Extract to table

If a document contains any substantive discussion of the topics listed above — even where such discussion appears as part of a broader financial, operational, or strategic analysis — the document is responsive and must be produced

However, proprietary analyses that incorporate or build upon publicly available data are responsive and must be produced

Identification of Custodians A critical step in the document collection process is identifying all individuals whose files must be searched for responsive materials

Primary Custodians The following individuals' files — including email accounts (active and archived), hard copy files, shared network drives, deal management platforms, and any other document repositories — must be searched comprehensively: 1