Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / memo-rate-adjustment-motive-evidence.docx
memo-rate-adjustment-motive-evidence.docx
Parties
HARKNESS LLP
Rate Inc
Vantor Holdings Corp
Stonefield Logistics Group Inc
Vantor Transport Services LLC
Ashford Meridian LLP
Cascade Freight Systems Inc
Kensington Analytics Group LLC
Dates
March 28, 2023
December 2, 2022
March 15, 2019
April 1, 2022
September 22, 2021
April 1, 2019
March 31, 2024
January 18, 2022
March 4, 2022
April 14, 2023
Amounts
$6.2
$95.4
$2.87
$3.28
$43.2
$6.18
$1.42
$1.28
$118
$680
Obligations
This is the narrative we must be prepared to confront
When a carrier rejects a tender, the shipper-broker must find alternative capacity to move the freight — it cannot simply leave loads sitting unshipped
Motivation by Rate Adjustment A critical analytical distinction must be drawn between awareness of an upcoming rate adjustment and motivation by that rate adjustment to manufacture a pretextual termination
Trial Preparation If the case proceeds to trial on the Cause/pretext issue — whether following a denial of summary judgment or because the Court determines that the wrongful termination claim presents questions for the jury — our witnesses must be thoroughly prepared to address the rate adjustment motive allegation
We must ensure that her trial testimony is consistent with her deposition testimony in all respects