Contract analysis

I. PRELIMINARY STATEMENT Defendant Northgate Fiber Americas Inc. ("NFA" or "Defendant"), by and through its attorneys, Calderwood & Harkness LLP, 425 Park Avenue, 33rd Floor, New York, New York 10022, hereby responds and objects to Plaintiff Meridian Infrastructure Partners LLC's ("Meridian" or "Plaintiff") First Set of Document Requests (Request Nos. 1 through 62), which were served on or about October 8, 2024, purs

II. GENERAL OBJECTIONS Defendant asserts the following General Objections, each of which is incorporated by reference into every specific response set forth below as though fully stated therein. The assertion of any specific objection to a particular request does not waive any General Objection, nor does any failure to assert a specific objection waive any objection, privilege, or right that Defendant may have. Gener

III. DEFINITIONS AND INSTRUCTIONS Defendant adopts, for the purposes of these responses, the definitions set forth in Plaintiff's First Set of Document Requests, except as specifically noted or objected to below. Defendant notes and acknowledges the following defined terms as used in Plaintiff's Requests and in these responses: • "Document" shall have the meaning set forth in Plaintiff's Requests, which Defendant und

1. Renata Voss — Vice President, US Network Infrastructure, NFA

2. Sean Calloway — Director, Construction Management, NFA

3. Helena Bright — Chief Financial Officer, Northgate Telecommunications PLC

4. Dominic Hale — General Counsel, Northgate Telecommunications PLC

5. Martin Griggs — Senior Project Manager, NFA

6. Priscilla Okonkwo — Director, Procurement and Contracts, NFA

7. Derek Blanchard — Vice President, Engineering, NFA

8. Yolanda Chu — Manager, Quality Assurance, NFA

9. Anton Ramirez — Director, Finance and Accounting, NFA

10. Claire Whitmore — Executive Assistant to the CEO, Northgate Telecommunications PLC Defendant has collected documents from these custodians' email accounts, personal and shared network drives, local hard drives, and relevant enterprise systems, including project management databases and financial reporting platforms, in accordance with the ESI Protocol.

IV. SPECIFIC RESPONSES AND OBJECTIONS TO DOCUMENT REQUESTS NOS. 1–62 The following are Defendant's specific responses and objections to each of Plaintiff's Document Request Nos. 1 through 62. Each response incorporates by reference all General Objections set forth in Section II above, whether or not specifically restated. A. Requests Relating to the Master Construction Agreement (Nos. 1–5) Request No. 1 Request: All