Contract analysis

1. Definition of "AHT." As used in this letter, the term "AHT" refers collectively to Arbor Health Technologies Inc. (EIN: 84-3291057; NPI: 1497253810), all Arbor Health Clinic locations, and any subsidiaries, affiliates, joint ventures, or other entities in which AHT holds a direct or indirect ownership interest or over which AHT exercises management or operational control. This definition includes, without limitati

2. Relevant Time Period. Unless otherwise specified with respect to a particular category or request, the relevant time period for this document request is January 1, 2019 through the present date (February 3, 2023). Where a request specifies a different time period, that specification controls.

3. Production Format. We request that all documents be produced in native electronic format where possible (e.g., Microsoft Word, Excel, or PDF files in their native format). Email communications should be produced in their native format with all attachments and metadata intact. Where documents exist only in hard copy, they should be scanned as searchable PDF files and produced electronically.

4. Custodian Identification. For each category of documents produced, we request that AHT identify the custodian or custodians from whom the documents were collected, including the custodian's name, title, and the physical or electronic location from which the documents were retrieved.

5. Documents Previously Shared with Westbrook Hale LLP. Documents previously shared with Westbrook Hale LLP (Elena Marchetti, Partner) in connection with the acquisition of Lakeview Medical Associates, P.C. or other corporate matters should be included in AHT's production unless subject to a separate privilege determination. To the extent that AHT determines that any such documents are subject to a privilege held by

6. Coordination with Halsted Accounting Group LLP. We request that AHT coordinate production with Halsted Accounting Group LLP (Ronald Desmond, Engagement Partner; 225 Dyer Street, Suite 800, Providence, RI 02903) to the extent that financial data, audit workpapers, management letters, or other materials in Halsted's possession are responsive to this request. Where Halsted holds documents relevant to our review, we r

7. Privilege Log. For any documents withheld from production on the basis of the attorney-client privilege, the work product doctrine, or any other applicable privilege or protection, AHT should prepare and produce a privilege log that identifies each withheld document by: (a) date; (b) author; (c) all recipients; (d) general subject matter description (to the extent possible without disclosing privileged content); a