry out its insurance functions. It does not access sensitive information that is irrelevant to SafeLease providing its contractual insurance services. SafeLease never has access to tenant credit card information. SafeLease uses secure, independently audited, SOC-2 certified processes when accessing and storing customer data.

51. Storable has known for years that SafeLease is an Authorized User to administer its customer insurance policies. In general, SafeLease can access facility management software to administer coverage policies by a direct connection to the software through an application programming interface (API) or as an Authorized User through the graphical user interface (GUI).

-12-

In 2021, just months after SafeLease opened, it reached out to defendants regarding API access for SiteLink. Defendants declined, saying they are “not planning to add additional providers.” As a result, SafeLease moved forward as an Authorized User and successfully has operated that way ever since.

52. As an Authorized User, SafeLease efficiently can collect targeted data every day or few days from a customer’s facility management software that it needs to administer policies.

SafeLease accesses the least data necessary and only the data that its customers allow, even gathering information more efficiently than if a user were manually operating the software.

SafeLease’s access to facility management software has not intensified in nature or scope across time. In fact, since 2021, SafeLease has further tailored its operations to make its access of facility management software even more narrow and efficient. Until this case was filed, defendants never claimed that SafeLease’s practices harmed defendants’ facility management software and never demanded that SafeLease stop or change its Authorized User access.

53. SafeLease’s ability to access the facility management software as an Authorized User has been beneficial to defendants. For example, SafeLease products are low-cost options that defendants admit are popular with and beneficial to facility operators and their tenants. Operators want to use SafeLease products, so having a facility management software that is compatible with SafeLease products enhances defendants’ software, making it more valuable to facility management software customers and increasing its marketability. Conversely, cutting off SafeLease’s access to facility management software hurts defendants’ own customers, who are left at risk of disruption and uninsured loss.

D. Defendants’ Actions Towards SafeLease 54. Since SafeLease’s founding, defendants have expressed interest in acquiring its insurance business. Storable’s CEO sees SafeLease’s business as “interesting” and “compelling.”

-13-

He believes SafeLease can “help our customers” increase tenant enrollment in insurance coverage, which “benefits” self-storage operators, their tenants, and insurance providers, which can “grow the business.” SafeLease repeatedly has declined defendants’ overtures.

55. In March 2022, less than a year after SafeLease’s founding, defendants inquired about buying SafeLease. The next year, following discussions in May 2023, the parties entered into a term sheet regarding a potential long-term partnership. The parties ultimately could not agree on terms and agreed to pause negotiations in March 2024. In September 2024, defendants again expressed general interest in acquiring SafeLease.

56. Defendants’ tactics then changed after acquisition talks broke down in October. On October 15, 2024, SafeLease got a cryptic email from defendants noting upcoming “security measures” on the facility management software, including “stricter policies around user roles, access authorization, and ensuring only authorized personnel can access Storable systems.” This raised possible concerns that defendants might limit SafeLease access to the facility management software—access that its shared customers long had authorized and that SafeLease successfully had used without issue for many years.

57. In this message and the surrounding communications, defendants made no specific complaint about any specific SafeLease practice—referring only to nebulous “security” issues but never telling SafeLease that defendants believed it was causing or responsible for any such issues.

They could not and did not explain any harm from SafeLease’s continued operation as an Authorized User in the same manner as it had done for years.

58. In response, SafeLease asked about an interim agreement with defendants to “avoid disruptions to the services and agreements with [their] shared customers.” SafeLease sought a call as soon as possible, including technical resources, so that it could understand the planned “security

-14- changes” and take appropriate measures. In addition, SafeLease proposed as a potential solution an agreement to access defendants’ API—access that they had denied years earlier.

59. Defendants responded with egregious terms to access the system via an API. They proposed a penalty price of $1.00 per unit per month, far greater than the market price for such access. Moreover, they would charge SafeLease an even higher price for units that had been served by defendants if the customer chose to switch to SafeLease for its insurance products. In that case, SafeLease would have to pay $1.50 for API access—50% more—whenever it out-competed defendants for business. The terms were confiscatory, exclusionary, anticompetitive, and another example of defendants flexing their monopoly power.

60. Indeed, defendants’ demanded price was so high that it would drive SafeLease out of business. Defendants knew this since they offer similar insurance plans and are well aware of the economics. For example, the most common protection plans typically cost a tenant $12/month for $2000 of coverage. The facility will keep most of that $12, as it has the relationship with the tenant, and a coverage provider like SafeLease will get $2-3/plan per month, which also must cover the cost of the insurance itself, which is not less than $2/plan per month. So, charging $1 to $1.50 per unit for API access would consume 50% or more of SafeLease’s gross profit, which would not leave enough to cover insurance premiums.

61. In short, API access was no option at all on defendants’ monopolistic terms, which were designed as merely another way to drive a low-cost competitor out of the market to the detriment of consumers and the industry.

62. Defendants then took their next step. On November 4, 2024, SafeLease noticed issues logging into storEDGE. Its engineers found that SafeLease IP addresses had been blocked

-15- from logging into storEDGE. On November 6, 2024, SiteLink similarly blocked SafeLease IP addresses, although SafeLease was able to re-establish its authorized access.

63. On December 4, 2024, there was another wave. Defendants blocked the IP address for the SafeLease office from accessing storEDGE and SiteLink facility management software.

This cut off SafeLease’s access to customer accounts and was a direct interference with servicing its policies. Again, SafeLease was able to engineer a solution to restore access.

64. At the same time, defendants’ buyout overtures continued. On December 9, 2024, they again expressed interest in acquiring SafeLease, warning that additional “security” measures soon would be implemented.

65. On December 17, 2024, defendants took a dramatic step. They blacklisted SafeLease from storEDGE. In addition to blocking the SafeLease office IP address, defendants deactivated storEDGE users with @safelease.com emails even though they were customer- designated as Authorized Users. There was no technical workaround. As a result, SafeLease could not access storEDGE on behalf of customers. It lost the ability to service 84,062 insurance plans for storage facilities that use storEDGE facility management software. This caused, and if left unchecked was set to cause more, serious harms, including gaps in coverage and delays in adjudication of claims for SafeLease and defendants’ shared customers.

66. SafeLease filed this petition and request for temporary and permanent injunctive relief on December 30, 2025, to prevent irreparable harm that would commence January 1, 2025.

SafeLease was due to issue thousands of contracted-for new and renewed policies to its customers, a process that it could not do without accessing its customers’ facility management software.

67. The Court acted swiftly and granted SafeLease’s requested temporary restraining order on December 31. Defendants’ actions in the hours that followed showed that the status quo

-16- imposed no burden at all on them. Indeed, less than an hour after the TRO became effective, defendants restored SafeLease’s access as a customer-designated Authorized User on storEDGE.

68. Defendants moved to dissolve the TRO on January 2, 2025. In turn, SafeLease moved for expedited discovery and to extend the TRO to allow for this discovery. On January 9, the Court denied the motion to dissolve, extended the TRO to January 21, and granted targeted discovery in advance of a temporary injunction hearing, which was set for January 16.

69. While the TRO was in effect prior to the temporary injunction hearing, SafeLease got to work. It was able again to service the parties’ mutual customers by: a. sending notices to self-storage facilities with tenants transferring into SafeLease insurance coverage; b. confirming coverage for 33,000+ units switching to SafeLease coverage for facilities using defendants’ facility management software; c. helping facilities meet insurance requirements by confirming tenants have valid homeowner policies linked to their accounts or are enrolled in SafeLease; d. collecting reports to bill facilities for premiums that must be paid to insurance carriers to maintain necessary coverage; and e. securing facility data to advance adjustor files to pay pending claims.

70. On January 16, 2025, the parties participated in an evidentiary hearing on the request for a temporary injunction to maintain the status quo through trial.

71. The Court denied the request for a temporary injunction on January 21, the day the TRO dissolved by its extended terms.

72. Defendants wasted no time in resuming their anticompetitive attacks. The next day, January 22, defendants reinstated their block on SafeLease access to storEDGE. Then they went further to cut off SafeLease from the other two facility management software products, SiteLink and Easy Storage Solutions.

-17-

73. The impact of defendants’ attacks has increased dramatically. SafeLease cannot access its customers’ data in the facility management software, despite express user authorization from those same mutual customers. The number of units, tenants, and facilities that defendants are preventing SafeLease from servicing properly and timely under their existing contracts has tripled.

There are over 275,000 tenants at nearly 2000 facilities who SafeLease no longer can provide the insurance services that they and the facilities have contracted for.

74. Defendants have not merely disabled SafeLease’s Authorized User accounts. They also have fully disabled SafeLease from having access by any means to any of defendants’ facility management software systems. Their excuse for cutting off access is alleged “security” concerns posed by SafeLease’s using automated log-in to its customers’ software to access its customer data (as customers have authorized and contracted for). Defendants have said that manually logging in would resolve those concerns. But they now will not allow even that means of access, that is, access that is identical to how any facility owner would access its own facility management software.

75. This newly restricted means of access for SafeLease is no different from how other contractors, consultants, or third parties with which facility owners do business access customers’ facility management software. For example, a certified public accountant who a facility owner has designated as an Authorized User to provide accounting or tax services also accesses the customer software via username and password manually. That access is allowed for third parties who don’t compete with defendants, but defendants have denied the same access to its competitor SafeLease.

76. Defendants took further steps to target SafeLease and eliminate competition. They disabled all SiteLink accounts where SafeLease had been using the system’s legacy custom third- party insurance module to provide insurance to facility customers. Disabling SafeLease’s accounts

-18- that used this custom insurance module has no legitimate purpose. It simply singles out SafeLease to block access for a competitor and to interfere with its contracts with customers.

77. This custom insurance module is a means of access long approved by defendants and used by other insurance vendors. The module was created by defendants specifically to enable facility owners to use an insurance provider that does not have API access to SiteLink. Facility owners pay defendants $10 per facility/month to use this custom insurance module, and SafeLease reimburses the customers. So, when and whether a facility owner is using a third-party insurance provider via this module is known to and long allowed by defendants.

78. Using this custom module poses none of the alleged security issues that defendants claim justify cutting SafeLease’s access. Indeed, this custom module is defendants’ own creation.

79. To SafeLease’s knowledge, defendants did not block access to this custom module for any other insurance provider. Cutting off SafeLease from even this method of accessing data and servicing customers further shows that defendants are targeting SafeLease, and their in-court excuses for removing SafeLease’s access are pretextual.

80. Since defendants cut off access again only days ago, the parties’ mutual customers have expressed confusion and concern about how it will impact them and their tenants. Reactions from customers have ranged from anxiety to frustration to anger, including the following: a. “Help me understand where our account stands as of today; 1. Are our tenants covered and how long will they be covered? 2. How do we continue coverage? 3. Will the payments by our tenants no longer be accessed by SafeLease? . . . I am just scratching the surface with questions, by my greatest concern is to make sure that our tenant protection doesn’t lapse during this struggle.”

b. “We utilize SiteLink at our facility and currently pay $10 per month for the ability to use SafeLease. We are concerned about the potential disruption of service and insurance coverage for our tenants.”

c. “I see that SafeLease has been deleted as a user in my corporate account. . . . Should I add you back as an authorized user? They deleted without

-19- mentioning anything to me. . . . Also, if a tenant moves in now, will they even have access to coverage?”

d. “I want safe lease to immediately have access to manage my tenant protection. . . . I have been with easy storage solutions way before storable purchased them. I have been a loyal customer since 2012 and demand the right to choose my tenant protection for the best options for my tenants.” (email sent to defendants) e. “Sounds like you already don’t have access to our system. What issues is this going to cause us until you regain access?”

f. “Safelease was removed from each of my locations. They are my tenant protection company. . . . I’m going to be adding them back in today so that I can go over my numbers as I do monthly with them. Please, can you make sure Storable does not remove someone I have given permission to.” (email sent to defendants) g. “Could you please clarify if Storable’s actions have also impacted the data transfer and service for SiteLink users who pay for SafeLease access? Are you still receiving our information, or has this been interrupted as well?”

h. “Team Storable, Please immediately restore access to all authorized users. SafeLease must have full access.” (email sent to defendants) i. “Have you guys looked into any legal recourse? My opinion is that Storable is doing some potentially illegal stuff throughout (not a lawyer).”

j. “This seems like it is breaking some sort of law and at a minimum a terrible way to do business.”

k. “We have also experienced the anticompetitive activities of Storable.

When we attempted to access our own data, they demanded an outrageous toll fee for the access.”

l. “Not surprised that Storable would pull such a dirty trick. Can’t expect much better from them.”

Common to the customer reactions to defendants’ actions are concerns about disruption of service, increased risks, and loss of protection for them and their tenants.

-20-

81. By contrast, as SafeLease was cut off from accessing these facility management software systems, defendants’ insurance products offered through Bader and StorSmart remained integrated in the software.

82. Defendants’ actions have been greatly damaging to SafeLease, its customers, and the industry. As a result, SafeLease cannot operate its business as it has done for years with defendants’ knowledge, consistent with its terms, and with customer authorization and agreement.

E. Relevant Markets 83. The relevant primary product market is for tenant insurance at independent self- storage facilities. SafeLease and defendants, as well as firms such as Xercor, Deans & Homer, Insurance Office of America, and MiniCo Insurance Agency, compete in this market.

84. Because of the fragmented nature of self-storage facility ownership and the fact that large public companies offer their own insurance plans, this tenant insurance is offered only at independent self-storage facilities. Consumers at these facilities can turn to either tenant protection or tenant insurance products. These products are substitutable in that a consumer reasonably could turn from one product to the other in response to a price increase to satisfy their insurance needs.

