UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
VANTOR HOLDINGS CORP.,
Plaintiff,
v.
STONEFIELD LOGISTICS GROUP INC.,
Defendant.
Case No. 22-cv-07841 (MTC)
Hon. Margaret T. Calloway, U.S.D.J.
DEFENDANT STONEFIELD LOGISTICS GROUP INC.'S SUBPOENA DUCES TECUM TO NON-PARTY CASCADE FREIGHT SYSTEMS INC. PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 45
Date Issued: June 28, 2023
Prepared by: Simone Laroche, Associate Calderwood & Harkness LLP 200 Park Avenue, 38th Floor New York, New York 10166
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
(Pursuant to AO 88A / AO 88B)
I. SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
A. Issuing Court
United States District Court for the Southern District of New York, 500 Pearl Street, New York, New York 10007.
B. Party on Whose Behalf This Subpoena Is Issued
This subpoena is issued on behalf of Defendant Stonefield Logistics Group Inc.
C. Non-Party Recipient of Subpoena
To: Cascade Freight Systems Inc. 4700 Lakehurst Court Columbus, OH 43016 (An Ohio corporation)
D. Command
YOU ARE COMMANDED to produce at the time, date, and place set forth below the following documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the material:
All documents and electronically stored information ("ESI") described in Attachment A to this Subpoena, which is incorporated herein by reference in its entirety. You are to produce such documents and ESI at the time, date, and place specified below, or to mail legible copies of such documents and ESI to the attorney identified below on or before the date specified. Production may also be accomplished by electronic means as set forth in Attachment A, Instruction B.5.
E. Place for Production
Calderwood & Harkness LLP 200 Park Avenue, 38th Floor New York, New York 10166
Attention: Simone Laroche
F. Date and Time for Production
On or before July 28, 2023 (thirty (30) days from the date of service of this Subpoena).
G. Issuing Attorney Information
Simone Laroche (N.Y. Bar No. SL-5297814) Calderwood & Harkness LLP 200 Park Avenue, 38th Floor New York, New York 10166 Telephone: (212) 558-4700 Facsimile: (212) 558-4701
Email: slaroche@calderwoodharkness.com
Counsel for Defendant Stonefield Logistics Group Inc.
H. Signature
The undersigned attorney is authorized to issue and sign this subpoena on behalf of the United States District Court for the Southern District of New York pursuant to Federal Rule of Civil Procedure 45(a)(3), as an attorney authorized to practice in this Court.
CALDERWOOD & HARKNESS LLP
By: ________
Simone Laroche (N.Y. Bar No. SL-5297814) Associate Counsel for Defendant Stonefield Logistics Group Inc.
Date: June 28, 2023
NOTICE: Failure to comply with this Subpoena may subject you to penalties for contempt of court. If you have questions about your obligations under this Subpoena, you should consult an attorney. See Attachment B for a summary of your rights and obligations under Federal Rule of Civil Procedure 45.
II. PROOF OF SERVICE
PROOF OF SERVICE OF SUBPOENA
This Subpoena for Cascade Freight Systems Inc. was received by me on the date indicated below.
Date of Service: ________
Manner of Service:
Personal Service (hand-delivered to an officer, managing or general agent, or other agent authorized by appointment or by law to receive service of process on behalf of Cascade Freight Systems Inc.)
Certified Mail, Return Receipt Requested (mailed to Cascade Freight Systems Inc., 4700 Lakehurst Court, Columbus, OH 43016)
Other (describe): ________
Name of Person Served: ________
Title of Person Served (if applicable): ________
Fees and Mileage Tendered: Yes No
If yes, amount: $________
Declaration of Server
I declare under penalty of perjury under the laws of the United States that the foregoing information is true and correct.
________________________________________
Signature of Server
________________________________________
Printed Name of Server
________________________________________
Address of Server
________________________________________
Date
III. NOTICE TO ALL PARTIES PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 45(a)(4)
NOTICE OF ISSUANCE AND SERVICE OF SUBPOENA DUCES TECUM TO NON-PARTY CASCADE FREIGHT SYSTEMS INC.
