Contract analysis

I. INTRODUCTORY STATEMENT Defendant Solstice Biomedical, Inc. ("Solstice" or "Defendant"), by and through its undersigned counsel, Calderwood & Harkness LLP, hereby serves its Responses and Objections to Plaintiff Apex Surgical Innovations, Inc.'s ("Apex" or "Plaintiff") First Set of Requests for Production of Documents (Nos. 1–42) (the "Requests"), which were served on Solstice on August 5, 2024. These Responses and

II. GENERAL OBJECTIONS Solstice makes the following General Objections, each of which is incorporated by reference into every specific response set forth in Section IV below. These General Objections are not intended to be exhaustive and are without prejudice to any additional or more specific objections asserted in the individual responses. General Objection No. 1 — Overbreadth and Undue Burden Solstice objects to a

III. DEFINITIONS AND INSTRUCTIONS Solstice acknowledges and, where consistent with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Delaware, and the Court's orders, adopts Apex's definitions and instructions as set forth in Apex's First Set of Requests for Production of Documents. To the extent any of Apex's definitions or instructions purport to impose ob

IV. SPECIFIC RESPONSES AND OBJECTIONS TO REQUESTS FOR PRODUCTION NOS. 1–42 REQUEST FOR PRODUCTION NO. 1 Request: Produce all documents relating to the design, development, engineering, and testing of the PrecisionEdge™ PE-5000 Series trocar assembly, including but not limited to design specifications, engineering drawings, CAD files, prototypes, and testing reports. Objections: Solstice objects to this Request on the