Contract analysis

1. Defendant objects to each Request to the extent it seeks information or the admission of facts that are protected by the attorney-client privilege, the work product doctrine, the joint defense or common interest privilege, or any other applicable privilege, protection, or immunity from disclosure recognized under federal or state law. No response herein is intended to, nor shall it be deemed to, waive any such pri

2. Defendant objects to each Request to the extent it is vague, ambiguous, overly broad, or utilizes undefined terms or phrases in a manner that renders the Request susceptible to multiple reasonable interpretations, thereby precluding Defendant from providing an unqualified admission or denial. To the extent Defendant responds to any such Request, Defendant does so based upon its own reasonable interpretation of the

3. Defendant objects to each Request to the extent it calls for a legal conclusion or seeks the admission of a mixed question of law and fact, rather than a straightforward factual admission. Requests for Admission under Rule 36 are properly limited to factual matters and the application of law to fact; they are not a proper vehicle for obtaining legal conclusions or concessions on contested legal issues.

4. Defendant objects to each Request to the extent it is compound, contains multiple embedded sub-parts, or seeks admission of multiple discrete factual propositions in a single Request. To the extent Defendant responds to any such compound Request, Defendant does so by addressing each identifiable factual proposition separately, and an admission of one factual component shall not be construed as an admission of any

5. Defendant objects to each Request to the extent it mischaracterizes documents, testimony, prior discovery responses, or facts, or to the extent it contains assumptions of fact not established in the record. By responding to any such Request, Defendant does not concede the accuracy of any characterization or assumption embedded therein.

6. Defendant objects to each Request to the extent it seeks admissions regarding the subjective intent, knowledge, motivation, or state of mind of any person or entity, as such matters are not properly the subject of requests for admission and are more appropriately addressed through deposition testimony, interrogatory responses, or trial testimony.

7. Defendant reserves and does not waive any and all objections, claims, affirmative defenses, and counterclaims set forth in its Answer, Affirmative Defenses, and Counterclaim filed on January 13, 2023 (ECF No. 18). Nothing in these responses shall be construed as a waiver, abandonment, or modification of any position taken therein.

8. Subject to and without waiver of these General Objections, and incorporating each such objection as if fully set forth in each individual response below, Defendant responds to the individual Requests for Admission as follows: RESPONSES TO INDIVIDUAL REQUESTS FOR ADMISSION REQUEST FOR ADMISSION NO. 1 Request: Admit that on March 15, 2019, Stonefield Logistics Group Inc. and Vantor Transport Services LLC executed a