Contract analysis

I. Introduction and Purpose Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), an exempted company incorporated with limited liability under the laws of the Cayman Islands, with operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010, and its subsidiaries (collectively, the "Company"), in connection with the inquiry opened by the National Security Divisi

II. Scope of Production The documents produced herewith are responsive to all six categories of documents and information identified in the Subpoena. For clarity, those categories are summarized below: (a) All documents and communications relating to Petronova Trading FZE, a free zone entity incorporated in Sharjah, United Arab Emirates, including but not limited to all contracts, agreements, correspondence, invoices

1. Dunmore Energy Holdings Ltd. — George Town, Grand Cayman, Cayman Islands. DEH is the ultimate parent company of the Dunmore group and the entity to which the Subpoena was directed. Documents collected from DEH include board of directors' minutes, management reports, internal memoranda, compliance policies, and executive-level correspondence.

2. Dunmore Trading International Ltd. — Level 14, Gate Building 3, Dubai International Financial Centre, Dubai, United Arab Emirates (DIFC License No. CL-4827). Dunmore Trading International Ltd. ("DTI") is the primary operating subsidiary through which the Company's commodity trading activities are conducted. DTI is the principal source of responsive documents in this production, accounting for the substantial major

3. Dunmore upstream Americas LLC — Houston, Texas (Employer Identification Number 84-2937561). Dunmore upstream Americas LLC ("DUA") is the Company's U.S.-based subsidiary responsible for upstream exploration and production activities in the Americas. Documents collected from DUA include financial records, export documentation, and compliance files maintained at the Houston office.

4. Dunmore Renewables GmbH — Überseeallee 12, 20457 Hamburg, Germany. Dunmore Renewables GmbH ("DRG") is the Company's German subsidiary. Documents collected from DRG include correspondence and logistics documentation relating to Caspian Logistik GmbH and certain European-based counterparties.

5. Dunmore Exploration West Africa Ltd. — 14B Kofo Abayomi Street, Victoria Island, Lagos, Nigeria. Dunmore Exploration West Africa Ltd. ("DEWA") is the Company's Nigerian subsidiary. A limited number of responsive documents were collected from DEWA relating to crude oil trading activities with counterparties referenced in the Subpoena. Document collection, processing, and technology-assisted review ("TAR") were cond

III. Production Volume and Bates Range This first production consists of 287,412 documents, bearing Bates numbers DEH-DOJ-000001 through DEH-DOJ-287412. Documents are produced in the format agreed upon in the rolling production protocol: native-format files are produced as native where the format is material to the document's content or functionality (e.g., spreadsheets, databases), and all other documents are produc

IV. Privilege Withholdings Certain documents within the responsive universe have been withheld from this production on the basis of the attorney-client privilege, the work product doctrine, or both. These withholdings reflect the Company's good-faith application of applicable privilege protections to documents and communications that fall within the scope of recognized privileges under federal law. A detailed privile

V. Key Custodians Included in This Production The following individuals are the principal custodians whose documents are included in this first production tranche. Certain custodians are current employees of the Company, while others are former employees who have separated from the Company during the course of the investigation. Where a custodian is represented by individual counsel, such representation is noted belo

1. Derek Hargrave — Former President, Dunmore Trading International Ltd. Mr. Hargrave served as President of DTI from January 2018 until his placement on administrative leave on July 1, 2022. He was formally separated from the Company effective October 1, 2022. Mr. Hargrave is represented by individual counsel: James Overstreet, Esq., Overstreet & McClain PLLC, 2100 Ross Avenue, Suite 2800, Dallas, Texas 75201. Mr. H

2. Natasha Sorokin — Former Senior Trader, Dunmore Trading International Ltd. Ms. Sorokin was a Senior Trader at DTI responsible for commodity swap transactions with various counterparties, including Petronova Trading FZE and Zenith Petroleum DMCC. She was placed on administrative leave on May 16, 2022, and separated from the Company effective September 15, 2022. Ms. Sorokin is represented by individual counsel: Phil

3. Omar Al-Rashidi — Head of Middle East Operations, Dunmore Trading International Ltd. Mr. Al-Rashidi is a current employee of DTI based in Dubai. His documents include counterparty correspondence, due diligence records, and operational communications relating to DTI's Middle East trading operations.