A. Notice of Subpoena
Pursuant to Federal Rule of Civil Procedure 45(a)(4), Defendant Stonefield Logistics Group Inc. ("Stonefield" or "Defendant") hereby provides notice to all parties in this action that the attached Subpoena Duces Tecum has been issued and served upon non-party Cascade Freight Systems Inc. ("Cascade"), an Ohio corporation with its principal place of business at 4700 Lakehurst Court, Columbus, OH 43016. The Subpoena commands Cascade to produce certain documents and electronically stored information, as more particularly described in Attachment A hereto, on or before July 28, 2023.
This Subpoena is issued in connection with the above-captioned civil action currently pending before the Honorable Margaret T. Calloway, United States District Judge, in the United States District Court for the Southern District of New York. The documents and information sought are relevant to the claims and defenses in this action and are proportional to the needs of the case.
B. Service of Notice
Copies of this Subpoena Duces Tecum, together with all attachments (Attachment A — Schedule of Documents and ESI to Be Produced; Attachment B — Obligations of the Non-Party Under FRCP 45), have been served upon the following counsel of record:
Counsel for Plaintiff Vantor Holdings Corp.:
Caldwell Royce & Shapiro LLP 1 Liberty Plaza, 22nd Floor New York, New York 10006
Attention: Jason Whitford, Senior Associate
Telephone: (212) 415-9300
Email: jwhitford@caldwellroyce.com
Note: Caldwell Royce & Shapiro LLP is counsel of record for Plaintiff Vantor Holdings Corp. as of the date of this notice, June 28, 2023. Service of notice upon this firm satisfies the requirements of Rule 45(a)(4).
C. Date of Notice
This notice is provided as of June 28, 2023, the same date as the issuance and service of the Subpoena Duces Tecum upon Cascade Freight Systems Inc.
IV. ATTACHMENT A — SCHEDULE OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION TO BE PRODUCED
ATTACHMENT A
SCHEDULE OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION TO BE PRODUCED BY CASCADE FREIGHT SYSTEMS INC.
A. Definitions. As used in the Document Requests set forth below, the following terms shall have the meanings indicated:
1. "Cascade" means Cascade Freight Systems Inc., including its current and former officers, directors, employees, agents, representatives, subsidiaries, affiliates, predecessors, and successors, and any person or entity acting on behalf of or at the direction of Cascade Freight Systems Inc.
2. "Stonefield" or "SLG" means Defendant Stonefield Logistics Group Inc., including its current and former officers, directors, employees, agents, representatives, subsidiaries, affiliates, predecessors, and successors, and any person or entity acting on behalf of or at the direction of Stonefield Logistics Group Inc.
3. "TSA" means the Transportation Services Agreement dated March 15, 2019 (Contract Reference No. SLG-VTS-2019-0315), entered into between Stonefield Logistics Group Inc. and Vantor Transport Services LLC, together with all schedules, exhibits, amendments, addenda, and side letters thereto.
4. "Lanes 8–14" means the origin-destination lane pairs designated as Lane 8, Lane 9, Lane 10, Lane 11, Lane 12, Lane 13, and Lane 14 in the TSA and/or in any contract, rate confirmation, load tender, or similar document between Cascade and Stonefield. For the avoidance of doubt, these lanes are classified as "Secondary Lanes" under Schedule C to the TSA and are not subject to the exclusivity provisions applicable to "Primary Lanes." As used herein, "Primary Lanes" refers to Lanes 1–7 and the corresponding designated origin-destination pairs as defined in Schedule C, Section 2(a) of the TSA. The term "Secondary Lanes" refers to all lane designations other than Primary Lanes, as set forth in Schedule C, Section 2(b) of the TSA, over which Stonefield retained the contractual right to engage alternative carriers without restriction.
5. "Relevant Period" means January 1, 2021 through March 31, 2022, inclusive.
6. "Document" or "Documents" shall have the broadest meaning ascribed to that term under Federal Rule of Civil Procedure 34(a), and includes, without limitation, all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information, and other data or data compilations — stored in any medium from which information can be obtained either directly or, if necessary, after translation by the responding party into a reasonably usable form. The term "Document" includes, but is not limited to, correspondence, memoranda, notes, reports, studies, analyses, presentations, spreadsheets, databases, calendars, appointment books, diaries, logs, ledgers, journals, financial records, contracts, agreements, purchase orders, invoices, receipts, checks, wire transfer records, and any drafts, revisions, or non-identical copies of the foregoing.
