Contract analysis

I. SUBPOENA IDENTIFICATION AND ISSUANCE INFORMATION This Subpoena to Produce Documents, Electronically Stored Information, or Objects or to Permit Inspection of Premises in a Civil Action is issued from the United States District Court for the Northern District of California in connection with the above-captioned civil action. This Subpoena has been prepared by: Calderwood & Harkness LLP 555 Mission Street, Suite 310

II. IDENTIFICATION OF PERSON OR ENTITY TO WHOM SUBPOENA IS DIRECTED This Subpoena is directed to: Corinth Ventures Fund III, LP 399 Boylston Street, Suite 1100 Boston, Massachusetts 02116 Entity Type: Delaware limited partnership Managing Director: Priya Chandrasekaran Corinth Ventures Fund III, LP ("Corinth") is a venture capital fund organized as a Delaware limited partnership with approximately $2.1 billion in ass

III. COMMAND TO PRODUCE YOU ARE COMMANDED to produce and permit inspection and copying of the documents and electronically stored information described in the attached Schedule A (Section V of this Subpoena), at the following location: Place of Production: Calderwood & Harkness LLP 555 Mission Street, Suite 3100 San Francisco, California 94105 Alternatively, at Corinth's election, production may be made via secure el

IV. DEFINITIONS A. Defined Terms For purposes of this Subpoena, including the document requests set forth in Schedule A, the following terms shall have the meanings set forth below: 1. "Helios" or "HPD" means Helios Precision Diagnostics, Inc., a Delaware corporation headquartered at 200 CambridgePark Drive, Suite 600, Cambridge, Massachusetts 02140, and includes its officers, directors, employees, agents, representa

1. Organization of Production. Documents shall be produced either (a) as they are kept in the ordinary course of business, maintaining the file structure, folder organization, and custodial associations in which they are maintained, or (b) organized and labeled to correspond with the categories and request numbers set forth in Schedule A.

2. Format of Production — Electronically Stored Information. Electronically stored information ("ESI") shall be produced in one of the following formats, at Corinth's election: (a) native file format, with all associated metadata intact and preserved; or (b) single-page TIFF images (300 DPI, Group IV compression) accompanied by extracted text files (in .txt format, one per document) and a load file (in concordance .d

3. Privilege Log. To the extent that Corinth withholds any document or communication on the basis of any privilege (including, without limitation, the attorney-client privilege, the work-product doctrine, or any common-interest privilege), Corinth shall provide a privilege log that conforms to the requirements of Federal Rule of Civil Procedure 45(e)(2)(A). The privilege log shall identify each withheld document with

4. Meet and Confer. Before filing any motion to quash or modify this Subpoena, Corinth is requested to meet and confer in good faith with counsel for GenomeDx regarding any objections, concerns, or issues relating to the scope, burden, or terms of this Subpoena. Counsel for GenomeDx is willing to discuss reasonable modifications to the scope or timing of production to minimize any undue burden on Corinth as a non-par

5. Continuing Obligation. If, after the date of initial production, Corinth identifies or comes into possession of additional documents responsive to this Subpoena that were not included in the initial production, Corinth shall promptly supplement its production to include such documents.

V. SCHEDULE A: DOCUMENTS AND CATEGORIES REQUESTED Request No. 1 — Investment Memoranda Relating to Helios All investment memoranda, investment committee presentations, deal screening reports, deal summaries, partnership meeting materials, and funding approval documents prepared by or for Corinth in connection with any investment in Helios, including but not limited to Corinth's Series A investment in Helios and any s

VI. OBJECTIONS AND PRIVILEGE Corinth may serve objections to this Subpoena in writing on Calderwood & Harkness LLP within fourteen (14) days after service of this Subpoena, or before the date for compliance specified herein, whichever is earlier, in accordance with Federal Rule of Civil Procedure 45(d)(2)(B). Any objections shall be served on Peter Vassiliev at the address, telephone number, and email address set for

VII. DUTY TO PRESERVE Upon receipt of this Subpoena, Corinth is hereby notified of its obligation to preserve all documents and electronically stored information that are responsive to the document requests set forth in Schedule A. Corinth shall take all reasonable steps to ensure that no responsive documents or electronically stored information are destroyed, deleted, altered, overwritten, concealed, or otherwise ma

VIII. APPLICABILITY OF PROTECTIVE ORDER All documents and electronically stored information produced by Corinth in response to this Subpoena shall be subject to and governed by the Stipulated Protective Order entered by the Honorable Jessica W. Langston on December 18, 2025 (Dkt. No. [__]) in Genome Dx Therapeutics Inc. v. Helios Precision Diagnostics, Inc., Case No. 3:25-cv-01847-JWL (N.D. Cal.) (the "Protective Ord

IX. RETURN / PROOF OF SERVICE This section is to be completed upon actual issuance and service of this Subpoena. This section is currently in draft form and contains blank fields to be filled in at the time of service. PROOF OF SERVICE I declare under penalty of perjury under the laws of the United States of America that I served this Subpoena on the person or entity identified in Section II of this Subpoena as follo

X. ATTORNEY CERTIFICATION AND SIGNATURE BLOCK I, the undersigned attorney, certify that this Subpoena has been issued on behalf of the Plaintiff, Genome Dx Therapeutics Inc., in connection with the above-captioned civil action, and that the documents and electronically stored information sought herein are relevant to the claims and defenses in this action and are proportional to the needs of the case, taking into acc

1. Purpose and Strategic Context The attached draft subpoena duces tecum is directed to Corinth Ventures Fund III, LP ("Corinth"), the majority equity holder in Defendant Helios Precision Diagnostics, Inc. ("Helios"). Corinth holds approximately 58.7% of Helios's outstanding equity and is believed to have exercised significant influence over Helios's strategic decisions, including decisions relating to the developmen

2. Service Considerations Several procedural and strategic issues must be addressed before this subpoena is finalized and served: a. Compliance with Rule 45(a)(2) — Issuing Court. Under Federal Rule of Civil Procedure 45(a)(2), a subpoena must be issued from the court where the action is pending. The subpoena may command production at a place within 100 miles of where the person served resides, is employed, or regula

3. Coordination with Pending discovery Motions On January 30, 2026, GenomeDx filed a motion to compel (Dkt. No. [__]) before Magistrate Judge Cabrera, challenging Helios's assertion of privilege over 34 documents identified in Helios's privilege log. These 34 documents include internal Helios memoranda, emails between Helios executives and outside patent counsel at Ridgecrest Durneval LLP, and several documents that

4. Estimated Timeline The following timeline is proposed for the finalization, service, and compliance with this subpoena: Key Timing Consideration: The current fact discovery close is March 6, 2026. If we serve this subpoena in February 2026, the 30-day compliance date would likely fall in March 2026 — at or around the discovery cutoff. While Rule 45 subpoenas to non-parties are not strictly subject to party discove