Contract analysis

1. Production Format. All documents shall be produced in the format specified in the Joint E-discovery Protocol dated June 20, 2022: TIFF images with extracted text and associated metadata fields, Bates-numbered sequentially, and accompanied by load files compatible with standard litigation-support platforms (e.g., Relativity, Ashgrove Technologies, or Vireo Systems). Native-format production is required for spreadsh

2. Organization. Documents shall be produced either as they are kept in the ordinary course of business or organized and labeled to correspond to the categories in each numbered Request. If documents are produced as kept in the ordinary course of business, the producing party shall identify the custodian and the folder or file path from which the document was collected.

3. Privilege Log. If any document responsive to any Request herein is withheld in whole or in part on the basis of attorney-client privilege, work-product protection, or any other privilege or immunity from disclosure, Coastal Palms shall provide a privilege log in compliance with Florida Rule of Civil Procedure 1.280(b)(6) and Section 7 of the Joint E-discovery Protocol. The privilege log shall identify, for each wi

4. Lost or Destroyed Documents. If any document responsive to any Request herein has been lost, destroyed, discarded, overwritten, or is otherwise unavailable for production, Coastal Palms shall: (a) identify the document with as much specificity as possible; (b) describe the document's contents; (c) state the date on which the document was lost, destroyed, or became unavailable; (d) identify the person(s) responsibl

5. Continuing Obligation. This Request is continuing in nature pursuant to Florida Rule of Civil Procedure 1.280(e). Coastal Palms is under a continuing obligation to supplement its responses and production promptly upon discovering any additional responsive documents or information.

6. Independent Construction. Each Request shall be construed independently of every other Request and shall not be limited by reference to any other Request. A document responsive to more than one Request need only be produced once, provided that it is identified as responsive to each applicable Request.

7. Scope of Possession, Custody, or Control. Production shall include all responsive documents in the possession, custody, or control of Coastal Palms, its Property-Level Entities (including Gulf Breeze Hospitality LLC and Savannah Lodging Partners LLC), Suncoast Room Management Inc., Randall Brecker (to the extent acting in his capacity as an officer, member, manager, or agent of any of the foregoing entities), and

8. Time Period. Unless otherwise specified in a particular Request, each Request covers the Relevant Period (January 1, 2013 through the date of production).

9. Singular / Plural; Conjunctive / Disjunctive. The singular shall include the plural, and the plural shall include the singular. The terms "and" and "or" shall be construed both conjunctively and disjunctively so as to bring within the scope of each Request all documents that might otherwise be construed as outside its scope.

10. Prior Productions. To the extent any documents responsive to this Second Request for Production were included in the initial production (approximately 84,000 documents, Bates Nos. CPFH-000001 through CPFH-084312) or the November 18, 2022 Supplemental Production (approximately 312,000 documents, Bates Nos. CPFH-SUP-000001 through CPFH-SUP-312247), such documents need not be re-produced, provided that Coastal Palms