Contract analysis

1. PURPOSE AND SCOPE OF THIS PROTOCOL 1.1 Purpose The purpose of this Document Review Protocol and Coding Manual (this "Protocol") is to establish uniform standards, procedures, and coding conventions for the review of documents and electronically stored information ("ESI") collected in connection with the defense of Meridian Infrastructure Partners LLC v. Northgate Fiber Americas Inc., Index No. 654321/2024 (Sup. Ct

2. MATTER BACKGROUND SUMMARY FOR REVIEWERS The following background information is provided to orient reviewers to the key facts, parties, contracts, and legal issues in this Litigation. Reviewers should familiarize themselves thoroughly with this section before beginning document review, as a working knowledge of the underlying facts is essential to accurate responsiveness, privilege, and issue coding. 2.1 Parties a

3. CUSTODIANS AND DATA SOURCES 3.1 Northgate/NFA Custodians (10 Total) The following individuals have been identified as document custodians in this matter, organized into three priority tiers based on their relevance to the key issues in the Litigation and the anticipated timing of their depositions. The tiering governs the order in which custodian collections are reviewed, as described in Section 10 below. 3.1.1 Pr

4. REVIEW PLATFORM AND ACCESS 4.1 Platform All document review for this matter shall be conducted exclusively on the Vantage-hosted Relativity platform. The workspace name is "1022-00005 — Northgate v. Meridian." All reviewers will receive individual access credentials from Vantage, and two-factor authentication is required for all logins. Reviewers must not share credentials with any other person, and must log out o

5. FIRST-LEVEL REVIEW: RESPONSIVENESS CODING 5.1 Responsiveness Determination The first level of review requires each document to be assessed for responsiveness — that is, whether the document falls within the scope of discovery and should be produced to Meridian (subject to privilege and other objections). Reviewers should apply the following standards: 5.1.1 Responsive. A document is Responsive if it is within the

6. PRIVILEGE REVIEW AND CODING Privilege review is one of the most critical aspects of this document review. Failure to identify and withhold privileged documents may result in waiver of applicable privileges, while over-designation of privilege may expose the review to challenge by Meridian and the Court. Reviewers must exercise careful judgment in applying the following privilege categories. 6.1 Privilege Categorie

7. CONFIDENTIALITY DESIGNATION CODING 7.1 Confidentiality Tiers All responsive, non-privileged documents produced to Meridian must be assigned a confidentiality designation in accordance with the Stipulation and Proposed Order Regarding Confidentiality of discovery Materials filed with the Court on October 1, 2024. The confidentiality designations are as follows: 7.1.1 Confidential. The Confidential designation appli

8. ISSUE TAGS (SUBSTANTIVE CODING) 8.1 Purpose Issue tags are substantive coding designations that enable the review team and case attorneys to rapidly identify and retrieve documents relevant to specific claims, defenses, counterclaims, witness topics, and subject matter areas. Effective issue tagging is essential for deposition preparation, motion practice, expert analysis, and trial preparation. The issue tag taxo