Contract analysis

1. Initial Case Assessment & Strategy | Review of Complaint, TSA (Contract Ref. SLG-VTS-2019-0315), termination documents, and key correspondence; legal research on material breach, liquidated damages enforceability under NY law, force majeure defense; development of defense strategy; client meetings and Ridgeline coordination | Sept. 2022 – Oct. 2022 | TSA contract review (Sections 13.1, 14.2, 12.1, 7.4, Schedule C)

2. Pleadings — Motion to Dismiss | Draft and file Rule 12(b)(6) motion targeting liquidated damages clause (Section 14.2) as unenforceable penalty and lost profits claim as inadequately pled; supporting declaration; review opposition; draft and file reply | Oct. 2022 – Dec. 2022 | Motion to Dismiss memorandum of law; Eklund declaration attaching TSA and Cure Notice; analysis of Vantor's opposition; reply memorandum;

3. Pleadings — Answer, Affirmative Defenses & Counterclaim | Analysis of Amended Complaint (filed Dec. 2, 2022, adding volume shortfall, exclusivity, and pretextual termination allegations); draft Answer with 14 affirmative defenses (valid Cause termination, unenforceable penalty, failure to mitigate, force majeure, unclean hands, contributory breach, waiver, estoppel, setoff, etc.) and declaratory judgment countercl

4. Written discovery — Propounding & Responding | Draft and serve interrogatories, requests for production, requests for admission; respond to Vantor's discovery requests; prepare privilege logs; manage document collection and review with Pinnacle Forensics (Project ID: PF-SLG-2022-0914); handle discovery disputes | Mar. 2023 – July 2023 | First Set of Interrogatories (25); First RFP (38 requests); First RFA (30 requ

5. Document Review & Production | First-pass and second-pass review of Stonefield ESI and hard-copy documents; privilege review; coding; quality control; production via Pinnacle Forensics platform; review and analysis of Vantor's productions; key document indexing; third-party subpoena responses (Cascade Freight Systems Inc., Briarwood Trucking Co.) | Mar. 2023 – Aug. 2023 | Estimated 150,000–200,000 pages of SLG doc

6. Depositions | Preparation, conduct, and defense of fact witness depositions for both parties; estimated 5–7 depositions | June 2023 – Oct. 2023 | Anticipated deponents: Derek Pruitt (VP, Business Development, Vantor); Sandra Milescu (COO, Vantor/VTS); Nikolai Vantorovich (CEO, Vantor); Rule 30(b)(6) corporate designee(s); defense preparation for Janet Kirkwood (VP, Carrier Relations, SLG), Raymond Hess (Director,

7. Expert Engagement & Reports | Retain and manage rebuttal damages/economics expert; review and analyze plaintiff's expert report; prepare rebuttal expert report; potential Daubert motion research | Oct. 2022 – Jan. 2024 | Retention of Kensington Analytics Group LLC (Dr. Evelyn Rosser, Managing Director); expert scope memorandum; analysis of Trask Greystone (Dr. Philip Trask) damages report ($95.4M claimed); rebutta

8. Summary Judgment / Dispositive Motions | Draft and file motion for summary judgment (full or partial); supporting declarations and exhibits; opposition to any cross-motion by Vantor; reply papers | Jan. 2024 – Mar. 2024 | Summary judgment roadmap: (1) valid termination for Cause — undisputed SLO failures (on-time pickup 78.2% vs. 95%, on-time delivery 81.6% vs. 93%, tender acceptance 71.4% vs. 90%, equipment avail

9. Case Management & Administration | Ongoing case management, court conferences, status reporting, lender notifications to Lakeshore National Bank (per Credit Agreement Section 6.03(b), threshold $25M), insurance coordination (Graymark D&O and Brindoval CGL), Ridgeline updates, billing administration | Sept. 2022 – Mar. 2024 | Monthly status reports to Tobias Wren; quarterly updates to Lakeshore National Bank (Cathe