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PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION

LITIGATION HOLD NOTICE

DOCUMENT PRESERVATION DIRECTIVE

This communication is protected by the attorney-client privilege and the work product doctrine. It is intended solely for the use of the addressees identified herein. Any unauthorized review, use, disclosure, or distribution is strictly prohibited. If you have received this notice in error, contact Calderwood & Harkness LLP immediately.

FROM: Calderwood & Harkness LLP 1301 K Street NW, Suite 1200 Washington, DC 20005 — on behalf of Cascade Retail Holdings Inc.

PREPARED BY: Bernard Crawford, Responsible Partner, and James Underwood, Lead Associate Labor & Employment Practice Group

ADDRESSED TO: All employees and officers of Cascade Retail Holdings Inc. ("CRH") who may possess, control, or have access to relevant documents and information, as further described herein

DATE: February 19, 2025

RE: Litigation Hold — Preservation of Documents and Electronically Stored Information Related to the Departure of Priya Rathore and Seven Other Former Merchandising Division Employees and Related Claims Against Verdana Commerce Group, Inc.

MATTER REFERENCE: Calderwood & Harkness LLP Matter No. 1038-00006

DISTRIBUTION DIRECTIVE: This notice is to be distributed by Theresa Yun-Park, General Counsel, and Roland Ashby, Chief People Officer, to all CRH employees identified on the attached distribution list, including but not limited to all current and former employees of the Merchandising Division, Information Technology Department, Human Resources Department, Legal Department, Finance Department, and the Office of the CEO. Each department head or functional leader receiving this notice shall ensure that all relevant personnel within his or her area of responsibility receive a copy of this notice and acknowledge its receipt in accordance with Section X below.

I. PURPOSE OF THIS NOTICE

Cascade Retail Holdings Inc. ("CRH" or the "Company") has retained outside counsel, Calderwood & Harkness LLP, in connection with anticipated and likely litigation arising from the coordinated resignation of eight senior employees of CRH's Merchandising Division on February 7, 2025. This litigation hold notice is being issued to ensure the preservation of all documents and electronically stored information ("ESI") that may be relevant to the Company's claims and potential counterclaims in this matter. Every CRH employee who receives this notice must read it carefully, comply with its directives in full, and acknowledge its receipt.

On February 7, 2025, the following eight employees of CRH's Merchandising Division tendered their resignations simultaneously and without advance notice, effective immediately or within the minimum notice periods specified in their respective employment agreements:

1. Priya Rathore — former Senior Vice President, Merchandising

2. Derek Linden — former Vice President, Hardlines Merchandising

3. Sonia Kaczmarek — former Vice President, Softlines Merchandising

4. Amara Osei — former Director, Private Label Strategy

5. Brent Halvorsen — former Director, Seasonal Planning & Analytics

6. Lucia Fernandez-Gill — former Director, Vendor Relations (Domestic)

7. Nathan Tsao — former Senior Manager, eCommerce Merchandising

8. Kira Johansson — former Senior Manager, Category Analytics

These eight individuals are referred to collectively in this notice as the "Rathore Group." The Rathore Group has departed CRH to join Verdana Commerce Group, Inc. ("Verdana" or "VCG"), a direct competitor of CRH headquartered in Wilmington, Delaware. Information available to CRH and its counsel indicates that the departures were coordinated in advance and that representatives of Verdana and/or its private equity sponsor, Greystone Capital Partners, LP ("Greystone"), may have actively recruited these individuals while they were still employed by CRH and subject to restrictive covenant obligations.

CRH has reasonable grounds to believe that the conduct of the Rathore Group and Verdana may constitute one or more of the following:

• Breach of restrictive covenant obligations, including non-competition, non-solicitation of employees, non-solicitation of vendors and business partners, and confidentiality and non-disclosure provisions, each of which is contained in employment agreements and related ancillary agreements between CRH and the individual members of the Rathore Group;

• Misappropriation of trade secrets and confidential business information, in violation of the Washington Uniform Trade Secrets Act (RCW 19.108), the federal Defend Trade Secrets Act of 2016 (18 U.S.C. § 1836), and applicable common law, including but not limited to the potential unauthorized taking, copying, downloading, or transmission of proprietary merchandising strategies, vendor negotiation playbooks, seasonal buying algorithms, private-label sourcing data, customer segmentation analyses, eCommerce assortment algorithms, and confidential materials relating to the strategic initiative known as "Project Ridgeline"; and

• Tortious interference with contractual relations, by Verdana Commerce Group, Inc., its officers and directors (including CEO Warren Dietrich and General Counsel Helen Tsoi), and Greystone Capital Partners, LP and Greystone Capital Fund VII, LP and their partners (including Managing Partner Elliot Westbrook), who may have knowingly induced the members of the Rathore Group to breach their contractual obligations to CRH.

CRH has a legal obligation to preserve all documents and electronically stored information that may be relevant to this matter once litigation is reasonably anticipated. Based on the facts known to CRH and its counsel, litigation is now reasonably anticipated or imminent. This obligation arises under federal and state law, applicable rules of civil procedure, and established case law. The duty of preservation attaches to CRH as an organization and to each of its employees and officers who may possess, control, or have access to relevant information.

Failure to comply with this litigation hold can result in severe legal consequences for CRH, including court-imposed sanctions, adverse inference instructions (i.e., the court or jury may be instructed to presume that destroyed or altered evidence was unfavorable to CRH), monetary penalties, and other remedial measures. Individuals who fail to comply with this directive may also be subject to disciplinary action, up to and including termination of employment. This is not a routine administrative matter. It is a mandatory legal directive, and your full compliance is essential.

II. EFFECTIVE DATE AND DURATION

This litigation hold is effective immediately as of February 19, 2025. It applies to all documents and ESI described in this notice, whether created before, on, or after the date of this notice.

The hold will remain in effect until Calderwood & Harkness LLP and CRH General Counsel Theresa Yun-Park jointly issue a written release specifically authorizing the termination of this hold. No oral communication, whether from outside counsel, in-house counsel, or any CRH manager or officer, shall be deemed sufficient to release or modify this hold. Only a written release signed by both Theresa Yun-Park and a partner at Calderwood & Harkness LLP shall be effective to terminate this preservation obligation.

No documents falling within the scope of this hold may be destroyed, deleted, altered, overwritten, or disposed of until the hold is formally released in writing, regardless of any existing document retention or destruction policies, records management schedules, or any other Company policy or practice that would otherwise authorize or require the destruction or disposal of such documents. To the extent that CRH's existing document retention policies conflict with this litigation hold, this hold supersedes and takes precedence over those policies in all respects.

All automatic deletion programs, retention schedule purges, routine recycling of backup tapes, auto-archiving routines, and any other programmatic or manual processes that could result in the destruction, alteration, or loss of potentially relevant documents and ESI must be suspended immediately with respect to the categories of documents and ESI described in Section III and Section IV below. This directive applies to all CRH systems, servers, networks, cloud-based platforms, email systems, collaboration tools, and any other data repositories maintained by, for, or on behalf of CRH. The IT Department is directed to implement the necessary technical measures to effectuate this suspension without delay and to confirm completion of those measures in writing to Theresa Yun-Park and Calderwood & Harkness LLP within forty-eight (48) hours of receipt of this notice.

III. SCOPE OF PRESERVATION — SUBJECT MATTER

The scope of this litigation hold extends to all documents and ESI relating to any of the following subject matter categories. These categories are intended to be broad and inclusive. If you are uncertain whether particular documents or ESI fall within the scope of the hold, you should preserve those materials and contact the individuals identified in Section XI for guidance. When in doubt, preserve.

A. The Rathore Group and Their Employment at CRH

All documents relating to the employment, hiring, onboarding, compensation, performance reviews, promotions, transfers, disciplinary actions, complaints, investigations, and termination or resignation of each of the eight departing employees identified above (the Rathore Group) must be preserved in their entirety. This includes, without limitation:

• Employment agreements, offer letters, term sheets, and any related correspondence or negotiations preceding or following the execution of such agreements for each member of the Rathore Group;

• Restrictive covenant agreements, non-competition agreements, non-solicitation agreements, confidentiality and non-disclosure agreements, invention assignment agreements, intellectual property assignment agreements, and any other agreements limiting the post-employment activities of any member of the Rathore Group, including all exhibits, schedules, amendments, restatements, waivers, and consents thereto;

• Equity award agreements, restricted stock unit ("RSU") grant agreements, stock option agreements, performance share unit agreements, bonus plan documents, incentive compensation plan documents, deferred compensation arrangements, and any amendments or restatements thereof for all eight individuals;

• Specific reference is made to Priya Rathore's initial Employment Agreement dated June 3, 2019, entered into between Ms. Rathore and CRH at the time of her hire as Vice President, Merchandising Strategy, and the Amended and Restated Employment Agreement dated March 15, 2021, entered into in connection with Ms. Rathore's promotion to Senior Vice President, Merchandising, including without limitation all restrictive covenant provisions contained therein (including but not limited to Section 7 (Non-Competition), Section 8 (Non-Solicitation of Employees), Section 9 (Non-Solicitation of Business Relationships), Section 10 (Confidentiality and Non-Disclosure), and Section 11 (Return of Company Property)). All documents interpreting, discussing, or relating to these provisions must be preserved;

• Resignation letters, notices of resignation, and any related correspondence from each member of the Rathore Group;

• Exit interview records, exit questionnaires, and any notes, memoranda, or summaries prepared by CRH personnel (including HR business partners) in connection with the departures;

• Final pay calculations, final benefits documentation, COBRA notices, PTO/vacation payout records, and any other records relating to the financial aspects of the departures;

• Equipment return records, asset tracking records, building access card and credential deactivation records, parking pass records, and any other documentation relating to the return of CRH property by members of the Rathore Group;

• System access termination records, including records of the deactivation or modification of network credentials, email accounts, VPN access, remote access tokens, and any other technology access for each departing employee;

• Records of any communications from the Rathore Group, whether before, during, or after their resignations, regarding their reasons for departure, future employment plans, job search activities, or intentions to join a competitor, including any conversations (whether documented in writing, email, or notes) with CRH managers, HR personnel, colleagues, or any other individuals.

