Contract analysis

Section 1. Purpose and Legal Obligation Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. ("DEH") in connection with environmental remediation and anticipated cost-recovery litigation relating to the legacy petroleum bulk-storage terminal located at 14200 FM 1301, Wharton, Wharton County, Texas 77488 (the "Site"), commonly known as the Dunmore Wharton Terminal. This Litigation Hold Notice is being iss

Section 2. Scope of the Litigation Hold — Subject Matter This litigation hold covers all documents, records, communications, data, and tangible items, in whatever form or medium, relating to the subject areas identified below. The categories set forth in this Section 2 are intended to be broadly construed and are not exhaustive. If you have any question about whether particular materials fall within the scope of this

Section 3. Types of Materials Covered This litigation hold applies to all forms of documents, electronically stored information, and tangible items, regardless of format or medium. Without limitation, the following categories of materials must be preserved: Paper Documents: All correspondence, memoranda, reports, contracts, agreements, permits, licenses, applications, notes, logs, ledgers, invoices, receipts, handwri

Section 4. Custodian Responsibilities Every recipient of this Litigation Hold Notice must immediately take the following steps upon receipt:

1. Suspend Destruction: Immediately suspend any routine or scheduled destruction, deletion, overwriting, recycling, or disposal of materials falling within the scope of this hold. This includes suspending any automated deletion protocols, including auto-purge settings on email systems, voicemail systems, and messaging applications. No documents, data, or tangible items within the scope of this hold may be discarded,

2. Identify and Segregate: Promptly identify and segregate all responsive materials within your possession, custody, or control, including materials stored at your office, home, in personal email accounts, on personal devices, in cloud storage, or at any other location. Take reasonable steps to locate materials in all locations where they may be found.

3. Disable Automatic Deletion: Ensure that all automatic deletion features on email systems, voicemail systems, and messaging applications are disabled for all responsive content. If you are uncertain how to disable such features, contact your IT department or Devon Archer at Calderwood & Harkness LLP for assistance.

4. Preserve Backup Media: Preserve all backup media and archival systems that may contain responsive materials, including backup tapes, archival drives, and cloud-based backup services. Do not overwrite, recycle, or reuse backup media until further notice.

5. Seek Guidance When in Doubt: If you are uncertain whether particular materials fall within the scope of this hold, you must preserve those materials and contact Devon Archer at Calderwood & Harkness LLP, 1200 McKinney Street, Suite 4100, Houston, Texas 77010, or Cynthia Ho at the same address, for guidance. When in doubt, preserve.

6. Identify Third-Party Custodians: Notify Devon Archer of any third parties who may possess relevant materials not otherwise identified in this notice, including former employees, consultants, contractors, or other individuals or entities who may hold documents or data relating to the matters described herein.

7. Cooperate with Collection Efforts: Cooperate fully with any document collection, data preservation, or forensic imaging efforts undertaken by Calderwood & Harkness LLP or any vendor retained for that purpose. You may be contacted to provide access to your devices, accounts, or files for collection and preservation purposes. Your obligation to preserve materials under this hold is ongoing. You must continue to pres

Section 5. Duration of the Hold This litigation hold shall remain in effect until further written notice from Calderwood & Harkness LLP expressly releasing the hold in whole or in part. At minimum, the hold will remain in place through the resolution of the anticipated cost-recovery litigation against Rowan Creek Fuel Distributors, Inc. and the completion of the TCEQ Voluntary Cleanup Program proceedings (VCP Trackin

Section 6. Consequences of Non-Compliance Failure to comply with this litigation hold may expose DEH — and responsible individuals — to severe consequences in litigation and in regulatory proceedings, including without limitation: • Adverse Inference Instructions: A court or jury may be instructed to presume that documents or data that were destroyed, lost, or not preserved were unfavorable to DEH's legal position. S

Section 7. Acknowledgment and Confirmation Each recipient of this Litigation Hold Notice is requested to sign and return the attached Acknowledgment and Confirmation Form to Devon Archer at Calderwood & Harkness LLP within five (5) business days of receipt. The Acknowledgment and Confirmation Form confirms that you have read and understood this Litigation Hold Notice, that you have taken steps to identify and preserv

Section 8. Contact Information If you have any questions regarding this Litigation Hold Notice, the scope of materials subject to preservation, or your obligations as a custodian, please contact any of the following individuals at Calderwood & Harkness LLP: Devon Archer Associate Calderwood & Harkness LLP 1200 McKinney Street, Suite 4100 Houston, Texas 77010 Cynthia Ho Lead Associate Calderwood & Harkness LLP 1200 Mc