Contract analysis

I. PRELIMINARY STATEMENT Defendant Cascade Retail Holdings Inc. ("Cascade" or "CRH") hereby propounds its First Set of Requests for Production of Documents, Set One, to Plaintiff Vantor Holdings Corp. ("Vantor" or "VHC") pursuant to California Code of Civil Procedure Sections 2031.010 through 2031.060. These Requests are served in connection with the Complaint filed by Vantor on September 7, 2021, in which Vantor all

II. DEFINITIONS As used in these Requests for Production, the following terms shall have the meanings set forth below. These definitions are intended to be read in conjunction with the Instructions set forth in Section III, and all terms shall be construed broadly to effectuate the fullest permissible scope of discovery under the California Code of Civil Procedure. 1. "Vantor," "You," or "Your" shall mean Vantor Hold

III. INSTRUCTIONS The following instructions apply to each of the Requests for Production set forth in Section IV below and shall be read in conjunction with the Definitions set forth in Section II. Instruction 1 — Scope of Production. These Requests seek documents in Vantor's possession, custody, or control. As used herein, "possession, custody, or control" means that the document is in Vantor's physical possession,

IV. REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST NO. 1: Exclusive Supply Agreements (Full Executed Copies) All fully executed copies of the Hemsworth Agreement (executed on or about March 15, 2019), the Tridale Agreement (executed on or about January 10, 2020), and the Orion Agreement (executed on or about July 1, 2018), including all exhibits, schedules, appendices, amendments, addenda, side letters, riders, and mod

V. VERIFICATION / DECLARATION DECLARATION OF PROPOUNDING PARTY I, Douglas Carmichael, am a Partner at Calderwood & Harkness LLP and counsel of record for Defendant Cascade Retail Holdings Inc. in the above-captioned action. I hereby declare, under penalty of perjury under the laws of the State of California, that the foregoing Requests for Production of Documents, Set One, have been propounded in good faith, are reas

VI. PROOF OF SERVICE PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of eighteen (18) and not a party to the within action. My business address is Calderwood & Harkness LLP, 600 South Grand Avenue, Suite 3200, Los Angeles, CA 90071. On March 15, 2022, I served the foregoing document described as: DEFENDANT CASCADE RETAIL HO