FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / second-request-response-strategy-memo.docx
second-request-response-strategy-memo.docx · 1038-00009

Parties

Harkness LLP
Crane LLP
Counsel Cascade Retail Holdings Inc
Development Cascade Retail Holdings Inc
NovaMart Global Inc
Cascade Retail Holdings Inc
Loewe LLP
BrightBazaar Inc

Dates

May 12, 2025
May 8, 2025
May 19, 2025
February 14, 2025
February 18, 2025
May 11, 2025
October 15, 2025
December 31, 2025
April 11, 2025
January 1, 2023

Amounts

$1,200,000,000
$14.7
$891
$6.2
$2,390,000
$1.2

Obligations

Both parties must certify substantial compliance before the new waiting period begins to run, so close coordination on timing is essential
The Clean Team Protocol remains in full force and effect and must be scrupulously observed throughout the Second Request response process
To the extent that the DOJ's investigation generates cross-party document sharing (for example, if Cascade's counsel needs to review NovaMart documents to prepare investigational hearing witnesses), such sharing must be conducted within the Clean Team framework
Any Cascade business personnel who are authorized to access NovaMart competitively sensitive information must be designated members of the Clean Team and must have executed the appropriate confidentiality undertakings under the Clean Team Protocol
Vasquez-Bright's files may be subject to attorney-client privilege and/or work product protection, but her files must nonetheless be collected and reviewed
All custodian email accounts, including both active mailboxes and archived messages, must be collected for the applicable time period