Contract analysis

I. DEFINITIONS As used in these Requests for Production, the following terms shall have the meanings set forth below: 1. "You," "Your," and "Plaintiff" shall mean Marcus Delano, individually and in any representative capacity asserted in this action, and any person acting or purporting to act on his behalf, including but not limited to his attorneys, agents, representatives, accountants, tax preparers, financial advi

1. Scope. These Requests seek documents within Plaintiff's possession, custody, or control. A document is within Plaintiff's "possession, custody, or control" if Plaintiff has the legal right or practical ability to obtain the document from any source, including but not limited to documents held by Plaintiff's agents, attorneys (to the extent not protected by attorney-client privilege or work-product doctrine), accou

2. Time Period. Unless otherwise specified in a particular Request, each Request covers the Relevant Period, which is defined as April 30, 2022 through the present date. Where a specific Request designates a different time period, the time period expressly stated in that Request shall govern.

3. Production Format. Documents shall be produced in the format specified in the parties' Joint Rule 26(f) Report filed on June 16, 2025, and in accordance with the ESI protocol agreed upon therein. To the extent no specific protocol applies to a particular category of documents, such documents shall be produced in their native format. If any responsive document was created or is maintained in electronic form, it sha

4. Privilege Log. To the extent Plaintiff withholds any responsive document, or any portion thereof, on the basis of any claim of attorney-client privilege, work-product protection, or any other privilege or immunity from discovery, Plaintiff shall produce a privilege log in accordance with Federal Rule of Civil Procedure 26(b)(5)(A) and the Court's Scheduling Order entered June 20, 2025. The privilege log shall iden

5. Continuing Obligation. Plaintiff's obligation to respond to these Requests is a continuing one pursuant to Federal Rule of Civil Procedure 26(e). If, after producing documents in response to these Requests, Plaintiff obtains, discovers, or creates additional documents responsive to any Request, Plaintiff shall promptly supplement its production with such additional documents.

6. Organization. Documents shall be produced as they are kept in the ordinary course of business, or shall be organized and labeled to correspond with each specific Request to which they are responsive, in accordance with Federal Rule of Civil Procedure 34(b)(2)(E).

7. Identification of Sources. For each document produced, Plaintiff shall identify the Request or Requests to which the document is responsive. Where a document is responsive to more than one Request, it need only be produced once, but Plaintiff shall indicate all Requests to which the document relates.

8. Objections. If Plaintiff objects to any Request, in whole or in part, Plaintiff shall state the objection with specificity and shall produce all responsive documents as to which no objection is made. An objection to any part of a Request shall not be deemed a basis for failing to respond to the remainder of the Request.

9. No Documents. If Plaintiff has no documents responsive to a particular Request, Plaintiff shall so state in writing, confirming that a diligent search has been conducted and that no responsive documents exist or are within Plaintiff's possession, custody, or control.

III. REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1 — Independent Contractor Operating Agreements All copies of any Independent Contractor Operating Agreement ("ICOA"), including any version (v1.0, v2.0, v3.0), amendment, addendum, side letter, exhibit, attachment, rider, or modification, between Plaintiff and Stonefield Logistics Group Inc., for the period from March 2021 (when Plaintiff first began performing