Contract analysis

I. Issuing Court Information Issuing Court: United States District Court for the Western District of Washington Court Address: 700 Stewart Street, Seattle, WA 98101 Case Number: 2:25-cv-01087-RAJ Case Caption: Federal Trade Commission v. Cascade Retail Holdings Inc. and Pinnacle Market Group Inc.

II. Identity of the Party Issuing the Subpoena This Subpoena Duces Tecum is issued on behalf of Defendants Cascade Retail Holdings Inc. and Pinnacle Market Group Inc. by and through their undersigned counsel of record. Prepared by: Aaron Liu, Associate Calderwood & Harkness LLP 555 California Street, Suite 2700 San Francisco, CA 94104 Telephone: (415) 782-4400 Facsimile: (415) 782-4401 Email: aliu@calderwoodharkness.

III. Recipient / Entity Commanded TO: Nomad Shops LLC 45 Main Street, Suite 700 Brooklyn, NY 11201 Nomad Shops LLC is a Delaware limited liability company that operates a curated artisan and small-business online marketplace platform. According to the Federal Trade Commission's Complaint filed in this action at paragraph 42, Nomad Shops LLC holds approximately 14.6% of U.S. online marketplace platform gross merchandi

IV. Command YOU ARE HEREBY COMMANDED, pursuant to Federal Rule of Civil Procedure 45, to produce the documents and electronically stored information ("ESI") described in Attachment A (Schedule of Document Requests) to the offices of: Calderwood & Harkness LLP 555 California Street, Suite 2700 San Francisco, CA 94104 Attention: Aaron Liu or, alternatively, via secure electronic transfer to a designated document reposi

V. Date of Issuance Date of Issuance: July 14, 2025 This date of issuance is consistent with the Scheduling Order entered by the Honorable Richard A. Johannsen on May 19, 2025 (Dkt. No. 47), which provides that fact discovery shall close on August 4, 2025, and that subpoenas to non-parties for document production must be served no later than twenty-one (21) days prior to the close of fact discovery.

VI. Signature — Officer of the Court This Subpoena is issued by the undersigned attorney as an officer of the Court authorized to issue subpoenas under Federal Rule of Civil Procedure 45(a)(3). The undersigned is an attorney admitted pro hac vice in the Western District of Washington and is authorized to practice before the Court in this matter. CALDERWOOD & HARKNESS LLP By: ________ Aaron Liu Associate Calderwood &

VII. Notice of Service on All Parties Pursuant to Federal Rule of Civil Procedure 45(a)(4), the undersigned hereby certifies that notice of this Subpoena Duces Tecum has been served on all parties in this action prior to or contemporaneously with service of the Subpoena on Nomad Shops LLC. Notice has been provided to the following counsel: Counsel for Plaintiff Federal Trade Commission: Claire Dunmore, Lead Trial Att

1. Governing Rules. Production pursuant to this Subpoena shall be made in accordance with Federal Rule of Civil Procedure 45, the Federal Rules of Civil Procedure generally, and the Local Rules of the United States District Court for the Western District of Washington. Nomad is directed to the provisions of Rule 45(d) and (e) regarding its duties in responding to this Subpoena.

2. Organization of Production. Documents shall be produced either (a) as they are kept in the ordinary course of business, with sufficient information to identify the custodian, source, and file location of each document, or (b) organized and labeled to correspond to each Document Request in this Attachment A. If documents are responsive to more than one Document Request, they need be produced only once, but Nomad sh

3. Privilege Log. If any document responsive to any Document Request is withheld in whole or in part on grounds of attorney-client privilege, work-product protection, or any other applicable privilege or protection, Nomad shall provide a privilege log identifying each withheld document with sufficient detail to enable the requesting party to assess the claim of privilege. The privilege log shall include, at a minimum

4. Relevant Period. Unless otherwise specified in a particular Document Request, the Relevant Period for all requests is January 1, 2022 through the date of production. This Relevant Period is designed to capture documents from the period preceding and during the negotiation of the Proposed Transaction, as well as documents reflecting the competitive dynamics of the online marketplace platform industry during the tim

5. Objections and Narrow Construction. If any Document Request is objected to as overbroad, unduly burdensome, or otherwise improper, Nomad is requested to (a) produce all documents responsive to the Document Request as reasonably and narrowly construed by Nomad, and (b) state with specificity the grounds for any objection, including the specific terms or aspects of the Document Request to which objection is made and

6. Previously Produced Documents. Documents that Nomad has previously produced to the FTC in connection with the FTC's pre-complaint investigation (File No. 251-0089), the FTC's administrative proceeding (Docket No. 9438), or any other aspect of the FTC's review of the Proposed Transaction need not be reproduced to Defendants, provided that Nomad identifies such documents by Bates number, production reference number,

7. Continuing Obligation. Nomad is requested to supplement its production if additional responsive documents are identified or come into existence after the initial date of production but before the close of fact discovery in this action (currently August 4, 2025).

