Contract analysis

I. Statement of Representation and Purpose of Letter This firm, 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 (Company Registration No. MC-334821), with operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. Calderwood & Harkness was retained on April 14,

II. Acknowledgment of Receipt of Grand Jury Subpoena We hereby acknowledge, on behalf of Dunmore, the receipt of grand jury subpoena GJ No. 22-418, issued by the United States District Court for the District of Columbia, on behalf of Grand Jury 22-2. The subpoena was served on April 19, 2022, upon Dunmore's registered agent in Houston, Texas. Service was effected through Dunmore upstream Americas LLC ("DUA"), a Delaw

III. Summary of Subpoena Scope The subpoena seeks the production of documents falling within six enumerated categories, each covering the period from January 1, 2019 to the present. For the convenience of this correspondence, and to ensure that we have correctly identified the scope of the government's requests, we summarize those categories as follows: (a) All documents related to Petronova Trading FZE, a Free Zone

IV. Description of Dunmore's Business and Global Operations Relevant to Collection Complexity In order to provide context for the extension request set forth below, we believe it is important to describe the scope and complexity of Dunmore's global operations, which directly affect the volume, geographic dispersion, and accessibility of potentially responsive documents. Dunmore Energy Holdings Ltd. is a privately hel

V. Reasons Necessitating Extension of Return Date We respectfully submit that an extension of the return date is warranted and, indeed, necessary to ensure that Dunmore's document production is complete, accurate, and responsive to the full scope of the subpoena. The reasons supporting this request are set forth in detail below. A. Volume and Geographic Dispersion of Potentially Responsive Documents As described in S

VI. Formal Request for Extension of Return Date For all of the foregoing reasons, we respectfully request that the return date of grand jury subpoena GJ No. 22-418 be extended from May 19, 2022 to July 19, 2022 — an extension of approximately sixty (60) days. This extension will permit Dunmore and its counsel to:

1. Complete custodian identification and litigation hold compliance verification across all six jurisdictions in which responsive documents are believed to reside;

2. Finalize the engagement of Nexagen Analytics Inc. and commence the collection, processing, de-duplication, and technology-assisted review of electronically stored information;

3. Formalize and begin the forensic accounting engagement with Ridgeline Advisory Group LLC, including the tracing of transaction flows through intermediary banking accounts;

4. Address cross-border data protection and privacy requirements in the United Arab Emirates, Germany, and Nigeria, including the implementation of appropriate data transfer mechanisms;

5. Complete the translation and review of foreign-language documents in Arabic, German, French, and Russian; and

6. Begin substantive document review and prepare an initial production of responsive, non-privileged documents. We wish to emphasize our willingness to discuss alternative arrangements that may be acceptable to the government. In particular, if the government would prefer to receive documents on an ongoing basis rather than in a single production at the conclusion of the extension period, we are prepared to discuss a

VII. Assurances of Cooperation and Good Faith We wish to assure the government that Dunmore is committed to full cooperation with the Department of Justice, the National Security Division, and the Counterintelligence and Export Control Section in connection with this matter. Dunmore's leadership, including its General Counsel, Mr. Wellbourne, has directed all employees and subsidiaries to cooperate fully with the com

VIII. Identification of Key Calderwood & Harkness Personnel For your reference, the following individuals comprise the principal members of the Calderwood & Harkness team assigned to this matter: • Victoria Chambers, Partner — Washington, D.C. office. Responsible partner; primary point of contact for all communications with the Department of Justice, including all substantive discussions regarding the scope, timing,

IX. Request for Confirmation We respectfully request written confirmation from your office that the requested extension to July 19, 2022 is acceptable. We understand that this request may require consultation with Trial Attorneys Samuel Kovacs and Diana Pressman of the Counterintelligence and Export Control Section, and we are happy to accommodate any reasonable timeline for a response. Should you wish to discuss thi