7. "Communication" or "Communications" means any transmission or exchange of information, whether oral, written, or electronic, between two or more persons, including but not limited to emails, text messages (SMS and MMS), letters, memoranda, instant messages (including messages sent via Northgate Data Systems, Meridian Solutions, or similar platforms), voicemails, and telephone calls (to the extent memorialized in any document, record, or log). Where a Communication is oral, the term refers to any document or record that memorializes, summarizes, confirms, or references the substance of such oral Communication.
8. "Relating to" or "Concerning" means directly or indirectly referring to, reflecting, constituting, describing, evidencing, pertaining to, mentioning, discussing, analyzing, or in any way bearing upon the subject matter in question, including any document that would be relevant to prove, disprove, or illuminate any fact at issue.
B. Instructions. The following instructions shall apply to each of the Document Requests set forth below:
1. Format of Production. Documents shall be produced in their native electronic format where possible. Where native production is not feasible or appropriate (e.g., for paper originals), documents shall be produced as single-page TIFF images (300 DPI minimum resolution) accompanied by extracted text (OCR where extracted text is unavailable) and all associated metadata in a standard load file compatible with Relativity or a similar litigation review platform. Load files should include, at a minimum, the following metadata fields where applicable: custodian, author, date created, date modified, date sent, date received, from, to, cc, bcc, subject, file name, file path, file extension, and file size. Email productions shall include all attachments grouped with their parent emails.
2. Privilege Log. If any document responsive to the requests below is withheld in whole or in part on the basis of any privilege, immunity, or other protection from disclosure (including, without limitation, the attorney-client privilege, the work product doctrine, or any other applicable privilege), Cascade shall provide a privilege log identifying each such document with sufficient particularity to enable the requesting party and the Court to evaluate the claim of privilege or protection. The privilege log shall include the following information for each withheld document:
(a) the date of the document;
(b) the author(s) or sender(s) of the document;
(c) all recipients and persons copied on the document;
(d) a description of the subject matter of the document sufficient to evaluate the claim of privilege, without revealing privileged information;
(e) the type of document (e.g., email, memorandum, letter, report);
(f) the specific privilege or protection asserted (e.g., attorney-client privilege, work product — fact, work product — opinion); and
(g) the factual basis for the asserted privilege or protection.
3. Organization of Production. Documents shall be produced as they are kept in the ordinary course of business, or organized and labeled to correspond to each category of request in this Attachment A. Each document shall be Bates-stamped with a unique, sequential production number, using the prefix "CASCADE" (e.g., CASCADE-000001, CASCADE-000002, etc.).
4. Conferral Regarding Burden or Scope. If Cascade contends that any request herein is unduly burdensome, overly broad, or otherwise objectionable, Cascade is requested to contact undersigned counsel promptly and in any event before the return date of this Subpoena to discuss the possibility of narrowing the scope of the request or reaching an accommodation concerning the manner of production, consistent with the obligations and protections set forth in Federal Rule of Civil Procedure 45(d). Defendant Stonefield Logistics Group Inc. is committed to engaging in good faith to minimize the burden on Cascade as a non-party while obtaining documents relevant to this litigation.
5. Method of Electronic Production. Production may be made electronically by uploading documents to the secure review platform maintained by Pinnacle Forensics LLC, which has been engaged by Defendant's counsel in connection with this litigation. The relevant project details are as follows:
Project ID: PF-SLG-2022-0914 Contact: Nathan Billings, Client Engagement Director Pinnacle Forensics LLC 12000 Findley Road, Suite 200 Johns Creek, GA 30097 Telephone: (770) 422-6100
Email: nbillings@pinnacleforensics.com
Alternatively, production may be made by any other mutually agreed secure electronic means (including encrypted file transfer or physical delivery of encrypted media). Cascade should contact undersigned counsel to coordinate the specific method of delivery.
