Contract analysis

I. INTRODUCTORY STATEMENT Defendant Nexford Industrial Holdings Inc. ("Nexford" or "Defendant"), by and through its attorneys, Calderwood & Harkness LLP, 200 South Wacker Drive, Suite 4400, Chicago, Illinois 60606, hereby responds and objects to Plaintiff Cardinal Peak Industries' ("Cardinal Peak" or "Plaintiff") First Request for Production of Documents ("Requests"), served on Defendant on November 28, 2022, pursuan

II. GENERAL OBJECTIONS Nexford sets forth the following General Objections, each of which is incorporated by reference into every specific response set forth below as if fully stated therein. The assertion of these General Objections does not waive any specific objections set forth in the individual responses, and the specific objections set forth in the individual responses do not waive these General Objections. A.

III. RESPONSE TO DEFINITIONS AND INSTRUCTIONS Nexford has reviewed the Definitions and Instructions set forth in Plaintiff's First Request for Production of Documents. Nexford adopts Plaintiff's definitions to the extent such definitions are not inconsistent with these General Objections and are not themselves overbroad or unduly burdensome. Where Plaintiff has not defined a term, Nexford interprets such term in its

IV. SPECIFIC RESPONSES TO REQUESTS FOR PRODUCTION REQUEST NO. 1 Request: All documents constituting or relating to the Master Supply Agreement dated January 15, 2020, between Cardinal Peak Industries and Nexford Industrial Holdings Inc. (MSA-NIH-CPI-2020-001), including all exhibits, amendments, supplements, and addenda thereto. Response: Nexford objects to this Request to the extent the phrase "relating to" is vague

V. PRIVILEGE LOG RESERVATION Nexford will provide a privilege log in compliance with Illinois Supreme Court Rule 201(n) identifying all documents withheld in whole or in part on the basis of the attorney-client privilege, the common interest privilege, the work product doctrine, or any other applicable privilege or protection. The privilege log will include sufficient information to enable Plaintiff and the Court to

VI. DOCUMENT PRODUCTION FORMAT Documents responsive to the Requests will be produced in electronic format, consisting of single-page TIFF images with corresponding load files (including Concordance and Relativity load files) and extracted or OCR-generated text files, in accordance with the parties' agreed-upon discovery protocols and any applicable standing orders of this Court regarding electronically stored informa

VII. RESERVATION OF RIGHTS Nexford expressly reserves the right to supplement, amend, or correct these Responses and Objections in accordance with its continuing obligations under Illinois Supreme Court Rules 214 and 201 through 218, as additional information and documents become available through ongoing investigation, discovery, and review. The production of documents in response to any Request shall not constitute