B. Project Ridgeline

The Company's strategic initiative known internally as "Project Ridgeline" is of central relevance to this matter. Project Ridgeline encompasses the five-year category expansion roadmap developed by and within the Merchandising Division under the leadership of Priya Rathore. All documents, presentations, memoranda, analyses, models, spreadsheets, reports, drafts, and communications relating to Project Ridgeline must be preserved, including without limitation:

• The Project Ridgeline master strategy deck and all drafts, working versions, and annotated copies thereof;

• All supporting financial models, pro forma analyses, category penetration models, and market-sizing analyses prepared in connection with Project Ridgeline;

• Category expansion roadmaps, timelines, implementation plans, and resource allocation documents;

• Vendor partnership strategies, proposed commercial terms, and negotiation frameworks developed in connection with Project Ridgeline;

• Competitive landscape assessments and gap analyses prepared as part of the Project Ridgeline initiative;

• All versions (including drafts, working copies, and final deliverables) of Project Ridgeline materials completed in or around October 2024, when the current phase of the initiative was substantially finalized;

• Documentation of who had access to Project Ridgeline materials, including access control lists, Aldermere Systems or document management system permission settings, distribution records, and any security classifications or sensitivity designations applied to those materials;

• Meeting agendas, meeting minutes, presentation materials, and follow-up action items from any meetings at which Project Ridgeline was discussed;

• Any documents reflecting the involvement of individual members of the Rathore Group in the development, review, approval, or dissemination of Project Ridgeline materials.

C. Merchandising Division Data and Trade Secrets

All documents and ESI constituting, containing, referencing, or relating to the following categories of confidential, proprietary, and trade secret information maintained by or for the Merchandising Division must be preserved:

• Proprietary vendor negotiation playbooks, including standardized and customized negotiation frameworks, discount structures, rebate schedules, markdown allowances, volume commitment thresholds, and vendor scoring methodologies;

• Seasonal buying algorithms and related analytical models, including demand forecasting models, inventory optimization algorithms, markdown optimization tools, and any underlying data sets and assumptions;

• Private-label sourcing strategies, cost models, and margin targets, including factory profiles, landed cost analyses, duty and logistics models, quality benchmarking data, and target margin structures for CRH's private-label portfolio;

• Customer segmentation data and analysis, including loyalty program data, demographic and psychographic segmentation models, purchase behavior analytics, lifetime value analyses, and targeted marketing strategies;

• eCommerce assortment algorithms, including product recommendation engines, assortment planning tools, digital merchandising models, and any proprietary algorithms or software developed by or for CRH's eCommerce merchandising function;

• Category expansion plans and competitive intelligence, including market research, competitive benchmarking studies, white-space analyses, category adjacency maps, and any other strategic planning documents relating to CRH's merchandising growth strategy;

• Any documents classified as confidential, proprietary, or trade secret within the Merchandising Division, whether so classified by formal designation, by marking, by restricted access controls, or by the nature of their content;

• Documentation of the security measures, access restrictions, and confidentiality protections applied to the materials described above, including information security policies, classification frameworks, access control procedures, password protections, encryption standards, clean-room protocols, and any other measures taken by CRH to protect the secrecy of its proprietary information.

D. Verdana Commerce Group, Inc. and Greystone Capital Partners, LP

All documents and communications referencing, relating to, or mentioning Verdana Commerce Group, Inc. (also known as "Verdana" or "VCG"), or any of its officers, directors, employees, or agents, must be preserved. This specifically includes, but is not limited to, any documents referencing Verdana's Chief Executive Officer, Warren Dietrich, and its General Counsel, Helen Tsoi.

All documents and communications referencing, relating to, or mentioning Greystone Capital Partners, LP (also known as "Greystone"), Greystone Capital Fund VII, LP, or any of its partners, employees, or agents, must be preserved. This specifically includes, but is not limited to, any documents referencing Greystone's Managing Partner, Elliot Westbrook.

Without limiting the generality of the foregoing, the following categories of documents relating to Verdana and Greystone must be preserved:

• Competitive intelligence reports, market analyses, strategic assessments, or board presentations concerning Verdana's business operations, product categories, growth initiatives, financial performance, or competitive positioning;

• Any documents relating to overlapping product categories between CRH and Verdana, including but not limited to home goods, seasonal décor, and private-label apparel;

• Industry conference materials, trade show records, or event attendance records reflecting interactions between CRH personnel and Verdana or Greystone personnel;

• Recruiter communications, job postings, or other talent acquisition materials relating to Verdana's hiring activities, particularly with respect to merchandising and related functions;

• Any documents reflecting prior business dealings, negotiations, or discussions between CRH and Verdana or between CRH and Greystone.

E. Data Access, Downloads, and IT Activity

The Company's IT Department is directed to preserve all records of system access and data activity by members of the Rathore Group. This preservation obligation covers the following categories of records:

• All IT and system access logs, audit trails, login records, authentication records, VPN connection logs, download histories, file transfer records, USB and removable media usage logs, email forwarding rules, auto-forwarding configurations, cloud storage access records, print logs, and any other records of system activity for each of the eight departing employees, covering the period from January 1, 2025 through February 7, 2025, and any available records from prior periods;

• Aldermere Systems access logs and download logs, including records of file access, file downloads, file modifications, permission changes, and sharing activities within any Aldermere Systems site, library, or list to which any member of the Rathore Group had access;

• Pinnacle Health IT access logs and export logs, including records of report generation, data exports, list views, and any bulk data extraction activities by any member of the Rathore Group;

• Records of access to or downloads from any CRH network drive, intranet portal, document management system (including any instance of Tidewater Systems, Vireo Data Systems, or comparable platforms), or cloud-based collaboration tool (including Northgate Data Systems, Larkspur Health IT, box, or comparable platforms) by any of the eight departing employees;

• Any records of personal cloud storage account connections detected on CRH networks or CRH-issued devices, including connections to personal Larkspur Technologies, Hollowell Health IT, Meridian Systems, personal Cobalt Ridge Systems, WeTransfer, or any other file-sharing or cloud storage service not authorized by CRH for business use;

• Data Loss Prevention ("DLP") alerts, incident reports, and investigation records triggered by or relating to the activities of any member of the Rathore Group;

• Forensic images, chain-of-custody documentation, and analysis reports relating to CRH-issued laptops, mobile devices, tablets, or other equipment used by or assigned to any of the eight departing employees.

Important Note Regarding Forensic Imaging: CRH has separately engaged Pinnacle Forensics LLC to conduct forensic imaging and analysis of all CRH-issued devices returned by or associated with the Rathore Group. The IT Department should coordinate all activities relating to forensic imaging through Calderwood & Harkness LLP. Under no circumstances should any CRH IT personnel independently access, boot, modify, or otherwise interact with the devices subject to forensic imaging without prior written authorization from Calderwood & Harkness LLP. Any requests from Pinnacle Forensics LLC for access to CRH systems, log data, or network information should be routed through Theresa Yun-Park or Bernard Crawford.

F. Communications. All communications to, from, or involving any member of the Rathore Group must be preserved, including:

• All emails (including all attachments, embedded images, and inline content), whether sent, received, or on which any member of the Rathore Group was copied or blind-copied, for the period from January 1, 2024 through the date of this notice;

• All text messages (SMS and MMS) sent to or received from any member of the Rathore Group on CRH-issued mobile devices or personal devices used for CRH business, for the same period;

• All instant messages, including messages sent or received via any enterprise messaging platform such as Meridian Solutions, Northgate Data Systems, Jabber, or any similar platform, for the same period;

• All voicemails left by or for any member of the Rathore Group on CRH voicemail systems, for the same period;

• All written or electronic correspondence of any kind sent to, received from, or involving any member of the Rathore Group, for the same period;

• All emails, text messages, instant messages, and written or electronic correspondence between any CRH employee and any representative of Verdana Commerce Group, Inc. or Greystone Capital Partners, LP, without time limitation — this includes all historical communications regardless of when they occurred;

• Calendar entries, meeting invitations, and meeting notes involving any of the eight departing employees for the period January 1, 2025 through February 7, 2025, including recurring meeting series, one-on-one meetings, team meetings, and any external meetings;

• Encrypted messaging applications: Any records or evidence of the use of encrypted or disappearing-message platforms on CRH-issued devices by any of the eight departing employees, including but not limited to Harborline Technologies, Meridian Services Inc., Signal, Pemberton Health IT, Confide, or any similar application. If any CRH employee has knowledge that any member of the Rathore Group used such applications for business-related communications, this information must be reported immediately to the contacts identified in Section XI.

