Contract analysis

I. Purpose and Introduction This letter accompanies the supplemental document production of Cascade Retail Holdings Inc. ("Cascade" or "CRH") in response to the Civil Investigative Demand ("CID") issued by the Washington State Attorney General's Office, Consumer Protection Division (the "Division"), on March 26, 2024, pursuant to the authority granted under RCW 19.86.110 of the Washington Consumer Protection Act. Cal

II. Description of Supplemental Production Cascade is producing approximately 8,700 additional documents with this supplemental production (the "Second Production"). Combined with the approximately 12,400 documents produced to the Division on April 23, 2024 as part of the First Production, the cumulative production now totals approximately 21,100 documents. Cascade has endeavored to identify, collect, review, and pro

III. Bates-Range Summary and Organization The supplemental production bears Bates numbers sequentially continuing from the First Production. The First Production encompassed documents bearing Bates stamps CRH-CID-000001 through CRH-CID-012437. The Second Production encompasses documents bearing Bates stamps CRH-CID-012438 through CRH-CID-021109. Consistent with the organizational methodology employed in the First Pro

IV. Updated Privilege Log An updated privilege log accompanies this production and is enclosed herewith. The privilege log identifies all documents that have been withheld in full or redacted in part on the basis of attorney-client privilege, the work-product doctrine, or both. The updated privilege log includes, in addition to entries carried forward from the First Production privilege log, entries reflecting commun

V. Reference to May 14, 2024 Meet-and-Confer Cascade acknowledges the productive meet-and-confer conference held on May 14, 2024, between representatives of Calderwood & Harkness — specifically, Alan Ngo (responsible partner) and Patrick Gallagher (lead associate) — and representatives of the Division — specifically, Meredith Calloway-Voss (Lead Assistant Attorney General), Jordan A. Kittridge (Investigating Assistan

VI. Cascade's Willingness to Negotiate an Assurance of Voluntary Compliance Cascade hereby confirms its willingness to engage in good-faith negotiation of an Assurance of Voluntary Compliance ("AVC") as discussed during the May 14, 2024 meet-and-confer conference. Cascade takes the concerns raised by the Division seriously and is committed to maintaining pricing practices that comply fully with the Washington Consume

VII. Completeness of Production and Continuing Obligations Cascade believes that this supplemental production, together with the April 23, 2024 initial production, substantially completes its document-production obligations under the CID. Cascade has conducted a thorough and diligent search for responsive documents across all relevant custodians, departments, and data repositories identified in the CID's specificatio

VIII. Reservation of Rights This production is made without waiver of any objections to the CID's scope, relevance, burden, or proportionality that Cascade may have raised in its initial response to the CID, or that Cascade may raise in the future. Cascade expressly preserves and does not waive any such objections by making this production. The production of documents in response to the CID does not constitute, and s

IX. Contact Information and Closing We invite the Division to direct any questions regarding this production, the accompanying privilege log, or any other aspect of Cascade's response to the CID to the undersigned, Patrick Gallagher, or to Alan Ngo, the responsible partner on this matter, at the contact information provided below: Patrick Gallagher, Associate Calderwood & Harkness LLP 1201 Third Avenue, Suite 4400 Se

1. Supplemental Document Production (approximately 8,700 documents; Bates Nos. CRH-CID-012438 through CRH-CID-021109)

3. Bates-Range Index by CID Request Number cc: Alan Ngo, Partner, Calderwood & Harkness LLP (responsible partner) cc: Diana Prescott-Levy, General Counsel, Cascade Retail Holdings Inc. cc: Jordan A. Kittridge, Investigating Assistant Attorney General, Consumer Protection Division, Office of the Attorney General, State of Washington