Contract analysis

1. Northwind is requested to produce all responsive documents in its possession, custody, or control, including documents held by its officers, directors, employees, agents, attorneys (to the extent not subject to a valid claim of attorney-client privilege or work product protection), accountants, consultants, brokers, and other representatives, whether located in the United States or abroad.

2. Documents shall be produced either as they are kept in the ordinary course of business or organized and labeled to correspond with the categories in each request, in accordance with CPLR § 3120.

3. If any document responsive to any request is withheld in whole or in part on the basis of attorney-client privilege, work product protection, or any other privilege or protection, Northwind shall provide a privilege log in accordance with CPLR § 3122, setting forth for each withheld document the following information: (a) the date of the document; (b) the author(s) of the document; (c) the recipient(s) and all per

4. If any document responsive to any request has been lost, destroyed, discarded, or is otherwise no longer in Northwind's possession, custody, or control, Northwind shall identify the document to the extent possible, describe its contents and subject matter, state the date or approximate date of its loss or destruction, and explain the circumstances under which the document was lost, destroyed, or became unavailable

5. Electronically stored information ("ESI") shall be produced in native format or in single-page TIFF images with extracted text and full metadata (including but not limited to author, date created, date modified, file name, and custodian), in accordance with the parties' ESI protocol, if one has been agreed upon, or in accordance with the Commercial Division's Guidelines for discovery of Electronically Stored Infor

6. Each request shall be construed independently and not by reference to any other request for purposes of limitation. No request shall be construed as limiting the scope of any other request.

7. If any request is deemed ambiguous by Northwind, Northwind is requested to contact the undersigned counsel to discuss the request before interposing an objection, in the spirit of the cooperation contemplated by the Commercial Division Rules. DOCUMENT REQUESTS REQUEST NO. 1: The Charter-Party and All Amendments Produce all drafts, executed copies, amendments, addenda, side letters, riders, recaps, fixture notes, a