Contract analysis

I. Introduction and Purpose We write on behalf of our client, defendant Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), to accompany Stonefield's first production of documents in the above-captioned matter. This production is made pursuant to Plaintiff Vantor Holdings Corp.'s ("Vantor" or "Plaintiff") First Request for Production of Documents, which was served on Stonefield on March 20, 2023, as well as in c

II. Description of Production In connection with this first production, Stonefield is producing a total of 42,387 documents, comprising approximately 186,000 pages of responsive material. The documents included in this production are Bates-stamped SLG-000001 through SLG-042387, with each document bearing a unique Bates number in consecutive order throughout the production. This production is made on behalf of defenda

III. Manner and Form of Production The documents comprising this production are being produced electronically via the hosted review platform operated by Pinnacle Forensics LLC, an electronic discovery and litigation support vendor retained by Stonefield in connection with this matter. The production has been designated as Project ID: PF-SLG-2022-0914 within the Pinnacle Forensics platform. Access credentials for the

IV. Bates Range Index An index of the Bates-stamped documents, organized by custodian and/or document source, is attached hereto as Exhibit A to this letter. The Bates Range Index provides a comprehensive breakdown of the documents included in this production, identifying the Bates range, custodian or source, and general document category for each subset of the production, thereby facilitating your review and organiz

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

2. Raymond Hess, Director, Contract Compliance, Stonefield Logistics Group Inc.

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

4. Tobias Wren, General Counsel, Stonefield Logistics Group Inc.

5. Priya Ramachandran, Chief Financial Officer, Stonefield Logistics Group Inc.

6. Marcus Denton, Chief Executive Officer, Stonefield Logistics Group Inc. In addition to the individual custodial files identified above, this production includes documents sourced from Stonefield's shared drives and document management systems, including materials related to the Vantor/VTS business relationship, the Transportation Services Agreement (Contract Ref. No. SLG-VTS-2019-0315), and the events surrounding

V. Privilege Log Concurrently with this document production, Stonefield is serving its Privilege Log, which identifies a total of 1,247 documents that have been withheld from production on the basis of the attorney-client privilege and/or the work product doctrine. The Privilege Log is attached hereto as Exhibit B to this letter. Each entry on the Privilege Log includes the following information, consistent with the

VI. Reservation of Rights and General Objections This production is made subject to, and without waiver of, any and all general or specific objections set forth in Stonefield's Responses and Objections to Plaintiff's First Request for Production of Documents, which are being served concurrently herewith on April 14, 2023. Stonefield's Responses and Objections should be read in conjunction with this letter and the acc

VII. Confidentiality Certain documents included in this production contain proprietary, commercially sensitive, or confidential business information of Stonefield Logistics Group Inc. and/or its affiliates, including Ridgeline Capital Partners, LP, Stonefield's majority equity holder. Such materials may include, without limitation, internal financial data, pricing structures, customer lists, vendor agreements, strate

VIII. List of Exhibits Accompanying This Letter The following exhibits are attached to and accompany this letter: Exhibit A: Bates Range Index for Stonefield Logistics Group Inc.'s First Production of Documents (SLG-000001 through SLG-042387), organized by custodian and/or document source, with corresponding Bates ranges and general document category descriptions. Exhibit B: Privilege Log for Stonefield Logistics Gro

IX. Contact Information Please direct any questions regarding the substance or scope of this production, the accompanying Responses and Objections, or the Privilege Log to the undersigned at the address below or by email at pgallagher@calderwoodharkness.com, or to David Moretti, Litigation Support and eDiscovery Manager, at Calderwood & Harkness LLP, 200 Park Avenue, 38th Floor, New York, New York 10166 (email: dmore