G. Human Resources and Compensation Records

• Complete personnel files for all eight departing employees, including all documents contained therein regardless of date of creation;

• Equity award records, RSU vesting schedules, stock option exercise records, performance share unit records, and any forfeiture or clawback documentation for all eight departing employees, including records of any accelerated vesting, forfeiture-for-cause provisions, post-termination exercise periods, or other equity-related determinations made in connection with the departures;

• Records maintained by or in coordination with Northland Trust Company (CRH's transfer agent) relating to equity awards, stock issuances, stock transfers, or other equity transactions for the departing employees;

• Payroll records, bonus calculations, commission records, incentive compensation determinations, and any other compensation-related records for all eight departing employees, covering the full period of their employment with CRH;

• Benefits enrollment records, 401(k) plan records, and any other employee benefit records for the departing employees;

• Organizational charts, reporting structure documentation, and any succession planning materials relating to the Merchandising Division.

H. Corporate Governance and Disclosure

• Board of Directors minutes, committee minutes (including Audit Committee, Compensation Committee, and any special committee minutes), and management reports or presentations discussing the departures, the Merchandising Division's operations following the departures, any potential litigation or legal claims arising from the departures, or any business impact assessments related thereto;

• Any communications with Hargrove & Tillett CPA, PLLC (CRH's outside auditors) referencing the departures, potential litigation contingencies, loss accrual analyses, or any related accounting or disclosure matters;

• Any communications with Keypoint National Bank, N.A. (administrative agent under CRH's $750 million revolving credit facility) relating to the departures, any material litigation reporting obligations under the credit agreement, any covenant compliance analyses affected by the departures, or any related borrower notices or certifications;

• SEC filings (whether filed or in draft form), including Forms 10-K, 10-Q, 8-K, proxy statements, and any internal analyses, legal memoranda, or drafts discussing the departures, the potential claims, litigation risk assessments, or any related disclosure obligations;

• Any communications with CRH's investor relations team, financial advisors, or investment bankers relating to the departures or their potential impact on the Company's financial position or strategic outlook;

• Insurance coverage notifications, claims submissions, or correspondence with CRH's directors and officers liability insurance carrier or employment practices liability insurance carrier relating to the anticipated litigation.

IV. SCOPE OF PRESERVATION — TYPES OF DOCUMENTS AND ESI

The term "documents" as used throughout this notice is to be interpreted in the broadest possible sense consistent with applicable federal and state rules of civil procedure, including the Federal Rules of Civil Procedure and the Washington State Superior Court Civil Rules, and includes, without limitation, the following categories:

Paper Documents:

Originals and all non-identical copies (including copies bearing annotations, highlighting, marginalia, or other markings) of letters, memoranda, notes, reports, analyses, charts, graphs, schedules, calendars, day planners, diaries, notebooks, handwritten notes, sticky notes, whiteboard photographs, flip chart pages, printed emails, printed spreadsheets, printed presentations, business cards, marketing materials, and any other tangible written or printed materials.

Electronic Documents:

Emails (including all attachments and embedded content), word processing files (including Microsoft Word, Stonefield Health IT, and comparable formats), spreadsheets (including Microsoft Excel, Stonefield Services Inc., and comparable formats), presentations (including Microsoft Northgate Services Inc., Pemberton Services Inc., Tidewater Data Systems, and comparable formats), databases and database extracts, PDF files, scanned images, digital photographs, screenshots, audio recordings, video recordings, webinar recordings, screen captures, and any other electronically created or stored files.

ESI on All Media:

Hard drives, solid-state drives, laptops, desktop computers, mobile phones (including smartphones), tablets, USB drives, thumb drives, external hard drives, CDs, DVDs, SD cards, backup tapes, archive tapes, cloud storage accounts (both corporate accounts provisioned by CRH and personal accounts if used for CRH business), network servers, file servers, email servers, NAS devices, SAN storage, and any other electronic storage media.

Metadata:

All metadata associated with electronic documents must be preserved. Metadata includes but is not limited to file creation dates, modification dates, access dates, author information, revision history, track changes, comments, and file properties. Documents should not be opened, modified, re-saved, or otherwise altered in a manner that could change their metadata.

Social Media and Public Postings:

Social media posts, Westmark Health IT activity (including profile changes, job announcements, posts, comments, and connections), Ashford Systems posts, Kestrel Services Inc. posts, Northpoint Services Inc. posts, blog posts, and any other publicly posted content by any of the eight departing employees referencing CRH, Verdana, their employment, their departure, or any related subject matter. CRH employees who become aware of such postings should immediately notify the contacts identified in Section XI.

V. SPECIFIC PRESERVATION INSTRUCTIONS

A. Do Not Destroy, Delete, or Alter

You must not destroy, discard, delete, shred, erase, overwrite, or alter any document or ESI falling within the scope of this hold. This prohibition applies regardless of whether the document is in paper or electronic form, regardless of the medium on which it is stored, and regardless of whether you believe the document to be duplicative of other copies. Specifically:

• Do not delete emails, text messages, instant messages, or voicemails that may be relevant to this matter;

• Do not empty your "Deleted Items" or "Trash" folder in your email system without first confirming with Theresa Yun-Park or Calderwood & Harkness LLP that no relevant items are contained therein;

• Do not modify, edit, or alter any document for the purpose of changing its content, metadata, or any other attribute;

• Do not re-organize or re-file documents in a way that would alter their existing organizational structure, obscure their location, or impair the ability to determine where documents were maintained in the ordinary course of business;

• Do not remove documents from existing file folders, directories, or other organizational structures in which they are currently maintained;

• Do not overwrite existing versions of documents by saving new versions with the same file name in the same location.

B. Suspend Routine Destruction

All routine document retention and destruction policies, records management schedules, and standard operating procedures for document disposal are hereby suspended as they apply to documents and ESI within the scope of this hold. This suspension takes precedence over any contrary instructions you may have previously received from management, IT, records management, or any other source.

IT Department — Immediate Action Required:

The IT Department must immediately take the following steps and confirm their completion in writing to Theresa Yun-Park and Calderwood & Harkness LLP:

• Suspend all auto-deletion policies for email, including any policies that automatically delete emails from user mailboxes, journaling systems, or archival systems after a specified retention period;

• Suspend all backup tape recycling and rotation schedules that could result in the overwriting or destruction of backup data containing relevant information;

• Suspend any server decommissioning, migration, or upgrade projects that could result in the loss of relevant data, unless alternative preservation measures have been approved in advance by Calderwood & Harkness LLP;

• Suspend any automated archiving processes that could alter the state or metadata of relevant documents;

• Ensure that litigation hold flags or comparable technical markers are applied to the email accounts, network drives, and cloud storage areas associated with the eight departing employees and all key custodians identified in Section VI.

HR Department — Immediate Action Required:

The HR Department must immediately suspend any routine purging, archiving, or disposal of personnel files, payroll records, benefits records, compensation records, or any other HR-maintained records for the eight departing employees. No such records may be destroyed, transferred to off-site storage, or otherwise made inaccessible without prior written approval from Theresa Yun-Park.

C. Preserve Devices and Physical Media

All CRH-issued devices — including laptops, desktop computers, mobile phones, tablets, and any other electronic equipment — that were returned by the eight departing employees must be preserved in their current state without any modification whatsoever. Specifically:

• Do not reimage, reformat, wipe, reset, reassign, recycle, donate, or otherwise dispose of any such device;

• Do not power on, boot, log into, or otherwise access any such device unless specifically directed to do so by Calderwood & Harkness LLP in connection with the forensic imaging process;

• Store all such devices in a secure location with restricted access and maintain a log of all persons who access the storage location;

• Coordinate with Pinnacle Forensics LLC through Calderwood & Harkness LLP for the forensic imaging and analysis of these devices. All communications with Pinnacle Forensics LLC regarding this matter should be routed through Bernard Crawford or James Underwood at Calderwood & Harkness LLP to preserve privilege.

In addition, any physical files, notebooks, paper records, binders, printed materials, or other tangible items from the offices, workstations, cubicles, conference rooms, or shared spaces used by the departing employees should be collected and secured immediately. These materials should be inventoried, placed in sealed and labeled containers, and stored in a designated secure location. Contact Theresa Yun-Park for instructions on the designated storage location.

D. Personal Devices and Accounts

If any CRH employee is aware or has reason to believe that any of the eight departing employees used personal devices (personal laptops, personal mobile phones, personal tablets, or other personal computing devices) or personal email or cloud storage accounts (personal Northgate Software, Cascade Health IT, Ridgeline Technologies, Larkspur Technologies, Hollowell Health IT, Meridian Systems, personal Cobalt Ridge Systems, or similar services) for CRH business purposes — including but not limited to sending, receiving, or storing CRH documents, emails, or other business information — this information must be reported immediately to Theresa Yun-Park or Calderwood & Harkness LLP. The same reporting obligation applies if you are aware that any departing employee maintained CRH business information on a home computer, personal network-attached storage device, or any other personal medium.

E. Ongoing Creation of Documents

Documents and ESI created after the date of this notice that fall within the subject matter scope described in Section III are also subject to this preservation hold. This includes, without limitation:

• Communications about the departures, their impact on CRH's business, or efforts to mitigate that impact;

• Communications about Verdana's competitive activities, hiring, or business developments;

• Communications about Project Ridgeline, its status, or its future;

• Internal investigation notes, findings, or reports relating to the departures;

• Any communications with or about the departing employees after February 7, 2025.

You should continue to create and maintain documents in the ordinary course of business. The hold does not prohibit the creation of new documents; it requires that all relevant documents, whether pre-existing or newly created, be preserved.