85. Market share in this market can be measured based on the number of facilities using a tenant insurance product. Defendants are collectively the largest provider in this market.

86. The relevant secondary product market is for facility management software.

Defendants dominate this market. Other competitors are Self Storage Management, Cubby, and WebSelfStorage.

87. Because of the fragmented nature of self-storage facility ownership and the fact that large public companies use their own proprietary management software, these facility management software products are offered only to independent self-storage facilities.

-21-

88. Market share can be measured based on the number of facilities that use facility management software. Defendants control over 75% of this market within the United States.

89. Defendants have a monopoly in this secondary market. They are leveraging their market power to harm and control competition in the primary market, for tenant insurance at independent self-storage facilities, and to acquire monopoly power.

a. Geographic Market 90. The relevant geographic market for both product markets is the United States.

91. For tenant insurance, the parties and others operate throughout the nation.

Consumers in Texas looking to purchase tenant insurance reasonably can turn to any such product offered by a provider if it is licensed to provide insurance in this State.

92. For facility management software systems, defendants and its competitors operate throughout the nation. Consumers looking to purchase such software for their independent self- storage facilities may turn to any competitor in the country to provide this product.

F. Defendants’ Anticompetitive Conduct and Effects 93. Defendants have engaged in an anticompetitive scheme to monopolize the market for tenant insurance and drive a low-cost competitor out of business. They are leveraging their monopoly power in the facility management software market to try to monopolize the connected market for tenant insurance. Facility management software is vital to the market they are attempting to monopolize, and defendants have a monopoly of that software market. Their actions are an attempt to exploit that connection to the detriment of consumers and competition.

94. So, armed with this unique power in an adjacent market, defendants are engaging in prohibited predatory conduct by refusing to deal with SafeLease by cutting off SafeLease’s access to their facility management software systems. This shuts out SafeLease from the tenant

-22- insurance market, excluding or foreclosing competition and harming consumers including with higher prices. SafeLease is precluded from accessing more than 75% of the market, so defendants will be able to scoop up the customers that SafeLease no longer can compete for.

95. Defendants cut off SafeLease after years of allowing what it now prohibits. This long-known and consented-to access was voluntary and to defendants’ benefit, as it made their facility management software product more enticing to consumers, some of whom would not have chosen it if SafeLease were not allowed access, severely limiting their tenant insurance options.

And defendants cut off SafeLease’s access without warning or valid business justification. As is clear from defendants’ conduct, their motive is to achieve anticompetitive ends.

96. Defendants are familiar with SafeLease and how it does business, including that it has Authorized User access to defendants’ facility management software granted by their shared customers. Defendants have expressed interest in partnering with or buying SafeLease. As recently as just weeks ago, they proposed acquiring SafeLease. It was only after talks broke down that they sought to drive SafeLease out of the market and remove a low-cost competitor. They retaliated by cutting off SafeLease and making a confiscatory “offer” for API access that was no offer at all and was, instead, another way to try to destroy a competitor to reduce competition, to the detriment of consumers. The timing shows that defendants’ “justifications” for their conduct are pretextual.

97. Defendants’ anticompetitive conduct escalated after suit was filed. In December, SafeLease successfully competed for a new customer that uses defendants’ SiteLink as its facility management software. That customer had used defendant Bader as its tenant insurance provider, until SafeLease out-competed Bader for this customer’s business. On December 31, 2024, the same day the Court granted the TRO, defendant Bader tried to scare the customer into switching back to Bader’s insurance coverage by informing the customer that defendants were going to block

-23-

SafeLease from accessing SiteLink, just as they had done with storEDGE. Confused and concerned, the customer alerted SafeLease, who assured the customer that a TRO was in place.

98. Although the TRO was in place, defendants’ threat to remove access proved too much for this customer. He determined that the risk of SiteLink severing ties with SafeLease posed a significant operational challenge and financial risk to the customer, which he could not bear, so he chose to cancel his planned contract with SafeLease.

99. This recent conduct is further proof of defendants’ plans to monopolize the tenant insurance market not by competing on the merits but by removing competition through leveraging their monopoly in the facility management software market and interfering with SafeLease’s prospective business with these customers.

100. With defendants’ monopoly power, their scheme to drive out competitors in the related tenant insurance market has a dangerous probability of success. Defendants know how vital facility management software is to independent self-storage facilities. Having captured more than 75% of the market for this software, while allowing SafeLease and others to access the software for years, defendants are able to leverage that monopoly and customer reliance on the software to drive out as many competitors in the tenant insurance market as it can by refusing to deal with them, or by allowing them to use defendants’ software products only on the condition that the competitors promise not to compete for defendants’ customers and pay a penalty if they do. This will, in turn, drive customers to their only practical option at that point: buying higher-cost tenant insurance from defendants.

101. This anticompetitive scheme is an attempt to monopolize the market for tenant insurance. It will harm competition and consumers, remove low-cost competitors like SafeLease, and drive-up costs and reduce options.

-24-

G. Damages and Continuing Injury 102. Defendants’ anticompetitive conduct is causing irreparable harm to SafeLease, its customers, and the industry.

103. On December 17, 2024, defendants cut off SafeLease accounts from accessing the storEDGE facility management software, revoking the Authorized User status granted to SafeLease by storage facility customers. The only thing that stopped this anticompetitive scheme and prevented further harm to SafeLease, consumers, and competition was the TRO. But when the TRO expired, defendants escalated their attacks by cutting off SafeLease from accessing all their facility management software systems. Without access, SafeLease cannot service insurance policies for tenants with units in facilities that use those systems. Practically, this means that SafeLease’s customers will experience delays in adjudication of their insurance claims and risky gaps in coverage while SafeLease is unable to renew or issue new policies it has or would have contracted with customers to issue.

104. This risk and these gaps cannot be filled by these mutual customers. They cannot legally intake or adjust tenant insurance claims, which is something that only a licensed insurance agent like SafeLease can do. This disruption and interference with customer-authorized access to customer data on its customers’ software has wholly impaired SafeLease’s ability to service more than 275,000 tenants and thousands of customer facilities. This harms not only SafeLease but also innocent customers and their tenants.

105. Defendants’ actions have jeopardized SafeLease’s entire business, which is worth over $100 million. It has and will continue to harm and cause loss to SafeLease’s goodwill, clientele, and operations. Defendants’ actions also put at risk the insurance coverage that customers secured through SafeLease, which exceeds $600 million.

-25-

106. Defendants’ unjustified and anticompetitive actions are calculated to and do destroy competition by excluding a low-cost competitor from competing in the market to the detriment of competition and consumers. This harm will be outsized in Texas which has more storage units than any other state and in which the parties are based and conduct their business.

H. Status Quo Poses No Harm to Defendants 107. SafeLease accessed defendants’ facility management software as an Authorized User with defendants’ consent for over three years until they abruptly cut off access in December.

Defendants’ actions after the TRO was entered show that returning to the status quo imposes no burden at all on them. Indeed, in less than an hour after the TRO became effective, defendants restored SafeLease’s access as a customer-designated Authorized User of storEDGE.

FIRST CAUSE OF ACTION Violation of the Texas Antitrust Act, Section B 108. SafeLease incorporates the material fact allegations from the preceding paragraphs.

109. Through anticompetitive conduct, defendants intend to secure dominant market power and a monopoly in the market for tenant insurance at independent self-storage facilities.

They leveraged their monopoly of the facility management software market to lessen or destroy competition in the tenant insurance market by cutting off SafeLease from accessing storEDGE, SiteLink, and Easy Storage Solutions facility management software on behalf of and for the benefit of customers. This refusal to deal is contrary to defendants’ prior voluntary practice of allowing such access for years, which benefited defendants, and it will harm defendants’ own customers.

110. This refusal to deal is intended to remove a discount competitor from the market to help defendants gain market share and solidify a second monopoly in the market for tenant insurance. Their monopoly of the facility management software market gives them a unique ability

-26- to exclude or foreclose competition in the market for tenant insurance by excluding competitors in that market, like SafeLease, from facility management software.

111. Defendants are exercising this unique anticompetitive ability here by excluding SafeLease from their facility management software systems after years of knowing use. Given this unique power to exclude or foreclose competition in the vast majority of the market, made possible by leveraging a monopoly of facility management software, defendants’ scheme has a dangerously high probability of success.

112. This conduct is an attempted monopolization in violation of TEX. BUS. & COMM.

CODE § 15.05(b). This unlawful conduct has been willful and flagrant.

113. As a direct and proximate result of this unlawful conduct, SafeLease has been injured in its business and property, including by being foreclosed from competing in the market for tenant insurance.

114. These injuries to SafeLease and the public are injuries to the competitive process and are the type of injuries that the antitrust laws are intended to prohibit. They constitute antitrust injuries in Texas.

115. SafeLease did and will suffer irreparable injury and loss of business and property, for which there is no adequate remedy at law, unless the Court enjoins defendants’ continuing and imminent violations.

116. SafeLease has been forced to retain attorneys to protect its rights and to prosecute this claim. Under TEX. BUS. & COMM. CODE § 15.21, it is entitled to recover its reasonable attorney fees and costs spent in this matter.

SECOND CAUSE OF ACTION Tortious Interference with Existing Contracts 117. SafeLease incorporates the material fact allegations from the preceding paragraphs.

-27-

118. SafeLease has a contract with each of its customers that use defendants’ facility management software. These contracts are commonly titled “Storage Partner Agreements.” They require the customers to provide SafeLease with access to their facility management software and their data that they keep on these software systems for the sole purpose of providing the parties’ contractually agreed insurance services.

119. SafeLease’s contracts with its customers are valid contracts. Defendants are not parties to these contracts.

120. Defendants are willfully and intentionally interfering with SafeLease’s contracts with its customers. Defendants know that SafeLease provides insurance services to their mutual customers. Defendants know that such services are under contracts between SafeLease and the customers. Defendants know that these services require SafeLease to access and use customer data that is stored on the facility management software systems. Defendants know that SafeLease’s customers grant it access to their facility management software as an Authorized User.

121. Defendants intentionally cut off SafeLease’s access to their facility management software. Defendants are preventing the parties’ mutual customers from providing SafeLease the access that the customers want and are obligated to provide. Defendants know or reasonably should know that blocking access interferes with the customers’ ability to perform under their contracts, including by preventing customers from being able to give SafeLease the agreed, desired, and necessary access to their facility management software systems and data.

122. Defendants cut off SafeLease’s access in order to interfere with performance of these obligations, and it was substantially certain that the consequences of cutting off access would be to interfere with performance of these obligations.

-28-

123. Defendants’ interference with SafeLease’s customer contracts proximately caused SafeLease harm and loss to its business, business operations, goodwill, and clientele. It threatens to destroy SafeLease’s entire business. This harm and loss are continuing, increase with every day, and given their nature are not easily or readily quantifiably.

THIRD CAUSE OF ACTION Tortious Interference with Prospective Business Relations 124. SafeLease incorporates the material fact allegations from the preceding paragraphs.

125. Defendants have willfully and intentionally interfered with SafeLease’s ability to compete in the market for tenant insurance. They have removed SafeLease’s ability to service customers that use defendants’ facility management software systems, which comprise over 75% of the market.

126. Defendants’ leveraging of their monopoly in the facility management software market to cut off SafeLease from thousands of customers in the tenant insurance market makes it nearly impossible for SafeLease to compete for new business, as customers now are effectively unreachable to SafeLease. Defendants are telling SafeLease’s prospective customers that they plan to and now have cut off SafeLease’s access, for the purpose of interfering with SafeLease’s attempts to enter contracts to provide services to the potential customers.

127. Defendants’ software is so vital to customers that their threat of stopping SafeLease access already has lost SafeLease customers, including a customer who cancelled his contract with SafeLease when he learned that SiteLink was planning to remove SafeLease’s access.

128. Defendants’ threats to remove SafeLease’s access and then actual removal of that access have caused customers to cancel or back out of agreements with SafeLease, thus injuring it. These injuries are the direct result and intent of defendants’ anticompetitive acts to leverage their monopoly power to interfere with SafeLease’s prospective business relations.

-29-

129. Defendants’ interference with SafeLease’s prospective business with customers has proximately caused SafeLease harm and loss to its business, business operations, goodwill, and clientele. It threatens to destroy SafeLease’s entire business. This harm and loss are continuing, increase with every day and with every prospective customer with which defendants interfere, and given their nature are not easily or readily quantifiably.

SERVICE ON ATTORNEY GENERAL 130. SafeLease has mailed a copy of this amended petition to the Attorney General of Texas, in compliance with TEX. BUS. & COMM. CODE §15.21(c).

VERIFIED APPLICATION FOR TEMPORARY RESTRAINING ORDER, TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION 131. SafeLease has requested that the Court issue a TRO and temporary injunction against defendants to prevent probable imminent and irreparable harm to SafeLease, its customers, and the industry. The Court issued the requested TRO on December 31, 2024 and extended it to January 21, 2025. In the interim, it held a temporary injunction hearing on January 16. The Court denied the requested temporary injunction via email notice from its clerk on January 21.