C. Document Requests
REQUEST NO. 1:
All contracts, agreements, master service agreements, rate confirmations, rate schedules, amendments, addenda, supplements, change orders, statements of work, and any other binding or non-binding agreements or understandings between Cascade and Stonefield that were in effect at any time during the Relevant Period, including but not limited to any agreements governing the provision of truckload ("TL"), less-than-truckload ("LTL"), intermodal, or any other freight transportation, brokerage, or logistics services. This Request encompasses the initial executed versions of all such agreements as well as any subsequent modifications, renewals, extensions, or terminations thereof.
REQUEST NO. 2:
All load tenders, tender acceptances, tender rejections, bills of lading (including straight bills of lading and order bills of lading), delivery receipts, proof-of-delivery documents, and any related shipping or dispatch records for shipments transported by Cascade on behalf of Stonefield on Lanes 8–14 during the Relevant Period. This Request includes documents in any format, including electronic data interchange ("EDI") transaction sets (e.g., EDI 204 load tenders, EDI 990 responses, EDI 214 status updates, EDI 210 freight invoices), transportation management system ("TMS") records, and any paper-based equivalents.
REQUEST NO. 3:
All rate confirmations, pricing proposals, quotes, rate amendments, rate negotiations, and any other documents between Cascade and Stonefield that establish, propose, modify, or discuss the rates applicable to transportation services on Lanes 8–14 during the Relevant Period, including any documents reflecting the per-mile rate, flat rate, accessorial charges, fuel surcharge schedule, minimum charge, or other pricing structure applicable to each lane. This Request also includes any bid or request-for-proposal materials exchanged between Cascade and Stonefield pertaining to Lanes 8–14.
REQUEST NO. 4:
All Communications between Cascade and Stonefield (including, without limitation, communications with any SLG employee, agent, or representative, including but not limited to Janet Kirkwood, Vice President, Carrier Relations; Carlos Medina, Senior Vice President, Operations; and Raymond Hess, Director, Contract Compliance) during the Relevant Period Concerning or Relating to:
(a) the assignment, tendering, or allocation of freight volumes on Lanes 8–14, including any discussions regarding volume commitments, minimum tender requirements, or preferred carrier status;
(b) Cascade's capacity, equipment availability, driver availability, or willingness to accept freight on Lanes 8–14, including any discussions regarding capacity constraints, equipment repositioning, or seasonal fluctuations in availability;
(c) any discussion, reference, or mention of Vantor Holdings Corp., Vantor Transport Services LLC ("VTS"), or VTS's performance, capacity, reliability, or service levels on any lane, including any Communications in which Stonefield or Cascade discussed transitioning, reallocating, or diverting freight from VTS to Cascade or to any other carrier;
(d) any discussion, reference, or mention of lane designations, lane exclusivity, "Primary Lanes" versus "Secondary Lanes," or the scope or applicability of any exclusivity provisions in the TSA or any other agreement between Stonefield and VTS.
REQUEST NO. 5:
All internal Cascade documents, including but not limited to memoranda, reports, analyses, presentations, spreadsheets, dashboards, forecasts, strategic plans, business reviews, and board or management communications (including materials prepared for or presented at board meetings, executive committee meetings, or management review meetings), created or maintained during the Relevant Period Concerning or Relating to Cascade's business relationship with Stonefield, including but not limited to any documents reflecting the volume of shipments, revenue generated, profitability, margin analysis, cost allocation, or financial performance of freight handled by Cascade for Stonefield on Lanes 8–14. This Request also includes any account management plans, customer relationship summaries, or business development materials pertaining to the Cascade-Stonefield relationship.
REQUEST NO. 6:
All documents reflecting the specific origin-destination pairs (i.e., the geographic origin point and geographic destination point) for each shipment or load transported by Cascade on behalf of Stonefield during the Relevant Period on Lanes 8–14, in sufficient detail to demonstrate the lane assignment and routing of each such shipment. Without limiting the generality of the foregoing, this Request seeks documents sufficient to demonstrate that the lane designations applicable to Cascade's freight on Lanes 8–14 are distinct from and do not overlap with the fourteen (14) "Primary Lanes" designated in Schedule C, Section 2(a) of the TSA. Responsive documents may include load-level shipment data exports, origin-destination reports, lane analysis summaries, or similar records maintained in Cascade's transportation management system or operational databases.
