Contract analysis

I. IDENTIFICATION OF RECIPIENT TO: Briarwood Trucking Co. A corporation organized and existing under the laws of the Commonwealth of Virginia 1280 Jefferson Davis Highway, Suite 310 Arlington, VA 22202 Attention: Custodian of Records / General Counsel

II. COMMAND You are hereby commanded, pursuant to Federal Rule of Civil Procedure 45, to produce and permit inspection and copying of the documents, electronically stored information, and tangible things described in Schedule A attached hereto and incorporated herein by reference. Production shall be made at the time and place set forth below: Place of Production: Calderwood & Harkness LLP 200 Park Avenue, 38th Floor

III. IDENTIFICATION OF ISSUING PARTY AND COUNSEL Issuing Party: Defendant Stonefield Logistics Group Inc. Counsel for Defendant: Calderwood & Harkness LLP 200 Park Avenue, 38th Floor New York, NY 10166 Responsible Partner: Samuel Eklund Lead Associate: Patrick Gallagher Contact Attorney: Simone Laroche, Associate Telephone: (212) 558-4000 Facsimile: (212) 558-4001 Email: simone.laroche@calderwoodharkness.com All comm

IV. CASE BACKGROUND This subpoena is issued in connection with the above-captioned civil action currently pending before the Honorable Margaret T. Calloway, United States District Judge, in the United States District Court for the Southern District of New York. The action arises out of a Transportation Services Agreement dated March 15, 2019 (Contract Reference No. SLG-VTS-2019-0315) (the "TSA"), entered into between

V. DEFINITIONS A. Defined Terms For purposes of this subpoena and the requests set forth in Schedule A, the following definitions shall apply: 1. "Briarwood" means Briarwood Trucking Co. and any of its subsidiaries, affiliates, divisions, predecessors, successors, officers, directors, employees, agents, and representatives, whether acting in an individual or representative capacity. 2. "Stonefield" or "SLG" means Sto

1. The terms "and" and "or" shall be construed conjunctively or disjunctively as necessary to make the applicable request inclusive rather than exclusive.

2. The term "including" means "including but not limited to" and shall not be construed to limit the scope of any request to the specific items or categories enumerated.

3. The terms "any" and "all" shall each mean "each and every."

4. The use of the singular form of any word includes the plural and vice versa.

5. The term "Communication" includes every manner or means of disclosure, transfer, or exchange of information, whether oral, written, or electronic, as further defined above.

6. The terms "relating to" or "concerning" mean referring to, describing, evidencing, constituting, reflecting, mentioning, pertaining to, or being in any way logically or factually connected with the subject matter referenced in the applicable request.

7. The term "person" includes any natural person, corporation, partnership, limited liability company, association, joint venture, governmental entity, or any other legal entity.

8. The term "identify," when used with respect to a natural person, means to provide the person's full name, last known address, telephone number, job title, and employer. When used with respect to a document, "identify" means to provide the document's date, author, type, subject matter, and current location or custodian.

VI. INSTRUCTIONS A. General Instructions

1. Documents responsive to the requests set forth in Schedule A shall be produced as they are kept in the ordinary course of business, or they shall be organized and labeled to correspond to the categories set forth in each numbered request.

2. If any document responsive to any request is withheld in whole or in part on the basis of any claim of privilege, protection, or immunity from disclosure — including but not limited to attorney-client privilege, work product protection, or any other applicable privilege — Briarwood shall provide a privilege log in accordance with Federal Rule of Civil Procedure 45(e)(2)(A). The privilege log shall identify each do

3. If any document responsive to any request has been lost, destroyed, discarded, deleted, or is otherwise no longer in Briarwood's possession, custody, or control, Briarwood shall identify such document with as much specificity as reasonably possible and shall state: (a) the nature and subject matter of the document; (b) the date or approximate date of the document; (c) the identity of the author(s) and recipient(s)

4. Briarwood shall produce all non-identical copies of responsive documents, including drafts, preliminary versions, annotated copies, and any versions bearing handwritten notes, comments, marginalia, or other markings.

5. Documents shall not be separated from their attachments, appendices, or enclosures. Where a document consists of multiple pages or components (including cover letters with enclosures, emails with attachments, or reports with exhibits), all such pages and components shall be produced together as a single document unit.

6. Staples, clips, or bindings should be removed only if necessary for scanning purposes. The original unitization and organization of documents shall be preserved to the greatest extent practicable.

7. If any request is deemed ambiguous, Briarwood shall construe the request in a reasonable manner and shall produce documents responsive to such reasonable construction, noting any assumed interpretation. B. ESI Instructions

1. Electronically stored information shall be produced in single-page TIFF image format (300 DPI, Group IV compression) accompanied by extracted or OCR text files and load files compatible with standard litigation review platforms (including but not limited to Relativity, Ashgrove Technologies, or equivalent). Load files shall include a DAT file with standard delimiters and an OPT or Harborline Services Inc. cross-re

2. Notwithstanding the foregoing, spreadsheets (including Microsoft Excel files and .csv files) and databases shall be produced in their native format, preserving all formulas, hidden columns, tabs, and embedded data.