GROUNDS FOR INJUNCTIVE RELIEF 132. Temporary injunctive relief is necessary to preserve the status quo prior to a trial on the merits. The last actual, peaceable, non-contested status preceding the pending controversy is SafeLease’s accessing defendants’ facility management software systems so that it may service the parties’ shared customers, which SafeLease did for years with defendants’ knowledge until they cut off access. See In re Newton, 146 S.W.3d 648, 651 (Tex. 2004) (status quo is “the last, actual, peaceable, non-contested status which preceded the pending controversy”) (cite omitted).

133. Defendants’ cutting off access to this critical software did and will cause irreparable harm to SafeLease, its customers, and the industry. Without access SafeLease will be unable to

-30- run its business and administer insurance services for its customers. Temporarily enjoining defendants imposes no or minimal burden on them and also will allow SafeLease to service these mutual customers as it had done with defendants’ knowledge and consent for years.

134. SafeLease pleads valid causes of action and has shown a probable right to relief. It has furnished evidence that defendants’ actions and threatened imminent actions are an illegal monopolization attempt of the market for tenant insurance, using an anticompetitive scheme and predatory or exclusory means. Given defendants’ monopoly power and ability to leverage it to exclude or foreclose competition, they have a dangerous probability of succeeding. Defendants’ actions also improperly interfere with SafeLease’s current and prospective customer contracts.

135. Federal antitrust case law, which the Texas Antitrust Act follows, supports the state law claim raised here. See, e.g., Eastman Kodak Co. v. Image Tech. Servs., 504 U.S. 451, 483 (1992) (“If Kodak [a monopolist] adopted its . . . policies [refusing to deal] as part of a scheme of willful acquisition or maintenance of monopoly power, it will have violated §2.”); Aspen Skiing Co. v. Aspen Highlands Skiing Corp., 472 U.S. 585 (1985) (monopolist liable for refusing to deal with competitor where parties had prior voluntary course of dealing that was ended without justification); United States v. Griffith, 334 U.S. 100 (1948) (finding monopolization where defendants used monopoly power in one market to acquire monopoly control of other markets); Covad Commc’ns Co. v. BellSouth Corp., 299 F.3d 1272, 1284 (11th Cir. 2002) (“Monopoly leveraging occurs when a firm uses its market power in one market to gain market share in another market other than by competitive means.”), vacated on other grounds, 540 U.S. 1147 (2004).

136. SafeLease also has shown probable imminent and irreparable injuries prior to a trial on the merits. Accessing defendants’ software is its only means of servicing customers that use the

-31- software. Without access, it cannot address claims made by tenants, correctly bill its customers, or commence new or renew insurance policies that it has contracted with tenants to provide.

137. The impact of this disruption is wholly or largely immeasurable to SafeLease and the tenants that it helps insure. It did and will cause immediate and irreparable harm to SafeLease’s business and customers by preventing SafeLease from, among other things, renewing or issuing new policies, notifying tenants of changes in coverage, adjusting or adjudicating insurance claims, or billing facilities accurately. This harm from loss of access critically impairs SafeLease’s business and its ability to service thousands of customers, is ongoing, and is irreparable because it places its entire business at risk, making much or all of the current harm to SafeLease’s business impossible to measure in damages.

138. As such, the Court issued a TRO enjoining defendants before the application for temporary injunction was heard: a. Defendants should be ordered to restore SafeLease’s status as an Authorized User on the storEDGE or any other facility management software for customer accounts that grant SafeLease such authorization.

b. Defendants should be ordered to take no action to remove or otherwise restrict SafeLease’s access to its storEDGE, SiteLink, or Easy Storage Solutions facility management software systems as an Authorized User for customer accounts that grant SafeLease such authorization.

139. SafeLease posted a bond to make the TRO effective. A minimal bond was required and warranted because the TRO simply restored the way that the parties have operated for years.

As a result, the risk of irreparable harm to defendants was nil.

140. SafeLease further requested that the Court temporarily enjoin Storable from these same acts until the trial of this case and that, after trial, the Court permanently enjoin Storable upon entry of final judgment.

141. On January 21, 2025, the Court denied the temporary injunction request.

-32-

PRAYER SafeLease respectfully seeks a TRO, temporary injunction, and permanent injunction that enjoins defendants and their officers, agents, servants, and employees from performing the anticompetitive and tortious acts described above, and a judgment for SafeLease and against defendants for reasonable and necessary attorney fees, costs of court, pre- and post-judgment interest, and all other relief to which SafeLease may be entitled.

Dated: January 28, 2025 Respectfully submitted, /s/ R. Paul Yetter R. Paul Yetter State Bar No. 22154200 [email protected] Susanna R. Allen State Bar No. 24126616 [email protected] Luke A. Schamel State Bar No. 24106403 [email protected] Shannon N. Smith State Bar No. 24110378 [email protected] YETTER COLEMAN LLP Main Street, Suite 4100 Houston, Texas 77002 (713) 632-8000 ATTORNEYS FOR PLAINTIFF

-33-

CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served on all counsel of record via the Court e-filing service and/or by email, on January 28, 2025.

_/s/ Shannon N. Smith_______ Shannon N. Smith

-34-

VERIFICATION

My name is StcYcn Stein. My date of birth is November 18, 1994. I am the Chief E:xccutiw Officer of plaintiff Sa fr Lease and have been since its inception . My business address is ~00 Brazos Street. Suite 320. Austin. Texas 7870 I. I declare ur1<.ler penalty of perjury that the material facts alleged in this Verified Second Amended Petition and Application for a Temporary Restraining Order. Temporary Injunction. and Permanent Injunction, except for paragraphs 80 and 97-98 (as to which another SafeLease employee is verifying), are true and correct based on my personal knowledge or, as indicated, on reliable referenced information sources.

Executed in Travis County , Texas on this 28th day of January, 2025 .

~;i

-35-

VERIFICATION

My name is Nathaniel Kinet. My date of birth is Occcmbcr 12. I986. f am Chief Revenue Officer of plaintiff Safclcasc and han~ been an employee of SafcLcase since May 2021 . My business address is 800 Brazos Street. Suite J20. Austin. Texas 7870 I . J declare under penalty of pc1:iury that the material facts alleged in paragraphs 80 and 97- 98 of this Verified Second Amended Petition and Application for a Temporary Restraining Order, Temporary Injunction. and Pennanent Injunction are true and cotTect based on my personal knowledge.

Executed in Travis County. Texas on this 28th day of January, 2025.

-36- Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Alyssa Smith on behalf of R. Yetter Bar No. 22154200 [email protected] Envelope ID: 96716932 Filing Code Description: Amended Filing Filing Description: PLAINTIFF’S VERIFIED SECOND AMENDED PETITION AND APPLICATION FOR A TEMPORARY RESTRAINING ORDER, TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION Status as of 1/29/2025 11:08 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Neil KentonAlexander [email protected] 1/28/2025 10:59:33 PM SENT Ray TTorgerson [email protected] 1/28/2025 10:59:33 PM SENT R. PaulYetter [email protected] 1/28/2025 10:59:33 PM SENT Delonda Dean [email protected] 1/28/2025 10:59:33 PM SENT Yetter Coleman [email protected] 1/28/2025 10:59:33 PM SENT Jacqueline Chin [email protected] 1/28/2025 10:59:33 PM SENT Ruth Tucker [email protected] 1/28/2025 10:59:33 PM SENT Stephanie Jennings [email protected] 1/28/2025 10:59:33 PM SENT Carolyn Reed [email protected] 1/28/2025 10:59:33 PM SENT Dolores Brunelle [email protected] 1/28/2025 10:59:33 PM SENT Austin Brumbaugh 24121929 [email protected] 1/28/2025 10:59:33 PM SENT Courtney Smith [email protected] 1/28/2025 10:59:33 PM SENT Susanna R.Allen [email protected] 1/28/2025 10:59:33 PM SENT Luke A.Schamel [email protected] 1/28/2025 10:59:33 PM SENT Alyssa Smith [email protected] 1/28/2025 10:59:33 PM SENT Elizabeth FEoff [email protected] 1/28/2025 10:59:33 PM SENT Jonna NSummers [email protected] 1/28/2025 10:59:33 PM SENT Lakshmi NKumar [email protected] 1/28/2025 10:59:33 PM SENT Justin Bernstein [email protected] 1/28/2025 10:59:33 PM SENT Shannon Smith [email protected] 1/28/2025 10:59:33 PM SENT Dale Wainwright [email protected] 1/28/2025 10:59:33 PM SENT 1

1 REPORTER'S RECORD FILED IN 2 VOLUME 4 OF 7 VOLUMES 15th COURT OF APPEALS AUSTIN, TEXAS 3 TRIAL COURT CAUSE NO. 25-BCO3A-261J&f)25 3:37 :13 PM CHRISTOPHER A. PRINE 4 APPELLATE CASE NO. 15-25-OOO2O-CV Clerk SAFELEASE INSURANCE SERVICES, LLC TEXAS BUSINESS COURT 7 Plaintiff, v. 9 DIVISION 3A STORABLE, INC., REDNOVA LABS, INC., (d/b/a STOREDGE), SITELINK SOFTWARE, LLC, EASY STORAGE SOLUTIONS, LLC, BADER CO., AND PROPERTY FIRST GROUP, LP TRAVIS COUNTY, TEXAS 12 Defendants.

15 HEARING ON PLAINTIFF'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER AND TEMPORARY INJUNCTION 16 AND ALTERNATIVE MOTION FOR RECONSIDERATION 19 On the 13th day of February, 2025, the following proceedings came on to be heard in the above-entitled and numbered cause before the Honorable Melissa Andrews, Judge Presiding, held in person in Austin, Travis County, Texas. 23 Proceedings reported by stenographic machine shorthand.

Donna A. Goree, CSR, RPR, CRR (979) 533-0422 2

1 A P P E A RA NC E S APPEARING FOR THE PLAINTIFFS: 3 YETTER COLEMAN, LLP Main Street, Suite 4100 4 Houston, Texas 77002-6125 (713) 632-8000 HON. R. PAUL YETTER 6 State Bar No. 22154200 [email protected] 7 HON. SUSANNA R. ALLEN State Bar No. 24126616 STONE HILTON, LLP 9 811 Main Street, Suite 4100 Houston, Texas 77002-6125 10 (713) 632-8000 11 HON. CHRISTOPHER HILTON State Bar No. 24087727 12 [email protected] APPEARING FOR THE DEFENDANTS: PORTER HEDGES, LLP 15 1000 Main Street, Floor 36 Houston, Texas 77002-6341 16 (713) 226-6650 17 HON. RAY T. TORGERSON State Bar No. 24003067 18 [email protected] 19 HON. NEIL KENTON ALEXANDER State Bar No. 00996600 20 [email protected] 21 HON. LIZA EOFF State Bar No. 24095062 22 [email protected] Donna A. Goree, CSR, RPR, CRR (979) 533-0422 3

2 A P P E A RA NC E S 3 GREENBERG TRAURIG, LLP West 6th Street, Suite 2050 4 Austin, Texas 78701 5 HON. DALE WAINWRIGHT State Bar No. 00000049 6 (512) 320-7226 [email protected] 7 [email protected] 8 HON. JUSTIN LEWIS BERNSTEIN State Bar No. 24105462 9 (617) 512-5191 [email protected] ALSO PRESENT: 12 Chuck Gordon Rick Verma 13 Lakshmi Kumar Donna A. Goree, CSR, RPR, CRR (979) 533-0422 4

1 VOLUME 4 OF 7 2 CHRONOLOGICAL INDEX 3 (February 13, 2025) TEMPORARY INJUNCTION HEARING PAGE VOL Case called/appearances 6 4 Housekeeping matters 6 4 Motion to compel by Ms. Allen 6 4 Response by Ms. Eoff 7 4 Adjournment 262 4 Certificate of Court Reporter 263 4 12 CHRONOLOGICAL WITNESS INDEX WITNESSES: D X RD RX VOL 14 NATE KINET 10 23 86 99 4 15 JULIETTE CAMINADE 103 163 208 215 4 16 JULIETTE CAMINADE 217 4 17 JOHN MANES 221 242 262 4 19 ALPHABETICAL WITNESS INDEX WITNESSES: D X RD RX VOL 21 CAMINADE, JULIETTE 103 163 208 215 4 22 CAMINADE, JULIETTE 217 4 23 KINET, NATE 10 23 86 99 4 24 MANES, JOHN 221 242 262 4 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 5

1 INDEX OF EXHIBITS PLAINTIFF'S EXHIBITS: NO. DESCRIPTION OFFERED RECEIVED VOL 185 Storable website page - About Us 198 4 197 List of customer cancelations 12 12 4 DEFENDANT'S EXHIBITS: NO. DESCRIPTION OFFERED RECEIVED VOL 352 Storable software integration page 140 140 4 357 Monopoly share analysis 136 4 359 Email from Stephen Skinner 52 52 4 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 08981

1 A. You could add up the amounts that those customers have been invoiced for as long as they have worked with us, yes.

4 Q. So, of those 10 or 12 customers, we could know, moving forward, how much to expect revenue Safe Lease would not be recognizing because of this cancellation; true?

7 A. If you are looking exclusively of the 12 that have so far canceled.

9 Q. Right. You would agree with that proposition though.

10 This 1s a knowable calculation, true?

11 A. For the knowable 12 customers, yes.

12 Q. Okay. I just want to be clear. To date, you have actually not had a problem with an insurance policy lapsing after January 21st; true?

15 A. I don't know.

16 Q. Certainly no data of that has been produced ,n this case; right? 18 A. I don't know. 19 Q. Okay. And as you sit here today, to your knowledge, since January 21st, has a single claim been denied or unpaid as a result of being blocked from the Storable platforms? 22 A. Again, I don't know. I don't oversee claims.

