Contract analysis

I. EXECUTIVE SUMMARY May 2023 was one of the most consequential months in this litigation to date. Both parties' initial document productions are now complete: Stonefield produced 42,387 documents (approximately 186,000 pages) on April 14, 2023, and Vantor produced 28,914 documents (approximately 112,000 pages) on April 28, 2023. Our team has been actively engaged in reviewing and analyzing Vantor's production throug

II. DOCKET ACTIVITY AND COURT PROCEEDINGS No court hearings, conferences, or oral arguments took place during the reporting period of May 2023. No orders were entered by the Court during this period. The next anticipated court interaction relates to the pending discovery dispute concerning Stonefield's Second Request for Production of Documents. As discussed in greater detail in Section VI below, if Vantor fails to r

III. DOCUMENT PRODUCTIONS — STATUS A. Stonefield's Production (Complete) Stonefield's First Production was served on April 14, 2023 via the Pinnacle Forensics LLC electronic review and production platform (Project ID: PF-SLG-2022-0914). The production consisted of 42,387 documents encompassing approximately 186,000 pages of material, bearing Bates numbers SLG-000001 through SLG-042387. The production was made in resp

IV. KEY DOCUMENTS IDENTIFIED IN VANTOR'S PRODUCTION A. Milescu-to-Vantorovich Email (VHC-008417) — November 12, 2021 This is the single most significant document identified to date in this litigation. The document is an internal email from Sandra Milescu, Chief Operating Officer of Vantor Transportation Solutions ("VTS"), to Nikolai Vantorovich, Chief Executive Officer of Vantor Holdings Corp., dated November 12, 202

V. DISCOVERY DISPUTE — STONEFIELD'S SECOND REQUEST FOR PRODUCTION A. Background On May 5, 2023, Stonefield served its Second Request for Production of Documents on Vantor, consisting of 12 targeted requests. The requests are narrowly focused on the categories of documents identified as missing or incomplete in Vantor's First Production. Specifically, the Second RFP seeks the following categories of documents: • Reque

VI. EXPERT REPORTS — PLAINTIFF'S DAMAGES EXPERT A. Dr. Philip Trask — Trask Greystone & Associates On May 15, 2023, Vantor served the expert report of Dr. Philip Trask of Trask Greystone & Associates (400 Madison Avenue, Suite 900, New York, NY 10017). Dr. Trask has been retained by Vantor to opine on the quantum of damages allegedly suffered by Vantor as a result of Stonefield's termination of the TSA. Dr. Trask's r

VII. REBUTTAL EXPERT — KENSINGTON ANALYTICS GROUP LLC Kensington Analytics Group LLC ("KAG"), located at 1700 Market Street, Suite 2800, Philadelphia, PA 19103, was retained in October 2022 pursuant to an engagement letter from Samuel Eklund to Dr. Evelyn Rosser, KAG's Managing Director and lead expert on this engagement. Dr. Rosser, an economist with over 25 years of experience in transportation industry litigation

VIII. DEPOSITION SCHEDULING Depositions of key fact witnesses on both sides are being scheduled for July and August 2023. We are coordinating scheduling with CRS through an exchange of availability dates and expect to finalize the deposition calendar in June 2023. The anticipated deposition schedule is as follows: Stonefield Witness Preparation. For each Stonefield witness to be deposed by CRS (Kirkwood and Hess), we

IX. THIRD-PARTY SUBPOENAS We are preparing subpoenas duces tecum to the following third-party carriers: Cascade Freight Systems Inc. 4700 Lakehurst Court Columbus, Ohio 43016 Briarwood Trucking Co. 1280 Jefferson Davis Highway, Suite 310 Arlington, Virginia 22202 The purpose of these subpoenas is to obtain contracts, rate confirmations, load tenders, and communications between these carriers and Stonefield for Lanes

X. LENDER AND INSURANCE UPDATES A. Lender Notification As you are aware, Stonefield's $425 million Senior Secured Credit Facility with Lakeshore National Bank (as Administrative Agent) (Ref. LNB-SLG-2017-CA-4402) requires quarterly litigation updates for matters in which the claimed amount exceeds $25 million. The Q2 2023 quarterly update is currently being prepared and is scheduled for submission in July 2023. There

XI. BUDGET AND FEES A. May 2023 Activity Significant activity occurred during May 2023 across multiple workstreams, including document review and analysis of Vantor's production, expert report analysis and preparation of rebuttal strategy, discovery dispute preparation and meet-and-confer correspondence, and deposition scheduling and initial preparation. Detailed time entries for the May 2023 billing period will be p

XII. UPCOMING KEY DATES AND ACTION ITEMS The following table summarizes the key dates and action items for the upcoming period: We will track these items closely and report on progress in next month's status report.

XIII. OVERALL ASSESSMENT AND RECOMMENDATION Stonefield's litigation position has materially strengthened during the month of May 2023. The two most significant developments — the identification of the Milescu email (VHC-008417) and the preliminary analysis of the weaknesses in the Trask expert report — have substantially improved Stonefield's posture on both liability and damages. Liability Assessment. The Milescu em

XIV. CLOSING This report was prepared by Patrick Gallagher, Lead Associate, Calderwood & Harkness LLP, with contributions from Simone Laroche, Senior Associate, and Kara Nystrom, Associate, under the supervision of Samuel Eklund, Responsible Partner. Should you have any questions regarding this report or wish to discuss any of the matters addressed herein, please do not hesitate to contact the undersigned at your con