Contract analysis

I. Description of the Second Document Production A. Volume and Bates Range This second production consists of sixty-three thousand four hundred (63,400) documents, Bates-stamped DUNMORE-048201 through DUNMORE-111600. The production is being made in the same format and on the same media as the first document production submitted to FERC Staff on July 24, 2023. B. Cumulative Production Statistics For FERC Staff's conve

1. Kyle Renfro, Senior Trader, MISO Day-Ahead Desk, DPT;

2. Anastasia Petrov, Trader, MISO Real-Time Desk, DPT;

3. Derek Sung, Senior Vice President, Power Marketing & Trading, DPT;

4. Rhonda Vasquez, Vice President, Regulatory Affairs, DEH;

5. Jennifer Caulfield, Chief Compliance Officer, DEH;

6. Elena Mirova, President & Chief Operating Officer, DEH; and

7. Five (5) additional trading desk and operations personnel as specified in the negotiated custodian list. We note that this second production includes additional documents from custodians whose electronic collections were still undergoing forensic processing, de-duplication, and attorney review at the time Dunmore's first production was submitted on July 24, 2023. In particular, the processing and review of documen

II. Production Format and Processing Consistent with the production format agreed upon between C&H and FERC Staff, the documents in this second production are produced in native format where feasible. Where native format production was not feasible — for example, in the case of certain hard-copy documents, handwritten notes, and legacy file formats — documents have been produced as single-page TIFF images accompanied

III. Privilege Withholdings and Redactions Certain documents collected from the identified custodians that are responsive to the First Data Request and/or the Supplemental Second Data Request have been withheld in their entirety, or produced in redacted form, on the basis of the attorney-client privilege and/or the work product protection doctrine. These withholdings and redactions are consistent with the legal bases

IV. Confidentiality Designations Certain documents included in this second production contain commercially sensitive, proprietary, or confidential business information pertaining to Dunmore's trading strategies, positions, financial condition, contractual relationships, personnel matters, and operational processes. Such documents have been designated as "CONFIDENTIAL" pursuant to 18 C.F.R. § 1b.9 and bear a correspon

V. Ongoing Production Obligations Dunmore's document review and production efforts are ongoing. The Company's counsel and document review teams continue to process and review potentially responsive materials from the identified custodians, and Dunmore continues to search for and collect additional materials that may be responsive to the outstanding data requests. Dunmore anticipates that additional responsive documen

VI. Reservation of Rights This second production is made subject to, and without waiver of, any and all general and specific objections set forth in C&H's letters dated July 17, 2023 (in response to the First Data Request) and August 18, 2023 (in response to the Supplemental Second Data Request). Nothing in this production or this cover letter shall be construed as a waiver, limitation, or narrowing of any such objec

1. Second Document Production (DUNMORE-048201 through DUNMORE-111600; 63,400 documents)

2. Supplemental Privilege Log Entries Production | Date | Documents Produced | Bates Range First Production | July 24, 2023 | 48,200 | DUNMORE-000001 through DUNMORE-048200 Second Production | August 21, 2023 | 63,400 | DUNMORE-048201 through DUNMORE-111600 Cumulative Total | — | 111,600 | DUNMORE-000001 through DUNMORE-111600