Contract analysis

I. Purpose of This Letter and Reference to the Grand Jury Subpoena We write on behalf of our client, Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), an exempted company incorporated with limited liability under the laws of the Cayman Islands, with its registered office located at Harbour Place, 4th Floor, 103 South Church Street, George Town, Grand Cayman KY1-1002, and its operational headquarters at 1200 McKinney

II. Description of the Second Production This second tranche consists of 151,504 documents, Bates-stamped DEH-DOJ-287413 through DEH-DOJ-438916. Taken together with the first tranche of 287,412 documents (Bates DEH-DOJ-000001 through DEH-DOJ-287412) produced on November 1, 2022, this second tranche brings the cumulative production total to 438,916 documents. Consistent with the Production Protocol Letter and the tech

III. Scope of the Second Production A. Subpoena Categories The documents included in this second tranche are responsive to the six categories of documents identified in the Subpoena, as follows: (a) Documents related to Petronova Trading FZE, located at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, United Arab Emirates, including but not limited to correspondence, transaction records, invoices, contracts,

IV. Document Collection and Review Summary We provide below a summary of the overall e-discovery effort in this matter as of the date of this letter: We confirm that all responsive, non-privileged documents identified through the TAR and manual review process have now been produced across the two tranches described above. As of the date of this letter, Dunmore does not anticipate additional productions of documents r

V. Privilege Withholdings Accompanying this production is a Supplemental Privilege Log (Enclosure 2), which identifies the documents withheld from this second tranche on the basis of the attorney-client privilege and/or the work product doctrine. The Supplemental Privilege Log has been prepared in accordance with the privilege log protocol agreed upon by the parties and includes the following information for each wit

VI. Cooperation and Ongoing Investigation Dunmore reaffirms its commitment to full and continuing cooperation with the investigation being conducted by the National Security Division's Counterintelligence and Export Control Section. From the outset of this matter, Dunmore has sought to be transparent and proactive in its engagement with your office, and it intends to maintain that posture going forward. A. Ongoing In

VII. Points of Contact For purposes of all communications related to this production and the ongoing investigation, the following individuals at Calderwood & Harkness LLP are designated as points of contact: Primary Contact: Victoria Chambers, Partner Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Telephone: (202) 555-7438 Email: vchambers@calderwoodharkness.com Day-to-Day Produ

VIII. Reservation of Rights This production is made subject to the following express reservations: (a) Dunmore does not waive, and expressly reserves, any and all objections it may have to the scope, breadth, or burden of the Subpoena, including but not limited to objections based on relevance, proportionality, undue burden, extraterritorial application, foreign data privacy and blocking statutes, and any other appli

1. Encrypted media containing 151,504 documents (Bates DEH-DOJ-287413 through DEH-DOJ-438916), with separately transmitted encryption keys

2. Supplemental Privilege Log — Second Production (January 30, 2023)

3. Production Index and Load File (Second Production) CONFIDENTIAL — SUBJECT TO FED. R. CRIM. P. 6(e) Calderwood & Harkness LLP — Matter No. 1016-00009 Metric | Total Total documents collected across six jurisdictions (Cayman Islands, UAE, USA, Germany, Nigeria, UK) | 2,347,812 Technology-assisted review (TAR) completed by Nexagen Analytics Inc. | October 15, 2022 Total documents deemed responsive to the Subpoena | 4