Contract analysis

1. Location of Production. All responsive documents and materials shall be produced at the offices of Calderwood & Harkness LLP, 110 SE 6th Street, Suite 2800, Fort Lauderdale, FL 33301, or, at the Bank's election, by secure electronic transfer to a designated document repository hosted by Nexagen Document Solutions LLC, as may be arranged between the Bank and undersigned counsel.

2. Deadline for Production. Production shall be made within thirty (30) days of service of this Subpoena, i.e., no later than September 7, 2022.

3. Format of Production. All documents shall be produced in their native electronic format, including all associated metadata, or as single-page TIFF images with extracted text and load files, consistent with the E-discovery Protocol set forth in the Joint Stipulation Regarding discovery of Electronically Stored Information filed in this action on June 20, 2022 (Dkt. No. 47). Documents that exist originally and solel

4. Copies in Lieu of Originals. The Bank may produce copies of documents in lieu of originals, provided that such copies are true, correct, and complete reproductions of the originals in all respects. The Bank shall preserve all original documents pending the resolution of this litigation, and Plaintiff reserves the right to inspect originals upon reasonable notice.

5. Completeness. All responsive documents shall be produced in their entirety, including all attachments, enclosures, cover letters, transmittal sheets, appendices, exhibits, and schedules, regardless of whether such accompanying materials are separately responsive to a specific request. SECTION 2: IDENTIFICATION OF PARTIES AND COUNSEL 2.1 Plaintiff. Verimark Hospitality Group Inc. is a Delaware corporation publicly

I. "Communication" means any written, electronic, or recorded exchange of information of any kind, including but not limited to letters, correspondence, emails, memoranda, text messages (including SMS and MMS), instant messages, messages transmitted through any messaging platform or application, facsimiles, notes of telephone conversations, voice messages, video messages, and any other form of transmission of informa