23 Q. And do you know if any of that information has been produced in this case?

25 A. Again, I don't know.

Donna A. Goree, CSR, RPR, CRR (979) 533-0422 09082

1 THE COURT: This is a good time 2 MR. TORGERSON: I'm almost done.

3 THE COURT: Okay.

4 Q. (BY MR. TORGERSON) You understand that those customers that terminated you, those 12 customers, there are other options for them in the market; right?

7 A. Sure.

8 Q. All right. And you know that there are other FMS providers out there, right?

10 A. I do, yes.

11 Q. And you agree with me that ,n some instances Safelease has been recommending that their customers consider Cubby as a replacement FMS provider, true?

14 A. That is true.

15 Q. All right.

16 A. In the same way that Storable recommends their customers go to one of their insurance companies. I don't see it being any different.

19 Q. Okay. Let's look at DX-348. Safelease has a head-of-talent job posting, right?

21 A. We do, yes.

22 Q. Does this report to you?

23 A. Does not.

24 Q. You are familiar with this posting?

25 A. I'm familiar with the role. I wouldn't say that I'm Donna A. Goree, CSR, RPR, CRR (979) 533-0422 09183

1 very familiar with this posting. I didn't write it. It's not, again, something that rolls up to me. So 3 Q. Let's look at the last sentence of the first paragraph, Mr. Kinet. It says: We're three years old, profitable, and intent on building the best insurance provider in storage.

7 Do you see that?

8 A. Yes.

9 Q. "Profitable," you know what that means.

10 A. I think there is a lot of different ways to define "prof i tab l e . " 12 Q. Profitable means you make more money than you lose, doesn't it?

14 A. I think in the simplest terms, yes.

15 Q. And in the simplest terms, you would agree with me that right now Safelease is not profitable?

17 A. I would agree with that.

18 Q. You understand that for no year of its existence has Safelease realized a net profit.

20 A. Yes.

21 Q. So, this statement that Safelease is profitable, ,n simplest terms, that is quite false; isn't it?

23 A. Again, I didn't write this. I can't speak to why it was written or what the meaning behind it was.

25 Q. Just to be clear -- Donna A. Goree, CSR, RPR, CRR (979) 533-0422 092263

1 THE STATE OF TEXAS: COUNTY OF AUSTIN: 3 CERTIFICATE OF COURT REPORTER 4 I, DONNA A. GOREE, Official Court Reporter 1n and for the Texas Business Court, Division 3A of Austin County, State of Texas, do hereby certify that the above and foregoing contains a true and correct transcription of all portions of evidence and other proceedings requested in writing by counsel for the parties to be included ,n this volume of the Reporter's Record, in the above-entitled and numbered cause, all of which occurred in open court and were stenographically reported by me.

13 I further certify that this Reporter's Record of the proceedings truly and correctly reflects the exhibits, if any, admitted by the respective parties.

16 WITNESS MY OFFICIAL HAND on this the 11th day of March, 2025.

1s1 Donna Goree DONNA A. GOREE, CSR, RPR, CRR 20 Official Court Reporter Texas Business Courts 21 Austin County, Texas 3721 Carmen Avenue 22 Rancho Viejo, Texas 78575 (979) 533-0422 23 Certificate No. 3909 Expiration Date: 07/31/2025 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 1

1 REPORTER'S RECORD FILED IN 2 VOLUME 5 OF 7 VOLUMES 15th COURT OF APPEALS AUSTIN, TEXAS 3 TRIAL COURT CAUSE NO. 25-BCO3A-261J&f)25 3:37 :13 PM CHRISTOPHER A. PRINE 4 APPELLATE CASE NO. 15-25-OOO2O-CV Clerk SAFELEASE INSURANCE SERVICES, LLC TEXAS BUSINESS COURT 7 Plaintiff, v. 9 DIVISION 3A STORABLE, INC., REDNOVA LABS, INC., (d/b/a STOREDGE), SITELINK SOFTWARE, LLC, EASY STORAGE SOLUTIONS, LLC, BADER CO., AND PROPERTY FIRST GROUP, LP TRAVIS COUNTY, TEXAS 12 Defendants.

15 HEARING ON PLAINTIFF'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER AND TEMPORARY INJUNCTION 16 AND ALTERNATIVE MOTION FOR RECONSIDERATION 19 On the 14th day of February, 2025, the following proceedings came on to be heard in the above-entitled and numbered cause before the Honorable Melissa Andrews, Judge Presiding, held in person in Austin, Travis County, Texas.

23 Proceedings reported by stenographic machine shorthand.

Donna A. Goree, CSR, RPR, CRR (979) 533-0422 2

1 A P P E A RA NC E S APPEARING FOR THE PLAINTIFF: 3 YETTER COLEMAN, LLP Main Street, Suite 4100 4 Houston, Texas 77002-6125 (713) 632-8000 HON. R. PAUL YETTER 6 State Bar No. 22154200 [email protected] HON. SUSANNA R. ALLEN 8 State Bar No. 24126616 [email protected] STONE HILTON, LLP 10 811 Main Street, Suite 4100 Houston, Texas 77002-6125 11 (713) 632-8000 12 HON. CHRISTOPHER HILTON State Bar No. 24087727 13 [email protected] APPEARING FOR THE DEFENDANTS: 16 PORTER HEDGES, LLP 1000 Main Street, Floor 36 17 Houston, Texas 77002-6341 (713) 226-6650 HON. RAY T. TORGERSON 19 State Bar No. 24003067 [email protected] HON. NEIL KENTON ALEXANDER 21 State Bar No. 00996600 [email protected] HON. LIZA EOFF 23 State Bar No. 24095062 [email protected] Donna A. Goree, CSR, RPR, CRR (979) 533-0422 3

1 A P P E A RA NC E S GREENBERG TRAURIG, LLP West 6th Street, Suite 2050 Austin, Texas 78701 (512) 320-7226 HON. DALE WAINWRIGHT 5 State Bar No. 00000049 [email protected] 6 [email protected] 7 HON. JUSTIN LEWIS BERNSTEIN State Bar No. 24105462 8 (617) 512-5191 [email protected] Donna A. Goree, CSR, RPR, CRR (979) 533-0422 4

1 VOLUME 5 OF 7 2 ***INDEX*** 3 (February 14, 2025) 4 PAGE VOL Case called/ appearances 7 5 Adjournment 286 5 Certificate of Court Reporter 287 5 8 CHRONOLOGICAL WITNESSES INDEX WITNESSES: D X RD RX VOL 10 STEVEN STEIN 12 58/131 135 5 11 CHARLES GORDON 138 169 222 222 5 12 DAN FRITCHER 233 248 5 13 DANIEL STEINBROOK 265 284 286 5 15 ALPHABETICAL WITNESS INDEX WITNESSES: D X RD RX VOL 17 FRITCHER, DAN 233 248 5 18 GORDON, CHARLES 138 169 222 222 5 19 STEIN, STEVEN 12 131 135 5 20 STEIN, STEVEN 58 5 21 STEINBROOK, DANIEL 265 284 286 5 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 5

1 VOLUME 5 OF 7 2 EXHIBIT INDEX 3 PLAINTIFF'S EXHIBITS NO. DESCRIPTION OFFERED RECEIVED VOL 178 ESS incident log 253 253 5 185 Wayback Machine 10 10 5 198 (Demonstrative) Safelease dashboard 21 5 206 (Demonstrative) 13 5 207 Storable letter to customer 11 11 5 208 Courtney to Storable email 1-28-25 11 11 5 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 6

1 VOLUME 5 OF 7 2 EXHIBIT INDEX 3 DEFENDANT'S EXHIBITS NO. DESCRIPTION OFFERED RECEIVED VOL 361 Email 2-6-25 Sudlow to Safelease 137 137 5 362 Excel spreadsheet 137 234 5 362 ESS database entry 234 5 363 Email 1-28-25 O'Risky to Safelease 137 137 5 364 Email 2-10-25 McAdams to Safelease 11 11 5 364 Email 2-10-25 McAdams to Safelease 137 5 365 Self Storage Association doc 137 5 366 Storable timeline 141 141 5 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 09927

1 A. That's correct.

2 Q. Where is Safelease's home state as it relates to insurance?

4 A. Texas.

5 Q. And who is bigger in the tenant coverage market, Safelease or Storable?

7 A. Storable.

8 Q. Storable's counsel at the prior hearing asked you about some marketing materials where Safelease says: It's the largest tenant protection and tenant insurance provider in the self-storage industry.

12 Can you explain to me how that's the case if Storable is a larger player in this market?

14 A. Safelease is one of the few producers that offers both of those products under one flag. Storable is a collection of different companies. Some of those companies only offer protection. Some only offer insurance.

18 Q. So, is it -- when it comes to Storable overall, is it fair to say that they are significantly larger than Safelease in the tenant insurance market?

21 A. They are.

22 Q. They just may not have one entity that offers both products?

24 A. That's correct.

25 Q. Do you consider Safelease a discount provider? Is Donna A. Goree, CSR, RPR, CRR (979) 533-0422 10028

1 that the term that you have heard?

2 A. It's not regularly used. I don't think it would be a mischaracterization. Occasionally, one deals on price. But I would like to think it's a combination of reasons why someone would work with us. Of course, price is always important in the insurance world.

7 Q. Do you agree that Safelease offers highly competitive prices?

9 A. We do, yes.

10 Q. And the term "discount provider," is that, in fact, a term that Storable has called Safelease in its papers in this litigation?

13 A. That's correct.

14 Q. About how many of your customers use the Storable product as their FMS?

16 A. I think it's now 1,800 facilities.

17 Q. Do you know about what percentage of your customers use a Storable FMS?

19 A. It's approximately 70 percent.

20 Q. 70 percent?

21 A. That's correct.

22 Q. Do you, Safelease, ever access the customer's Facility Management Software without their permission?

24 A. Never. We wouldn't be able to. The customer has to create the credentials.

Donna A. Goree, CSR, RPR, CRR (979) 533-0422 10129

1 MS. ALLEN: I would like to just very quickly pull up Plaintiff's Exhibit 70, which is "outside, counsel eyes only."

4 Please don't. Okay. Apologies. Thank you.

5 You can republish the document.

6 Q. (BY MS. ALLEN) Is this an example of a contract between Safelease and a facility customer that includes that authorization?

9 A. Yeah, this is the first page.

10 Q. Let's go to Page 2 in the program. Is this an example a customer can send for you to access their Facility Management Software as an authorized user?

13 A. It is, yes.

14 Q. And it also authorizes you to access the customer's data?

16 A. It does, yes.

17 Q. For every customer, do you have a consent like this?

18 A. We do.

19 Q. Whose data ,s stored on the FMS?

20 A. It's only the customer's data, and they are authorizing just for the purposes of facilitating the insurance program.

23 Q. It's the facility's data?

24 A. That's correct.

25 Q. And does even Storable acknowledge that?

Donna A. Goree, CSR, RPR, CRR (979) 533-0422 102287

1 THE STATE OF TEXAS: TEXAS BUSINESS COURTS: 4 CERTIFICATE OF COURT REPORTER 5 I, DONNA A. GOREE, Official Court Reporter 1n and for the Texas Business Courts, State of Texas, do hereby certify that the above and foregoing contains a true and correct transcription of all portions of evidence and other proceedings requested in writing by counsel for the parties to be included in this volume of the Reporter's Record, in the above-entitled and numbered cause, all of which occurred in open court and were stenographically reported by me.

13 I further certify that this Reporter's Record of the proceedings truly and correctly reflects the exhibits, if any, admitted by the respective parties.

16 WITNESS MY OFFICIAL HAND on this the 12th day of March, 2025.

1s1 Donna Goree DONNA A. GOREE, CSR, RPR, CRR 20 Official Court Reporter Texas Business Courts 21 3721 Carmen Avenue Rancho Viejo, Texas 78575 22 (979) 533-0422 [email protected] 23 Texas Certification No. 3909 Expiration Date: 07/31/2025 Donna A. Goree, CSR, RPR, CRR (979) 533-0422 E-filed in the Office of the Clerk for the Business Court of Texas 2/25/2025 1:00 PM 103 Accepted by: Alexis Jennings Case Number: 25-BC03A-0001 CAUSE NO. 25-BC03A-0001 SAFELEASE INSURANCE SERVICES, § THE BUSINESS COURT OF TEXAS LLC § Plaintiff, § § § THIRD DIVISION v. § § STORABLE, INC., REDNOVA LABS, § INC., (d/b/a STOREDGE), SITELINK § SOFTWARE, LLC, EASY STORAGE § SOLUTIONS, LLC, BADER CO., AND § PROPERTY FIRST GROUP, LP.

§ Defendants. § TRAVIS COUNTY, TEXAS

NOTICE OF APPEAL Pursuant to Rules 25.1 and 28.1 of the Texas Rules of Appellate Procedure, Defendants Storable, Inc.; RedNova Labs, Inc. (d/b/a storEDGE); Sitelink Software, LLC; Easy Storage Solutions, LLC; Bader Co.; and Property First Group, LP (collectively “Storable” or “Defendants”) hereby file this Notice of Appeal.

Defendants desire to appeal to the Fifteenth Court of Appeals, which has exclusive jurisdiction over this appeal pursuant to Texas Government Code Sections 22.220(d)(3) and 25A.007 because this is an appeal from an order of a business court. Defendants appeal the Order Granting Temporary Injunction signed February 19, 2025 in the above- styled case, and all adverse rulings and failures to rule related to the Order Granting Temporary Injunction, including, but not limited to, rulings made during hearings and the February 10, 2025 Opinion and Order denying Defendants’ motion to remand.