8. Contact Information. Any questions regarding this Subpoena or the Document Requests contained herein should be directed to Aaron Liu at (415) 782-4400 or aliu@calderwoodharkness.com, or to Howard Bellamy at (202) 661-8800 or hbellamy@calderwoodharkness.com. DOCUMENT REQUESTS Request No. 1: Marketplace Platform Operations — General Produce all Documents Concerning Nomad's online marketplace platform operations duri

1. General Format All documents shall be produced in electronic format. Paper documents, if any, shall be scanned and produced electronically in accordance with these specifications. Nomad may produce documents using any of the following methods: (a) TIFF Production: Documents shall be produced as single-page TIFF images (Group IV, 300 dpi, black and white or color as appropriate) accompanied by extracted text files

2. Bates Numbering Each page of each produced document shall be assigned a unique, sequential Bates number. Bates numbers shall be stamped on each TIFF image or, in the case of native file production, identified in the load file associated with each document. The Bates numbering prefix shall be "NOMAD-" followed by a sequential numeric identifier with leading zeros sufficient to accommodate the total volume of produc

3. Email Production Email documents shall be produced together with all attachments as family groups. The parent email and all associated attachments shall be linked in the load file so that the family relationship is preserved. Email metadata fields shall include, at a minimum: To, From, CC, BCC, Date Sent, Time Sent, Subject, Attachment File Names, and Custodian.

4. Metadata For all produced documents, the following metadata fields shall be captured and included in the production load file, to the extent reasonably available: • Bates Begin / Bates End • Custodian • Author • Date Created • Date Modified • Date Sent (for emails) • Date Received (for emails) • To / From / CC / BCC (for emails) • Subject (for emails) • File Name • File Extension • File Path • File Size • MD5 or S

5. De-Duplication Nomad may de-duplicate documents across custodians based on MD5 or SHA-1 hash values, provided that all custodians who possessed a copy of a de-duplicated document are identified in the load file. De-duplication within email families (i.e., removal of duplicate emails within a single email thread) is not permitted; all emails in a thread shall be produced individually.

6. Date Range Filters Documents may be filtered by the Relevant Period (January 1, 2022 through the date of production) based on the "Date Created," "Date Modified," or "Date Sent" metadata fields, as applicable. If Nomad applies date range filters, Nomad shall disclose the specific filtering methodology and date fields used.

7. Custodian Identification Each produced document shall be identified by custodian in the load file. If a document was collected from a shared drive, shared mailbox, or other non-custodial source, the source shall be identified in the load file.

8. Confidentiality Designations Documents may be designated as "CONFIDENTIAL," "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY," or "HIGHLY CONFIDENTIAL — SOURCE CODE" in accordance with the Stipulated Protective Order entered in Case No. 2:25-cv-01087-RAJ on June 9, 2025 (Dkt. No. 52). Confidentiality designations shall be applied by stamping the designation on TIFF images or PDF pages and by including the designation i

9. Delivery Method Production may be delivered via: (a) secure electronic transfer using a mutually agreed-upon file transfer protocol (such as Crestline Technologies, box, Aldermere Systems, or other secure cloud-based repository); or (b) encrypted external hard drive or USB device, shipped via tracked overnight courier to Calderwood & Harkness LLP, 555 California Street, Suite 2700, San Francisco, CA 94104, Attenti

10. Production Cover Letter Each production shall be accompanied by a cover letter identifying: (a) the date of production; (b) the total number of documents and pages produced; (c) the Bates number range of the production; (d) the custodians and non-custodial sources included in the production; (e) any limitations, qualifications, or objections applicable to the production; and (f) the confidentiality designations a

1. Right to Object. Nomad Shops LLC has the right to serve written objections to this Subpoena on the issuing party. Any objections must be served before the earlier of: (a) the time specified for compliance with the Subpoena (i.e., twenty-one days following service), or (b) fourteen (14) days after service of the Subpoena. If Nomad serves timely written objections, the issuing party may not inspect, copy, test, or s

2. Right to Move to Quash or Modify. Nomad Shops LLC has the right to move the Court to quash or modify this Subpoena pursuant to Federal Rule of Civil Procedure 45(d)(3). The Court must quash or modify a subpoena that: (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits specified in Rule 45(c); (iii) requires disclosure of privileged or other protected matt

3. Protection from Undue Burden. This Subpoena must not impose undue burden on Nomad Shops LLC. If compliance with this Subpoena would impose undue burden or require the disclosure of trade secrets or other confidential research, development, or commercial information, Nomad Shops LLC may move to quash or modify the Subpoena or may seek a protective order under Federal Rule of Civil Procedure 26(c). The issuing party