REQUEST NO. 7:
All invoices, freight bills, payment records, remittance advices, accounts receivable records, payment ledgers, and any related financial documents reflecting payments made by Stonefield to Cascade for transportation services on Lanes 8–14 during the Relevant Period. This Request includes documents reflecting the amount invoiced, the date of invoice, the date of payment, any deductions or chargebacks applied, and any outstanding or disputed amounts.
REQUEST NO. 8:
All documents reflecting any request by Stonefield to Cascade to provide surge capacity, additional equipment, expedited or time-critical service, dedicated capacity, or any form of enhanced or expanded transportation services on any lane during the Relevant Period, including but not limited to any documents reflecting the circumstances, reasons, or justifications given by Stonefield for such requests. This Request also includes any Communications in which Stonefield discussed or referenced service disruptions, carrier performance failures, or capacity shortfalls experienced with other carriers as a reason for engaging Cascade's services.
REQUEST NO. 9:
All documents reflecting any lane-specific performance metrics, service level data, key performance indicator ("KPI") reports, on-time pickup rates, on-time delivery rates, transit time data, tender acceptance rates, tender rejection rates, cargo claims data, claims ratios, damage rates, loss rates, or customer scorecards for shipments handled by Cascade on behalf of Stonefield on Lanes 8–14 during the Relevant Period. This Request includes any performance review materials, quarterly business review presentations, or carrier scorecard reports exchanged between Cascade and Stonefield.
REQUEST NO. 10:
All documents reflecting Communications or negotiations between Cascade and Stonefield Concerning or Relating to any potential expansion of the business relationship between Cascade and Stonefield, addition of new lanes, increase in freight volumes, extension of contract terms, or broadening of the scope of services during the Relevant Period, including but not limited to any documents reflecting discussions about transitioning freight from other carriers (including but not limited to Vantor Transport Services LLC) to Cascade, or any documents reflecting Stonefield's expressed interest in increasing its reliance on Cascade as a carrier for freight previously handled by other service providers.
V. ATTACHMENT B — OBLIGATIONS OF THE NON-PARTY UNDER FEDERAL RULE OF CIVIL PROCEDURE 45
ATTACHMENT B
SUMMARY OF RIGHTS AND OBLIGATIONS OF NON-PARTY CASCADE FREIGHT SYSTEMS INC. UNDER FEDERAL RULE OF CIVIL PROCEDURE 45
The following is a summary of the principal rights and obligations of Cascade Freight Systems Inc. ("Cascade") as a non-party recipient of this Subpoena Duces Tecum. This summary is provided for informational purposes and is not a substitute for independent legal advice. Cascade is encouraged to consult with its own counsel regarding its rights and obligations under the Federal Rules of Civil Procedure and applicable law.
A. Duty to Respond
Under Federal Rule of Civil Procedure 45(d), a person commanded to produce documents or electronically stored information pursuant to a subpoena must comply with the subpoena by producing the requested documents on or before the return date specified in the subpoena, or by serving timely written objections as described in Section B below. Compliance with this Subpoena requires the production of all non-privileged, responsive documents in Cascade's possession, custody, or control as described in Attachment A on or before July 28, 2023, or within such other time as may be agreed upon by the parties or ordered by the Court.
Failure to comply with a lawfully issued subpoena may subject the non-party to sanctions, including a finding of contempt of court pursuant to Federal Rule of Civil Procedure 45(g). The Court may impose such sanctions as it deems appropriate, including monetary penalties, upon any person who fails without adequate excuse to obey a subpoena served upon that person.
B. Right to Object
Cascade may serve written objections to this Subpoena on undersigned counsel within fourteen (14) days after service of the Subpoena, or before the time specified for compliance, whichever is earlier. Written objections should be served upon:
Simone Laroche Calderwood & Harkness LLP 200 Park Avenue, 38th Floor New York, New York 10166
Email: slaroche@calderwoodharkness.com
If timely written objections are served, Cascade need not produce the documents to which objections have been made until the objections are resolved by agreement of the parties, by order of the Court, or by other appropriate means. The party serving the subpoena may move to compel production under Federal Rule of Civil Procedure 45(d)(2)(B)(i) if the objections are not resolved by agreement.
