Contract analysis

I. PRELIMINARY STATEMENT Defendant Cascade Retail Holdings Inc. ("Cascade" or "Defendant"), a Delaware corporation with its principal place of business and corporate headquarters located at 2200 Elliott Avenue West, Suite 1400, Seattle, Washington 98119, and publicly traded on the Nasdaq Global Select Market under the ticker symbol "CRHI," by and through its attorneys of record, Calderwood & Harkness LLP, 600 South G

II. GENERAL OBJECTIONS Cascade hereby asserts the following General Objections, which are incorporated by reference into each individual response set forth below. The assertion of a General Objection does not mean that the objection is applicable to every request; rather, each General Objection is asserted to the extent that it is applicable to any particular request.

1. Attorney-Client Privilege and Work Product Doctrine. Cascade objects to each and every request to the extent it calls for the production of documents or information that is protected by the attorney-client privilege and/or the attorney work product doctrine under California Code of Civil Procedure section 2018.010 et seq. and applicable case law. No document that is protected by any applicable privilege or immunit

2. Relevance and Proportionality. Cascade objects to each and every request to the extent it seeks documents that are not relevant to any party's claim or defense in this action or is not proportional to the needs of the case, as required by California Code of Civil Procedure section 2017.010 and the principles articulated by the courts of this state. In assessing proportionality, Cascade has considered the importanc

3. Overbreadth and Undue Burden. Cascade objects to each and every request to the extent it is overbroad in scope, temporal range, or subject matter, or to the extent that compliance would impose an undue burden or expense on Cascade that is disproportionate to the needs of the case. Cascade is a large, publicly traded retail corporation that operates more than 340 retail locations across 22 states and maintains a ma

4. Vagueness and Ambiguity. Cascade objects to each and every request to the extent it uses terms that are vague, ambiguous, or undefined, such that Cascade cannot reasonably determine the scope of documents sought. Where Cascade has nevertheless responded to such requests, it has done so based on its reasonable interpretation of the request, and that interpretation shall not be deemed a concession that the request i

5. Third-Party Privacy and Confidentiality. Cascade objects to each and every request to the extent it seeks information that is confidential, proprietary, or constitutes trade secrets belonging to Cascade or to third parties, including but not limited to suppliers, customers, employees, and business partners. Production of such information is subject to any protective order entered by the Court, including the Stipul

6. Documents Equally Available. Cascade objects to each and every request to the extent it seeks documents that are equally available to Vantor, that are in the public domain, or that are in the possession, custody, or control of third parties and can be obtained directly from those third parties through appropriate discovery mechanisms. Cascade is not required to act as a conduit for the production of third-party do

7. Continuing Obligation. These responses are based on information reasonably available to Cascade as of the date hereof. Cascade's investigation and document review are ongoing. Cascade expressly reserves the right to supplement, amend, or correct these responses as additional information or documents become available, and will do so in accordance with its obligations under the California Code of Civil Procedure and

III. DEFINITIONS AND INTERPRETIVE NOTES For purposes of these responses, the following terms shall have the meanings set forth below: "Project Atlas" refers to the internal Cascade initiative launched in or about February 2021 to identify, evaluate, and onboard new suppliers across the home goods, consumer electronics accessories, and personal care product categories. Project Atlas was led by Annika Bergström, Vice P

IV. RESPONSES TO INDIVIDUAL REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1 Request: All documents relating to the planning, development, approval, implementation, and/or execution of the initiative known as "Project Atlas." Objections: Cascade objects to this request on the grounds of overbreadth to the extent the request seeks "all documents relating to" Project Atlas without limitation. Project Atlas was a br