VI. KEY CUSTODIANS

The following individuals are identified as key custodians who are likely to possess documents and ESI of particular relevance to this matter. These individuals should take particular care to identify, preserve, and safeguard all documents and ESI within the scope of this hold:

• Marcus Langford, Chief Executive Officer

• Theresa Yun-Park, General Counsel

• Roland Ashby, Chief People Officer

• Martin Cho, Vice President, Merchandising (serving as Interim Senior Vice President, Merchandising following the departure of Priya Rathore)

• All direct reports of Priya Rathore within the Merchandising Division, including those who assumed interim responsibilities following the Rathore Group's departure

• All IT personnel responsible for systems administration, network security, data management, and information security for the Merchandising Division, including the IT Director and all members of the IT support team assigned to the Merchandising Division's systems and applications

• All HR business partners who supported the Merchandising Division, including those who participated in the onboarding, performance management, or exit processing for any member of the Rathore Group

• Finance and Accounting personnel responsible for equity compensation administration, payroll processing, and financial reporting for the Merchandising Division, including personnel who interface with Northland Trust Company in connection with equity transactions

Key custodians should conduct a thorough search of their own files, email accounts, hard drives, personal network folders, desk drawers, filing cabinets, home offices, and any other locations where relevant documents may be stored, and ensure that all such documents are preserved in place. Key custodians should not collect or move documents unless instructed to do so by Theresa Yun-Park or Calderwood & Harkness LLP; the primary directive is to preserve documents where they are.

Additional custodians may be identified as the matter develops and as the investigation progresses. Supplemental preservation notices will be issued as needed to address new custodians, new subject matter categories, or modifications to the scope of this hold.

VII. REPORTING OBLIGATIONS

Prompt and complete reporting of relevant information is essential to the Company's ability to protect its legal rights. Any CRH employee who becomes aware of any of the following must report such information immediately to the contacts identified below:

(a) The destruction, deletion, alteration, or loss of any documents or ESI potentially within the scope of this hold, whether intentional or inadvertent, and regardless of when such destruction, deletion, alteration, or loss occurred;

(b) Additional sources of relevant documents or ESI not specifically addressed in this notice, including previously unknown file locations, backup systems, personal devices, third-party storage, or other repositories;

(c) Any communications with or from any of the eight departing employees, Verdana Commerce Group, Inc., Greystone Capital Partners, LP, or any of their representatives, received or initiated after February 7, 2025, regardless of the subject matter of the communication;

(d) Any social media activity, public statements, or published content by any member of the Rathore Group that references CRH, Verdana, or their employment or departure;

(e) Any other information potentially relevant to this matter, including rumors, observations, or knowledge regarding the circumstances of the departures, the coordination thereof, or the involvement of Verdana or Greystone in recruiting the Rathore Group.

Reports should be made to:

Theresa Yun-Park General Counsel Cascade Retail Holdings Inc. 2200 Elliott Avenue West, Suite 3400 Seattle, WA 98119

Email: tyunpark@cascaderetail.com

Phone: (206) 555-4100

Bernard Crawford Partner, Calderwood & Harkness LLP 1301 K Street NW, Suite 1200 Washington, DC 20005

Email: bcrawford@calderwoodharkness.com

Phone: (202) 555-7800

Do not attempt to investigate or collect documents on your own. Do not conduct interviews, review the personal effects of departing employees, access their former offices or workstations (beyond normal business use of shared spaces), or take any other investigative steps without prior authorization from Theresa Yun-Park or Calderwood & Harkness LLP. Unauthorized collection or investigation activities could compromise the integrity of evidence, create privilege issues, or otherwise prejudice CRH's legal position.

VIII. CONFIDENTIALITY

This litigation hold notice, its contents, and the existence of the anticipated litigation are confidential and subject to the attorney-client privilege and the work product doctrine. The protections afforded by these doctrines are essential to CRH's legal position and must not be compromised.

Accordingly, you must observe the following confidentiality requirements:

• Do not discuss this notice, the anticipated litigation, the subject matter of this hold, or any information you have provided or received in connection with this hold with any person outside of CRH, unless you have been specifically directed to do so by Theresa Yun-Park or Calderwood & Harkness LLP;

• Do not forward this notice, in whole or in part, to any person who is not on the approved distribution list maintained by Theresa Yun-Park and Roland Ashby;

• Do not discuss this notice, the anticipated litigation, or any related subject matter with any of the eight departing employees, any representative of Verdana Commerce Group, Inc., any representative of Greystone Capital Partners, LP, or any other third party, including but not limited to members of the press, industry analysts, personal attorneys, or family members;

• Do not post any information about this notice or the anticipated litigation on social media, personal blogs, or any other public or semi-public platform;

• If you are contacted by any representative of Verdana, Greystone, or any of the departing employees regarding any subject matter potentially related to this hold, do not substantively respond and immediately report the contact to Theresa Yun-Park or Bernard Crawford.

Unauthorized disclosure of this notice or the information contained herein may constitute a waiver of attorney-client privilege, which could have significant adverse consequences for CRH in the anticipated litigation. Any such unauthorized disclosure may also subject the disclosing individual to disciplinary action.

IX. CONSEQUENCES OF NON-COMPLIANCE

CRH takes its document preservation obligations extremely seriously. The preservation of evidence is a legal obligation of the highest order, and compliance with this litigation hold is mandatory for every CRH employee who receives it.

Failure to comply with this litigation hold may result in:

(a) Severe legal consequences for CRH, including court-imposed sanctions, adverse inference instructions (pursuant to which a court or jury may be instructed to presume that any destroyed, deleted, or altered evidence was unfavorable to CRH), exclusion of evidence, dismissal of claims, default judgments, monetary penalties, and attorneys' fees awards. Courts have imposed substantial sanctions on parties and individuals who fail to preserve relevant evidence, and CRH cannot afford to have its legal position compromised by the carelessness or misconduct of any individual employee.

