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Contract analysis / subpoena-cascade-freight.docx
subpoena-cascade-freight.docx
1012-00005 · 11 clauses
High · 5 Medium · 1 Standard · 1
I. SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS High
⚑ Penalty / liquidated damages
I. SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS A. Issuing Court United States District Court for the Southern District of New York, 500 Pearl Street, New York, New York 10007. B. Party on Whose Behalf This Subpoena Is Issued This subpoena is issued on behalf of Defendant Stonefield Logistics Group Inc. C. Non-Party Recipient of Subpoena To: Cascade Freight Systems Inc. 4700 Lakehurst Court Columbus, OH 430
II. PROOF OF SERVICE High
⚑ Penalty / liquidated damages
II. PROOF OF SERVICE PROOF OF SERVICE OF SUBPOENA This Subpoena for Cascade Freight Systems Inc. was received by me on the date indicated below. Date of Service: ________ Manner of Service: Personal Service (hand-delivered to an officer, managing or general agent, or other agent authorized by appointment or by law to receive service of process on behalf of Cascade Freight Systems Inc.) Certified Mail, Return Receipt
III. NOTICE TO ALL PARTIES PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 45(a)(4) Medium
⚑ Notice / time limit to track
III. NOTICE TO ALL PARTIES PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 45(a)(4) NOTICE OF ISSUANCE AND SERVICE OF SUBPOENA DUCES TECUM TO NON-PARTY CASCADE FREIGHT SYSTEMS INC. A. Notice of Subpoena Pursuant to Federal Rule of Civil Procedure 45(a)(4), Defendant Stonefield Logistics Group Inc. ("Stonefield" or "Defendant") hereby provides notice to all parties in this action that the attached Subpoena Duces Tecum has
IV. ATTACHMENT A — SCHEDULE OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION TO BE PRODU High
⚑ Non-compete / exclusivity restraint
IV. ATTACHMENT A — SCHEDULE OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION TO BE PRODUCED ATTACHMENT A SCHEDULE OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION TO BE PRODUCED BY CASCADE FREIGHT SYSTEMS INC. A. Definitions. As used in the Document Requests set forth below, the following terms shall have the meanings indicated: 1. "Cascade" means Cascade Freight Systems Inc., including its current and former off
1. Format of Production. Documents shall be produced in their native electronic format whe
1. Format of Production. Documents shall be produced in their native electronic format where possible. Where native production is not feasible or appropriate (e.g., for paper originals), documents shall be produced as single-page TIFF images (300 DPI minimum resolution) accompanied by extracted text (OCR where extracted text is unavailable) and all associated metadata in a standard load file compatible with Relativit
2. Privilege Log. If any document responsive to the requests below is withheld in whole or
2. Privilege Log. If any document responsive to the requests below is withheld in whole or in part on the basis of any privilege, immunity, or other protection from disclosure (including, without limitation, the attorney-client privilege, the work product doctrine, or any other applicable privilege), Cascade shall provide a privilege log identifying each such document with sufficient particularity to enable the reque
3. Organization of Production. Documents shall be produced as they are kept in the ordinar
3. Organization of Production. Documents shall be produced as they are kept in the ordinary course of business, or organized and labeled to correspond to each category of request in this Attachment A. Each document shall be Bates-stamped with a unique, sequential production number, using the prefix "CASCADE" (e.g., CASCADE-000001, CASCADE-000002, etc.).
4. Conferral Regarding Burden or Scope. If Cascade contends that any request herein is und
4. Conferral Regarding Burden or Scope. If Cascade contends that any request herein is unduly burdensome, overly broad, or otherwise objectionable, Cascade is requested to contact undersigned counsel promptly and in any event before the return date of this Subpoena to discuss the possibility of narrowing the scope of the request or reaching an accommodation concerning the manner of production, consistent with the obl
5. Method of Electronic Production. Production may be made electronically by uploading doc High
⚑ Non-compete / exclusivity restraint
5. Method of Electronic Production. Production may be made electronically by uploading documents to the secure review platform maintained by Pinnacle Forensics LLC, which has been engaged by Defendant's counsel in connection with this litigation. The relevant project details are as follows: Project ID: PF-SLG-2022-0914 Contact: Nathan Billings, Client Engagement Director Pinnacle Forensics LLC 12000 Findley Road, Sui
V. ATTACHMENT B — OBLIGATIONS OF THE NON-PARTY UNDER FEDERAL RULE OF CIVIL PROCEDURE 45 High
⚑ Penalty / liquidated damages
V. ATTACHMENT B — OBLIGATIONS OF THE NON-PARTY UNDER FEDERAL RULE OF CIVIL PROCEDURE 45 ATTACHMENT B SUMMARY OF RIGHTS AND OBLIGATIONS OF NON-PARTY CASCADE FREIGHT SYSTEMS INC. UNDER FEDERAL RULE OF CIVIL PROCEDURE 45 The following is a summary of the principal rights and obligations of Cascade Freight Systems Inc. ("Cascade") as a non-party recipient of this Subpoena Duces Tecum. This summary is provided for informa
VI. CERTIFICATE OF SERVICE Standard
⚑ Commercial term
VI. CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I, Simone Laroche, an associate at Calderwood & Harkness LLP and counsel for Defendant Stonefield Logistics Group Inc. in the above-captioned action, hereby certify that on June 28, 2023, a true and correct copy of the foregoing Subpoena Duces Tecum to Non-Party Cascade Freight Systems Inc., together with Attachment A (Schedule of Documents and Electronically Stored I