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Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / second-request-compliance-strategy-memo.docx
second-request-compliance-strategy-memo.docx
Parties
HARKNESS LLP
Loomis LLP
Delaware General Corp
Dates
September 18, 2023
September 15, 2023
August 18, 2023
August 10, 2023
July 10, 2023
March 10, 2024
June 10, 2024
July 7, 2023
August 8, 2023
August 25, 2023
Amounts
$800,000,000
$13.70
$500,000,000
$300,000,000
$111.4
$445.6
$45,000,000
Obligations
Interrogatories — Key Areas The CID includes 12 interrogatories that require detailed narrative responses, each of which must be verified under oath by an authorized officer of Halcyon
The data must cover the period from September 2016 to the present (the full seven-year lookback period for pricing-related specifications)
While many of these documents will be privileged and withheld from production, her files must nonetheless be collected and reviewed to identify non-privileged responsive documents and to ensure comprehensive privilege logging
• Communications with financial advisors: Communications with Ridgeline Partners (Halcyon's financial advisor) and Clearwater Zanthor must be reviewed carefully
• Communications with auditors: Communications with Thornbury Wight (Halcyon's auditor) and Linden Ross (Vectris's auditor) must be reviewed for privilege issues, particularly with respect to any communications that involve legal advice or that were prepared at the direction of counsel
However, documents that reflect purely business-planning activities — such as headcount reduction plans, organizational restructuring proposals, and operational integration timelines — are generally not privileged and must be produced