Contract analysis

I. Preamble. Defendant Stonefield Logistics Group Inc. ("Stonefield" or "Defendant"), by and through its undersigned attorneys, Calderwood & Harkness LLP, hereby requests that Plaintiff Vantor Holdings Corp. ("Vantor" or "Plaintiff"), pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure and the Local Civil Rules of the United States District Court for the Southern District of New York, admit or deny th

II. Definitions. As used in these Requests for Admission, the following terms shall have the meanings set forth below: 1. "TSA" means the Transportation Services Agreement dated March 15, 2019, by and between Stonefield Logistics Group Inc. (in its capacity as "Shipper-Broker") and Vantor Transport Services LLC (in its capacity as "Carrier-Provider"), including all Schedules, Exhibits, Appendices, amendments, modific

III. Instructions. The following instructions apply to each Request for Admission contained herein:

1. Each Request for Admission should be answered separately and fully in writing, under oath, in accordance with the requirements of Rule 36(a) of the Federal Rules of Civil Procedure.

2. If Plaintiff cannot truthfully admit or deny a Request in its entirety, Plaintiff should specify so much of it as is true and qualify or deny the remainder, in accordance with Federal Rule of Civil Procedure 36(a)(4). A denial shall fairly respond to the substance of the matter, and when good faith requires that a party qualify an answer or deny only a part of a matter, the answer shall specify the part admitted a

3. When a Request involves a matter of which Plaintiff lacks knowledge or information sufficient to form a belief as to the truth of the matter, Plaintiff shall so state, but only after Plaintiff has made reasonable inquiry and the information known or readily obtainable by Plaintiff is insufficient to enable Plaintiff to admit or deny the statement. A Plaintiff may not give lack of information or knowledge as a reas

4. Reference to specific TSA sections, schedules, exhibits, and appendices throughout these Requests is for convenience of identification only and is not intended to limit the scope of any Request or to suggest that the referenced provision is the sole or exclusive source of the obligation or fact identified. Plaintiff is requested to review the TSA in its entirety in responding to each Request.

5. These Requests for Admission are continuing in nature pursuant to the Case Management Order entered February 17, 2023 by the Honorable Margaret T. Calloway, United States District Judge. If, after serving responses, Plaintiff obtains or becomes aware of additional information that would change or supplement any response, Plaintiff is obligated to promptly amend or supplement its responses in accordance with Rule 2

6. A matter admitted under Rule 36 is conclusively established unless the Court, on motion, permits the admission to be withdrawn or amended pursuant to Rule 36(b). REQUESTS FOR ADMISSION SECTION A: EXISTENCE AND EXECUTION OF THE TSA Request for Admission No. 1: Admit that on or about March 15, 2019, Stonefield Logistics Group Inc. and Vantor Transport Services LLC entered into the Transportation Services Agreement i