Contract analysis

I. PRELIMINARY STATEMENT Plaintiff Meridian Consumer Brands LLC ("MCB"), by and through its attorneys Calderwood & Harkness LLP, hereby propounds this First Set of Requests for Production of Documents (Nos. 1–30) upon Defendant Brindoval Home Goods Inc. ("Brindoval") and requests that Brindoval produce the documents and things described below in accordance with Rules 26 and 34 of the Federal Rules of Civil Procedure

II. DEFINITIONS As used in these Requests for Production, the following terms shall have the meanings set forth below. These definitions are to be read in addition to, and not in derogation of, the definitions contained in the Federal Rules of Civil Procedure: 1. "You," "Your," "Defendant," or "Brindoval" means Brindoval Home Goods Inc., a Delaware corporation with its principal place of business in Minneapolis, Minn

III. INSTRUCTIONS The following instructions apply to each Request for Production set forth below:

1. Time Period. Unless otherwise specified in a particular Request, these Requests cover the Relevant Period from January 1, 2020 through the date of production.

2. Scope of Production. Brindoval shall produce all responsive Documents in its possession, custody, or control, regardless of the physical location of such Documents. The phrase "possession, custody, or control" shall be construed broadly and includes Documents held by Brindoval's officers, directors, employees, agents, attorneys (to the extent not protected by a valid claim of privilege), consultants, accountants,

3. Format of Production. Documents shall be produced in their native electronic format or as searchable image files (TIFF or PDF) with associated metadata intact and Bates-numbered load files, in accordance with the parties' ESI protocol dated December 19, 2022, or any applicable order of the Court. Native files shall be produced for spreadsheets, databases, and other documents for which native format is necessary to

4. Privilege Log. If any Document responsive to these Requests is withheld in whole or in part, or redacted, on the basis of any claim of privilege, including attorney-client privilege, work-product doctrine, or any other applicable privilege or immunity, Brindoval shall provide a privilege log in accordance with Rule 26(b)(5) of the Federal Rules of Civil Procedure and Local Civil Rule 26.2 of the Southern District

5. Organization of Production. Documents shall be produced either (a) as they are kept in the ordinary course of business, including identification of the custodian from whose files the documents were collected, or (b) organized and labeled to correspond to the categories in each numbered Request.

6. Continuing Obligation to Supplement. These Requests impose a continuing obligation to supplement Brindoval's production pursuant to Rule 26(e) of the Federal Rules of Civil Procedure. If, after making its initial production, Brindoval becomes aware of additional responsive Documents, Brindoval shall promptly produce such Documents and notify MCB's counsel in writing.

7. Objections. If Brindoval objects to any Request, in whole or in part, Brindoval shall state the specific grounds for the objection with particularity and, notwithstanding the objection, shall produce all responsive Documents as to which no objection is asserted, or as to which the objection does not apply. No general, boilerplate, or non-specific objection shall be deemed to excuse a complete failure to respond to

8. Construction. The use of the singular form of any word includes the plural, and vice versa. The use of the masculine, feminine, or neuter gender includes all genders. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of each Request all responses that might otherwise be construed to be outside its scope. The use of "including" or "include

IV. REQUESTS FOR PRODUCTION REQUEST NO. 1 Adoption and Selection of the MERIDIAN FRESH Mark All Documents relating to the conception, creation, selection, evaluation, clearance, or adoption of the mark MERIDIAN FRESH for use on household cleaning products or any other goods, including but not limited to: brainstorming notes; naming proposals; brand name candidate lists; naming evaluation criteria and scoring matrices