Contract analysis

I. PRELIMINARY STATEMENT These Document Requests (the "Requests") are propounded pursuant to the JAMS Comprehensive Arbitration Rules & Procedures (the "JAMS Rules") and the discovery schedule established by the Honorable Margaret Liu Chen (Ret.) at the preliminary conference held on May 15, 2023 (the "Discovery Order"). The discovery Order authorized each party to serve up to twenty (20) document requests and establ

II. DEFINITIONS As used in these Requests, the following terms shall have the meanings set forth below: 1. "Appraisal" or "Beacon Appraisal" means the appraisal of the assets of Palmetto Grand Ventures LLC prepared by Beacon Valuation Group Inc. ("Beacon"), under the direction of Dr. Priya Ramanathan, CFA, ASA, Lead Appraiser, completed on or about April 14, 2023, concluding a Fair Market Value of $151.5 million for

III. INSTRUCTIONS The following instructions apply to each of the Document Requests set forth below:

1. Scope of Production. These Requests require the production of all responsive Documents in MSH's possession, custody, or control. A Document is in MSH's "possession, custody, or control" if MSH has the legal right or practical ability to obtain it, including Documents held by MSH's agents, consultants, accountants, attorneys (to the extent not subject to a valid claim of privilege), financial advisors, appraisers,

2. Privilege Log. If any Document is withheld in whole or in part on the basis of any claim of privilege, work-product protection, or any other immunity from disclosure, MSH shall provide a privilege log that identifies, for each withheld Document or portion thereof: (a) the date of the Document; (b) the author(s) and all recipient(s) (including persons copied); (c) the general subject matter of the Document, describ

3. Format of Production. Documents shall be produced in their native electronic format, preserving all metadata, or, for hard-copy originals without an electronic counterpart, as searchable PDF images at a resolution of no less than 300 DPI. All productions shall be organized by Request number. If Documents are produced from an email system, each email shall be produced together with all attachments, and the producti

4. Cross-Referencing. If a Document is responsive to more than one Request, it need be produced only once, but MSH shall identify, by Bates number or other unique identifier, each Request to which the Document is responsive.

5. Time Period. Unless a specific time period is stated in a particular Request, these Requests cover the period from January 1, 2017, through the date of production.

6. Continuing Obligation. These Requests are continuing in nature. MSH is obligated to supplement its responses promptly if additional responsive Documents come into its possession, custody, or control after the initial production, whether through the receipt of new Documents, the discovery of previously unlocated Documents, or otherwise, consistent with the JAMS Rules and the discovery Order.

IV. DOCUMENT REQUESTS REQUEST NO. 1 — The Beacon Appraisal and Supporting Materials All Documents constituting, relating to, or supporting the appraisal of PGV's assets prepared by Beacon Valuation Group Inc. (Dr. Priya Ramanathan, CFA, ASA, Lead Appraiser), completed on or about April 14, 2023 (the "Beacon Appraisal"), including but not limited to: (a) All drafts of the Beacon Appraisal, including preliminary, inter

V. CERTIFICATION OF SERVICE I, Francesca Morano, counsel for Respondent/Counter-Claimant Pellegrino Capital Group LLC, hereby certify that on June 12, 2023, a true and correct copy of the foregoing Respondent/Counter-Claimant Pellegrino Capital Group LLC's First Set of Document Requests to Claimant Meridian Shores Hospitality LLC was served upon counsel for Claimant Meridian Shores Hospitality LLC by email and by ove