# DOCUMENT 1 — LITIGATION HOLD NOTICE

**PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION**
**Matter:** Ridgeline Foods — VX-9 proximity sensors (Hold No. 25-04)
**From:** D. Alvarez, Litigation Counsel, Trellick Automation
**Date:** Today, effective immediately
**Action required:** Acknowledge within 2 business days.

**1. Why you received this**
Trellick has received a demand letter from Ridgeline Foods asserting claims relating to VX-9 proximity sensors on packaging equipment. Litigation is reasonably anticipated, so Trellick has a legal duty to preserve potentially relevant information. This notice is procedural. It takes no position on the claims and states no conclusion about the equipment or the incidents.

**2. Custodians**
Sara Okafor and all six VX-9 firmware engineers; the two Fenwick Embedded LLC contract firmware engineers; the test/validation engineering manager and validation-rig operators; sensor-line QA staff and Marcus Bell's manager; the Ridgeline account manager and supporting sales staff; support and field-service personnel who handled the two line-stoppage matters; manufacturing/operations leads for the affected lines; IT infrastructure, DevOps, the Slack workspace owner, and CRM/support-platform administrators. Separate letters issue to Fenwick Embedded LLC, to Mr. Bell, and to the support-ticket vendor.

**3. Subject matter**
Preserve anything relating to: VX-9 design, firmware, source code, commits, branches, builds and Jira issues; validation, test-bench and telemetry data, calibration and QA records; defects, false trips, latency, known issues, workarounds, patches, release notes; the two Ridgeline line-stoppage events and any root-cause or escalation work; RMAs, returned or failed units at any customer; the Ridgeline relationship (contracts, specs, quotes, warranties, correspondence); VX-9 component suppliers; and this dispute.

**Date range:** January 1, 2022 (or the earliest VX-9 work, if earlier) through today, and continuing until counsel tells you in writing that the hold is lifted.

**4. Sources**
Company email and calendars; Slack channels and DMs; Jira; Git repositories, branches, tags and CI logs; test-bench telemetry and local rig files; shared and personal network drives; laptops, desktops, local and downloaded files; CRM records and support tickets with attachments; **personal phones, tablets and home computers used for work**, including the team messaging app and its group thread, SMS, and personal email used for work; voicemail; notebooks, handwritten notes and whiteboard photos; and physical items — sensor units, returned or failed units, and test fixtures.

**5. What you must do now**

- **Do not delete, alter, overwrite, archive out, or move** anything in scope, and do not reformat, reset, wipe, trade in, or dispose of any device.
- **Turn off auto-delete/disappearing messages today** in the team messaging app on every device, personal or company, and do not leave or clear the group thread.
- **Do not run or permit any cleanup, purge, archive, reimaging, or retention job** touching in-scope material; report any that is scheduled to me immediately.
- **Do not delete Jira issues, Git branches or tags, and do not force-push or rewrite history.**
- **Do not select what to keep.** You may not judge relevance, cull duplicates, "tidy," or summarize and delete originals. Preserve everything in scope and let counsel review it.
- **Make personal devices available** for targeted collection when contacted; collection will be scoped to work content.
- Route all Ridgeline contact to me. Do not discuss this notice outside the recipient list, and do not create commentary, speculation, or analyses about the incidents.

**6. Acknowledgment**
Sign and return the attached acknowledgment within 2 business days, listing any additional sources or devices you use for work. Questions — including any burden or privacy concern — go only to me: D. Alvarez, dalvarez@trellick.com, (312) 555-0142.

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# DOCUMENT 2 — PRESERVATION ACTION MEMO

**To:** General Counsel **From:** D. Alvarez, Litigation Counsel
**Re:** Ridgeline/VX-9 — technical, collection and vendor actions outside the hold notice

**Most time-critical:** Item 1. The one-week auto-delete messaging app is the only source destroying evidence *continuously and irreversibly right now*: there is no server-side or backup copy, everything older than seven days is already gone, and each additional day permanently erases a day of the design team's substantive discussion. Every other exposure is a scheduled event we can stop with a single instruction; this one runs by the hour, and loss continuing after notice risks an intent-to-deprive finding.

| # | Action | Owner | Deadline |
|---|---|---|---|
| 1 | Disable disappearing messages on all messaging-app threads (Okafor, 6 engineers, 2 contractors); scope and run targeted forensic capture of chats from 9 devices | Counsel + IT Security with forensic vendor | Disable today; collection within 3 business days |
| 2 | Cancel Friday reimaging of Bell's laptop; sequester and forensically image it; place legal hold on his mailbox to block 30-day deletion; send Bell a preservation letter covering personal accounts/devices | IT Asset Mgr.; Messaging Admin; HR; Counsel | Cancel + mailbox hold today; image by Thursday 5 p.m. |
| 3 | Cancel the company-wide shared-drive "spring cleanup"; confirm the job is disabled in the scheduler, in writing | Infrastructure Manager | Today; written confirmation by Friday noon |
| 4 | Slack: suspend 45-day deletion (plan/retention change), export all current workspace content, and ask vendor whether deleted messages are recoverable | Workspace Owner / IT Director | 24 hours |
| 5 | Test rigs: stop the 21-day telemetry overwrite, copy current buffers to preserved storage, start forward capture, search backups for the incident windows | Test Engineering Mgr. + IT | 24 hours |
| 6 | Jira/Git: revoke delete rights, protect branches, block force-push and history rewrite, snapshot repos, export Jira project | DevOps Lead | 48 hours |
| 7 | Fenwick Embedded LLC: preservation demand invoking contract records/audit rights; preserve contractor laptops, chat data, repo access logs; obtain written acknowledgment | Counsel + Procurement | Letter today; acknowledgment in 3 business days |
| 8 | Support vendor + CRM: legal-hold letter suspending the 12-month closed-ticket attachment purge; export all Ridgeline tickets, attachments and CRM records; disable CRM purge | Counsel; Support Director; CRM Admin | Letter today; exports in 5 business days |
| 9 | Apply litigation hold to all custodian mailboxes; suspend auto-archive/PST purge; log every step, track acknowledgments, interview custodians for unlisted sources; 30-day re-verification | Messaging Admin; Counsel/paralegal | Holds in 24 hours; log ongoing |