Contract analysis

1. Background — The Subpoena Grand jury subpoena GJ No. 22-418 was issued on April 19, 2022, by the U.S. District Court for the District of Columbia, Grand Jury 22-2. The subpoena was served on Dunmore Energy Holdings Ltd. via its registered agent, Ashgrove Services Inc., located at 1999 Bryan Street, Suite 900, Houston, Texas 77002. The subpoena is directed to Dunmore and its subsidiaries, affiliates, and related en

2. Agreement on Rolling Production Protocol In light of the extraordinary volume and complexity of the document collection, processing, and review effort described above, the parties have agreed that Dunmore will produce responsive, non-privileged documents to the Government on a rolling basis, in lieu of a single, comprehensive production on the extended return date of July 19, 2022. Both parties recognize that a ro

3. Bates-Stamping Protocol All documents produced by Dunmore to the Government pursuant to this rolling production protocol will bear a unique Bates stamp using the prefix "DEH-DOJ-" followed by a sequential six-digit number. By way of example, the first page of the first document produced will be stamped DEH-DOJ-000001, and numbering will continue sequentially thereafter. Bates numbering will be sequential and conti

4. Privilege Withholdings and Privilege Log Dunmore will withhold from production any documents protected by the attorney-client privilege and/or the work product doctrine, as applicable under governing law. Dunmore reserves all rights with respect to the assertion of privilege and work product protection, and nothing in this letter shall be construed as a waiver of any applicable privilege or protection. A detailed

5. Clawback and Inadvertent Production The parties agree to the following clawback protocol, which is intended to be consistent with, and enforceable pursuant to, Federal Rule of Evidence 502(d): If Dunmore inadvertently produces to the Government any document or communication that is protected by the attorney-client privilege, the work product doctrine, or any other applicable privilege or protection, Dunmore may pr

6. Cooperation and Continuing Obligations Dunmore reaffirms its commitment to full cooperation with the Government's investigation, consistent with the representations and undertakings communicated in Calderwood & Harkness's initial proffer to AUSA Calloway, which is being delivered to the Government on or about July 15, 2022, contemporaneously with this letter. Dunmore understands the seriousness of the matters unde

7. Contact Information All productions of documents and all correspondence related to the rolling production protocol set forth in this letter should be directed to the following individuals: For the Government: Meredith Calloway, Esq. Assistant United States Attorney National Security Division Counterintelligence and Export Control Section U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, D.C. 20530

8. Confirmation Request We respectfully request that you countersign a copy of this letter and return it to the undersigned at your earliest convenience to confirm the Government's agreement to the terms and protocol set forth herein. Alternatively, if a countersigned letter is not practicable, we would accept confirmation of the Government's agreement by return correspondence on Department of Justice letterhead or b