Common use of Requests for Production of Documents Clause in Contracts

Requests for Production of Documents. In lieu of promulgating document requests and responses thereto pursuant to Federal Rule of Civil Procedure 34, and in an effort to expeditiously resolve or commence mediation of the Mansfield Claims, the Parties shall work together in good faith to identify and exchange documents relevant to the Mansfield Claims pursuant to the following schedule: a. The Debtors shall, by March 28, 2018, provide the Parties with a proposed list of documents or categories of documents relating to the Mansfield Claims to be disclosed to the Parties, including the custodians of such documents (the “Diligence List”). b. The Mansfield Parties, the Ad Hoc Noteholder Group, and the Committee (if it agrees to participate by such time) shall respond with additions to or comments on the Diligence List by April 10, 2018. c. The Parties shall work in good faith, including by meeting and conferring as needed to resolve any objections to materials requested in connection with the Diligence List, to finalize the Diligence List by April 20, 2018; provided that the Diligence List may be reasonably supplemented after April 20, 2018 based on ongoing discovery. d. The Parties shall exchange documents agreed upon in the Diligence List on a rolling basis, and will substantially complete their exchange of documents by July 15, 2018 or by a date as modified pursuant to paragraph 22 of this Stipulation and Protocol. e. For the avoidance of doubt, nothing in this paragraph 12 shall preclude any of the Parties from seeking relief from the Bankruptcy Court with respect to the Diligence List, including without limitation any requests, responses, productions, or objections made in connection therewith, pursuant to paragraph 22 of this Stipulation and Protocol.