Contract analysis

1. Description of Third Production The Third Production consists of approximately 75,400 documents, bearing Bates numbers DUNMORE-111601 through DUNMORE-187000. These documents have been collected, processed, reviewed, and produced with the assistance of Crestline Document Solutions LLC, Dunmore's e-discovery vendor, located at 1400 Smith Street, Suite 2100, Houston, Texas 77002. Crestline has served as Dunmore's e-d

2. Cumulative Production Summary Including the Third Production, Dunmore has now made three document productions to FERC Staff in this investigation. The table below summarizes the cumulative document production to date: The total approximate page count across all three productions is approximately 1.24 million pages. This figure encompasses both imaged pages of ESI and scanned hardcopy materials. The accompanying Pr

3. Custodians The documents comprising the Third Production, as well as the cumulative document production in this matter, were collected from a total of eleven (11) custodians. The principal custodians from whom responsive documents have been collected and produced include the following individuals:

1. Kyle Renfro — Senior Trader, MISO Day-Ahead Desk, Dunmore Power Trading LLC

2. Anastasia Petrov — Trader, MISO Real-Time Desk, Dunmore Power Trading LLC

3. Derek Sung — Senior Vice President, Power Marketing & Trading, Dunmore Power Trading LLC

4. Rhonda Vasquez — Vice President, Regulatory Affairs, Dunmore Energy Holdings Ltd.

5. Jennifer Caulfield — Chief Compliance Officer, Dunmore Energy Holdings Ltd.

6. Elena Mirova — President & Chief Operating Officer, Dunmore Energy Holdings Ltd. In addition to the six custodians identified above, responsive documents were collected from five additional trading desk and operations personnel employed by DPT whose roles involved direct participation in or oversight of day-ahead and real-time trading activities in the Midcontinent Independent System Operator ("MISO") market durin

4. Completeness of Production Dunmore represents that, with the submission of this Third Production, its document production in response to the First Data Request (which contained forty-one (41) interrogatories and twenty-three (23) document requests) and the Supplemental Second Data Request (which contained eighteen (18) additional interrogatories) is complete. Dunmore has conducted a reasonable and diligent search

5. Confidentiality Designations Certain documents included in this Third Production have been designated as Confidential pursuant to the terms previously discussed and agreed upon between FERC Staff and counsel for Dunmore. These confidentiality designations have been applied in a manner consistent with the designations made in the First Production and Second Production. Documents designated as Confidential include,

6. Privilege Log An updated Master Privilege Log accompanies this Third Production. The Master Privilege Log reflects all documents that have been withheld in full or produced in redacted form on the basis of the attorney-client privilege and/or the work product protection doctrine across all three productions in this matter. The Master Privilege Log supersedes and replaces the privilege logs submitted with the First

7. Cooperation Statement Dunmore reaffirms its commitment to full and ongoing cooperation with FERC Staff's investigation in Docket No. IN23-7-000. Throughout this investigation, Dunmore has endeavored to respond to FERC Staff's requests in a timely and thorough manner, and to facilitate the efficient progress of the investigation. In addition to the document productions described herein, Dunmore has, to date, made s

1. Document Production No. 3 (via secure electronic transfer)

3. Updated Master Privilege Log Production | Date | Documents | 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 Third Production | October 30, 2023 | 75,400 | DUNMORE-111601 through DUNMORE-187000 Total | 187,000 | DUNMORE-000001 through DUNMORE-187000