C. Motion to Quash or Modify
Cascade may, on timely motion, move the Court to quash or modify this Subpoena pursuant to Federal Rule of Civil Procedure 45(d)(3) if the Subpoena:
(i) fails to allow a reasonable time to comply;
(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);
(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies;
(iv) subjects a person to undue burden; or
(v) requires disclosure of a trade secret or other confidential research, development, or commercial information.
Any such motion should be filed promptly and, if possible, before the return date of the Subpoena. Undersigned counsel is willing to discuss any concerns Cascade may have regarding the scope or burden of this Subpoena prior to any formal motion practice. Counsel for Defendant Stonefield Logistics Group Inc. is committed to resolving any such concerns cooperatively and in a manner that minimizes the burden on Cascade as a non-party, consistent with the Court's obligations under Rule 45(d)(1) to avoid imposing undue burden or expense on a person subject to a subpoena.
D. Protection of Privileged Information
If any document responsive to the requests contained in Attachment A is withheld in whole or in part on the grounds of any privilege, immunity, or other protection from disclosure (including but not limited to the attorney-client privilege, the work product doctrine, or any other applicable privilege or protection), Cascade must provide a privilege log as described in Attachment A, Instruction B.2. The privilege log must be provided on or before the return date of this Subpoena, or at such other time as may be agreed upon by the parties.
In the event that Cascade inadvertently produces documents that are protected by privilege, the provisions of Federal Rule of Civil Procedure 26(b)(5)(B) and Federal Rule of Evidence 502(b) shall apply. Cascade should promptly notify undersigned counsel of any claim that inadvertently produced materials are privileged, and upon such notification, Defendant will sequester and return, destroy, or otherwise handle such materials in accordance with applicable law and any Stipulated Protective Order entered in this action.
E. Reimbursement of Costs
Defendant Stonefield Logistics Group Inc. acknowledges that Cascade is a non-party to this litigation and recognizes Cascade's right to reimbursement for the reasonable costs of compliance with this Subpoena. Defendant will reimburse Cascade for reasonable costs incurred in connection with searching for, collecting, reviewing, and producing responsive documents, including reasonable copying costs, data processing costs, and media costs, upon Cascade's submission of an itemized invoice documenting such costs. Cascade is encouraged to contact undersigned counsel to discuss the anticipated costs of compliance prior to incurring significant expense, so that the parties may agree upon a reasonable approach to cost reimbursement.
Any invoice for reimbursement of costs should be directed to:
Simone Laroche Calderwood & Harkness LLP 200 Park Avenue, 38th Floor New York, New York 10166
Email: slaroche@calderwoodharkness.com
VI. CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
I, Simone Laroche, an associate at Calderwood & Harkness LLP and counsel for Defendant Stonefield Logistics Group Inc. in the above-captioned action, hereby certify that on June 28, 2023, a true and correct copy of the foregoing Subpoena Duces Tecum to Non-Party Cascade Freight Systems Inc., together with Attachment A (Schedule of Documents and Electronically Stored Information to Be Produced) and Attachment B (Obligations of the Non-Party Under FRCP 45), was served upon the following:
Service on Non-Party
Cascade Freight Systems Inc. 4700 Lakehurst Court Columbus, OH 43016
Method of Service: Certified Mail, Return Receipt Requested, and by contemporaneous transmission via email to Cascade's registered agent and general counsel's office.
Witness fees and mileage, as required by Federal Rule of Civil Procedure 45(b)(1), were tendered concurrently with service.
Notice to Parties
Caldwell Royce & Shapiro LLP (Counsel for Plaintiff Vantor Holdings Corp.) 1 Liberty Plaza, 22nd Floor New York, New York 10006
Attention: Jason Whitford, Senior Associate
Method of Service: Via the Court's ECF electronic filing system, which constitutes service on all registered parties, and by contemporaneous transmission via email to jwhitford@caldwellroyce.com.
CALDERWOOD & HARKNESS LLP
By: ________
Simone Laroche (N.Y. Bar No. SL-5297814) Associate 200 Park Avenue, 38th Floor New York, New York 10166 Telephone: (212) 558-4700
Email: slaroche@calderwoodharkness.com
Counsel for Defendant Stonefield Logistics Group Inc.
Dated: June 28, 2023