Contract analysis

I. Deficiencies in Vantor's Interrogatory Responses A. Interrogatory No. 9 — Fleet Redeployment Decisions Stonefield's Interrogatory No. 9 asked Vantor to identify and describe in detail all decisions made by Vantor Transport Services LLC ("VTS") — Vantor's wholly owned subsidiary and the operating entity under the relevant contract — to reassign, redeploy, or otherwise reduce the number of tractors and trailers dedi

II. Deficiencies in Vantor's Document Production A. Failure to Produce Fleet Redeployment Records Stonefield's First Request for Production, specifically Request Nos. 8, 12, and 15, sought documents relating to VTS's fleet management practices, equipment allocation processes, and any reassignment of tractors or trailers from Stonefield-dedicated service during the period from April 1, 2021 through March 4, 2022. Thes

III. Demand for Compliance In light of the foregoing, Stonefield makes the following specific demands: First, Stonefield demands that Vantor provide complete, verified, supplemental responses to Interrogatories Nos. 9, 14, and 18 — addressing all of the deficiencies identified in Section I of this letter — within fourteen (14) calendar days of this letter, i.e., by June 13, 2023. Second, Stonefield demands that Vanto

IV. Reservation of Rights and Notice of Intent to Seek Court Intervention This letter constitutes a good-faith effort to meet and confer regarding the discovery deficiencies identified herein, as required by Federal Rule of Civil Procedure 37(a)(1) and Local Civil Rule 37.2 of the Southern District of New York. We take seriously our obligation to attempt to resolve discovery disputes without burdening the Court, and