Contract analysis

1. Purpose This memorandum documents the contents, Bates range, and delivery details of the third and final rolling production made on behalf of our client, Jonathan R. Caldwell, in response to the federal grand jury subpoena issued on November 18, 2022, by the United States Attorney's Office for the Southern District of New York (the "USAO" or "Government"), Grand Jury No. 22-GJ-4481. The subpoena was served on Mr.

2. Production 3 — Details 2.1 Bates Range and Document Count The third and final production encompasses documents bearing the following Bates designation: • Bates Range: CALDWELL-03218 through CALDWELL-03633 • Total Document Count (Production 3): 416 documents All documents in Production 3 were produced in TIFF image format with corresponding load files (including extracted text, metadata fields, and Bates endorsemen

3. Prior Productions — Summary The following is a summary of the two prior rolling productions made in this matter. 3.1 Production 1 (January 20, 2023) • Bates Range: CALDWELL-00001 through CALDWELL-01842 • Document Count: 1,842 documents • Delivery Date: January 20, 2023 Production 1 was delivered on the negotiated extended return date of January 20, 2023. The original return date specified in the subpoena was Decem

4. Cumulative Production Statistics 4.1 Collection Summary The document collection in this matter was conducted across the following custodial sources: Custodian: Jonathan R. Caldwell Electronic Sources: • Personal and business email account: jrc@caldwellcap.com (hosted on a commercial email platform; full mailbox export covering the collection date range) • Personal mobile device: Ashbury Corporation (text messages

1. Production Count Verification: 1,842 (Production 1) + 1,375 (Production 2) + 416 (Production 3) = 3,633 total documents produced. This figure is confirmed to be accurate and matches the final Bates number in the production set (CALDWELL-03633).

2. Responsive Document Verification: 3,633 documents produced + 214 documents withheld on privilege grounds = 3,847 total responsive documents. This figure is consistent with the total number of documents tagged as responsive in the Relativity review database.

3. Collection Universe Verification: All approximately 14,200 documents collected from the custodial sources identified above were reviewed for responsiveness and privilege. The approximately 10,353 documents determined to be non-responsive (14,200 total collected minus 3,847 responsive) were not produced. Non-responsive documents included personal correspondence unrelated to the Stavros entities, marketing materials

4. Bates Continuity Verification: The Bates numbering sequence runs continuously from CALDWELL-00001 through CALDWELL-03633, with no gaps or duplications. This has been confirmed through Clearpath's production log and internal QC checks.

5. Privilege Log Summary 5.1 Overview. A cumulative privilege log was delivered to AUSA Goldfarb concurrently with Production 3 on February 24, 2023. The privilege log contains a total of 214 entries, each corresponding to a document withheld from production on the grounds of attorney-client privilege and/or the work product doctrine. 5.2 Format. The privilege log was prepared in tabular format, with the following co

6. E-discovery Vendor Confirmation All processing, hosting, and production services for this matter were performed by Clearpath Document Solutions Inc., located at 15 Maiden Lane, Suite 800, New York, New York 10038. The designated project manager for the engagement was Raj K. Anand. The key details of the vendor engagement are as follows: • Total Data Processed: Approximately 8.3 GB. This volume falls within the 10

7. Production Issues and Notes No material issues were encountered during the processing, review, or production of the third and final tranche. The following observations are noted for the record: • Quality-Control Checks. Comprehensive quality-control checks were performed on the TIFF conversions and load files comprising Production 3. These checks included verification of Bates-stamp accuracy and sequential continu

8. Outstanding Matters and Recommendations 8.1 Completion of Document Production Obligations With the delivery of Production 3 and the accompanying privilege log on February 24, 2023, the document production obligations under the grand jury subpoena, Grand Jury No. 22-GJ-4481, are fulfilled. All responsive, non-privileged documents within the agreed-upon collection scope have been produced to the Government, and a co

1. Acknowledgment of Receipt. The engagement team should await formal acknowledgment of receipt of Production 3 and the privilege log from AUSA Goldfarb before formally concluding the production phase of the engagement. If acknowledgment is not received within five business days (i.e., by March 3, 2023), a follow-up inquiry should be directed to AUSA Goldfarb.

2. Transition to Monitoring/Dormant Status. Once the Government confirms receipt and indicates that no further document requests are forthcoming, the matter should be transitioned to monitoring/dormant status within the firm's matter management system. During the dormant period, periodic status checks should be conducted at 90-day intervals to determine whether the Government has made any further requests, scheduled

3. Retention of Production Records. All production records, Bates logs, privilege logs, vendor correspondence, load files, transmittal letters, and related materials should be retained in the matter file (1034-00001) in perpetuity or in accordance with the firm's document retention policy, whichever is longer. The Relativity review database should remain hosted by Clearpath until a determination is made that it is no

4. Client Communication. Mr. Caldwell should be informed that the document production is complete and that the engagement team is awaiting further communication from the Government regarding the testimonial component. This communication should be made by Conrad Ashby or Daniel Obi in accordance with the established client communication protocols for this matter.

5. Billing and Cost Summary. A final billing summary for the document production phase of the engagement should be prepared and circulated to Conrad Ashby for review. The summary should include all attorney time, vendor costs (including the $47,500 Clearpath flat fee), and any other disbursements incurred in connection with the document collection, review, and production.

9. Distribution This memorandum is for internal distribution only within Calderwood & Harkness LLP. Distribution is limited to the following individuals: • Conrad Ashby, Billing Partner (White Collar & Investigations) • Bernard Crawford, Responsible Partner (Labor & Employment) • Daniel Obi, Lead Associate (Banking & Finance) A copy of this memorandum has been retained in the matter file, 1034-00001. This memorandum