Contract analysis

1. Purpose and Scope of Report This report constitutes the quarterly docket check for the second quarter of 2024, covering the period from April 13, 2024 through July 8, 2024. The review has been conducted pursuant to the case dormancy protocol established in the Internal Memorandum — Case Dormancy Protocol dated April 15, 2024, authored by Patrick Gallagher, Lead Associate, and approved by Samuel Eklund, Responsible

2. Case Status Summary Current Case Posture: Dormant. There are no pending motions before the Court. All discovery and dispositive motion deadlines were previously stayed by the Court pursuant to the October 18, 2023 order granting the withdrawal of Caldwell Royce & Shapiro LLP as counsel for the plaintiff, Vantor Holdings Corp. The stay remains in effect, and no party has moved to lift or modify it. No scheduling co

3. Docket Review — Q2 2024 Review Method: The docket review was conducted via the PACER/ECF electronic case filing system for the United States District Court for the Southern District of New York. The docket for Case No. 22-cv-07841 was accessed and reviewed in its entirety on July 8, 2024. In addition to reviewing the docket sheet entries, the undersigned confirmed that no new documents had been uploaded to the ECF

4. Summary of Key Prior Docket Events (Context) For reference and to provide appropriate context for this report, the following chronological table summarizes the critical docket entries in this matter from the filing of the original complaint through the current reporting period: This chronological summary is intended to provide a concise reference tool for the litigation team. The complete docket sheet, as download

5. Days of Inactivity As of the date of this report (July 8, 2024), the following measures of inactivity are noted: • Days since last docket entry: Approximately 147 days (nearly five months) have elapsed since the last docket entry on February 12, 2024 (the minute entry reflecting the Order to Show Cause hearing). No filing, order, or other activity of any kind has appeared on the docket since that date. • Days sinc

6. Assessment and Observations Based on the docket review conducted for the Q2 2024 reporting period, the following assessment and observations are offered for the litigation team's consideration: Failure to Comply with Court-Ordered Deadlines. Vantor Holdings Corp. has now failed to comply with two successive court-ordered deadlines to retain substitute counsel. The first deadline, December 17, 2023, was set in the

7. Recommended Next Steps Based on the findings of this quarterly docket check, the following next steps are recommended:

1. Continue Quarterly Docket Monitoring. The dormancy protocol should remain in effect, and docket monitoring should continue on a quarterly basis. The next quarterly docket check is scheduled for approximately October 7, 2024, covering the Q3 2024 period (July 9, 2024 through approximately October 7, 2024). The undersigned will prepare and circulate the Q3 2024 Quarterly Docket Check Report promptly following that r

2. Consider Affirmative Motion Practice. This report is flagged for the attention of Patrick Gallagher, Lead Associate, and Samuel Eklund, Responsible Partner: the team should consider whether the time has come to file a renewed motion to dismiss for failure to prosecute under Fed. R. Civ. P. 41(b), or alternatively, to submit a letter to the Court pursuant to Judge Calloway's Individual Practices requesting that the

3. Draft Motion to Dismiss Available for Finalization. The draft Motion to Dismiss for Failure to Prosecute, initially prepared on January 15, 2024 by Patrick Gallagher and Simone Laroche, Junior Associate, remains available in the matter file. That draft was prepared in anticipation of the possibility that Vantor would fail to comply with the original December 17, 2023 deadline and was held in abeyance when the Cour

4. Client Communication — Lakeshore National Bank. The litigation team should confirm whether a mid-year quarterly litigation update to Lakeshore National Bank is warranted at this time. Catherine Devereaux, Senior Vice President, Loan Administration, at Lakeshore National Bank, has historically received quarterly updates on this matter as required under the reporting covenant in Stonefield's credit facility. The mos

8. Distribution and Filing This report is being provided to Patrick Gallagher, Lead Associate, Litigation (General), for his review and for further distribution as he deems appropriate. In particular, distribution to the following individuals may be warranted: • Samuel Eklund, Partner, Responsible Partner for this matter; • Linda Osei, Partner, Billing Partner for this matter. Distribution to the client, including To