Contract analysis

1. Derek Pruitt (VP, Business Development, Vantor) — Primary relationship manager with Stonefield; key witness on mitigation efforts (or lack thereof) and on VTS's awareness of SLO failures during Q3 and Q4 2021.

2. Sandra Milescu (COO, Vantor/VTS) — Author of the November 12, 2021 internal email (the "smoking gun" email) in which she directed fleet redeployment away from the Stonefield account; essential testimony regarding operational decision-making.

3. Nikolai Vantorovich (CEO and Founder, Vantor) — Overall corporate decision-making; awareness of SLO failures; potential conflicts regarding fee arrangements with CRS (possible leverage point).

4. Gregory Fielding (CFO, Vantor) — Damages calculations; financial condition of Vantor and VTS; revenue attributable to the TSA; mitigation cost figures.

5. Rule 30(b)(6) Designee(s) — Corporate topics including fleet management, contract performance, damages methodology, mitigation efforts, corporate structure (VHC/VTS relationship), and financial records. [The remaining 5 deposition slots should be reserved for additional fact witnesses as identified during discovery or for follow-up depositions if warranted. Potential additional deponents include VTS drivers or dis

1. Derek Pruitt (Vice President, Business Development, Vantor Holdings Corp.) — Pruitt was the primary relationship manager for the Vantor/Stonefield account and participated in all quarterly business reviews. He is a key witness on: (a) VTS's awareness of SLO failures during Q3 and Q4 2021; (b) communications between VTS and Stonefield regarding performance issues; (c) Vantor's mitigation efforts (or lack thereof) f

2. Sandra Milescu (Chief Operating Officer, Vantor Holdings Corp. / Vantor Transport Services LLC) — Milescu is the author of the November 12, 2021 internal email (the "smoking gun" email) directing the redeployment of approximately 85 tractors and 140 trailers from the Stonefield account to the Northwind Distribution Co. account, which directly contributed to VTS's inability to meet SLOs in Q4 2021. This email is a

3. Nikolai Vantorovich (CEO and Founder, Vantor Holdings Corp.) — Vantorovich is the ultimate decision-maker at Vantor and had overall responsibility for the company's relationship with Stonefield. Key topics include: (a) awareness of SLO failures; (b) authorization of the fleet redeployment; (c) role in the decision to file suit; (d) overall corporate strategy and financial condition. Note: informal intelligence sug

4. Gregory Fielding (CFO, Vantor Holdings Corp.) — Fielding is the principal witness on damages and financial matters. Key topics include: (a) preparation and methodology of Vantor's damages calculations; (b) financial condition of Vantor and VTS before and after termination; (c) revenue attributable to the TSA; (d) mitigation costs; (e) alternative revenue sources post-termination.

5. Rule 30(b)(6) Designee(s) — Corporate deposition topics to be noticed include: fleet management policies and procedures; contract performance metrics and SLO compliance; damages methodology and computation; mitigation efforts and timeline; corporate structure (VHC/VTS relationship, including assignments, guarantees, and intercompany transactions); and financial records and accounting practices. [Stonefield Witness

1. Janet Kirkwood (Vice President, Carrier Relations, Stonefield Logistics Group Inc.) — Kirkwood oversaw the Stonefield-Vantor relationship on behalf of Stonefield and is the author of the September 22, 2021 internal email (the "pull the plug" email). This email is the single most significant risk document in the case. In it, Kirkwood wrote to Carlos Medina: "Honestly I think we should just pull the plug on the whol

2. Raymond Hess (Director, Contract Compliance, Stonefield Logistics Group Inc.) — Hess was responsible for monitoring VTS's performance against the SLOs and issued the Cure Notice on January 18, 2022. Hess must be prepared to testify regarding: (a) the metric verification methodology used to determine SLO non-compliance (based on data from VTS's own Carrier Performance Portal, which is the agreed-upon data source un

3. Carlos Medina (SVP, Operations, Stonefield Logistics Group Inc.) — Medina was the recipient of the Kirkwood "pull the plug" email and may have additional responsive communications. Medina may be designated as a 30(b)(6) witness or may be deposed individually on operational decisions, including lane allocation, carrier selection, and the decision to engage Cascade and Briarwood on Secondary Lanes. Preparation shoul

4. Tobias Wren (General Counsel, Stonefield Logistics Group Inc.) — Wren signed the Termination Letter dated March 4, 2022. Although Wren is an attorney and many of his communications will be privileged, he may be deposed on non-privileged factual matters, including the factual basis for the termination decision and the issuance of the Cure Notice and Termination Letter. Careful privilege preparation is essential; Pa