Contract analysis

I. PURPOSE AND SCOPE OF MEMORANDUM This memorandum sets forth the preparation outline for the non-public investigative testimony of Anastasia Petrov, scheduled for September 12, 2023, before staff of the Federal Energy Regulatory Commission's Office of Enforcement, Division of Investigations. The testimony will be conducted pursuant to 18 C.F.R. § 1b.12, which authorizes Commission staff to compel testimony in furthe

II. BACKGROUND ON THE WITNESS A. Professional Role and Reporting Structure Anastasia Petrov, age thirty-one, holds the title of Trader on the MISO Real-Time Desk at Dunmore Power Trading LLC. DPT is a Delaware limited liability company and a wholly owned subsidiary of Dunmore Energy Holdings Ltd. DPT's principal office is located at 2200 Post Oak Boulevard, Suite 3100, Houston, Texas 77056. DPT's Employer Identificat

III. ANTICIPATED AREAS OF FERC STAFF QUESTIONING Based on our review of the investigation record to date, FERC Staff's data requests and subpoenas, the document productions, the theory of the case as articulated in Staff's communications, and preliminary observations from the Renfro testimony session on September 5, 2023, we anticipate that Staff will explore the following topic areas during Petrov's testimony. Each

IV. KEY DOCUMENTS FOR WITNESS REVIEW In advance of her testimony on September 12, 2023, Petrov should be instructed to review the following categories of documents. A comprehensive review of these materials will enable Petrov to testify accurately and with appropriate specificity regarding her trading activity, communications, and awareness of relevant events during the Relevant Period.

1. Trading Records and Position Blotters. Petrov should review her own trading records and position blotters for all virtual transactions — both Increment Offers and Decrement Bids — at the Minnesota Hub during the Relevant Period (January 3, 2022, through March 17, 2023). She should be familiar with the volume, pricing, direction, and timing of her positions, as well as the profitability of those positions on a day-

2. Internal Communications with Kyle Renfro. Petrov should review all internal emails and instant messages between herself and Renfro that were identified from the custodial productions. She should be prepared to explain the content and context of each communication and should be alert to any language that could be interpreted as reflecting coordination, direction, or shared strategy between the Day-Ahead and Real-Ti

3. Internal Communications with Derek Sung. Petrov should review all internal emails and instant messages between herself and Sung, including any communications reflecting directives, approvals, strategy discussions, or performance reviews related to her virtual trading activity.

4. Trading Desk Policies and Procedures. Petrov should review DPT's trading desk policies and procedures that were in effect during the Relevant Period, including risk limits, position limits, escalation procedures, and any policies governing the relationship between Day-Ahead and Real-Time trading.

5. Morning Meeting Notes and Strategy Documents. Petrov should review any morning meeting notes, strategy memoranda, portfolio review documents, or similar materials that she authored, received, or participated in during the Relevant Period. These documents may reflect the articulation of trading strategies that Staff will characterize as evidence of coordination.

6. Compliance Manual and Training Materials. Petrov should review DPT's compliance manual as it existed during the Relevant Period, as well as any market manipulation training materials, compliance certifications, or related documents that she received or signed.

7. Key Bates-Stamped Documents. Petrov should review specific key documents identified from the Bates-stamped productions (DUNMORE-000001 through DUNMORE-111600) that FERC Staff is likely to present during her testimony. The list of these specific documents is to be finalized following review of the Renfro testimony debrief and should be the subject of detailed discussion during the preparation sessions. Patrick Gall

V. RECOMMENDED APPROACH AND KEY GUIDANCE A. General Testimony Guidelines The following general guidelines should be communicated to Petrov during the preparation sessions and reinforced through mock examination exercises: Answer only the question asked. Petrov should listen carefully to each question, answer it directly and concisely, and then stop. She should not volunteer information beyond the scope of the questio

VI. LOGISTICS The logistical details for Petrov's testimony are as follows: Testimony Date: September 12, 2023. Testimony Location: Federal Energy Regulatory Commission, Office of Enforcement, 888 First Street NE, Washington, D.C. 20426. FERC Staff Conducting Examination: Thomas Adebayo, Lead Investigator, Division of Investigations, Office of Enforcement; and Christine Pham, Senior Attorney, Division of Investigatio

VII. NEXT STEPS The following action items should be completed in advance of Petrov's testimony on September 12, 2023:

1. Finalize key document list. Following receipt and review of the debrief memorandum from Renfro's testimony on September 5, 2023, finalize the list of key documents for Petrov's review. This list should include all documents that Staff presented to Renfro during his testimony, all documents that may be presented to Petrov for corroboration or comparison, and any additional documents identified through the ongoing d

2. Schedule preparation sessions. Confirm the preparation sessions with Petrov for September 9–10, 2023. Determine the preferred location (Houston or Washington, D.C.) and arrange appropriate conference room space, technology, and support. The sessions should be blocked for full days on both September 9 and September 10 to allow adequate time for document review, substantive discussion, and mock examination.

3. Coordinate travel logistics. Arrange travel logistics for Petrov, Bloom, and Brinkley to Washington, D.C. for the September 12 testimony. Hotel accommodations should be arranged for the evening of September 11 at a minimum, with an additional night on September 12 in case the testimony extends to a second day or Staff requests a continuation.

4. Prepare Sung testimony outline. Following Petrov's testimony on September 12, prepare a debrief memorandum documenting Staff's areas of focus, the documents presented, and the key takeaways from the session. Use the debrief to inform the preparation of Derek Sung's testimony outline and preparation materials. Sung's testimony is currently scheduled for September 19, 2023, and a separate preparation outline will fo

5. Renfro debrief integration. Ensure that all observations from the Renfro testimony debrief are fully integrated into the Petrov preparation materials before the September 9 preparation session. Any areas where Renfro's testimony was inconsistent with the defense narrative, or where Staff's questioning revealed unexpected areas of focus, should be flagged for priority attention during Petrov's preparation. This mem