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION
LITIGATION HOLD NOTICE
DOCUMENT PRESERVATION DIRECTIVE
This communication is protected by the attorney-client privilege and the work product doctrine. It is intended solely for the use of the addressees identified herein. Any unauthorized review, use, disclosure, or distribution is strictly prohibited. If you have received this notice in error, contact Calderwood & Harkness LLP immediately.
FROM: Calderwood & Harkness LLP 1301 K Street NW, Suite 1200 Washington, DC 20005 — on behalf of Cascade Retail Holdings Inc.
PREPARED BY: Bernard Crawford, Responsible Partner, and James Underwood, Lead Associate Labor & Employment Practice Group
ADDRESSED TO: All employees and officers of Cascade Retail Holdings Inc. ("CRH") who may possess, control, or have access to relevant documents and information, as further described herein
DATE: February 19, 2025
RE: Litigation Hold — Preservation of Documents and Electronically Stored Information Related to the Departure of Priya Rathore and Seven Other Former Merchandising Division Employees and Related Claims Against Verdana Commerce Group, Inc.
MATTER REFERENCE: Calderwood & Harkness LLP Matter No. 1038-00006
DISTRIBUTION DIRECTIVE: This notice is to be distributed by Theresa Yun-Park, General Counsel, and Roland Ashby, Chief People Officer, to all CRH employees identified on the attached distribution list, including but not limited to all current and former employees of the Merchandising Division, Information Technology Department, Human Resources Department, Legal Department, Finance Department, and the Office of the CEO. Each department head or functional leader receiving this notice shall ensure that all relevant personnel within his or her area of responsibility receive a copy of this notice and acknowledge its receipt in accordance with Section X below.
I. PURPOSE OF THIS NOTICE
Cascade Retail Holdings Inc. ("CRH" or the "Company") has retained outside counsel, Calderwood & Harkness LLP, in connection with anticipated and likely litigation arising from the coordinated resignation of eight senior employees of CRH's Merchandising Division on February 7, 2025. This litigation hold notice is being issued to ensure the preservation of all documents and electronically stored information ("ESI") that may be relevant to the Company's claims and potential counterclaims in this matter. Every CRH employee who receives this notice must read it carefully, comply with its directives in full, and acknowledge its receipt.
On February 7, 2025, the following eight employees of CRH's Merchandising Division tendered their resignations simultaneously and without advance notice, effective immediately or within the minimum notice periods specified in their respective employment agreements:
1.  Priya Rathore — former Senior Vice President, Merchandising
2.  Derek Linden — former Vice President, Hardlines Merchandising
3.  Sonia Kaczmarek — former Vice President, Softlines Merchandising
4.  Amara Osei — former Director, Private Label Strategy
5.  Brent Halvorsen — former Director, Seasonal Planning & Analytics
6.  Lucia Fernandez-Gill — former Director, Vendor Relations (Domestic)
7.  Nathan Tsao — former Senior Manager, eCommerce Merchandising
8.  Kira Johansson — former Senior Manager, Category Analytics
These eight individuals are referred to collectively in this notice as the "Rathore Group." The Rathore Group has departed CRH to join Verdana Commerce Group, Inc. ("Verdana" or "VCG"), a direct competitor of CRH headquartered in Wilmington, Delaware. Information available to CRH and its counsel indicates that the departures were coordinated in advance and that representatives of Verdana and/or its private equity sponsor, Greystone Capital Partners, LP ("Greystone"), may have actively recruited these individuals while they were still employed by CRH and subject to restrictive covenant obligations.
CRH has reasonable grounds to believe that the conduct of the Rathore Group and Verdana may constitute one or more of the following:
•  Breach of restrictive covenant obligations, including non-competition, non-solicitation of employees, non-solicitation of vendors and business partners, and confidentiality and non-disclosure provisions, each of which is contained in employment agreements and related ancillary agreements between CRH and the individual members of the Rathore Group;
•  Misappropriation of trade secrets and confidential business information, in violation of the Washington Uniform Trade Secrets Act (RCW 19.108), the federal Defend Trade Secrets Act of 2016 (18 U.S.C. § 1836), and applicable common law, including but not limited to the potential unauthorized taking, copying, downloading, or transmission of proprietary merchandising strategies, vendor negotiation playbooks, seasonal buying algorithms, private-label sourcing data, customer segmentation analyses, eCommerce assortment algorithms, and confidential materials relating to the strategic initiative known as "Project Ridgeline"; and
•  Tortious interference with contractual relations, by Verdana Commerce Group, Inc., its officers and directors (including CEO Warren Dietrich and General Counsel Helen Tsoi), and Greystone Capital Partners, LP and Greystone Capital Fund VII, LP and their partners (including Managing Partner Elliot Westbrook), who may have knowingly induced the members of the Rathore Group to breach their contractual obligations to CRH.
CRH has a legal obligation to preserve all documents and electronically stored information that may be relevant to this matter once litigation is reasonably anticipated. Based on the facts known to CRH and its counsel, litigation is now reasonably anticipated or imminent. This obligation arises under federal and state law, applicable rules of civil procedure, and established case law. The duty of preservation attaches to CRH as an organization and to each of its employees and officers who may possess, control, or have access to relevant information.
Failure to comply with this litigation hold can result in severe legal consequences for CRH, including court-imposed sanctions, adverse inference instructions (i.e., the court or jury may be instructed to presume that destroyed or altered evidence was unfavorable to CRH), monetary penalties, and other remedial measures. Individuals who fail to comply with this directive may also be subject to disciplinary action, up to and including termination of employment. This is not a routine administrative matter. It is a mandatory legal directive, and your full compliance is essential.
II. EFFECTIVE DATE AND DURATION
This litigation hold is effective immediately as of February 19, 2025. It applies to all documents and ESI described in this notice, whether created before, on, or after the date of this notice.
The hold will remain in effect until Calderwood & Harkness LLP and CRH General Counsel Theresa Yun-Park jointly issue a written release specifically authorizing the termination of this hold. No oral communication, whether from outside counsel, in-house counsel, or any CRH manager or officer, shall be deemed sufficient to release or modify this hold. Only a written release signed by both Theresa Yun-Park and a partner at Calderwood & Harkness LLP shall be effective to terminate this preservation obligation.
No documents falling within the scope of this hold may be destroyed, deleted, altered, overwritten, or disposed of until the hold is formally released in writing, regardless of any existing document retention or destruction policies, records management schedules, or any other Company policy or practice that would otherwise authorize or require the destruction or disposal of such documents. To the extent that CRH's existing document retention policies conflict with this litigation hold, this hold supersedes and takes precedence over those policies in all respects.
All automatic deletion programs, retention schedule purges, routine recycling of backup tapes, auto-archiving routines, and any other programmatic or manual processes that could result in the destruction, alteration, or loss of potentially relevant documents and ESI must be suspended immediately with respect to the categories of documents and ESI described in Section III and Section IV below. This directive applies to all CRH systems, servers, networks, cloud-based platforms, email systems, collaboration tools, and any other data repositories maintained by, for, or on behalf of CRH. The IT Department is directed to implement the necessary technical measures to effectuate this suspension without delay and to confirm completion of those measures in writing to Theresa Yun-Park and Calderwood & Harkness LLP within forty-eight (48) hours of receipt of this notice.
III. SCOPE OF PRESERVATION — SUBJECT MATTER
The scope of this litigation hold extends to all documents and ESI relating to any of the following subject matter categories. These categories are intended to be broad and inclusive. If you are uncertain whether particular documents or ESI fall within the scope of the hold, you should preserve those materials and contact the individuals identified in Section XI for guidance. When in doubt, preserve.
A. The Rathore Group and Their Employment at CRH
All documents relating to the employment, hiring, onboarding, compensation, performance reviews, promotions, transfers, disciplinary actions, complaints, investigations, and termination or resignation of each of the eight departing employees identified above (the Rathore Group) must be preserved in their entirety. This includes, without limitation:
•  Employment agreements, offer letters, term sheets, and any related correspondence or negotiations preceding or following the execution of such agreements for each member of the Rathore Group;
•  Restrictive covenant agreements, non-competition agreements, non-solicitation agreements, confidentiality and non-disclosure agreements, invention assignment agreements, intellectual property assignment agreements, and any other agreements limiting the post-employment activities of any member of the Rathore Group, including all exhibits, schedules, amendments, restatements, waivers, and consents thereto;
•  Equity award agreements, restricted stock unit ("RSU") grant agreements, stock option agreements, performance share unit agreements, bonus plan documents, incentive compensation plan documents, deferred compensation arrangements, and any amendments or restatements thereof for all eight individuals;
•  Specific reference is made to Priya Rathore's initial Employment Agreement dated June 3, 2019, entered into between Ms. Rathore and CRH at the time of her hire as Vice President, Merchandising Strategy, and the Amended and Restated Employment Agreement dated March 15, 2021, entered into in connection with Ms. Rathore's promotion to Senior Vice President, Merchandising, including without limitation all restrictive covenant provisions contained therein (including but not limited to Section 7 (Non-Competition), Section 8 (Non-Solicitation of Employees), Section 9 (Non-Solicitation of Business Relationships), Section 10 (Confidentiality and Non-Disclosure), and Section 11 (Return of Company Property)). All documents interpreting, discussing, or relating to these provisions must be preserved;
•  Resignation letters, notices of resignation, and any related correspondence from each member of the Rathore Group;
•  Exit interview records, exit questionnaires, and any notes, memoranda, or summaries prepared by CRH personnel (including HR business partners) in connection with the departures;
•  Final pay calculations, final benefits documentation, COBRA notices, PTO/vacation payout records, and any other records relating to the financial aspects of the departures;
•  Equipment return records, asset tracking records, building access card and credential deactivation records, parking pass records, and any other documentation relating to the return of CRH property by members of the Rathore Group;
•  System access termination records, including records of the deactivation or modification of network credentials, email accounts, VPN access, remote access tokens, and any other technology access for each departing employee;
•  Records of any communications from the Rathore Group, whether before, during, or after their resignations, regarding their reasons for departure, future employment plans, job search activities, or intentions to join a competitor, including any conversations (whether documented in writing, email, or notes) with CRH managers, HR personnel, colleagues, or any other individuals.
B. Project Ridgeline
The Company's strategic initiative known internally as "Project Ridgeline" is of central relevance to this matter. Project Ridgeline encompasses the five-year category expansion roadmap developed by and within the Merchandising Division under the leadership of Priya Rathore. All documents, presentations, memoranda, analyses, models, spreadsheets, reports, drafts, and communications relating to Project Ridgeline must be preserved, including without limitation:
•  The Project Ridgeline master strategy deck and all drafts, working versions, and annotated copies thereof;
•  All supporting financial models, pro forma analyses, category penetration models, and market-sizing analyses prepared in connection with Project Ridgeline;
•  Category expansion roadmaps, timelines, implementation plans, and resource allocation documents;
•  Vendor partnership strategies, proposed commercial terms, and negotiation frameworks developed in connection with Project Ridgeline;
•  Competitive landscape assessments and gap analyses prepared as part of the Project Ridgeline initiative;
•  All versions (including drafts, working copies, and final deliverables) of Project Ridgeline materials completed in or around October 2024, when the current phase of the initiative was substantially finalized;
•  Documentation of who had access to Project Ridgeline materials, including access control lists, Aldermere Systems or document management system permission settings, distribution records, and any security classifications or sensitivity designations applied to those materials;
•  Meeting agendas, meeting minutes, presentation materials, and follow-up action items from any meetings at which Project Ridgeline was discussed;
•  Any documents reflecting the involvement of individual members of the Rathore Group in the development, review, approval, or dissemination of Project Ridgeline materials.
C. Merchandising Division Data and Trade Secrets
All documents and ESI constituting, containing, referencing, or relating to the following categories of confidential, proprietary, and trade secret information maintained by or for the Merchandising Division must be preserved:
•  Proprietary vendor negotiation playbooks, including standardized and customized negotiation frameworks, discount structures, rebate schedules, markdown allowances, volume commitment thresholds, and vendor scoring methodologies;
•  Seasonal buying algorithms and related analytical models, including demand forecasting models, inventory optimization algorithms, markdown optimization tools, and any underlying data sets and assumptions;
•  Private-label sourcing strategies, cost models, and margin targets, including factory profiles, landed cost analyses, duty and logistics models, quality benchmarking data, and target margin structures for CRH's private-label portfolio;
•  Customer segmentation data and analysis, including loyalty program data, demographic and psychographic segmentation models, purchase behavior analytics, lifetime value analyses, and targeted marketing strategies;
•  eCommerce assortment algorithms, including product recommendation engines, assortment planning tools, digital merchandising models, and any proprietary algorithms or software developed by or for CRH's eCommerce merchandising function;
•  Category expansion plans and competitive intelligence, including market research, competitive benchmarking studies, white-space analyses, category adjacency maps, and any other strategic planning documents relating to CRH's merchandising growth strategy;
•  Any documents classified as confidential, proprietary, or trade secret within the Merchandising Division, whether so classified by formal designation, by marking, by restricted access controls, or by the nature of their content;
•  Documentation of the security measures, access restrictions, and confidentiality protections applied to the materials described above, including information security policies, classification frameworks, access control procedures, password protections, encryption standards, clean-room protocols, and any other measures taken by CRH to protect the secrecy of its proprietary information.
D. Verdana Commerce Group, Inc. and Greystone Capital Partners, LP
All documents and communications referencing, relating to, or mentioning Verdana Commerce Group, Inc. (also known as "Verdana" or "VCG"), or any of its officers, directors, employees, or agents, must be preserved. This specifically includes, but is not limited to, any documents referencing Verdana's Chief Executive Officer, Warren Dietrich, and its General Counsel, Helen Tsoi.
All documents and communications referencing, relating to, or mentioning Greystone Capital Partners, LP (also known as "Greystone"), Greystone Capital Fund VII, LP, or any of its partners, employees, or agents, must be preserved. This specifically includes, but is not limited to, any documents referencing Greystone's Managing Partner, Elliot Westbrook.
Without limiting the generality of the foregoing, the following categories of documents relating to Verdana and Greystone must be preserved:
•  Competitive intelligence reports, market analyses, strategic assessments, or board presentations concerning Verdana's business operations, product categories, growth initiatives, financial performance, or competitive positioning;
•  Any documents relating to overlapping product categories between CRH and Verdana, including but not limited to home goods, seasonal décor, and private-label apparel;
•  Industry conference materials, trade show records, or event attendance records reflecting interactions between CRH personnel and Verdana or Greystone personnel;
•  Recruiter communications, job postings, or other talent acquisition materials relating to Verdana's hiring activities, particularly with respect to merchandising and related functions;
•  Any documents reflecting prior business dealings, negotiations, or discussions between CRH and Verdana or between CRH and Greystone.
E. Data Access, Downloads, and IT Activity
The Company's IT Department is directed to preserve all records of system access and data activity by members of the Rathore Group. This preservation obligation covers the following categories of records:
•  All IT and system access logs, audit trails, login records, authentication records, VPN connection logs, download histories, file transfer records, USB and removable media usage logs, email forwarding rules, auto-forwarding configurations, cloud storage access records, print logs, and any other records of system activity for each of the eight departing employees, covering the period from January 1, 2025 through February 7, 2025, and any available records from prior periods;
•  Aldermere Systems access logs and download logs, including records of file access, file downloads, file modifications, permission changes, and sharing activities within any Aldermere Systems site, library, or list to which any member of the Rathore Group had access;
•  Pinnacle Health IT access logs and export logs, including records of report generation, data exports, list views, and any bulk data extraction activities by any member of the Rathore Group;
•  Records of access to or downloads from any CRH network drive, intranet portal, document management system (including any instance of Tidewater Systems, Vireo Data Systems, or comparable platforms), or cloud-based collaboration tool (including Northgate Data Systems, Larkspur Health IT, box, or comparable platforms) by any of the eight departing employees;
•  Any records of personal cloud storage account connections detected on CRH networks or CRH-issued devices, including connections to personal Larkspur Technologies, Hollowell Health IT, Meridian Systems, personal Cobalt Ridge Systems, WeTransfer, or any other file-sharing or cloud storage service not authorized by CRH for business use;
•  Data Loss Prevention ("DLP") alerts, incident reports, and investigation records triggered by or relating to the activities of any member of the Rathore Group;
•  Forensic images, chain-of-custody documentation, and analysis reports relating to CRH-issued laptops, mobile devices, tablets, or other equipment used by or assigned to any of the eight departing employees.
Important Note Regarding Forensic Imaging: CRH has separately engaged Pinnacle Forensics LLC to conduct forensic imaging and analysis of all CRH-issued devices returned by or associated with the Rathore Group. The IT Department should coordinate all activities relating to forensic imaging through Calderwood & Harkness LLP. Under no circumstances should any CRH IT personnel independently access, boot, modify, or otherwise interact with the devices subject to forensic imaging without prior written authorization from Calderwood & Harkness LLP. Any requests from Pinnacle Forensics LLC for access to CRH systems, log data, or network information should be routed through Theresa Yun-Park or Bernard Crawford.
F. Communications.  All communications to, from, or involving any member of the Rathore Group must be preserved, including:
•  All emails (including all attachments, embedded images, and inline content), whether sent, received, or on which any member of the Rathore Group was copied or blind-copied, for the period from January 1, 2024 through the date of this notice;
•  All text messages (SMS and MMS) sent to or received from any member of the Rathore Group on CRH-issued mobile devices or personal devices used for CRH business, for the same period;
•  All instant messages, including messages sent or received via any enterprise messaging platform such as Meridian Solutions, Northgate Data Systems, Jabber, or any similar platform, for the same period;
•  All voicemails left by or for any member of the Rathore Group on CRH voicemail systems, for the same period;
•  All written or electronic correspondence of any kind sent to, received from, or involving any member of the Rathore Group, for the same period;
•  All emails, text messages, instant messages, and written or electronic correspondence between any CRH employee and any representative of Verdana Commerce Group, Inc. or Greystone Capital Partners, LP, without time limitation — this includes all historical communications regardless of when they occurred;
•  Calendar entries, meeting invitations, and meeting notes involving any of the eight departing employees for the period January 1, 2025 through February 7, 2025, including recurring meeting series, one-on-one meetings, team meetings, and any external meetings;
•  Encrypted messaging applications: Any records or evidence of the use of encrypted or disappearing-message platforms on CRH-issued devices by any of the eight departing employees, including but not limited to Harborline Technologies, Meridian Services Inc., Signal, Pemberton Health IT, Confide, or any similar application. If any CRH employee has knowledge that any member of the Rathore Group used such applications for business-related communications, this information must be reported immediately to the contacts identified in Section XI.
G. Human Resources and Compensation Records
•  Complete personnel files for all eight departing employees, including all documents contained therein regardless of date of creation;
•  Equity award records, RSU vesting schedules, stock option exercise records, performance share unit records, and any forfeiture or clawback documentation for all eight departing employees, including records of any accelerated vesting, forfeiture-for-cause provisions, post-termination exercise periods, or other equity-related determinations made in connection with the departures;
•  Records maintained by or in coordination with Northland Trust Company (CRH's transfer agent) relating to equity awards, stock issuances, stock transfers, or other equity transactions for the departing employees;
•  Payroll records, bonus calculations, commission records, incentive compensation determinations, and any other compensation-related records for all eight departing employees, covering the full period of their employment with CRH;
•  Benefits enrollment records, 401(k) plan records, and any other employee benefit records for the departing employees;
•  Organizational charts, reporting structure documentation, and any succession planning materials relating to the Merchandising Division.
H. Corporate Governance and Disclosure
•  Board of Directors minutes, committee minutes (including Audit Committee, Compensation Committee, and any special committee minutes), and management reports or presentations discussing the departures, the Merchandising Division's operations following the departures, any potential litigation or legal claims arising from the departures, or any business impact assessments related thereto;
•  Any communications with Hargrove & Tillett CPA, PLLC (CRH's outside auditors) referencing the departures, potential litigation contingencies, loss accrual analyses, or any related accounting or disclosure matters;
•  Any communications with Keypoint National Bank, N.A. (administrative agent under CRH's $750 million revolving credit facility) relating to the departures, any material litigation reporting obligations under the credit agreement, any covenant compliance analyses affected by the departures, or any related borrower notices or certifications;