This is an accelerated appeal because it is an appeal of an interlocutory order. TEX. R. APP. P. 28.1(a). In compliance with Texas Rule of Appellate Procedure 25.1(d)(6), Defendants confirm that this appeal is not a parental termination or child protection case, or an appeal from an order certifying a child to stand trial as an adult.

Respectfully submitted, GREENBERG TRAURIG, LLP By: /s/ Dale Wainwright______ Dale Wainwright State Bar No. 00000049 [email protected] Justin Bernstein State Bar No. 24105462 [email protected] West 6th Street, Suite 2050 Austin, Texas 78701 T: (512) 320-7200 F: (512) 320-7210 COUNSEL FOR APPELLANTS/DEFENDANTS

-2-

CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing instrument has been served to all attorneys of record, in compliance with Rule 21a of the Texas Rules of Civil Procedure and Rule 25.1(e) of the Texas Rules of Appellate Procedure, on February 25, 2025.

/s/ Dale Wainwright Dale Wainwright

-3- Automated Certificate of eService This automated certificate of service was created by the efiling system.

Sylvia Dominguez on behalf of Dale Wainwright Bar No. 49 [email protected] Envelope ID: 97769294 Filing Code Description: Notice of Appeal Filing Description: Defendants' Notice of Appeal Status as of 2/25/2025 1:51 PM CST Associated Case Party: SafeLease Insurance Services LLC Name BarNumber Email TimestampSubmitted Status Courtney Smith [email protected] 2/25/2025 1:00:29 PM SENT Luke A.Schamel [email protected] 2/25/2025 1:00:29 PM SENT Christopher Hilton [email protected] 2/25/2025 1:00:29 PM SENT Judd Stone [email protected] 2/25/2025 1:00:29 PM SENT Alyssa Smith [email protected] 2/25/2025 1:00:29 PM SENT Bonnie Chester [email protected] 2/25/2025 1:00:29 PM SENT Alexander Dvorscak [email protected] 2/25/2025 1:00:29 PM SENT Shannon Smith [email protected] 2/25/2025 1:00:29 PM SENT R. PaulYetter [email protected] 2/25/2025 1:00:29 PM SENT Susanna R.Allen [email protected] 2/25/2025 1:00:29 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Justin Bernstein [email protected] 2/25/2025 1:00:29 PM SENT Business Court Division 3A [email protected] 2/25/2025 1:00:29 PM SENT Dale Wainwright [email protected] 2/25/2025 1:00:29 PM SENT

Associated Case Party: Storable, Inc. Name BarNumber Email TimestampSubmitted Status Neil KentonAlexander [email protected] 2/25/2025 1:00:29 PM SENT Ray TTorgerson [email protected] 2/25/2025 1:00:29 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

Sylvia Dominguez on behalf of Dale Wainwright Bar No. 49 [email protected] Envelope ID: 97769294 Filing Code Description: Notice of Appeal Filing Description: Defendants' Notice of Appeal Status as of 2/25/2025 1:51 PM CST Associated Case Party: Storable, Inc. Ray TTorgerson [email protected] 2/25/2025 1:00:29 PM SENT Carolyn Reed [email protected] 2/25/2025 1:00:29 PM SENT Jonna NSummers [email protected] 2/25/2025 1:00:29 PM SENT Lakshmi NKumar [email protected] 2/25/2025 1:00:29 PM SENT Dolores Brunelle [email protected] 2/25/2025 1:00:29 PM SENT Liza Eoff [email protected] 2/25/2025 1:00:29 PM SENT FILED IN BUSINESS COURT 108 OF TEXAS BEVERLY CRUMLEY, CLERK ENTERED 2/27/2025 The Business Court of Texas, Third Division SAFELEASE INSURANCE § SERVICES LLC, § Plaintiff, § v. § Cause No. 25-BC03A-0001 § STORABLE, INC., et al., § Defendants. § AGREED PROTECTIVE ORDER & TEMPORARY SEALING ORDER The Court enters the following Agreed Protective Order and Temporary Sealing Order (the Agreed Protective Order or Protective Order) as agreed to by the parties, except that the Court has deleted paragraph 24 and modified paragraph 20 to comply with Rule 76a and grant a temporary sealing order.

In order to expedite the flow of discovery material, facilitate the prompt resolution of disputes over confidentiality, adequately protect material entitled to be kept confidential, and ensure that protection is afforded only to material so entitled, entry of this Agreed Protective Order pursuant to Texas Rule of Civil Procedure 192.6 is merited. This Protective Order applies to materials produced in advance of the Temporary Injunction hearing and functions as the operative Protective Order for this matter until such time as this Order is amended or replaced.

It is hereby ORDERED that: 1. All Confidential Information and Outside Counsel’s Eyes Only Information produced or exchanged by the parties in the course of this litigation, including information produced by third parties/non-parties, shall be used solely for the purpose of preparation, trial, and appeal of this litigation and for no other purpose whatsoever, and shall not be disclosed to any person except in accordance with the terms hereof.

2. “Confidential Information” as used herein means any information of any type, kind, or character which is designated as “Confidential” by any of the supplying or receiving parties, including third parties/non-parties supplying said information, whether it be a document, information contained in a document, discovery materials, information or testimony revealed during a deposition, or otherwise.

3. “Outside Counsel’s Eyes Only Information” as used herein means any information that is “Confidential” as described herein and additionally may not be disclosed to anyone except the Qualified Persons described in Paragraph 6, infra. “Outside Counsel’s Eyes Only Information” includes trade secrets or other non-public, proprietary, or sensitive business or financial information. More specifically, an “Outside Counsel’s Eyes Only” designation means that the materials so denoted may not be disclosed to any party or employee, representative, or affiliate of a party, except by agreement or a subsequent Order by this Court.

4. In designating information as “Confidential” or “Outside Counsel’s Eyes Only,” a party or third party/non-party supplying information will make such designation only as to that information that it in good faith believes contains “Confidential” or “Outside Counsel’s Eyes Only” information. Information or material which is available to the public, including industry materials, advertising materials, and the like shall not be classified as “Confidential” or “Outside Counsel’s Eyes Only.”

5. “Qualified Persons” as used herein for “Confidential Information” means: (a) Attorneys of record for the parties in this litigation and employees and/or agents of such attorneys to whom it is necessary that the information be shown for purposes of this litigation; (b) Actual or potential independent experts or consultants (and their administrative or clerical staff) engaged in connection with this litigation (which shall not include the current employees, officers, members, or agents of the parties or affiliates of the parties) who have signed a document in the form of Exhibit A attached hereto (such signed document to be maintained by the attorney retaining such person); (c) The parties and their respective in-house counsel, paralegals, legal staff or experts; (d) The Court and its staff, including court reporters; (e) Vendors engaged by the parties or the parties’ respective counsel, including independent copy services, printers, or illustrators, and court reporters for the purpose of this litigation who have signed a document in the form of Exhibit A attached hereto (such signed document to be maintained by the attorney retaining such person); (f) The authors and original recipients of the documents or information unless any such person no longer has a right to access or possess any such documents or information by virtue of a change in employment, position, or other circumstance; (g) The designated corporate representative for the party that produced the documents or information as “Confidential” or “Outside Counsel’s Eyes Only”; or (h) By agreement of the parties, or if this Court so elects, any other person designated as a Qualified Person by order of this Court, after notice to all the parties and hearing.

6. For “Outside Counsel’s Eyes Only Information,” “Qualified Persons” includes (a), (b), and (d) - (h), above.

7. Documents produced in this action may be designated by any party or parties or by any third party and/or non-party producing said documents as “Confidential” or “Outside Counsel’s Eyes Only” information by marking each page of the document(s) with the word(s) “Confidential” or “Outside Counsel’s Eyes Only.” However, for documents produced in electronic native form, such as Excel spreadsheets, the designation may be affixed to the drive, disk, or other medium on which the documents or materials are produced or in the file names without marking each page of the documents or materials “Confidential” or “Outside Counsel’s Eyes Only.”

8. In lieu of marking the original of a document, if the original is not produced, the designating party may mark the copies that are produced or exchanged.

9. Information disclosed at (a) the deposition of a party or one of its present or former officers, directors, employees, agents or independent experts retained by counsel for the purpose of this litigation, or (b) the deposition of a third party (which information pertains to a party) may be designated by any party, including a third party/non-party disclosing said information or being deposed, as “Confidential” or “Outside Counsel’s Eyes Only” information by indicating on the record at the deposition that the testimony is “Confidential” or “Outside Counsel’s Eyes Only” and is subject to the provisions of this Order.

10. Any party or third party/non-party disclosing said information or being deposed may also designate said information disclosed at such deposition as “Confidential” or “Outside Counsel’s Eyes Only” by notifying all of the parties, in writing within 30 days of receipt of the transcript, of the specific pages and lines of the transcript which should be treated as “Confidential” or “Outside Counsel’s Eyes Only” thereafter. Each party shall attach a copy of such written notice or notices to the face of the transcript and each copy thereof in his possession, custody or control. All deposition transcripts shall be treated as “Confidential” for a period of 30 days after the receipt of the transcript, apart from any portions designated on the record as “Outside Counsel’s Eyes Only,” which portions shall be treated as Attorneys’ Eyes Only.

11. To the extent possible, the court reporter shall segregate into separate transcripts information designated as “Confidential” or “Outside Counsel’s Eyes Only” with blank, consecutively numbered pages being provided in a non-designated main transcript. The separate transcript containing “Confidential” or “Outside Counsel’s Eyes Only” information shall have page numbers that correspond to the blank pages in the main transcript.

12. “Confidential” or “Outside Counsel’s Eyes Only” information shall not be disclosed or made available by the receiving party to persons other than Qualified Persons as delineated above. Notwithstanding the foregoing, nothing in this Protective Order restricts the ability of a party and/or third party/non-party to review, disclose, or disseminate its own documents or information as it sees fit.

Documents unintentionally produced without designation as “Confidential” or “Outside Counsel’s Eyes Only” may be retroactively designated in the same manner and shall be treated appropriately from the date written notice of the designation is provided to the receiving party. The burden shall be on the party claiming confidentiality to prove the confidential nature of the documents.

14. Documents to be inspected shall be treated as “Confidential” during inspection. At the time of copying for the receiving parties, such inspected documents shall be marked or stamped prominently “Confidential” or “Outside Counsel’s Eyes Only” by the producing party.

15. If a receiving party learns of any unauthorized disclosure of “Confidential” or “Outside Counsel’s Eyes Only,” the party shall immediately upon learning of such disclosure inform the producing party of all pertinent facts relating to such disclosure and shall make all reasonable efforts to prevent disclosure by each unauthorized person who received such information.

16. Nothing herein shall prevent disclosure beyond the terms of this Protective Order if each party or third party/non-party designating the information as “Confidential” or “Outside Counsel’s Eyes Only” consents in writing to such disclosure or if the Court orders such disclosure.

Nor shall anything herein prevent any counsel of record from utilizing “Confidential” or “Outside Counsel’s Eyes Only” information in the examination or cross-examination of any person who is indicated on the document as being an author, source or recipient of the “Confidential” or “Outside Counsel’s Eyes Only” information, or if counsel has a reasonable belief that such person was an author, source or recipient of “Confidential” or “Outside Counsel’s Eyes Only” information irrespective of which party or third party/non-party produced such information.

17. A party shall not be obligated to challenge the propriety of a designation as “Confidential” or “Outside Counsel’s Eyes Only” at the time made, and a failure to do so shall not preclude a subsequent challenge thereto. In the event that any party to this litigation disagrees at any stage of these proceedings with the designation by the designating party of any information as “Confidential” or “Outside Counsel’s Eyes Only” or the designation of any person as a

Qualified Person, the parties shall first try to resolve such dispute in good faith on an informal basis, such as production of redacted copies. If the dispute cannot be resolved, the objecting party may invoke this Protective Order by objecting in writing to the party or third party/non-party who has designated the document or information as “Confidential” or “Outside Counsel’s Eyes Only” or designated any person as a Qualified Person. The designating party shall be required to move the Court for an order preserving the designated status of such information or person within 30 business days of receipt of the written objection. The disputed information shall remain “Confidential” or “Outside Counsel’s Eyes Only” unless and until the Court orders otherwise. Failure to move for an order shall constitute a termination of the restricted status of such item unless the parties otherwise agree. The party or third party/non-party objecting to disclosure bears the burden of proof to establish the confidentiality of the document.

18. The parties may, by stipulation, provide for exceptions to this Protective Order, and any party may seek an order of this Court modifying this Protective Order.

19. Nothing shall be regarded as “Confidential” or “Outside Counsel’s Eyes Only” information if it is information that either: (a) is in the public domain at the time of disclosure supported by appropriate evidence; or (b) becomes part of the public domain through no fault of the other party, as supported by appropriate evidence.

