Extract to table

B below provide further detail, but this memorandum should be read expansively; if there is any doubt as to whether a particular document falls within the scope of the hold, the document must be preserved

Any documents that existed as of the date the preservation duty attached and that fall within the scope of the hold must be preserved, regardless of when the litigation hold notice is formally distributed within the Company

Additionally, backup tapes and archived data must be preserved to the extent they contain unique, non-duplicative information that is not otherwise available from active data sources

Subject Matter Categories The following categories of documents and ESI must be preserved

If a document or item of ESI could reasonably fall within the scope of any of these categories, or could otherwise be relevant to the claims or defenses in this litigation, it must be preserved

All documents relating in any way to the proposed acquisition of Pinnacle must be preserved in their entirety