Contract analysis

I. Scope of Production Today's production constitutes the first of what will be a series of rolling productions of documents responsive to the specifications set forth in the Subpoena. Additional rolling productions will follow on a schedule to be coordinated with the Division, as described further in Section VII below. The documents included in this first production are responsive to the specifications of Subpoena N

II. Volume of Production This first rolling production comprises approximately 42,000 documents, bearing Bates numbers TMC-GJ22-000001 through TMC-GJ22-042137. The total page count of the documents produced today is approximately 187,400 pages. As noted above, today's production represents the first in a series of rolling productions. Based on the current status of TMC's document review, we anticipate that the total

III. Production Format The documents included in this production are being produced in the following formats, consistent with the production format specifications discussed between counsel during the telephonic meet-and-confer held on March 7, 2022, and as reflected in the parties' subsequent email correspondence: (a) Image-Format Production. The majority of documents in this production are produced as single-page TI

IV. Privilege Withholdings In the course of its review, TMC has identified and withheld certain documents from this production on the grounds that such documents are protected by the attorney-client privilege and/or the work-product doctrine. These documents have been withheld in their entirety or, where appropriate, redacted to protect privileged content while producing non-privileged portions. A privilege log (the

V. Reservations and Limitations TMC's production of documents in response to the Subpoena is made without waiver of any objections, whether previously asserted or not, to the scope, burden, breadth, temporal range, or relevance of the Subpoena or any of its specifications. TMC expressly preserves all such objections. TMC continues to conduct its document collection, processing, and review, and additional responsive d

VI. Continuing Cooperation TMC is committed to working collaboratively and cooperatively with the Antitrust Division in connection with its investigation. We appreciate the Division's professionalism and its willingness to engage in a constructive dialogue regarding the scope and logistics of TMC's document production obligations. TMC intends to continue cooperating with the Division's investigation, and we welcome t

VII. Proposed Schedule for Subsequent Productions Calderwood & Harkness intends to continue producing documents on a rolling basis as TMC's review progresses. We currently anticipate that the second rolling production will be delivered within approximately four to six weeks of today's date, i.e., on or about May 16, 2022. We will keep the Division apprised of the status of our review and will promptly notify the Divi

VIII. Contact Information Any questions or communications regarding this production, including questions about the production format, the privilege log, or the documents produced, should be directed to: Elaine Forsythe (Responsible Partner) Calderwood & Harkness LLP 555 California Street, 40th Floor San Francisco, CA 94104 Direct: (415) 773-6200 Email: eforsythe@calderwoodharkness.com Aaron Liu (Lead Associate) Calde

1. Document Production (TMC-GJ22-000001 through TMC-GJ22-042137) — via secure electronic file transfer and encrypted external media (delivered by hand)

2. Privilege Log — First Production, dated April 4, 2022 cc: Priya Anand, General Counsel, Torchlight Mining Corp. (via email) Aaron Liu, Calderwood & Harkness LLP Monica Reyes, Calderwood & Harkness LLP