**LITIGATION HOLD NOTICE**

**TO:** All Engineering Staff (including VP of Engineering Sara Okafor and Firmware Team), QA Leadership, Sales, Customer Support, IT Administration, and Third-Party Contractors (Fenwick Embedded LLC)
**FROM:** Litigation Counsel
**DATE:** October 24, 2023
**RE:** LITIGATION HOLD – Ridgeline Foods Dispute / Sensor Model VX-9

**1. NOTICE OF POTENTIAL LITIGATION**
Trellick Automation has received a demand letter regarding alleged defects in the proximity sensors used in packaging equipment (Model VX-9). Litigation is reasonably anticipated. You are hereby instructed to preserve all information related to this matter. Failure to comply may result in disciplinary action and legal sanctions.

**2. SCOPE OF PRESERVATION**
You must preserve all electronically stored information (ESI) relating to the design, development, testing, sales, or support of the **VX-9 sensor model**, from **October 24, 2020, through the present**. This includes information regarding line-stoppage incidents in the past 90 days.

**3. SPECIFIC SOURCES TO PRESERVE**
Do not delete or alter any relevant information on the following sources:
*   **Work Devices:** Company laptops, email accounts, and workstations.
*   **Collaboration Tools:** Slack (suspend auto-deletion), Jira tickets, Git repositories, and shared drives.
*   **Testing Data:** Test-bench telemetry from validation rigs (do not allow overwriting).
*   **Personal Devices:** Any work-related communications on personal phones or tablets. Specifically, **VP Okafor and the firmware team must NOT rely on auto-delete messaging apps.** Preserve all messages immediately; do not curate or select what to keep based on relevance.
*   **Contractors:** Fenwick Embedded LLC personnel must preserve all emails and app messages related to Trellick work.

**4. DESTRUCTION POLICIES**
Immediately suspend any routine retention policies, auto-deletion settings, or data purging schedules that may affect the scope above. Do not manually delete emails, chats, or files.

**5. ACKNOWLEDGMENT**
You must sign and return the attached Acknowledgment Form to Litigation Counsel by **end of business today**, confirming you have read this notice and understand your obligations.

For technical assistance with preservation, contact IT Security (ext. 440). Legal questions should be directed to the undersigned. Do not discuss the merits of this dispute with third parties.

***

**MEMORANDUM**

**TO:** General Counsel
**FROM:** Litigation Counsel
**DATE:** October 24, 2023
**RE:** IMMEDIATE PRESERVATION ACTIONS REQUIRED

Per the litigation hold issued above, the following technical suspensions and collections must occur outside of custodian instructions. These are ordered by urgency.

1.  **Marcus Bell Laptop Imaging (IT Security)**
    *   **Deadline:** Thursday COB (Before Friday reissue).
    *   **Action:** Image Marcus Bell’s laptop immediately upon return or intercept reimaging process. Suspend email account deletion scheduled for 30 days post-departure indefinitely.
2.  **Shared Drive "Spring Cleanup" Suspension (IT Administration)**
    *   **Deadline:** Tonight (Before Weekend Purge).
    *   **Action:** Halt the company-wide folder purge script to prevent loss of documents older than 24 months relevant to VX-9 history.
3.  **Test-Bench Telemetry Snapshot (QA Lead / IT)**
    *   **Deadline:** Immediate.
    *   **Action:** Export all current telemetry data from sensor validation rigs before the 21-day overwrite cycle completes.
4.  **Personal Messaging App Forensics (IT Security / VP Okafor)**
    *   **Deadline:** Within 48 hours.
    *   **Action:** Coordinate with Sara Okafor and team to export/screenshot work-related messages from the personal auto-delete app before the weekly cycle runs. Instruct Fenwick contractors to export logs.
5.  **Slack Retention Configuration (Workspace Admin)**
    *   **Deadline:** Within 48 hours.
    *   **Action:** Upgrade workspace or configure exception to prevent 45-day message deletion for relevant channels.
6.  **Support Ticket Vendor Freeze (Customer Support Lead)**
    *   **Deadline:** Within 72 hours.
    *   **Action:** Contact vendor to suspend the 12-month attachment retention policy for closed Ridgeline tickets.

**Most Time-Critical Action:** Marcus Bell Laptop Imaging.
**Reason:** The scheduled reimaging occurs this Friday. Once reissued, the data is irretrievably overwritten. Unlike rolling systems (telemetry/Slack), this is a hard destruction deadline occurring in less than 72 hours, posing the highest immediate risk of non-replaceable information loss and potential spoliation sanctions.

We require budget approval for forensic imaging tools by EOD today to execute Action #1 without delay.