20. The following provisions govern the treatment of “Confidential” or “Outside Counsel’s Eyes Only” Information used in connection with Court filings or proceedings: (a) Temporary Sealing Order. There have been hearings in this case in connection with plaintiff’s request for a temporary restraining order (TRO) and temporary injunction

(TI). The Court has determined that the criteria of Rule 76a(5) is satisfied and hereby GRANTS a temporary sealing order covering (1) the exhibits that are designated as “Confidential” or “Outside Counsel’s Eyes Only” and (2) the transcripts of those proceedings. This temporary sealing order will remain in effect until March 24, 2025. (b) Sealing Motion, Notice, and Hearing. At 1 p.m. on March 20, 2025, the Court will hold a hearing on whether to permanently seal the materials covered by the temporary sealing order in subsection (a), above. At least 14 days before the hearing, the parties, either jointly or individually, must (1) file a motion to seal any portions of the material covered by the temporary sealing order that should not be made public upon expiration of the temporary sealing order; and (2) comply with the notice requirements of Rule 76a(3). The motion(s) must identify the specific portions of the hearing transcript(s) to be sealed by page and line. The Court will not seal the entire transcript(s). The exhibits to be sealed must be identified by exhibit numbers.

Any documents or transcripts previously provided to the Court need not be provided again, but any transcripts or exhibits that a party seeks to seal that were not previously provided to the Court should be provided to the Court in the same manner as the hearing exhibits for the TI hearing and served on the other parties subject to this Agreed Protective Order. (c) Future hearings. For future hearings at which the parties expect to disclose “Confidential” or “Outside Counsel’s Eyes Only” Information or documents containing such information, the parties may move for a temporary sealing order under Rule 76a(5) before the hearing. Any material at issue in the motion that has not previously been provided to the Court should be provided to the Court for in camera inspection but not filed in the case. If granted, the temporary sealing order will remain in place for 30 days after the hearing and may be extended for good cause. The parties may move for permanent sealing by obtaining a hearing date from the Court and complying with Rule 76a and the procedures in subsection (b), above, relating to the motion and notice. For any part of the hearing record that contains “Confidential” or “Outside Counsel’s Eyes Only” Information that has been sealed under a prior sealing order, the motion to seal need only identify the portion of the record (by page and line or exhibit number) to be sealed and the applicable sealing order. (d) Filings. To the extent documents containing or revealing “Confidential” or “Outside Counsel’s Eyes Only” Information are filed in this Court after the date of this order, the parties shall undertake the following procedures: 1. The filing party must redact any material that would disclose “Confidential” or “Outside Counsel’s Eyes Only” Information from the Court filing and simultaneously serve an unredacted version on the other parties subject to this Protective Order.

2. The redacted filing must identify the redacted material by Bates Number, page and line, or as specifically as possible.

3. The parties have five days after such filing to move to temporarily or permanently seal the designated information. If no motion to seal is timely filed, the filing party will file the unredacted version of the document with the Court. If a motion to seal is timely filed, the filing party will wait until the Court rules on the motion to seal, then file the unredacted version of the document under seal or not under seal, as dictated by the Court’s ruling.

4. The foregoing notwithstanding, if the parties agree that any or all of the redacted material is not needed for the resolution of the matter, that material may remain redacted, will not become part of the Court’s record, and will not be considered by, relied on, or before the Court.

(e) - Trial. - - The use of “Confidential” or “Outside Counsel’s Eyes Only” Information at trial will be addressed in the pretrial order and/or at the pretrial conference.

(f) The parties understand that material provided to the Court for in camera inspection but not filed in the case will not be part of the record unless further action is taken.

(g) The parties understand that material filed in the case under a temporary sealing order may become part of the public record if a permanent sealing order is denied.

21. Unless otherwise agreed to in writing by the parties or ordered by the Court, all proceedings involving or relating to “Confidential” or “Outside Counsel’s Eyes Only” documents or information shall be subject to the provisions of this Protective Order.

22. After the conclusion of this litigation and any appeal thereof, any “Confidential” or “Outside Counsel’s Eyes Only” documents and all copies or reproductions of such documents produced by a party or third party/non-party in the possession of any of the “Qualified Persons” shall be returned to the producing party or third party/non-party within 60 days of receipt of a timely written request by said producing party or third party/non-party, except as this Court may otherwise order or to the extent such information was used as evidence at the trial. As far as the provisions of any protective orders entered in this action restrict the communication and use of the documents produced thereunder, such orders shall continue to be binding after the conclusion of this litigation, except (a) that there shall be no restriction on documents that are used as exhibits in open court, and (b) that a party may seek the written permission of the producing party or order of the Court with respect to dissolution or modification of such protective orders. Alternatively, at the conclusion of this litigation, in lieu of the actual physical return of “Confidential” or “Outside Counsel’s Eyes Only” documents, counsel for each party may provide a certification certifying that (1) all experts and any other person(s) receiving “Confidential” or “Outside Counsel’s Eyes Only” documents have been instructed to delete or destroy all documents; and (2) all “Confidential” or “Outside Counsel’s Eyes Only” documents in the possession of counsel have been deleted or destroyed.

23. Any party designating any person as a “Qualified Person” shall have the duty to reasonably ensure that such person observes the terms of this Protective Order.

Signed this 27th day of February, 2025.

Hon. Melissa Andrews Judge Presiding

EXHIBIT A AGREEMENT TO BE BOUND BY TERMS OF PROTECTIVE ORDER My name is, , my date of birth is , and my address is, . I have read and am familiar with the terms of the Protective Order concerning the records and testimony produced by the respective parties in this case, and I agree to abide by all terms of said Protective Order and not to reveal or otherwise communicate any of the information disclosed to me pursuant thereto to anyone except in accordance with the terms of said Protective Order. I agree not to make any use of that information or materials other than for the purpose of this litigation.

I declare under penalty of perjury that the foregoing is true and correct.

Executed in County, State of Date: E-filed in the Office of the Clerk for the Business Court of Texas 4/4/2025 8:29 PM 120 Accepted by: Alexis Jennings Case Number: 25-BC03A-0001 The Business Court of Texas, Third Division SAFELEASE INSURANCE § SERVICES LLC, § § Plaintiff, § § Cause No. 25-BC03A-0001 v. § § STORABLE, INC., et al., § § Defendants. § ______________________________________________________________________________ Storable’s Motion to Modify Protective Order/Require Disclosure and Request for Expedited Consideration ______________________________________________________________________________ Pursuant to the February 27, 2025 Protective Order, and the Court’s inherent authority under the Texas Rules of Civil Procedure, Defendants Storable, Inc., RedNova Labs, Inc., SiteLink Software, LLC, Easy Storage Solutions, LLC, Bader Co., and Property First Group, LP (“Storable” or “Defendants”) respectfully move the Court on an expedited basis for an order requiring Plaintiff SafeLease Insurance Services LLC (“SafeLease”) to disclose information necessary to investigate potential unauthorized access to Storable’s “Outside Counsel’s Eyes Only” (“OCEO”) Documents—information which SafeLease is refusing to provide. Storable further moves the Court for an order modifying the Protective Order (“PO”) to exclude attorney Adam Locke (“Locke”) from accessing Storable’s OCEO documents going forward. Given the nature of the relief requested, Storable respectfully requests the Court’s expedited consideration and would show as follows: Summary of the Argument During the Court’s hearing on the temporary injunction, one of Plaintiffs’ counsel, Mr. Yetter, represented in open court that SafeLease’s “outside general counsel is Adam Locke” and that “when we get into outside/counsel only, we will ask him to be excused.” TI Hr’g Tr. (Feb.

11, 2025) at 95:12–16, Exhibit A (emphasis added). SafeLease is now attempting to insert Locke—its general counsel, who is also its former chief operating officer, and a witness in this case—as an outside counsel of record with full access to Storable’s OCEO documents. When the parties entered into an Agreed Protective Order, which the Court issued on February 27, 2025, both Storable and the Court understood that SafeLease was excluding Locke from OCEO materials. Just a few weeks later, however, on March 24, 2025, Locke entered an appearance in this case and has admitted to reviewing Storable’s OCEO documents as early as the very next day, March 25, 2025, and is continuing to access and review such documents.

Now, despite Storable’s multiple requests, SafeLease refuses to provide basic information—e.g., what OCEO documents Locke reviewed and when—for Storable to determine whether there was unauthorized access to its OCEO documents. SafeLease is required to provide this information under the PO, and the Court should order it to do so.

Storable further requests that the Court modify the PO to expressly exclude Locke from reviewing Storable’s OCEO documents going forward consistent with SafeLease’s conduct, and Storable’s understanding at the time of the PO, prior to Locke’s attempted hat change. Had Storable known that Locke planned to appear in the case and access OCEO materials, Storable would not have agreed to the PO in its current form. Whether strategic or unintentional, Locke’s March 24 appearance, weeks after the PO was entered, deprived Storable of the opportunity to advocate for provisions in the PO necessary to protect its OCEO documents.

Because of the issues raised in this motion, Storable respectfully requests that the Court consider the motion on an expedited basis. Storable requested that SafeLease temporarily pause Locke’s access to OCEO documents to avoid a need for expedited relief, yet SafeLease refused.

-2-

Relevant Background I. Adam Locke Locke is SafeLease’s current outside General Counsel. At the February 11, 2025 hearing on Plaintiffs’ Temporary Injunction Motion, Plaintiffs’ counsel, Mr. Yetter, represented to the Court that SafeLease’s “outside general counsel is Adam Locke” and that “when we get into outside/counsel only, we will ask him to be excused.” TI Hr’g Tr. (Feb. 11, 2025) at 95:12–16, Exh. A. Plaintiff’s counsel similarly represented at the January 16, 2025 hearing on Plaintiff’s TI motion before the District Court that Locke was one of SafeLease’s “client representatives” and that “he is the outside General Counsel.” TI Hr’g Tr. (Jan. 16, 2025) at 35:21–25, Exhibit B.

Locke was repeatedly excused during the course of the TI hearing in this Court when OCEO materials were being introduced or discussed.

Locke is also SafeLease’s former Chief Operating Officer, a position he held during the relevant time period for purposes of this case and therefore is likely a potential witness in this case.

See Press Release: SafeLease Hires Adam Locke as Chief Operating Officer (Jul. 20, 2022), https://www.safelease.com/resources/safelease-hires-adam-locke-as-chief-operating-officer, Exhibit C.

II. The Agreed Protective Order As of the Court’s February 11 hearing, the Parties had been operating under a Rule 11 Agreement permitting one another to designate produced documents as “Confidential” or “Outside Counsel’s Eyes Only.” However, on February 20, 2025, the Parties submitted a Proposed Agreed Protective Order to formalize those protections. See [Proposed] Agreed PO (Feb. 20, 2025). On February 27, 2025, this Court entered the PO in the form submitted by the Parties with slight modifications. See PO, Exhibit D. At the time the Parties agreed to the Proposed Agreed PO and when the Court entered the PO, both Defendants and the Court understood, pursuant to Plaintiff’s

-3- counsel’s representations, that Locke was SafeLease’s general counsel and not permitted to view documents marked by Defendants as OCEO.

The PO provides that “Documents produced in this action may be designated by any party . . . as ‘Confidential’ or ‘Outside Counsel’s Eyes Only’ information by marking each page of the document(s) with the words ‘Confidential’ or ‘Outside Counsel’s Eyes Only.’” Id. § 7. The PO “applies to materials produced in advance of the Temporary Injunction hearing” and granted a temporary sealing order for all exhibits to those hearings marked “Confidential” or “Outside Counsel’s Eyes Only,” which the Court determined to meet the standards for temporary sealing under Rule 76a(5). Id. § 20(a). Both Plaintiff and Defendants have marked several documents produced as OCEO, including several exhibits to the TI hearings.

Under the PO, documents designated OCEO “may not be disclosed to any party or employee, representative, or affiliate of a party, except by agreement or a subsequent Order by this Court.” Id. § 3. The PO specifies the limited individuals who may view OCEO documents, including only: counsel of record for the Parties and their staff; experts or consultants for the Parties in this litigation and their staff; the Court and its staff; vendors engaged by the Parties’ counsel; authors and recipients of any particular document (subject to restrictions); a party’s corporate representative (but only as to documents designated as OCEO by such party); and other materials as may be agreed by the Parties or ordered by the Court. Id. §§ 5(a)–(b) & (d)–(h), 6.

III. Locke Appears as Counsel of Record and Admits to Having Reviewed An OCEO Document the Next Day On March 24, 2025 Locke filed a notice of appearance in this matter. See Notice of Appearance of Counsel (Mar. 24, 2025). The following day, counsel for the Parties participated in a meet-and-confer regarding the Parties’ motions to seal, which was conducted by teleconference. Locke attended this meeting and other counsel for SafeLease represented that

-4-

Locke is a “member of SafeLease’s outside counsel team.” Declaration of Defendants’ Counsel, A. Bergman, Exhibit E. During the meeting, Locke stated that he reviewed one of the TI hearing exhibits that Defendants marked OCEO as an example of a document he did not believe should be sealed, and he explained his reasoning based on the contents of the document. Id. At the end of the meeting, counsel for Defendants stated, for the record, that Defendants do not accept Plaintiff’s characterization of Locke as “outside counsel” for SafeLease, to which Locke responded “we’ll raise it with the Court.” Id. IV. Locke Refuses to Stop Accessing Storable’s OCEO Documents and to Provide a List of Which Storable OCEO Documents He Reviewed and When.

Later on March 25, 2025, and shortly after Locke’s admission that he reviewed an OCEO document, counsel for Defendants sent a letter to lead counsel for Plaintiff, P. Yetter, formally demanding that Locke cease and desist from viewing documents marked by Defendants as OCEO.

