Contract analysis

From: Harrison Caldwell <hcaldwell@caldwellroyce.com> To: Samuel Eklund <seklund@calderwoodharkness.com> Cc: Meredith Shapiro <mshapiro@caldwellroyce.com> Date: Mon, 25 Sep 2023 04:17:00 -0000 Subject: Vantor Holdings Corp. v. Stonefield Logistics Group Inc., No. 22-cv-07841 (S.D.N.Y.) — Resolution Discussion

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I am writing with respect to the above-captioned matter, pending before the Hon. Margaret T. Calloway, U.S.D.J. As you are aware, fact discovery under the Case Management Order has effectively concluded, and the parties have exchanged expert reports — our Trask Greystone report was served on May 15, and your Kensington Analytics rebuttal followed on August 25. The case is now proceeding toward expert depositions and,

I have had the opportunity to discuss this matter at length with my client and Mr. Vantorovich, and Vantor would be open to discussing a resolution of this dispute short of further litigation. Both sides have devoted considerable resources to this case over the past year, and while we remain confident in the merits of our claims, we recognize that a negotiated resolution — if achievable on appropriate terms — could s

With that in mind, I would propose that the parties engage in a formal mediation before a mutually agreeable neutral mediator, ideally within the next 45 to 60 days. A session in the mid-November to mid-December timeframe should be workable without disrupting the current case schedule or pending expert discovery deadlines. I am happy to discuss mediator candidates at your convenience and would welcome any suggestions

I hope we can explore this constructively. Please feel free to call me at your convenience if you would like to discuss.

**Harrison Caldwell** Partner Caldwell Royce & Shapiro LLP 1 Liberty Plaza, 22nd Floor New York, New York 10006 T: (212) 554-8100 F: (212) 554-8101 hcaldwell@caldwellroyce.com

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