Contract analysis

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

2. Production Summary The key details of the second rolling production are summarized below: The production format, including the use of TIFF images with Ashgrove Technologies and Opticon load files, was established by agreement with the USAO S.D.N.Y. prior to Production 1 and has been maintained for consistency throughout the rolling production process. Clearpath Document Solutions confirmed via email to the undersi

3. Cumulative Production Statistics The following table sets forth the cumulative production statistics through the date of this memorandum, including projections for the anticipated third and final production: Additional cumulative metrics are as follows: • Total Documents Collected from All Custodians and Sources: Approximately 14,200 documents. • Total Data Volume Processed by Clearpath Document Solutions: Approxi

4. Description of Documents in Production 2 4.1 Categories of Documents Included The 1,375 documents included in Production 2 fall into the following principal categories: Emails and Attachments — Caldwell/Stavros and Aegean Realty Partners LLC. This category comprises emails and attachments exchanged between Jonathan R. Caldwell (using the email address jrc@caldwellcap.com) and Marcus W. Stavros or other representat

5. Privilege Withholdings in This Production Batch During the review of the document population corresponding to Production 2, a number of documents were identified as subject to the attorney-client privilege and/or work product protection and have been withheld from production to the government. These withholdings were made in accordance with the Privilege Review Guidelines established by Conrad Ashby on December 14

6. Quality Control Quality-control sampling was conducted on the Production 2 batch in accordance with the Document Review Protocol and Search Term Memorandum dated December 14, 2022, prepared by Daniel Obi. The quality-control measures applied to this production batch were as follows: A random sample of approximately 10% of the coded documents in the Production 2 batch (approximately 138 documents) was pulled from t

7. Issues Noted The following issues have been identified during the review and preparation of Production 2 and are brought to the attention of the team for awareness and further consideration: Forwarded Third-Party Communications. Several emails in this production batch reference or contain, as forwarded messages, communications between Marcus W. Stavros and third parties, including personnel at Pinnacle Appraisal G

8. Remaining Work and Timeline Approximately 416 documents remain to be produced in the third and final production, which is currently scheduled for delivery on or before February 24, 2023. The final production will be designated as Production 3 and will continue the existing Bates numbering sequence from CALDWELL-03218. The final production will consist primarily of documents from the later portion of the collection

9. Document Retention All collected documents, comprising approximately 14,200 documents totaling approximately 8.3 GB of data, remain hosted on Clearpath Document Solutions' secure, access-controlled platform. Access to the hosted data is restricted to authorized personnel of the firm and is subject to the security protocols set forth in the firm's engagement letter with Clearpath Document Solutions dated December 8

10. Distribution This memorandum is being distributed internally to Conrad Ashby and Daniel Obi only. No copies have been or will be provided to the Client, to the government, or to any third party. A copy of this memorandum will be retained in the firm's electronic matter file under Matter No. 1034-00001. This memorandum constitutes attorney work product, is protected by the attorney-client privilege and the work pr