See K. Treistman Letter to P. Yetter (Mar. 25, 2025), Exhibit F. The letter requested (1) counsel’s confirmation that Locke would immediately and permanently cease and desist from reviewing OCEO documents unless and until any such OCEO designation is properly challenged and removed by the Court; and (2) a list of all documents marked OCEO by Defendants that Locke has reviewed. Id. The letter also requested a Rule 11 agreement to memorialize Plaintiff’s agreement that Locke will cease and desist from the improper conduct. See id. On March 26, 2025, Locke sent a response letter in which he insists that he is “outside counsel” and entitled to access Storable’s OCEO documents. See A. Locke Letter to K. Treistman (Mar. 26, 2025), Exhibit G. Locke’s response did not state whether he would provide the requested list of documents, nor whether he would agree to stop looking at Storable’s OCEO documents going forward.

-5-

On March 28, counsel for Storable conferred with Locke by telephone and email and asked once again that he stop viewing Storable’s OCEO documents, and that, in the alternative he stop doing so temporarily while the parties resolve this issue in order to avoid the need to go to the Court on an expedited basis. Locke again insisted that he is SafeLease’s outside counsel and should have full access to Storable’s OCEO documents. See A. Locke Email to K. Treistman (Mar. 28, 2025), Exhibit H. His response did not address the proposed temporary pause. See id. On March 31, undersigned counsel sent Locke another letter asking him to confirm his refusal to stop accessing Storable’s OCEO documents and to provide the list of which OCEO documents he has reviewed and when. See K. Treistman Letter to A. Locke (Mar. 31, 2025), Exhibit I. The March 31 letter also proposed an alternative solution—namely that if Locke would agree to stop accessing Storable’s OCEO documents across the board, Storable would consider de-designations of certain OCEO documents if one of SafeLease’s outside law firms, Yetter Coleman or Stone Hilton, determines that Locke’s review of such documents is necessary for SafeLease to pursue its case. Id. at 2.

In a response letter on April 2, 2025, Locke confirmed his refusal to stop accessing Storable’s OCEO’s documents, but again refused to provide a response to the requested list of Storable’s OCEO documents that he reviewed and when he reviewed them. See A. Locke Letter to K. Treistman (Apr. 2, 2025), Exhibit J. Locke did, however, reject Storable’s proposal to discuss de-designations of particular OCEO documents that SafeLease’s outside law firms may need Locke to review. Id. at 3.

In yet another attempt to reach a resolution without the Court’s intervention, on April 3, Storable’s counsel conferred in writing asking SafeLease to confirm its refusal to provide the list

-6- of documents (which it failed to provide despite two requests). As of this filing, SafeLease has not responded to this final request.

Legal Standard The PO’s paragraph 15 provides that “[i]f a receiving party learns of any unauthorized disclosure of [OCEO], the party shall immediately upon learning of such disclosure inform the producing party of all pertinent facts relating to such disclosure . . . .” PO § 15, Exh. D. As with any order, Court has “all powers necessary” to enforce the PO. T EX. GOV. CODE § 21.001(a).

Those powers include aiding “the exercise of [the Court’s] jurisdiction,” facilitating “the administration of justice,” and preserving “the independence and independence and integrity of the judicial system.” Brewer v. Lennox Hearth Products, LLC, 601 S.W.3d 704, 718 (Tex. 2020).

The Texas Rules of Civil Procedure also allow courts to issue any protective orders regarding discovery “in the interest of justice.” T EX. R. CIV. P. § 192.6(b).

Argument and Authorities The Court should require SafeLease to disclose which of Storable’s OCEO documents Locke reviewed and when he reviewed them. The Court should also modify the PO to exclude Locke from viewing Storable’s OCEO documents going forward.

I. SafeLease Must Provide Facts Relevant to Determine Whether There Was Any Unauthorized Disclosure of Storable’s OCEO Documents.

The Court should order SafeLease to disclose which of Storable’ OCEO documents Locke reviewed and when he reviewed them. Under the PO, SafeLease is required to promptly disclose “all pertinent facts” relating to any unauthorized disclosure of OCEO documents. PO § 15, Exh.

D. The record shows that there has been at least some—if not a significant amount—of unauthorized disclosure of Storable’s OCEO documents. See Exhs. E, H, J.

-7-

A. If Locke Was Not Permitted to View OCEO Documents, then Storable is Entitled to Know Which Documents He Reviewed First, and as an initial matter, it is not clear at all that an “outside general counsel” such as Locke is truly an “outside counsel” within the letter or spirit of the PO’s OCEO provisions. If he is not, then it is essential for SafeLease to disclose all Storable OCEO documents that Locke has viewed so that Storable and the Court can determine the extent of protected OCEO information that was compromised.

Under the PO, counsel permitted to view OCEO documents include “[a]ttorneys of record for the parties in this litigation . . . to whom it is necessary that the information be shown for purposes of this litigation.” PO §§ 5(a), 6 (emphasis added), Exh. D. OCEO materials, however, “may not be disclosed to any party or employee, representative, or affiliate of a party . . . .” Id. § 3 (emphasis added). SafeLease has already affirmed in open court that Locke is a “client representative[,]” TI Hr’g Tr. (Jan. 16, 2025) at 35:21–25, Exh. B, and expressly took the position that he needed to be excused from discussion and review of OCEO materials that were before the Court. TI Hr’g Tr. (Feb. 11, 2025) at 95:12–16, Exh. A.

Locke cannot erase, or attempt to somehow explain, these judicial admissions as to his role simply by filing a notice of appearance. If a party’s general counsel could do this, then it would render the PO’s OCEO restrictions a nullity. In any event, SafeLease has litigated this case for months before Locke’s March 24 notice of appearance—including prosecuting a TI motion before two different courts involving multiple days of hearings—so it is unclear why SafeLease’s general counsel now suddenly qualifies as attorney “to whom it is necessary that [OCEO] information be shown for purposes of this litigation.” PO §§ 5(a), 6 (emphasis added), Exh. D.

-8-

To the extent Locke does not qualify to review Storable’s OCEO documents under the PO, SafeLease is required under section 15 to provide Storable with, at minimum, a list of the OCEO documents Locke reviewed, and all other “pertinent facts relating to such disclosure[.]” Id. § 15.1 B. Even if Locke Might Qualify to Review OCEO Materials—Storable is Still Entitled to Know Which Documents he Reviewed and When.

Even if Locke’s March 24, 2025 notice of appearance could transform him from a client “representative” (required to be excluded from OCEO materials), into an “outside counsel” with full access to those materials under the PO (which is not clear at all), Storable is plainly entitled to know which of its OCEO materials Locke reviewed and, most importantly, when (or, at minimum, whether the review occurred before or after his appearance). See id. § 15. At bare minimum, counsel must file an appearance in the case to be an “attorney of record” who may view OCEO materials under the PO. Id. §§ 5(a), 6 (emphasis added).

There can be no realistic dispute that Locke’s review, if any, of Storable’s OCEO documents before his March 24 notice of appearance would have been improper. Given that Locke filed his notice of appearance at 6:26 PM on March 24, 2025—yet was discussing a Storable OCEO document that he reviewed at the parties’ 2:00 PM meet-and-confer the very next day (see Exh. E), it is possible, if not likely, that Locke was accessing and viewing Storable’s OCEO documents before his March 24, 6:26 PM notice of appearance. At minimum, there is enough indicia of unauthorized disclosure to trigger SafeLease’s requirement to provide Storable with the pertinent facts—including which OCEO documents Locke reviewed and when—pursuant to section 15 of the PO.

Storable respectfully reserves it right to move for an order to show cause or other relief for any violations of the PO.

It does not do so at this time simply because it was necessary to seek the more limited relief in this motion on an expedited basis—namely to (1) get the information needed to investigate any unauthorized disclosure of its OCEO information in the first instance and (2) to seek modification of the PO going forward. If the Court determines on its own that an order to show cause is warranted, Storable respectfully requests that it be permitted to provide its position in the ordinary course and consistent with the Court’s procedures.

-9-

II. The Court Should Modify PO Section 3 to Expressly Exclude Locke from Viewing Storable’s OCEO Information.

When the PO was entered on February 27, 2025, everyone—the Court, Storable, and SafeLease’s lead counsel, Mr. Yetter—understood that Locke was a “client representative” of SafeLease who had to be excluded from viewing OCEO materials. See Exh. A, Exh. B. Regardless of whether the PO as written permits Locke to change hats simply by filing a notice of appearance, going forward, the Court should modify section 3 of the PO as follows to reflect the Parties’ and the Court’s understanding at the time it was entered: 3. . . . More specifically, an “Outside Counsel’s Eyes Only” designation means that the materials so denoted may not be disclosed to any party or employee, representative, or affiliate of a party, except by agreement or a subsequent Order by this Court. For the avoidance of doubt, materials containing an “Outside Counsel’s Eyes Only” designation produced by Defendants may not be disclosed to attorney Adam Locke, who is Plaintiff’s outside general counsel, except by agreement or a subsequent Order of this Court.

Modifying the PO in this manner is “in the interests of justice” for several reasons.

First, the PO was an agreed protective order which the parties negotiated and which the Court entered (with slight modifications not relevant here). At the time of the Parties’ agreement, Storable did not know that Locke planned to appear in the case as counsel of record and obtain access to OCEO documents. Neither Locke nor SafeLease ever disclosed this intention before the PO was entered, and indeed, Locke did not actually file his appearance until almost a month after the PO was entered. Instead, SafeLease made exactly the opposite representation regarding Locke’s role at the hearings before this Court and the District Court. See Exh. A, Exh. B. Neither a party’s good faith agreement to a protective order, nor a Court’s approval of such an order, should ever be procured on a bait-and-switch basis as SafeLease has done here—and least of all where the agreement at issue concerns a party’s confidential and competitively sensitive materials produced with the expectation that the opposing party’s client representatives, like Locke, would

-10- not see them. The Court should ensure that the PO’s provisions fairly reflect the Parties’ and the Court’s mutual understanding as to who could review OCEO documents at the time the order was entered.

Second, even putting aside settled expectations at the time the PO was entered, Locke is objectively a client representative of SafeLease who should not in fairness be permitted to view Storable’s OCEO documents going forward. Locke’s correspondences regarding this matter admit that he is SafeLease’s “outside general counsel”—a role in which he provides SafeLease with “general legal advice” that SafeLease relies on. Exh. G at 2–3. This role is different from an outside counsel retained for this litigation. SafeLease is a direct competitor of Storable, and Storable’s OCEO materials include competitively sensitive information. See PO § 3, Exh. D (OCEO documents include “trade secrets or other non-public, proprietary, or sensitive business or financial information”). Storable’s right to the confidentiality and propriety of such information under the PO is violated if individuals like Locke, who are involved in SafeLease’s general business operations or discussions, are privy to OCEO documents.

Finally, SafeLease will not be prejudiced if Locke were to be excluded from viewing Storable’s OCEO materials. This is not a situation in which a business litigant with limited means cannot afford more than one lawyer to serve as its general counsel and its outside litigation counsel.

Rather, independent of Locke, SafeLease has hired two entirely capable outside law firms, Yetter Coleman and Stone Hilton, that were ably handling this case for months before Locke filed his March 24 notice of appearance. If Locke is excluded from OCEO materials, SafeLease will still have several qualified and experienced outside counsel with access to these documents. Further, Storable remains willing to consider de-designating certain OCEO documents if SafeLease’s outside law firms determine that Locke needs to review them (see Exh. I at 2), and even if the

-11- parties cannot agree on de-designations, the PO has a procedure for challenging OCEO designations. See PO § 17, Exh. D.

III. The Grounds for the Relief Sought in this Motion Call for Expedited Consideration In this case between competitors, the PO’s OCEO provisions apply to the Parties’ highly sensitive trade secret, financial, and other proprietary information. See id. § 3. Accordingly, under the PO, Storable has a right to be “immediately” informed of “all pertinent facts” relating to any unauthorized disclosure of its OCEO information. Id. § 15. Similarly, wrongful disclosure of trade secret information, even under a protective order, constitutes irreparable harm. See In re Leviton Mfg. Co., Inc., 1 S.W.3d 898, 900 (Tex. App.—Waco 1999, orig. proceeding) (emphasis added). SafeLease has refused to provide the requested information, and Locke has refused to stop viewing Storable’s OCEO documents—either in general or even temporarily to avoid the need Court intervention.

Conclusion Accordingly, Storable respectfully requests that the Court expedite its consideration of this Motion and require SafeLease to disclose which of Storable’s OCEO documents Locke viewed and when; modify the February 27, 2025 PO to exclude Locke from viewing OCEO materials going forward; and grant any other relief to which Storable may justly be entitled.

