Extract to table

The purpose of this letter is to advise the Company of its immediate and continuing obligation to identify, preserve, and protect all documents, electronically stored information ("ESI"), and tangible things that may be relevant to this dispute, and to set forth the steps that must be taken without delay to satisfy that obligation

All routine destruction, deletion, overwriting, recycling, or disposal of materials covered by this hold must cease immediately

Scope of the Dispute To assist in identifying the categories of materials that must be preserved, we provide the following summary of the dispute and the principal grounds asserted by Pinnacle Atlantic in its February 14, 2026 demand letter

Furthermore, to the extent that any materials from periods outside TY 2021 through TY 2023 are relevant to the interpretation or performance of the Treaty, the underlying claims, or the parties' course of dealing, such materials must also be preserved

Categories of Materials to Be Preserved The following is a detailed, but non-exhaustive, description of the categories of documents, ESI, and tangible things that must be preserved under this hold

If there is any doubt as to whether a particular document or category of information falls within the scope of this hold, the presumption must be in favor of preservation, and the question should be directed to C&H for a determination