3. The following metadata fields shall be preserved and produced for all ESI: (a) Custodian; (b) Author; (c) Date Created; (d) Date Last Modified; (e) Date Sent; (f) Date Received; (g) Sender (From); (h) Recipient(s) (To); (i) CC; (j) BCC; (k) Subject Line; (l) File Name; (m) Original File Path; (n) File Type / Extension; and (o) MD5 or SHA-1 Hash Value.

4. Email attachments shall be produced as separate documents linked to their parent email messages via unique document identifiers (e.g., Bates-prefix parent-child relationships or ATTACHMENTBEGDOC / ATTACHMENTENDDOC fields in the load file).

5. De-duplication may be performed on an exact-duplicate basis only (based on MD5 or SHA-1 hash values) across custodians, provided that the custodian field for each de-duplicated document identifies all custodians from whose files the document was collected. C. Cooperation and Rights Under Fed. R. Civ. P. 45

1. Pursuant to Federal Rule of Civil Procedure 45(d)(2)(B), if Briarwood has any objection to the inspection or production of documents commanded by this subpoena, such objection must be served in writing on Defendant's counsel at the address set forth in Section III above within fourteen (14) days after service of this subpoena, or before the time specified for compliance, whichever is earlier. The objection shall s

2. Briarwood is encouraged to contact Simone Laroche at Calderwood & Harkness LLP at the address, telephone number, and email address set forth in Section III above to discuss the scope of this subpoena, negotiate the terms of a reasonable production schedule, address any concerns regarding the burden or cost of compliance, or resolve any objections informally and cooperatively, consistent with the obligations of the

3. Briarwood is advised that, pursuant to Federal Rule of Civil Procedure 45(d)(3), it may file a motion to quash or modify this subpoena in the United States District Court for the Eastern District of Virginia (as the court for the district where compliance is required if production occurs at Briarwood's offices in Arlington, Virginia) or in this Court, on the grounds set forth in Rule 45(d)(3)(A) or (B).

VII. SCHEDULE A — DOCUMENTS AND CATEGORIES REQUESTED Request No. 1 All contracts, agreements, master service agreements, carrier agreements, transportation agreements, broker-carrier agreements, rate confirmations, amendments, supplements, addenda, side letters, and any other related documents between Briarwood and Stonefield, entered into, effective, or in force at any time during the Relevant Period, including but

VIII. COMPLIANCE AND RETURN OF SERVICE INFORMATION This subpoena is served pursuant to Federal Rule of Civil Procedure 45(b). The manner and proof of service shall be documented as follows: Prior notice of this subpoena has been served on all parties to this action, as required by Federal Rule of Civil Procedure 45(a)(4), including counsel for Plaintiff Vantor Holdings Corp.: Caldwell Royce & Shapiro LLP 1 Liberty Pl

IX. DUTIES IN RESPONDING TO SUBPOENA — FED. R. CIV. P. 45(d) & (e) NOTICE Briarwood Trucking Co. is advised of the following obligations and rights under Federal Rule of Civil Procedure 45:

1. Duty to Avoid Undue Burden. A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The Court may impose an appropriate sanction — including lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply with this duty. Fed. R. Civ. P. 45(d)(1).

2. Objections. A person commanded to produce documents may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing, or sampling any or all of the materials, or to inspecting the premises. The objection must be served before the earlier of the time specified for compliance or fourteen (14) days after the subpoena is served. Fed. R. Civ. P. 45(d)(2)(B). If an object

3. Motion to Quash or Modify. On timely motion, the court for the district where compliance is required must quash or modify a subpoena that: (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits specified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or (iv) subjects a person to undue burd

4. Claiming Privilege. If Briarwood withholds any document or information on the basis of a claim of privilege or protection, Briarwood must: (i) expressly assert the claim; and (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim. Fed. R. Civ. P. 45(e)(2)(A).

5. Costs of Compliance. Defendant Stonefield Logistics Group Inc., as the issuing party, acknowledges its obligation to bear the reasonable costs of compliance with this subpoena, including the reasonable costs of copying, scanning, and producing responsive documents and ESI. Briarwood is encouraged to communicate with Defendant's counsel regarding costs of compliance prior to commencing production.

6. Contempt. The court for the district where compliance is required may hold in contempt a person who, having been served with a subpoena, fails without adequate excuse to obey the subpoena or an order related to the subpoena. Fed. R. Civ. P. 45(g).

X. SIGNATURE The undersigned counsel hereby certifies that this subpoena is issued in good faith and not for any improper purpose, and that the documents and information sought are relevant to the claims and defenses in the above-captioned action and proportional to the needs of the case. Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ Simone Laroche, Associate Calderwood & Harkness LLP 200 Park Avenue

1. Briarwood Trucking Co. 1280 Jefferson Davis Highway, Suite 310 Arlington, VA 22202 Attention: Custodian of Records / General Counsel Method of Service: Certified United States Mail, Return Receipt Requested, and concurrent courtesy copy via overnight delivery service (Severin Partners LLC tracking confirmation to be filed upon receipt).

2. Caldwell Royce & Shapiro LLP Attorneys for Plaintiff Vantor Holdings Corp. 1 Liberty Plaza, 22nd Floor New York, NY 10006 Attention: Jason Whitford, Senior Associate Method of Service: Via email to jwhitford@caldwellroyce.com and via first-class United States mail, postage prepaid. I declare under penalty of perjury that the foregoing is true and correct. ________________________________________ Simone Laroche, As