Respectfully submitted April 4, 2025. /s/ Katherine G. Treistman Katherine G. Treistman State Bar No. 00796632 Andrew D. Bergman State Bar No. 24101507 ARNOLD & PORTER KAYE SCHOLER LLP Louisiana Street, Suite 4000 Houston, Texas 77002–2755 Tel.: (713) 576–2400 Fax: (713) 576–2499 [email protected] [email protected]

-12-

Mikaila Skaroff (admitted pro hac vice) Colorado Bar No. 60688 ARNOLD & PORTER KAYE SCHOLER LLP 1144 Fifteenth St, Suite 3100 Denver, Colorado 80202 Tel.: (303) 863–1000 Fax: (303) 863–2301 [email protected] Ray T. Torgerson State Bar No. 24003067 Neil Kenton Alexander State Bar No. 00996600 Jonna N. Summers State Bar No. 24060649 Elizabeth “Liza” Eoff State Bar No. 24095062 Lakshmi N. Kumar State Bar No. 24144581 PORTER HEDGES LLP 1000 Main Street, 36th Floor Houston, Texas 77002 Tel.: (713) 226–6000 Fax: (713) 226–6000 [email protected] [email protected] [email protected] [email protected] [email protected] Dale Wainwright State Bar No. 00000049 Justin Bernstein State Bar No. 24105462 West 6th Street, Suite 2050 Austin, Texas 78701 Tel.: (512) 320–7240 Fax: (512) 320–7240 [email protected] [email protected] Counsel for Defendants

-13-

Certificate of Conference The Parties conferred multiple times via email, telephone calls, and letters exchanged from March 25, 2025 through April 3, 2025 regarding the relief requested in this Motion. Counsel for Plaintiff indicated that it would not discontinue Mr. Locke’s access to OCEO materials. Counsel for Plaintiff failed to response to repeated requests for the disclosure of information requested in this Motion. On April 3, 2025, counsel for Defendants attempted one final time to confer with Plaintiff’s counsel regarding Plaintiff’s position on the relief requested in this Motion. As of this filing on April 4, 2025, Plaintiff’s counsel has not responded. Due to the exigent nature of the underlying dispute, Defendants have proceeded to file this Motion, despite the lack of response.

Based on Plaintiff’s counsel’s statements in the parties’ meet-and-confer discussions, it is my understanding that Plaintiff is opposed to the relief requested in this Motion. /s/ Katherine G. Treistman Katherine G. Treistman

Certificate of Compliance I hereby certify that this document complies with Local Rule 5(a) and contains 3,783 words, excluding the case caption, any index, table of contents or table of authorities, signature blocks, attached evidence, or any required certificates. /s/ Katherine G. Treistman Katherine G. Treistman

Certificate of Service The undersigned hereby certifies that a true and correct copy of the foregoing was served upon counsel of record in accordance with the Texas Rules of Civil Procedure on April 4, 2025. /s/ Katherine G. Treistman Katherine G. Treistman

-14- Automated Certificate of eService This automated certificate of service was created by the efiling system.

Cathy Hodges on behalf of Katherine Ginzburg Treistman Bar No. 796632 [email protected] Envelope ID: 99322069 Filing Code Description: Motions - All Other Filing Description: Storable's Motion to Modify Protective Order - Require Disclosure and Request for Expedited Consideration Status as of 4/7/2025 9:37 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Ray TTorgerson [email protected] 4/4/2025 8:29:07 PM SENT Delonda Dean [email protected] 4/4/2025 8:29:07 PM SENT Yetter Coleman [email protected] 4/4/2025 8:29:07 PM SENT Carolyn Reed [email protected] 4/4/2025 8:29:07 PM SENT Courtney Smith [email protected] 4/4/2025 8:29:07 PM SENT Melissa Sanchez [email protected] 4/4/2025 8:29:07 PM SENT Edockets Calendaring [email protected] 4/4/2025 8:29:07 PM SENT Andrew Bergman [email protected] 4/4/2025 8:29:07 PM SENT Elizabeth FEoff [email protected] 4/4/2025 8:29:07 PM SENT Katherine G.Treistman [email protected] 4/4/2025 8:29:07 PM SENT Luke A.Schamel [email protected] 4/4/2025 8:29:07 PM SENT Christopher Hilton [email protected] 4/4/2025 8:29:07 PM SENT Judd Stone [email protected] 4/4/2025 8:29:07 PM SENT Alyssa Smith [email protected] 4/4/2025 8:29:07 PM SENT Bonnie Chester [email protected] 4/4/2025 8:29:07 PM SENT Jonna NSummers [email protected] 4/4/2025 8:29:07 PM SENT Lakshmi NKumar [email protected] 4/4/2025 8:29:07 PM SENT R. PaulYetter [email protected] 4/4/2025 8:29:07 PM SENT Susanna R.Allen [email protected] 4/4/2025 8:29:07 PM SENT Justin Bernstein [email protected] 4/4/2025 8:29:07 PM SENT Business Court Division 3A [email protected] 4/4/2025 8:29:07 PM SENT Dolores Brunelle [email protected] 4/4/2025 8:29:07 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

EXHIBIT A

137 1

1 REPORTER'S RECORD 2 VOLUME 3 OF 13 VOLUMES CAUSE NO. 15-25-00020-CV 4 TRIAL COURT CAUSE NO. 25-BC03A-0001 IN THE FIFTEENTH COURT OF APPEALS 5 Sitting at Austin, Texas STORABLE, INC.; REDNOVA LABS, INC. (D/B/A STOREDGE); SITELINK SOFTWARE, LLC; EASY STORAGE SOLUTIONS, LLC; BADER CO.; AND PROPERTY FIRST GROUP, LP 9 V. 10 SAFELEASE INSURANCE SERVICES, LLC -------------------------------------------------------- 12 REPORTER'S RECORD 13 FEBRUARY 11, 2025 -------------------------------------------------------- On the 11th day of February, 2025, the hearing on Discovery Motions and a Temporary Injunction came on to be heard in the above-entitled and -numbered cause; and the following proceedings were had before the Honorable Melissa Andrews, Judge Presiding, held in Austin, Travis County, Texas: 19 Proceedings reported by computerized stenotype machine; Reporter's Record produced by computer-assisted transcription.

KIMBERLY KIDD, DEPUTY COURT REPORTER [email protected] 138 95

1 THE COURT: Thank you very much.

2 If the plaintiff would like to go forward with their first witness.

4 MR. YETTER: Yes. Our first witness is Dr. Williams, as I said earlier; and our colleague, Mr. Schamel, will present his examination.

7 MR. TORGERSON: We would like to invoke the rule as to fact witnesses, and I would like time to rearrange with my co-counsel.

10 THE COURT: Okay.

11 MR. YETTER: I neglected to introduce our CEO, who is our corporate representative. That is Mr. Stein, Steven Stein; and the outside general counsel is Adam Locke, L-O-C-K-E. He is not a witness; but when we get into outside/counsel only, we will ask both of them to be excused. But they're not subject to the rule because one is a lawyer and one is our corporate representative. Thank you.

19 MR. SCHAMEL: Good morning, Your Honor.

20 SafeLease calls Dr. Williams.

21 (Whereupon, the witness was sworn) 22 MR. SCHAMEL: May it please the court.

23 THE COURT: Please proceed.

24 MR. SCHAMEL: Before I get started, we prepared a PowerPoint slide. May I approach and give

KIMBERLY KIDD, DEPUTY COURT REPORTER [email protected] 139 327

1 THE STATE OF TEXAS COUNTY OF HARRIS

4 I, Kimberly Kidd, Deputy Court Reporter in and for the Business Court of Texas, Third Division, Travis County, Texas, do hereby certify that the above and foregoing contains a true and correct transcription of all portions of evidence and other proceedings requested in writing by counsel for the parties to be included in this volume of the Reporter's Record, in the above-styled and numbered cause, all of which occurred in open court or in chambers and were reported by me.

13 I further certify that this Reporter's Record of the proceedings truly and correctly reflects the exhibits, if any, admitted, tendered in an offer of proof or offered into evidence.

17 I further certify that the total cost for te preparation of this Reporter's Record is $2,837.65 and was paid by Defendant.

20 WITNESS my hand this the 12th day of March, 2025.

/s/Kimberly Kidd 23 Kimberly Kidd, Texas CSR No. 2437 Expiration Date: 8/31/26 24 Deputy Court Reporter 1104 Londonderry Avenue 25 Friendswood, Texas 77546 [email protected]

KIMBERLY KIDD, DEPUTY COURT REPORTER [email protected]

EXHIBIT B

1 REPORTER'S RECORD CAUSE NO. D-1-GN-24-010233 SAFELEASE INSURANCE SERVICES, )IN THE DISTRICT COURT OF LLC, ) 4 Plaintiff, ) ) v. ) )TRAVIS COUNTY, TEXAS STORABLE, INC., REDNOVA LABS ) (D/B/A storEDGE), SITELINK ) SOFTWARE, LLC, EASY STORAGE ) SOLUTIONS, LLC, BADER CO., AND) PROPERTY FIRST GROUP, LP, ) Defendants. )345TH JUDICIAL DISTRICT ________________________________________________________ TEMPORARY INJUNCTION HEARING ________________________________________________________ 17 On the 16th day of January, 2025, the following proceedings came on to be held in the above-titled and numbered cause before the Honorable Jessica Mangrum, Judge Presiding, held in Austin, Travis County, Texas.

21 Proceedings reported in computerized machine shorthand by a Texas Certified Shorthand Reporter, Certification Number 7076.

1 P R O C E E D I N G S 2 THURSDAY, JANUARY 16, 2025 3 (9:07 a.m.)

4 THE COURT: All right. Good morning, everyone. Welcome to the 200th District Court. We are here this morning in Cause No. GN-24-010233, SafeLease Insurance Services, LLC versus Storable, Inc., et al.

8 If we could start off with introductions, just let me know you're here and who you're representing.

11 APPEARANCES 12 MR. YETTER: Yes, good morning, Your Honor. Paul Yetter for the Plaintiff, and with me are my colleagues: Susanna Allen, who is with me -- 15 MS. ALLEN: Good morning.

16 THE COURT: Good morning.

17 MR. YETTER: -- at Counsel table. Luke Schamel will be here. Shannon Smith is behind me and my colleague Alyssa Smith and Bronson Parker is our courtroom graphics person.

21 And, Your Honor, our client representatives in the back: Steven Stein; he is -- will be a witness, and he is also the chief executive of the Plaintiff, and the outside General Counsel is Adam Locke, who is next to him.

1 REPORTER'S CERTIFICATE STATE OF TEXAS ) COUNTY OF TRAVIS ) 5 I, Janis Simon, Official Court Reporter in and for the 200th District Court of Travis, State of Texas, do hereby certify that the above and foregoing contains a true and correct transcription of all portions of evidence and other proceedings requested in writing by counsel for the parties to be included in this volume of the Reporter's Record in the above-styled and numbered cause, all of which occurred in open court and were reported by me.

14 I further certify that this Reporter's Record of the proceedings truly and correctly reflects the exhibits, if any, offered by the respective parties.

17 WITNESS MY OFFICIAL HAND this 30th day of January, 2025.

19 /s/ Janis Simon 20 Janis Simon, CSR Texas CSR 7076 21 Expires: 07/31/2026 Official Court Reporter 22 200th District Court Travis County, Texas 23 P.O. Box 1748 Austin, Texas 78767 24 Telephone: (512) 854-9325

EXHIBIT C

01231245ÿ7289 ÿ

Experienced leader will focus on operational efficiencies, risk management, and ongoing compliance to accelerate company growth • Locke has a strong track record of driving efficiencies and managing complex processes at law firms and early-stage companies • His experience as an outside general counsel and corporate attorney brings a new perspective to the Safelease leadership team and positions the company to effectively manage risk AUSTIN,July 20,2022 - SafeLease, the leader in self-storage tenant protection, is pleased to announce the appointment of Adam Locke as the company's Chief Operating Officer. Locke will focus on ensuring the company's strategic business objectives are met by increasing operational capabilities and driving efficiencies across all functional departments.

Locke worked with Safe Lease as an outside advisor prior to joining the company as its COO. During that time, he gained expert knowledge of SafeLease's products, market positioning, and the value the company delivers to its customers.

"SafeLease is excited to bring Adam on board to spearhead new operational initiatives," says Steven Stein, Founder and CEO at SafeLease. "His deep regulatory acumen and

8111 1 ! "# 710 01231245ÿ7289 ÿ cross-functional strengths complement our fast-growing product, sales, and marketing functions."

"SafeLease is well-positioned to redefine risk management solutions for the commercial real estate industry," says Locke. ''The space SafeLease is innovating in is ripe for disruption. With such a talented team and tremendous market opportunity, I was thrilled to join. I look forward to working with my new colleagues to ensure the company reaches its full potential."

Prior to joining SafeLease, Locke owned and ran a boutique law firm where he was outside general counsel to tech startups, commercial real estate firms, and investment managers. Locke also owned and operated an advisory firm focused on legal assets. He has advised on transactions totaling over $200 million.

Locke began his career as a litigator and advisor at corporate law firms and clerked for a federal appellate judge. He earned a law degree from Yale.

Click here to read the press release on Cision PR Newswire.

SELF-STORAGE PRESS RELEASE

4.1 -- ·-

JULY 9, 2024 JULY 12, 2024 JUNE 27, 2024 SafeLease and As seen on ISS: DaVinci Lock Safe Lease Tenant Insurance Announce Launches or a Tenant- Strategic Reputation Protection Plan? Partnership Management Tool Guidance to Help for Self-Storage You Choose the Right Product for Your Self-Storage Business 8111 1 ! "# 210 01231245ÿ7289 ÿ

8111 1 ! "# 010

EXHIBIT D

FILED IN BUSINESS COURT 149 OF TEXAS BEVERLY CRUMLEY, CLERK ENTERED 2/27/2025 The Business Court of Texas, Third Division SAFELEASE INSURANCE § SERVICES LLC, § Plaintiff, § v. § Cause No. 25-BC03A-0001 § STORABLE, INC., et al., § Defendants. § AGREED PROTECTIVE ORDER & TEMPORARY SEALING ORDER The Court enters the following Agreed Protective Order and Temporary Sealing Order (the Agreed Protective Order or Protective Order) as agreed to by the parties, except that the Court has deleted paragraph 24 and modified paragraph 20 to comply with Rule 76a and grant a temporary sealing order.