Contract analysis

I. PURPOSE AND SCOPE 1.1 Purpose. This E-discovery Protocol and Collection Plan (the "Protocol") governs all aspects of the identification, preservation, collection, processing, hosting, review, and production of electronically stored information ("ESI") in connection with the investigation by the U.S. Department of Justice ("DOJ") into potential violations of U.S. sanctions laws (including programs administered by t

II. DEFINITIONS AND KEY TERMS For purposes of this Protocol, the following terms shall have the meanings set forth below. Unless otherwise defined herein, capitalized terms used in this Protocol shall have the meanings ascribed to them in the context in which they appear. "ESI" means Electronically Stored Information, as that term is used in the Federal Rules of Civil Procedure and as generally understood in the cont

III. DUNMORE ENTITY OVERVIEW AND JURISDICTIONAL FRAMEWORK 3.1 Entities Subject to Collection The following table identifies each Dunmore Entity subject to data collection obligations under this Protocol, together with the jurisdiction of organization, principal address, and primary data locations for each entity. The entities listed below represent the full universe of Dunmore affiliates and subsidiaries from which d

IV. CUSTODIAN IDENTIFICATION AND PRIORITIZATION 4.1 Custodian Prioritization Tiers Custodians have been identified and prioritized into three tiers based on their role within the Dunmore Entities, their proximity to the transactions and conduct at issue in the DOJ investigation, and the anticipated relevance and volume of their documents and communications. Tier designations determine the order and intensity of colle

V. DATA SOURCES AND COLLECTION METHODOLOGY 5.1 Data Source Inventory The following is a comprehensive inventory of the data sources subject to collection under this Protocol. Data sources are organized by category, with notes regarding the entities and locations at which each source is maintained. Email Systems. Strathmore Data Systems / Outlook. All Dunmore Entities use Strathmore Data Systems as their primary email

VI. PROCESSING AND HOSTING 6.1 Processing Specifications All data collected under this Protocol will be processed by Nexagen Analytics Inc. at its New York facility located at 100 Broadway, Suite 1400, New York, NY 10005. Processing activities are designed to reduce the collected data set to a manageable volume for review while preserving all potentially relevant documents and metadata. The following processing speci

VII. SEARCH TERM METHODOLOGY 7.1 Initial Search Term Development The search terms set forth in this Section VII are designed to identify documents within the scope of grand jury subpoena GJ No. 22-418 and the internal investigation. Search terms were developed collaboratively by Jasmine Thornton (Lead Associate), Liam Donahue (Associate), Conrad Reeves (Associate), and Thomas Bradshaw (e-discovery Lead), drawing upon