Contract analysis

I. DEFINITIONS As used in this Second Request for Production of Documents, the following terms shall have the meanings set forth below. These definitions are intended to be read broadly and in a manner consistent with the Federal Rules of Civil Procedure: 1. "Agreement" or "TSA" shall mean the Transportation Services Agreement dated March 15, 2019 (Contract Ref. No. SLG-VTS-2019-0315) between Stonefield Logistics Gro

II. INSTRUCTIONS The following instructions apply to each Request for Production set forth herein:

1. Time for Response. Vantor shall respond to these Requests within thirty (30) days of service, or such other time as may be agreed by the parties in writing or ordered by the Court, in accordance with Federal Rule of Civil Procedure 34(b)(2). Responses must state, with respect to each individual Request, whether Documents will be produced, whether the Request is objected to (and the specific basis for each objectio

2. Scope of Production. These Requests are directed to Vantor Holdings Corp. and Vantor Transport Services LLC, jointly and severally. To the extent any responsive Documents are in the possession, custody, or control of VTS or any other subsidiary, affiliate, division, or agent of Vantor—including, without limitation, any third-party technology vendor, fleet management service provider, document storage provider, or

3. Production Format. Documents shall be produced in the format specified in the Case Management Order dated February 17, 2023 (Dkt. No. 34), and in accordance with the ESI Protocol agreed upon by the parties and filed with the Court on March 1, 2023 (Dkt. No. 39). In particular: (a) All Documents other than structured data shall be produced as single-page TIFFs with searchable text (OCR or extracted text), accompani

4. Privilege Log. If any Document responsive to these Requests is withheld in whole or in part on the basis of any privilege, immunity, or other protection from disclosure—including but not limited to attorney-client privilege, work-product protection, or any other applicable privilege—Vantor shall provide a privilege log entry for each such Document in compliance with Federal Rule of Civil Procedure 26(b)(5)(A) and

5. Continuing Obligation. These Requests are continuing in nature pursuant to Federal Rule of Civil Procedure 26(e). If, after serving its initial response, Vantor discovers or obtains additional responsive Documents, or if Vantor's prior responses are or become materially incomplete or inaccurate, Vantor shall promptly supplement its production and amend its responses as necessary.

6. Relationship to Prior Requests. These Requests supplement and are in addition to Defendant Stonefield's First Request for Production of Documents, which was served on March 6, 2023 (the "First Request"). Vantor is not excused from responding to any Request herein on the ground that responsive Documents may overlap with Documents requested in the First Request, unless such Documents have already been produced and a

7. Organization of Production. Documents shall be produced as they are kept in the usual course of business, or organized and labeled to correspond to each Request to which they are responsive, in accordance with Federal Rule of Civil Procedure 34(b)(2)(E).

8. Construction. Each Request shall be construed broadly and liberally so as to encompass the maximum amount of information and Documents permissible under the Federal Rules of Civil Procedure. The singular shall include the plural and vice versa. The terms "and" and "or" shall be construed conjunctively and disjunctively as necessary to make each Request inclusive rather than exclusive. The use of the present tense

III. REQUESTS FOR PRODUCTION REQUEST NO. 1 All Documents relating to any decision, plan, analysis, proposal, evaluation, consideration, or recommendation by VTS, Vantor, or any of their officers, directors, managers, or employees to reassign, redeploy, remove, redirect, divert, or otherwise reduce tractor or trailer units from the SLG Dedicated Fleet or SLG Dedicated Lanes during the period from July 1, 2021 through

IV. RESERVATION OF RIGHTS Stonefield Logistics Group Inc. expressly reserves the right to serve additional requests for production of documents, interrogatories, requests for admission, deposition notices, subpoenas, and other discovery as may be necessary and appropriate in this action, consistent with the Federal Rules of Civil Procedure, the Court's Case Management Order, and any applicable scheduling orders or di