Contract analysis

1. Scope of Production. Ironclad shall produce all responsive, non-privileged documents in its possession, custody, or control. As used herein, "possession, custody, or control" includes documents held by Ironclad's officers, directors, employees, agents, attorneys, adjusters (including Arbor Claims Services LLC), experts, consultants, reinsurers, and any other person or entity acting or purporting to act on Ironclad

2. Time Period. Unless otherwise expressly specified in a particular Request, these Requests cover the period from January 1, 2022 through the date of production. Where a Request references predecessor policies or historical documents, the applicable time frame is specified within that Request.

3. Bates Numbering. All documents produced shall bear consecutive Bates numbers (e.g., IRONCLAD-0000001, IRONCLAD-0000002, etc.) sufficient to uniquely identify each page of every document produced. The Bates numbering convention shall be applied consistently throughout all productions in response to these Requests and any supplemental productions.

4. Format of Production. Documents shall be produced in one of the following formats, at Ironclad's election: (a) for electronically stored information, in native format with all associated metadata preserved, accompanied by load files (Concordance DAT and OPT files or their functional equivalent) containing extracted text and metadata fields including, at a minimum, custodian, author, date created, date modified, da

5. Privilege Log. To the extent that any responsive document or communication is withheld in whole or in part on the basis of the attorney-client privilege, the attorney work-product doctrine, or any other privilege or protection, Ironclad shall prepare and serve, contemporaneously with its document production, a privilege log in accordance with Florida Rule of Civil Procedure 1.280(b)(6). The privilege log shall ide

6. Continuing Obligation to Supplement. These Requests are continuing in nature pursuant to Florida Rule of Civil Procedure 1.280(e). If, at any time after Ironclad's initial production, Ironclad obtains, locates, discovers, or becomes aware of additional documents responsive to any Request, Ironclad shall promptly supplement its production and serve such additional documents upon VHG's counsel without further reques

7. Identification of Documents Not Produced. If any document responsive to any Request has been lost, destroyed, discarded, deleted, overwritten, or is otherwise unavailable for production, Ironclad shall: (a) identify the document with as much specificity as possible, including its date, author, recipient(s), and general subject matter; (b) describe the contents of the document to the extent known; (c) state the dat