•  SEC filings (whether filed or in draft form), including Forms 10-K, 10-Q, 8-K, proxy statements, and any internal analyses, legal memoranda, or drafts discussing the departures, the potential claims, litigation risk assessments, or any related disclosure obligations;
•  Any communications with CRH's investor relations team, financial advisors, or investment bankers relating to the departures or their potential impact on the Company's financial position or strategic outlook;
•  Insurance coverage notifications, claims submissions, or correspondence with CRH's directors and officers liability insurance carrier or employment practices liability insurance carrier relating to the anticipated litigation.
IV. SCOPE OF PRESERVATION — TYPES OF DOCUMENTS AND ESI
The term "documents" as used throughout this notice is to be interpreted in the broadest possible sense consistent with applicable federal and state rules of civil procedure, including the Federal Rules of Civil Procedure and the Washington State Superior Court Civil Rules, and includes, without limitation, the following categories:
Paper Documents:
Originals and all non-identical copies (including copies bearing annotations, highlighting, marginalia, or other markings) of letters, memoranda, notes, reports, analyses, charts, graphs, schedules, calendars, day planners, diaries, notebooks, handwritten notes, sticky notes, whiteboard photographs, flip chart pages, printed emails, printed spreadsheets, printed presentations, business cards, marketing materials, and any other tangible written or printed materials.
Electronic Documents:
Emails (including all attachments and embedded content), word processing files (including Microsoft Word, Stonefield Health IT, and comparable formats), spreadsheets (including Microsoft Excel, Stonefield Services Inc., and comparable formats), presentations (including Microsoft Northgate Services Inc., Pemberton Services Inc., Tidewater Data Systems, and comparable formats), databases and database extracts, PDF files, scanned images, digital photographs, screenshots, audio recordings, video recordings, webinar recordings, screen captures, and any other electronically created or stored files.
ESI on All Media:
Hard drives, solid-state drives, laptops, desktop computers, mobile phones (including smartphones), tablets, USB drives, thumb drives, external hard drives, CDs, DVDs, SD cards, backup tapes, archive tapes, cloud storage accounts (both corporate accounts provisioned by CRH and personal accounts if used for CRH business), network servers, file servers, email servers, NAS devices, SAN storage, and any other electronic storage media.
Metadata:
All metadata associated with electronic documents must be preserved. Metadata includes but is not limited to file creation dates, modification dates, access dates, author information, revision history, track changes, comments, and file properties. Documents should not be opened, modified, re-saved, or otherwise altered in a manner that could change their metadata.
Social Media and Public Postings:
Social media posts, Westmark Health IT activity (including profile changes, job announcements, posts, comments, and connections), Ashford Systems posts, Kestrel Services Inc. posts, Northpoint Services Inc. posts, blog posts, and any other publicly posted content by any of the eight departing employees referencing CRH, Verdana, their employment, their departure, or any related subject matter. CRH employees who become aware of such postings should immediately notify the contacts identified in Section XI.
V. SPECIFIC PRESERVATION INSTRUCTIONS
A. Do Not Destroy, Delete, or Alter
You must not destroy, discard, delete, shred, erase, overwrite, or alter any document or ESI falling within the scope of this hold. This prohibition applies regardless of whether the document is in paper or electronic form, regardless of the medium on which it is stored, and regardless of whether you believe the document to be duplicative of other copies. Specifically:
•  Do not delete emails, text messages, instant messages, or voicemails that may be relevant to this matter;
•  Do not empty your "Deleted Items" or "Trash" folder in your email system without first confirming with Theresa Yun-Park or Calderwood & Harkness LLP that no relevant items are contained therein;
•  Do not modify, edit, or alter any document for the purpose of changing its content, metadata, or any other attribute;
•  Do not re-organize or re-file documents in a way that would alter their existing organizational structure, obscure their location, or impair the ability to determine where documents were maintained in the ordinary course of business;
•  Do not remove documents from existing file folders, directories, or other organizational structures in which they are currently maintained;
•  Do not overwrite existing versions of documents by saving new versions with the same file name in the same location.
B. Suspend Routine Destruction
All routine document retention and destruction policies, records management schedules, and standard operating procedures for document disposal are hereby suspended as they apply to documents and ESI within the scope of this hold. This suspension takes precedence over any contrary instructions you may have previously received from management, IT, records management, or any other source.
IT Department — Immediate Action Required:
The IT Department must immediately take the following steps and confirm their completion in writing to Theresa Yun-Park and Calderwood & Harkness LLP:
•  Suspend all auto-deletion policies for email, including any policies that automatically delete emails from user mailboxes, journaling systems, or archival systems after a specified retention period;
•  Suspend all backup tape recycling and rotation schedules that could result in the overwriting or destruction of backup data containing relevant information;
•  Suspend any server decommissioning, migration, or upgrade projects that could result in the loss of relevant data, unless alternative preservation measures have been approved in advance by Calderwood & Harkness LLP;
•  Suspend any automated archiving processes that could alter the state or metadata of relevant documents;
•  Ensure that litigation hold flags or comparable technical markers are applied to the email accounts, network drives, and cloud storage areas associated with the eight departing employees and all key custodians identified in Section VI.
HR Department — Immediate Action Required:
The HR Department must immediately suspend any routine purging, archiving, or disposal of personnel files, payroll records, benefits records, compensation records, or any other HR-maintained records for the eight departing employees. No such records may be destroyed, transferred to off-site storage, or otherwise made inaccessible without prior written approval from Theresa Yun-Park.
C. Preserve Devices and Physical Media
All CRH-issued devices — including laptops, desktop computers, mobile phones, tablets, and any other electronic equipment — that were returned by the eight departing employees must be preserved in their current state without any modification whatsoever. Specifically:
•  Do not reimage, reformat, wipe, reset, reassign, recycle, donate, or otherwise dispose of any such device;
•  Do not power on, boot, log into, or otherwise access any such device unless specifically directed to do so by Calderwood & Harkness LLP in connection with the forensic imaging process;
•  Store all such devices in a secure location with restricted access and maintain a log of all persons who access the storage location;
•  Coordinate with Pinnacle Forensics LLC through Calderwood & Harkness LLP for the forensic imaging and analysis of these devices. All communications with Pinnacle Forensics LLC regarding this matter should be routed through Bernard Crawford or James Underwood at Calderwood & Harkness LLP to preserve privilege.
In addition, any physical files, notebooks, paper records, binders, printed materials, or other tangible items from the offices, workstations, cubicles, conference rooms, or shared spaces used by the departing employees should be collected and secured immediately. These materials should be inventoried, placed in sealed and labeled containers, and stored in a designated secure location. Contact Theresa Yun-Park for instructions on the designated storage location.
D. Personal Devices and Accounts
If any CRH employee is aware or has reason to believe that any of the eight departing employees used personal devices (personal laptops, personal mobile phones, personal tablets, or other personal computing devices) or personal email or cloud storage accounts (personal Northgate Software, Cascade Health IT, Ridgeline Technologies, Larkspur Technologies, Hollowell Health IT, Meridian Systems, personal Cobalt Ridge Systems, or similar services) for CRH business purposes — including but not limited to sending, receiving, or storing CRH documents, emails, or other business information — this information must be reported immediately to Theresa Yun-Park or Calderwood & Harkness LLP. The same reporting obligation applies if you are aware that any departing employee maintained CRH business information on a home computer, personal network-attached storage device, or any other personal medium.
E. Ongoing Creation of Documents
Documents and ESI created after the date of this notice that fall within the subject matter scope described in Section III are also subject to this preservation hold. This includes, without limitation:
•  Communications about the departures, their impact on CRH's business, or efforts to mitigate that impact;
•  Communications about Verdana's competitive activities, hiring, or business developments;
•  Communications about Project Ridgeline, its status, or its future;
•  Internal investigation notes, findings, or reports relating to the departures;
•  Any communications with or about the departing employees after February 7, 2025.
You should continue to create and maintain documents in the ordinary course of business. The hold does not prohibit the creation of new documents; it requires that all relevant documents, whether pre-existing or newly created, be preserved.
VI. KEY CUSTODIANS
The following individuals are identified as key custodians who are likely to possess documents and ESI of particular relevance to this matter. These individuals should take particular care to identify, preserve, and safeguard all documents and ESI within the scope of this hold:
•  Marcus Langford, Chief Executive Officer
•  Theresa Yun-Park, General Counsel
•  Roland Ashby, Chief People Officer
•  Martin Cho, Vice President, Merchandising (serving as Interim Senior Vice President, Merchandising following the departure of Priya Rathore)
•  All direct reports of Priya Rathore within the Merchandising Division, including those who assumed interim responsibilities following the Rathore Group's departure
•  All IT personnel responsible for systems administration, network security, data management, and information security for the Merchandising Division, including the IT Director and all members of the IT support team assigned to the Merchandising Division's systems and applications
•  All HR business partners who supported the Merchandising Division, including those who participated in the onboarding, performance management, or exit processing for any member of the Rathore Group
•  Finance and Accounting personnel responsible for equity compensation administration, payroll processing, and financial reporting for the Merchandising Division, including personnel who interface with Northland Trust Company in connection with equity transactions
Key custodians should conduct a thorough search of their own files, email accounts, hard drives, personal network folders, desk drawers, filing cabinets, home offices, and any other locations where relevant documents may be stored, and ensure that all such documents are preserved in place. Key custodians should not collect or move documents unless instructed to do so by Theresa Yun-Park or Calderwood & Harkness LLP; the primary directive is to preserve documents where they are.
Additional custodians may be identified as the matter develops and as the investigation progresses. Supplemental preservation notices will be issued as needed to address new custodians, new subject matter categories, or modifications to the scope of this hold.
VII. REPORTING OBLIGATIONS
Prompt and complete reporting of relevant information is essential to the Company's ability to protect its legal rights. Any CRH employee who becomes aware of any of the following must report such information immediately to the contacts identified below:
