Contract analysis

I. INTRODUCTORY PARAGRAPH Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Defendants Cascade Retail Holdings Inc. ("Cascade" or "CRH") and Pinnacle Market Group Inc. ("Pinnacle" or "PMG") (collectively, "Defendants"), by and through their undersigned counsel, hereby propound their First Set of Requests for Production of Documents to Plaintiff Federal Trade Commission ("FTC" or "Plaintiff"). Defen

II. DEFINITIONS As used in these Requests for Production, the following terms have the meanings specified below. These definitions are intended to be construed broadly and in accordance with the Federal Rules of Civil Procedure. A. "Document" or "Documents" shall have the broadest meaning ascribed to that term under Fed. R. Civ. P. 34(a) and shall include, without limitation, all writings, communications, memoranda,

I. "Third Party" or "Third Parties" shall mean any person or entity other than the FTC, Cascade, or Pinnacle, including but not limited to competitors, customers, consumers, sellers, merchants, vendors, trade associations, industry analysts, market research firms, consultants, academics, journalists, and any other non-party to this litigation. J. "IOSA" shall mean the Independent Online Sellers Alliance, a 501(c)(6)

III. INSTRUCTIONS A. Scope of Production. The FTC is requested to produce all responsive, non-privileged documents in its possession, custody, or control. For purposes of this instruction, the FTC's "possession, custody, or control" includes documents held by or accessible to the Bureau of Competition (including the Mergers IV Division and all other divisions), Bureau of Economics, Bureau of Consumer Protection, Offi

IV. REQUESTS FOR PRODUCTION REQUEST NO. 1 — The FTC Complaint and Administrative Complaint Produce all documents constituting, supporting, or relating to the preparation, drafting, review, editing, and filing of the Complaint for Temporary Restraining Order and Preliminary Injunction in this action (Case No. 2:25-cv-01087-RAJ, Dkt. No. 1) and the Administrative Complaint (FTC Docket No. 9438), including without limit

V. CERTIFICATION AND SIGNATURE BLOCK Respectfully submitted this 14th day of July, 2025. CALDERWOOD & HARKNESS LLP By: ________ Howard Bellamy Responsible Partner Calderwood & Harkness LLP 1401 K Street NW, Suite 1200 Washington, D.C. 20005 Telephone: (202) 555-4100 Facsimile: (202) 555-4101 Email: hbellamy@calderwoodharkness.com Elaine Forsythe Billing Partner Calderwood & Harkness LLP 1401 K Street NW, Suite 1200 W

VI. CERTIFICATE OF SERVICE I, Elliot Nguyen, hereby certify that on July 14, 2025, a true and correct copy of the foregoing Defendants' First Set of Requests for Production of Documents to Plaintiff Federal Trade Commission was served upon the following counsel of record by the means indicated