Contract analysis

I. DEFINITIONS A. Defined Terms As used in this Request for Production, the following terms shall have the meanings set forth below. These definitions are intended to be cumulative and not exclusive of any broader meaning that any term may have under the Florida Rules of Civil Procedure or applicable law. 1. "Coastal Palms" or "CPFH" shall mean Defendant Coastal Palms Franchise Holdings LLC, a Florida limited liabili

1. Scope of Production. Each Request shall be construed to call for all responsive documents within Coastal Palms' possession, custody, or control. For purposes of this Request, documents shall be deemed to be within Coastal Palms' "possession, custody, or control" if Coastal Palms has the legal right or practical ability to obtain such documents, including without limitation documents held by Suncoast Room Managemen

2. Privilege Log. If any document responsive to any Request is withheld in whole or in part on the basis of attorney-client privilege, the work-product doctrine, or any other asserted privilege or protection, Coastal Palms shall provide a privilege log that identifies, for each withheld document: (a) the nature and type of the document (e.g., email, memorandum, letter); (b) the date of the document; (c) the author(s)

3. Organization of Production. Documents shall be produced either (a) as they are kept in the ordinary course of business, organized and labeled to correspond to the categories in the Requests to which they are responsive, or (b) in electronic format, Bates-stamped with sequential numbering (e.g., CPFH-000001), accompanied by a load file and any necessary supporting files (e.g., TIFF images, extracted text files, nat

4. Lost or Destroyed Documents. If any document responsive to any Request is no longer in existence or has been lost, destroyed, discarded, or otherwise disposed of, Coastal Palms shall identify the document to the fullest extent possible, including its nature, date, author(s), recipient(s), and subject matter, and shall state when and how the document was lost, destroyed, discarded, or disposed of, and shall identif

5. Time Period. Unless a specific time period is stated in a particular Request, each Request covers the Relevant Period, defined as January 1, 2007 through the date of production.

6. Continuing Obligation. These Requests are continuing in nature pursuant to Florida Rule of Civil Procedure 1.280(e). Coastal Palms has a continuing obligation to supplement its responses as additional responsive documents are identified, located, or come into its possession, custody, or control, including documents created or received after the date of Coastal Palms' initial response.

II. REQUESTS FOR PRODUCTION Category A: Franchise License Agreements and Related Documents REQUEST NO. 1: All twenty-two (22) Franchise License Agreements between Verimark and Coastal Palms (or any Property Entity), including the first FLA executed on or about June 15, 2007 (covering the Naples, Florida property) and the most recent FLA executed on or about September 3, 2019, together with all amendments, addenda, su