Extract to table

If, after a diligent and thorough search, Northwind maintains that no responsive communications exist, Northwind must so state in writing, identify the custodians searched, describe the search methodology employed, and certify the completeness of its search

Moreover, if Northwind received consideration from Eastbourne in connection with a settlement — whether in the form of cash payments, hire credits, revised charter terms, or other consideration — that consideration must be accounted for in calculating Northwind's net damages, if any, against TSL

Governing Legal Standards The legal standards governing document discovery in this action are clear and well-established, and they compel the conclusion that Northwind's production deficiencies must be remedied

Nothing in this letter shall be construed as a waiver or limitation of any of Defendants' rights or positions in this action