Below are the two documents. --- # Document 1: Litigation Hold Notice **PRIVILEGED AND CONFIDENTIAL** **LEGAL HOLD NOTICE** **To:** Sara Okafor; all current sensor firmware team members; [the two Fenwick Embedded LLC firmware engineers]; Marcus Bell; and all sales/support employees with Ridgeline Foods account or ticket responsibilities. **Re:** Ridgeline Foods / VX-9 Proximity Sensors Trellick has received a demand letter from Ridgeline Foods concerning VX-9 proximity sensors on packaging equipment and two line-stoppage incidents. Litigation is reasonably anticipated. This notice overrides any routine deletion, retention, reimaging, or cleanup schedule. **Preserved subject matter.** Preserve all Potentially Relevant Information (“PRI”) relating to: - the design, development, coding, testing, validation, manufacture, sale, installation, maintenance, and support of VX-9 proximity sensors; - communications with Ridgeline Foods about VX-9 sensors, packaging equipment, performance, line stoppages, incidents, warranty, or support; - firmware, source code, code reviews, bug reports, Jira tickets, test-bench telemetry, validation logs, quality records, and customer complaints involving VX-9; - the two line-stoppage incidents described in the demand letter. **Time period:** [date three years before this notice] through the present. Preserve older related information as well. **Sources you must preserve:** - All email, including personal email used for work; calendars, contacts, drafts, deleted items, archives, and attachments. - All messaging applications used for work, including the personal-phone messaging app used by the firmware team and all group threads. If an app auto-deletes messages, disable that setting now. Until auto-deletion is disabled or the data has been collected, do not use that app for work-related communications. If you cannot disable auto-deletion, contact Legal immediately and preserve messages by export or screenshot before deletion. - Slack channels, DMs, threads, files, and attachments. - Jira tickets, comments, attachments, and engineering records. - Git repositories, source code, commits, branches, pull requests, build logs, and local code copies. - Test-bench telemetry, raw logs, validation data, and sensor records. - Shared drives, local drives, cloud storage, USB drives, and personal devices used for work. - CRM records and support-ticket platform content relating to Ridgeline Foods. - Marcus Bell’s laptop, email account, and any other data used for work. - If you are a contractor, all Trellick-related data in your possession, custody, or control, including data on personal devices. **Instructions:** 1. Do not delete, modify, destroy, move, encrypt, or alter any PRI or metadata. 2. Do not run cleanup, purge, auto-delete, overwrite, reimage, or reset functions on any device or system containing PRI. 3. Do not decide whether information is relevant or whether you agree with Ridgeline’s claims. If uncertain, preserve it and contact Legal. 4. Keep PRI in place and in native form. Do not filter, consolidate, or transfer it. 5. If you control or direct any third-party system or vendor holding Trellick data, ensure that data is preserved and notify Legal before any scheduled deletion. **Point of contact:** [Name], [title], [email], [phone]. **Acknowledgment required.** Please reply to this notice by [date/time] with the following statement: “I have received, read, and will comply with this Legal Hold Notice.” If you believe you have no responsive information, reply and say so. This notice is not an admission of liability or fact. Trellick reserves all rights. --- # Document 2: Preservation Action Memo **PRIVILEGED AND CONFIDENTIAL** **To:** General Counsel **From:** Litigation Counsel **Re:** Preservation Actions – Ridgeline / VX-9 **Date:** [Date] The custodial hold notice is being issued separately. These technical and vendor actions are ordered by urgency. 1. **Preserve Marcus Bell’s laptop and mailbox.** Owner: IT. Deadline: before Friday’s reimage and before any 30-day mailbox deletion. **Most time-critical:** the laptop has a fixed Friday reimage date, no backup has been identified, and reimaging would irretrievably destroy unique QA-lead evidence. IT should image the laptop, preserve the mailbox, and not reimage or reissue until Legal authorizes. 2. **Collect personal-phone messaging app data.** Owner: IT/forensic vendor, with Sara Okafor. Deadline: today. Disable auto-delete and export all work-related chats and group threads. The rolling seven-day deletion will continue destroying data daily. 3. **Suspend the shared-drive “spring cleanup.”** Owner: IT Infrastructure. Deadline: before the scheduled weekend run. Preserve all shared-drive data, including folders older than 24 months. 4. **Disable Slack 45-day deletion and export Slack content.** Owner: Slack admin/IT. Deadline: today. Suspend the purge and export all VX-9/Ridgeline channels, DMs, threads, and files. 5. **Stop test-bench telemetry overwrite and archive VX-9 data.** Owner: Engineering/IT. Deadline: within 24 hours. Disable the 21-day rolling overwrite and preserve all raw telemetry and validation logs. 6. **Snapshot Jira and Git repositories.** Owner: DevOps. Deadline: within 72 hours. Freeze any cleanup, and preserve repos, branches, commits, pull requests, tickets, comments, and attachments. 7. **Send a preservation notice to Fenwick Embedded LLC.** Owner: Legal/Procurement. Deadline: today. Require Fenwick and its two engineers to preserve all Trellick-related email, source code, messaging app data, local copies, and backups. 8. **Place a vendor preservation hold on CRM and support-ticket data.** Owner: Sales/Support Ops and Legal. Deadline: before any 12-month retention deletion. Instruct the vendor to preserve all Ridgeline records, closed tickets, attachments, and CRM data and suspend deletion. Please confirm completion of each action. Item 1 is the most time-critical because Bell’s laptop reimage is an imminent, fixed-date destruction event and its data would otherwise be irreplaceable.