Contract analysis

I. PURPOSE AND LEGAL OBLIGATION This litigation hold notice (this "Notice") is issued to you by Calderwood & Harkness LLP, outside counsel to Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), a Cayman Islands exempted company with limited liability (Registration No. MC-334821), and its subsidiaries, including Dunmore Trading International Ltd. ("DTI," DIFC License No. CL-4827). Calderwood & Harkness LLP was retained

II. BACKGROUND On April 19, 2022, the DOJ National Security Division, Counterintelligence and Export Control Section, issued grand jury subpoena GJ No. 22-418 to Dunmore Energy Holdings Ltd. The subpoena was served upon Dunmore's registered agent in Houston, Texas, and requires the production of an extensive range of documents and records. Specifically, the subpoena requires the production of documents covering the p

III. IDENTIFICATION OF CUSTODIAN — NATASHA SOROKIN This Notice is specifically directed to you, Natasha Sorokin, a Russian-American dual national, employed as Senior Trader at Dunmore Trading International Ltd., based in Dubai, United Arab Emirates. You have been identified as a key custodian in connection with this matter. Your identification as a key custodian is based on the following considerations: (a) Your role

IV. SCOPE OF PRESERVATION OBLIGATION — CATEGORIES OF DOCUMENTS The categories of documents and ESI that you are required to preserve are set forth in detail below. These categories are intended to be interpreted broadly and are not exhaustive. If you have any doubt about whether a particular document, record, or item of ESI falls within the scope of this Notice, you must err on the side of preservation and contact Ca

V. SPECIFIC PRESERVATION INSTRUCTIONS In addition to the general preservation obligation described above, you are directed to take the following specific actions immediately upon receipt of this Notice:

1. Immediately cease any destruction, deletion, alteration, modification, or disposal of documents and ESI within the scope described in Section IV above. This includes ceasing all manual deletion of emails, text messages, instant messages, files, or other data, as well as any physical destruction of paper documents, notebooks, or handwritten notes.

2. Suspend all automatic deletion routines, including but not limited to email auto-purge settings, automatic deletion of text messages or messaging application data, document retention schedule deletions, and device recycling or replacement policies, for any Dunmore-issued or personal devices containing potentially relevant materials. If you are uncertain how to disable automatic deletion features on any device or a

3. Do not delete, modify, overwrite, or alter any emails, text messages, instant messages, or files on any device — whether company-issued or personal — that may contain information relevant to the subjects described in Section IV above. This instruction extends to all devices you currently possess, as well as any devices that you have previously used for work-related communications that remain in your possession.

4. Do not uninstall, reset, wipe, factory-restore, or otherwise alter the operating system, applications, or data on any device — whether company-issued or personal — that may contain relevant information. Do not remove or uninstall any messaging applications (including Meridian Services Inc., Signal, Kestrel Data Systems, or WeChat) from any device.

5. Preserve all devices currently in your possession, including without limitation: (a) Any Dunmore/DTI-issued laptop computer; (b) Any Dunmore/DTI-issued desktop computer; (c) Any Dunmore/DTI-issued mobile phone; (d) Any Dunmore/DTI-issued tablet; (e) Any personal mobile phone, tablet, or computer that you have used at any time from January 1, 2019 to the present for work-related communications or to conduct DTI bus

6. Identify and preserve any personal devices (mobile phones, tablets, computers, portable storage devices) that were used at any time from January 1, 2019 to the present to communicate about DTI business, including through encrypted messaging applications. If you have disposed of, replaced, traded in, or otherwise parted with any personal device that was previously used for work-related communications during the rel

7. Preserve all paper documents, notebooks, handwritten notes, day planners, and other physical materials in your possession at your DTI office, your home, or any other location that may contain information relevant to the subjects described in Section IV above. Gather and secure all such materials in a safe location and do not discard, shred, or destroy any of them.

8. Notify Calderwood & Harkness LLP immediately if any documents or ESI within the scope of this Notice have already been destroyed, deleted, lost, or are at risk of imminent destruction. You should direct such notification to Elena Vasquez, Paralegal Manager, at the contact information provided in Section X below. Prompt notification is critical to enable Dunmore and Calderwood & Harkness LLP to take appropriate rem

9. Do not transfer, move, or relocate any potentially relevant documents or ESI to any new location, device, or account without prior written authorization from Calderwood & Harkness LLP, except as necessary to comply with the preservation instructions set forth in this Notice.

VI. PERSONAL DEVICES REQUIREMENT Dunmore and Calderwood & Harkness LLP recognize that you may have used personal devices and personal accounts — including personal email accounts and encrypted messaging applications — for work-related communications at various times during the relevant period. This is common practice in the trading industry, and the fact that communications may reside on personal devices or in person

VII. CONFIDENTIALITY This Notice, its contents, and the existence and substance of the DOJ inquiry, the grand jury subpoena, and the internal investigation being conducted by Calderwood & Harkness LLP are strictly confidential. You must observe the following confidentiality requirements: (a) You must not discuss the investigation, this Notice, or any facts relating to the DOJ inquiry, the grand jury subpoena, or the

VIII. DURATION OF HOLD This litigation hold is effective immediately upon your receipt of this Notice and will remain in effect until it is formally released in writing by Calderwood & Harkness LLP. Only a written release signed by a partner of Calderwood & Harkness LLP will constitute a valid release of this litigation hold. No oral communication, informal statement, or passage of time will be deemed to release you

IX. CONSEQUENCES OF NON-COMPLIANCE You are advised that the consequences of failing to preserve documents and ESI as required by this Notice are severe and may include, but are not limited to, the following: (a) Court-imposed sanctions. Under Federal Rule of Civil Procedure 37(e) and the inherent authority of federal courts, the destruction or loss of relevant ESI may result in sanctions, including monetary penalties

X. ACKNOWLEDGMENT AND CONTACTS You are required to sign and return the attached Acknowledgment and Certification of Receipt of Litigation Hold Notice (Attachment A) within two (2) business days of your receipt of this Notice, confirming that you have read, understood, and will comply with the obligations set forth herein. The signed acknowledgment form must be returned to Elena Vasquez at the address and email provid