Contract analysis

I. PURPOSE This memorandum summarizes the final disposition of Matter No. 1006-00005, Crestline Packaging Solutions LLC v. Ridgeway Freight Services Inc., Cause No. 342-2021-04871-TX, in the 342nd Judicial District Court of Tarrant County, Texas. The purpose of this memorandum is to provide a comprehensive record of the matter from engagement through resolution, to confirm that all closing actions required under the

II. MATTER SUMMARY The following table presents the key identifying details and background information for Matter No. 1006-00005: The dispute arose from Ridgeway's systematic overbilling of CPS on freight transportation invoices submitted under the parties' MTSA. Over a 26-month period beginning in February 2019 and continuing through March 2021, Ridgeway overcharged CPS a total of $1,847,632.19 through a combination

III. OUTCOME A. Settlement. The matter was resolved through a negotiated settlement reached at a full-day mediation session conducted on November 18, 2021, at the Lone Star Dispute Resolution Center, 300 Throckmorton Street, Suite 1200, Fort Worth, Texas 76102. The mediation was conducted by Judge (Ret.) Constance Farr, a widely respected neutral with extensive experience in complex commercial disputes in the Tarrant

IV. FINANCIAL SUMMARY A. Recovery. The following table summarizes CPS's gross recovery under the Settlement Agreement: For context, the total documented overcharges by Ridgeway during the 26-month overbilling period were $1,847,632.19. The overcharges were categorized as follows based on the forensic analysis conducted by Meridian Forensic Accounting Group LLC: Inflated Per-Mile Rates: $1,104,891.53. This category re

V. HOURS SUMMARY The following table sets forth the hours billed and fees charged by each attorney who worked on the matter, reflecting the 10% courtesy discount applied to all attorney fees: ¹ A minor rounding adjustment was applied at the final invoice level to yield a billed total of $287,437.50 for the matter. Specifically, the Espinoza hours were billed at 243.333 hours at the detail level on the final invoice t

VI. LITIGATION TIMELINE The following is a chronological summary of all key events in the matter, organized by phase: Pre-Engagement Phase. April 15, 2019: The Master Transportation Services Agreement ("MTSA") between CPS and Ridgeway became effective. The MTSA had a three-year term running through April 14, 2022, and governed all freight transportation services provided by Ridgeway for CPS's shipping operations acro

VII. KEY TURNING POINTS The following narrative discussion identifies and analyzes the four pivotal developments that shaped the trajectory and outcome of this matter.

1. Meridian Forensic Report (September 10, 2021) The engagement of Meridian Forensic Accounting Group LLC and the completion of its forensic invoice analysis proved to be a foundational element of CPS's litigation strategy. Nathan Crowley, CPA, CFF, Meridian's engagement partner, led a team that conducted an invoice-by-invoice reconciliation of all 9,843 Ridgeway invoices submitted during the overbilling period again

2. Court's Order on Motion to Compel (October 28, 2021) The Court's order granting CPS's Motion to Compel discovery was a pivotal procedural milestone that broke through the discovery impasse created by Ridgeway's obstructive tactics. From the outset of the discovery phase, Ridgeway had adopted a strategy of stonewalling on the most critical categories of discovery — including its internal rate files, communications

3. Whitford Emails (November 11, 2021) The single most significant development in the entire matter was the production, on November 11, 2021, of internal emails from James Whitford, Ridgeway's Vice President of Pricing & Rate Management. These emails were produced as part of Ridgeway's supplemental document production pursuant to the Court's October 28 order on CPS's Motion to Compel. Their contents were extraordinar

4. Mediation (November 18, 2021) The full-day mediation on November 18, 2021, at the Lone Star Dispute Resolution Center in Fort Worth, Texas, represented the culmination of the engagement team's strategic efforts throughout the matter. With the Whitford emails in hand, CPS entered mediation in a position of overwhelming strength. CPS's opening mediation demand was $2,097,632.19, consisting of the full overcharge amo

VIII. OPEN ITEMS The following items remain open or require continued monitoring following the closing of this matter:

1. Second Installment ($575,000.00) The second and final installment of $575,000.00 under the Settlement Agreement is due by March 3, 2022, which is ninety (90) days from the December 3, 2021 execution date of the Settlement Agreement. A calendar reminder has been set for February 15, 2022 — approximately two weeks prior to the due date — to prompt a status check on receipt of the payment. If the second installment i

2. Final Invoice Calderwood & Harkness's final invoice for this matter is Invoice No. SC-0487-F, dated December 15, 2021, in the amount of $18,647.25. The invoice has been transmitted to Harold Inman at CPS. The remaining balance of CPS's evergreen retainer, in the amount of $12,382.50, will be applied against this invoice, leaving a remaining balance due of $6,264.75. This remaining balance is due net 30 from the da

3. File Retention Pursuant to the Firm's document retention policy, the matter file for 1006-00005 will be maintained for seven (7) years from the date of closing. The retention period therefore extends through December 17, 2028. All electronic files, including correspondence, pleadings, discovery materials, work product memoranda, the Meridian forensic report, the Settlement Agreement and Mutual Release, the Agreed

IX. CLIENT RELATIONSHIP This matter represented Calderwood & Harkness's inaugural engagement for Crestline Packaging Solutions LLC, and it has established an excellent foundation for a long-term client relationship. The engagement was referred to the Firm by Gerald Fleischmann, Managing Partner of Pinnacle Ridge Capital Partners LP, CPS's private equity sponsor. Pinnacle Ridge Capital Partners LP is headquartered at

X. CONCLUSION Matter No. 1006-00005, Crestline Packaging Solutions LLC v. Ridgeway Freight Services Inc., Cause No. 342-2021-04871-TX, is hereby closed with a status designation of closed_completed as of December 17, 2021. All substantive deliverables associated with the matter have been completed. The Agreed Order of Dismissal with Prejudice has been entered by the 342nd Judicial District Court of Tarrant County, Te