Contract analysis

I. EXECUTIVE SUMMARY The purpose of this report is to provide the case team with a comprehensive overview of the current status of all eDiscovery processing, review, and production activities undertaken in connection with the defense of our client, Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), in the above-captioned action brought by Vantor Holdings Corp. ("Vantor") through its wholly owned subsidiary Vant

II. SCOPE OF COLLECTION AND PRESERVATION A. Litigation Hold Implementation Promptly upon the firm's engagement by Stonefield, a comprehensive litigation hold memorandum was issued on September 2, 2022 by Patrick Gallagher to the following key Stonefield custodians identified as individuals with knowledge of, or possession of documents related to, the matters at issue in this litigation:

1. Tobias Wren — General Counsel, Stonefield Logistics Group Inc.

2. Priya Ramachandran — Chief Financial Officer, Stonefield Logistics Group Inc.

3. Carlos Medina — Senior Vice President, Operations, Stonefield Logistics Group Inc.

4. Janet Kirkwood — Vice President, Carrier Relations, Stonefield Logistics Group Inc.

5. Raymond Hess — Director, Contract Compliance, Stonefield Logistics Group Inc. The litigation hold memorandum instructed each custodian to take immediate steps to preserve all documents and electronically stored information ("ESI") in their possession, custody, or control that are related to any aspect of the Vantor/VTS relationship. Specifically, the hold covered all materials related to the Transportation Service

III. PROCESSING AND CULLING A. Processing by Pinnacle Forensics All collected data was transferred to Pinnacle Forensics LLC via secure encrypted upload to their hosted review environment. Data transfers were completed between September 12 and September 19, 2022, with Pinnacle confirming receipt and chain-of-custody documentation for each transfer batch. Nathan Billings provided written confirmation that all data was

IV. DOCUMENT REVIEW A. Review Methodology The document review was conducted pursuant to a two-pass review protocol established in the Document Review Protocol Memorandum dated March 15, 2023, which was jointly prepared by David Moretti and Patrick Gallagher and approved by Samuel Eklund. The two-pass protocol is designed to ensure both efficiency and thoroughness by separating the initial responsiveness and privilege

V. PRODUCTION SUMMARY A. First Production — Stonefield The first production of documents by Stonefield to Vantor (through CRS) was completed on April 14, 2023. The key details of the production are as follows: The production format was agreed upon with CRS during meet-and-confer discussions and provides documents in both native format (for electronically created documents such as spreadsheets and presentations where

VI. KEY / HOT DOCUMENT SUMMARY During the document review process, a total of 6,842 documents were flagged with "Hot" or "Key" significance designations, indicating that these documents are of particular importance to the substantive defense of the case and require focused attorney analysis. These documents have been organized into the following topic categories: VTS Performance / SLO Failures Documents in this categ

VII. VANTOR PRODUCTION — PRELIMINARY STATUS Pursuant to the Case Management Order entered by Judge Calloway, Vantor is required to make its first document production on or before April 28, 2023. Based on meet-and-confer discussions with CRS and the Vantor production estimates provided in Vantor's initial disclosures, the production is expected to consist of approximately 28,914 documents comprising approximately 112,

VIII. COST SUMMARY AND PROJECTIONS A. eDiscovery Costs Incurred to Date The following table summarizes Pinnacle Forensics costs incurred from the inception of the engagement through the reporting period (September 2022 – April 2023): These Pinnacle Forensics costs are included within the approximately $620,000 in total costs and disbursements tracked for the matter through the reporting period. Internal review costs

IX. OUTSTANDING ITEMS AND ACTION ITEMS The following action items are outstanding as of the date of this report and require attention from the identified responsible parties: With respect to Action Item 7, it should be noted that the current TAR 2.0 recall rate of 91.3% is well within the thresholds accepted by courts in this district and nationally as sufficient for defensible use of technology-assisted review. Comp

X. APPENDICES (REFERENCED) The following appendices are referenced in this report and are maintained as separate attachments to this memorandum: Appendix A — Custodian List and Data Source Inventory. A table listing each of the six primary custodians, the data sources collected from each, the date ranges covered, and the volume statistics (raw data volume, pre-deduplication document counts, and post-deduplication doc