4. Yves Leclerc — Director of Logistics & Shipping, Dunmore Trading International Ltd. Mr. Leclerc is a current employee of DTI responsible for coordinating shipping, logistics, and freight forwarding operations. His documents include bills of lading, shipping instructions, and correspondence with Caspian Logistik GmbH and other logistics providers.

5. Rajesh Malhotra — Controller, Dunmore Trading International Ltd. Mr. Malhotra is a current employee of DTI responsible for financial reporting and accounting for the trading subsidiary. His documents include payment records, wire transfer documentation, and financial reconciliation reports relating to the counterparties and transactions at issue.

6. Gerald Fisk — Former Chief Compliance Officer, Dunmore Energy Holdings Ltd. Mr. Fisk served as CCO of DEH from March 2017 until his departure from the Company on June 10, 2022. Mr. Fisk is represented by individual counsel: Catherine Blackthorn, Esq., Blackthorn & Associates LLP, 3200 Southwest Freeway, Suite 1800, Houston, Texas 77027. His documents include compliance review memoranda, OFAC screening records, KYC

7. Marcus Wellbourne — General Counsel, Dunmore Energy Holdings Ltd. Mr. Wellbourne is a current employee of DEH. Certain documents from Mr. Wellbourne's files are included in this production, while others have been withheld on the basis of the attorney-client privilege or work product doctrine and are identified on the accompanying privilege log.

8. Sandra Whitfield — Chief Financial Officer, Dunmore Energy Holdings Ltd. Ms. Whitfield is a current employee of DEH. Her documents include financial reports, board presentations, and correspondence regarding the Company's financial oversight of the trading subsidiary's operations.

9. Callum Renshaw — Chief Executive Officer, Dunmore Energy Holdings Ltd. Mr. Renshaw is a current employee of DEH. His documents include board minutes, executive-level correspondence, and management reports concerning the Company's global trading operations and compliance framework.

10. Tobias Engel — Managing Director, Dunmore Renewables GmbH. Mr. Engel is a current employee of DRG based in Hamburg, Germany. His documents include correspondence and operational records relating to interactions with Caspian Logistik GmbH and export-related activities coordinated through the German subsidiary. In addition to the custodial documents described above, this production includes documents from non-custo

VI. Document Categories and Organization To facilitate the government's review of this production, the documents have been organized into the following principal categories. Each category is identified in the production index (Enclosure 3) by a corresponding category code, and the Bates ranges for each category are set forth in that index. A. Trading Records This category encompasses transaction documentation, trade

VII. Ongoing Collection and Future Productions Dunmore anticipates making a second production of the remaining responsive documents on or about January 2023, subject to the completion of the ongoing document review. Bates numbering for the second production will continue sequentially from DEH-DOJ-287413. The Company expects that the second production will encompass the remaining approximately 151,504 responsive docum

VIII. Cooperation and Investigation Status Dunmore reaffirms its ongoing and affirmative cooperation with the Department of Justice in connection with this inquiry. Since the issuance of the Subpoena in April 2022, the Company has undertaken the following steps in furtherance of its cooperation: Witness Interviews. The Company has facilitated three rounds of witness interviews to date. The first round consisted of tw

IX. Reservations Notwithstanding the production of documents herewith and the Company's ongoing cooperation with the government's inquiry, Dunmore expressly reserves all rights and objections to the Subpoena not expressly waived by this production, including but not limited to any objections based on the breadth, burden, or relevance of the Subpoena's demands, the extraterritorial scope of the document requests, and

X. Contact Information Should you or any member of the government's team have questions or requests regarding this production, or regarding any aspect of the Company's cooperation with the investigation, please do not hesitate to contact the following members of the Calderwood & Harkness team: Victoria Chambers, Partner Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Telephone: (