(a) The destruction, deletion, alteration, or loss of any documents or ESI potentially within the scope of this hold, whether intentional or inadvertent, and regardless of when such destruction, deletion, alteration, or loss occurred;
(b) Additional sources of relevant documents or ESI not specifically addressed in this notice, including previously unknown file locations, backup systems, personal devices, third-party storage, or other repositories;
(c) Any communications with or from any of the eight departing employees, Verdana Commerce Group, Inc., Greystone Capital Partners, LP, or any of their representatives, received or initiated after February 7, 2025, regardless of the subject matter of the communication;
(d) Any social media activity, public statements, or published content by any member of the Rathore Group that references CRH, Verdana, or their employment or departure;
(e) Any other information potentially relevant to this matter, including rumors, observations, or knowledge regarding the circumstances of the departures, the coordination thereof, or the involvement of Verdana or Greystone in recruiting the Rathore Group.
Reports should be made to:
Theresa Yun-Park General Counsel Cascade Retail Holdings Inc. 2200 Elliott Avenue West, Suite 3400 Seattle, WA 98119
Email: tyunpark@cascaderetail.com
Phone: (206) 555-4100
Bernard Crawford Partner, Calderwood & Harkness LLP 1301 K Street NW, Suite 1200 Washington, DC 20005
Email: bcrawford@calderwoodharkness.com
Phone: (202) 555-7800
Do not attempt to investigate or collect documents on your own. Do not conduct interviews, review the personal effects of departing employees, access their former offices or workstations (beyond normal business use of shared spaces), or take any other investigative steps without prior authorization from Theresa Yun-Park or Calderwood & Harkness LLP. Unauthorized collection or investigation activities could compromise the integrity of evidence, create privilege issues, or otherwise prejudice CRH's legal position.
VIII. CONFIDENTIALITY
This litigation hold notice, its contents, and the existence of the anticipated litigation are confidential and subject to the attorney-client privilege and the work product doctrine. The protections afforded by these doctrines are essential to CRH's legal position and must not be compromised.
Accordingly, you must observe the following confidentiality requirements:
•  Do not discuss this notice, the anticipated litigation, the subject matter of this hold, or any information you have provided or received in connection with this hold with any person outside of CRH, unless you have been specifically directed to do so by Theresa Yun-Park or Calderwood & Harkness LLP;
•  Do not forward this notice, in whole or in part, to any person who is not on the approved distribution list maintained by Theresa Yun-Park and Roland Ashby;
•  Do not discuss this notice, the anticipated litigation, or any related subject matter with any of the eight departing employees, any representative of Verdana Commerce Group, Inc., any representative of Greystone Capital Partners, LP, or any other third party, including but not limited to members of the press, industry analysts, personal attorneys, or family members;
•  Do not post any information about this notice or the anticipated litigation on social media, personal blogs, or any other public or semi-public platform;
•  If you are contacted by any representative of Verdana, Greystone, or any of the departing employees regarding any subject matter potentially related to this hold, do not substantively respond and immediately report the contact to Theresa Yun-Park or Bernard Crawford.
Unauthorized disclosure of this notice or the information contained herein may constitute a waiver of attorney-client privilege, which could have significant adverse consequences for CRH in the anticipated litigation. Any such unauthorized disclosure may also subject the disclosing individual to disciplinary action.
IX. CONSEQUENCES OF NON-COMPLIANCE
CRH takes its document preservation obligations extremely seriously. The preservation of evidence is a legal obligation of the highest order, and compliance with this litigation hold is mandatory for every CRH employee who receives it.
Failure to comply with this litigation hold may result in:
(a) Severe legal consequences for CRH, including court-imposed sanctions, adverse inference instructions (pursuant to which a court or jury may be instructed to presume that any destroyed, deleted, or altered evidence was unfavorable to CRH), exclusion of evidence, dismissal of claims, default judgments, monetary penalties, and attorneys' fees awards. Courts have imposed substantial sanctions on parties and individuals who fail to preserve relevant evidence, and CRH cannot afford to have its legal position compromised by the carelessness or misconduct of any individual employee.
(b) Disciplinary action up to and including termination of employment for any CRH employee who willfully or negligently fails to comply with the preservation obligations set forth in this notice. This includes the willful destruction or concealment of documents, the deliberate failure to report known sources of relevant information, and the negligent failure to take reasonable steps to preserve documents within the employee's possession or control.
If you have any uncertainty about what is required of you under this hold, or if you believe that compliance with any aspect of this hold may be impracticable or unduly burdensome, you must raise those concerns with Theresa Yun-Park or Calderwood & Harkness LLP before taking (or failing to take) any action that could affect the preservation of relevant documents. Do not make unilateral decisions about what to preserve or what to discard. When in doubt, preserve everything and ask for guidance.
X. ACKNOWLEDGMENT REQUIREMENT
Each recipient of this notice is required to sign and return the attached Acknowledgment and Compliance Certification Form (Attachment A) to Theresa Yun-Park or her designee within three (3) business days of receipt of this notice. The deadline for return of the Acknowledgment Form is therefore no later than the close of business on February 24, 2025 (assuming receipt on the date of issuance).
The Acknowledgment Form confirms that you have read this notice in its entirety, that you understand the preservation obligations set forth herein, and that you will comply fully with those obligations. Your signature on the Acknowledgment Form constitutes a personal commitment to preserve all relevant documents and ESI within your possession, custody, or control.
If you have questions about whether specific documents or ESI fall within the scope of this hold, or if you need clarification on any aspect of this notice, contact Theresa Yun-Park or Bernard Crawford immediately. Do not delay returning the Acknowledgment Form while awaiting responses to questions; you may submit the form and raise questions in parallel.
CRH will maintain a log of all Acknowledgment Forms received and will follow up with any recipients who fail to return the form within the specified timeframe. Failure to return the Acknowledgment Form does not relieve you of the obligation to comply with this litigation hold. The preservation obligations described herein are effective immediately upon your receipt of this notice, regardless of whether you have signed or returned the Acknowledgment Form.
XI. CONTACT INFORMATION
For any questions about this litigation hold, the scope of preservation, your individual obligations, or any other matter relating to this notice, please contact:
Theresa Yun-Park General Counsel Cascade Retail Holdings Inc. 2200 Elliott Avenue West, Suite 3400 Seattle, WA 98119
Email: tyunpark@cascaderetail.com
Phone: (206) 555-4100
Bernard Crawford Partner Calderwood & Harkness LLP 1301 K Street NW, Suite 1200 Washington, DC 20005
Email: bcrawford@calderwoodharkness.com
Phone: (202) 555-7800
James Underwood Associate Calderwood & Harkness LLP 1301 K Street NW, Suite 1200 Washington, DC 20005
Email: junderwood@calderwoodharkness.com
Phone: (202) 555-7815
Please do not hesitate to reach out with any questions, no matter how minor they may seem. It is far better to ask a question and receive guidance than to make an incorrect assumption about your preservation obligations.
This Litigation Hold Notice has been prepared by Calderwood & Harkness LLP on behalf of Cascade Retail Holdings Inc. and is issued pursuant to the direction of CRH General Counsel Theresa Yun-Park. Distribution of this notice to the persons identified on the attached distribution list has been authorized by Ms. Yun-Park and Roland Ashby, Chief People Officer.
ATTACHMENT A
ACKNOWLEDGMENT AND COMPLIANCE CERTIFICATION FORM
LITIGATION HOLD NOTICE — ACKNOWLEDGMENT AND COMPLIANCE CERTIFICATION
Calderwood & Harkness LLP Matter No. 1038-00006
I acknowledge receipt of the Litigation Hold Notice dated February 19, 2025, issued by Calderwood & Harkness LLP on behalf of Cascade Retail Holdings Inc. ("CRH") in connection with the matter referenced as Calderwood & Harkness LLP Matter No. 1038-00006 (the "Notice").
I have read and understand the Notice in its entirety. I confirm that I will comply with all preservation obligations set forth therein. Specifically, I will not destroy, delete, alter, overwrite, or dispose of any documents or electronically stored information ("ESI") falling within the scope of the litigation hold described in the Notice. I will take all reasonable steps to identify and preserve relevant documents and ESI within my possession, custody, or control. I will promptly report to the designated contacts identified in the Notice any relevant information, potential preservation issues, additional sources of relevant documents, or any communications from or regarding the departing employees, Verdana Commerce Group, Inc., or Greystone Capital Partners, LP.
I understand that failure to comply with the preservation obligations described in the Notice may result in severe legal consequences for CRH, including court-imposed sanctions, and may result in disciplinary action against me, up to and including termination of my employment.
I understand that the Notice, its contents, and the existence of the anticipated litigation are confidential and privileged, and I will not disclose or discuss this information with any person outside of CRH or with any unauthorized person, as described in the Notice.
________________________________________
Signature
________________________________________
Printed Name
________________________________________
Title / Department
________________________________________
Date
________________________________________
Email Address
________________________________________
Phone Number
RETURN INSTRUCTIONS: Please sign this form and return it within three (3) business days of your receipt of the Litigation Hold Notice. Completed forms should be returned by one of the following methods:
•  Email: Scan the signed form and email to Theresa Yun-Park at tyunpark@cascaderetail.com
•  Interoffice Mail: Send to Theresa Yun-Park, General Counsel, Legal Department, Suite 3400
•  Hand Delivery: Deliver to the Legal Department, Suite 3400, 2200 Elliott Avenue West, Seattle, WA 98119
If you have questions about this form or the Litigation Hold Notice, contact Theresa Yun-Park at (206) 555-4100 or Bernard Crawford at (202) 555-7800.
ATTACHMENT B
LIST OF DEPARTING EMPLOYEES
The following individuals, collectively referred to as the "Rathore Group," resigned from Cascade Retail Holdings Inc. simultaneously on February 7, 2025. Each of these individuals has accepted a position at Verdana Commerce Group, Inc., a direct competitor of CRH headquartered in Wilmington, Delaware.
Note: All eight individuals listed above were employed within CRH's Merchandising Division. They resigned on the same date and in a coordinated manner. CRH's counsel has reason to believe that these departures were planned in advance and may have been facilitated by representatives of Verdana Commerce Group, Inc. and/or its private equity sponsor, Greystone Capital Partners, LP. All documents and ESI relating to these individuals and the circumstances of their departures must be preserved in accordance with the Litigation Hold Notice to which this Attachment B is appended.
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION Calderwood & Harkness LLP Matter No. 1038-00006
No. | Name | Former CRH Title
1 | Priya Rathore | Senior Vice President, Merchandising
2 | Derek Linden | Vice President, Hardlines Merchandising
3 | Sonia Kaczmarek | Vice President, Softlines Merchandising
4 | Amara Osei | Director, Private Label Strategy
5 | Brent Halvorsen | Director, Seasonal Planning & Analytics
6 | Lucia Fernandez-Gill | Director, Vendor Relations (Domestic)
7 | Nathan Tsao | Senior Manager, eCommerce Merchandising
8 | Kira Johansson | Senior Manager, Category Analytics