Dear AUSA Calloway,
I write on behalf of our client, Dunmore Energy Holdings Ltd. ("Dunmore"), in connection with the inquiry being conducted by the Department of Justice, National Security Division, Counterintelligence and Export Control Section, and the grand jury subpoena designated GJ No. 22-418, issued by the U.S. District Court for the District of Columbia (Grand Jury 22-2). As you know, the return date for the subpoena was extended to July 19, 2022, pursuant to your letter of April 28, 2022, and we appreciate the government's accommodation in that regard.
**Request to Schedule Initial Proffer Meeting**
I am writing to request that we schedule an initial proffer meeting at which Calderwood & Harkness, on behalf of Dunmore, would present a summary of our preliminary findings from the ongoing internal investigation and outline Dunmore's cooperation posture going forward. We believe an early meeting would be productive and would demonstrate the seriousness and good faith with which Dunmore has approached this matter.
We propose holding the meeting on **Friday, July 15, 2022**, in Washington, D.C. We are happy to host the meeting at Calderwood & Harkness's Washington office at 1750 Pennsylvania Avenue NW, Suite 800, Washington, DC 20006, or alternatively to meet at the DOJ's offices, at your preference.
**Proposed Attendees**
From Calderwood & Harkness, the following attorneys plan to attend:
- Victoria Chambers, Partner (Responsible Partner) - Jasmine Thornton, Associate (Lead Associate) - Conrad Reeves, Senior Counsel (Export Controls & Sanctions), who will be available to address sanctions and export control–specific aspects of the matter
We would appreciate confirmation of which members of the DOJ team will participate. I have copied Trial Attorney Samuel Kovacs on this correspondence and would ask whether Trial Attorney Diana Pressman and/or FBI Special Agent Paul Reinhardt will also be in attendance.
**Proffer Meeting — Anticipated Substance**
At the meeting, we are prepared to provide an initial proffer summarizing the following:
1. **Cooperation Efforts and Internal Investigation.** An overview of Dunmore's cooperation efforts to date, including the scope and status of the ongoing internal investigation. Document collection has been undertaken across six jurisdictions, and a first round of 22 witness interviews was conducted between May 18 and June 30, 2022.
2. **Preliminary Findings Regarding Transactions at Issue.** A summary of preliminary findings regarding the transactions under review, including the 14 crude oil swap transactions totaling approximately $218.7 million in notional value involving Petronova Trading FZE and Zenith Petroleum DMCC.
3. **Forensic Accounting Analysis.** An update on the forensic accounting analysis being conducted by Ridgeline Advisory Group LLC, which was retained on May 2, 2022. Preliminary forensic results are available and will be discussed.
4. **Remedial Actions.** An overview of remedial measures already undertaken by Dunmore, including the following personnel actions: - Natasha Sorokin — placed on administrative leave effective May 16, 2022 - Derek Hargrave — placed on administrative leave effective July 1, 2022 - Gerald Fisk, former Chief Compliance Officer — departed the company on June 10, 2022
Dunmore is committed to full and transparent cooperation with the Department, consistent with the DOJ Corporate Enforcement Policy, and we look forward to demonstrating the breadth and depth of that cooperation at the proffer meeting.
**Rolling Production Protocol**
In connection with the extended subpoena return date of July 19, 2022, we will also be prepared to discuss a rolling production protocol for responsive documents at the meeting. As you may be aware, Nexagen Analytics Inc. has been engaged to process the collected document universe, which currently comprises over 2.3 million documents. We intend to propose a Bates-stamping protocol using the prefix DEH-DOJ. We will send a separate letter, anticipated on or about July 10, 2022, memorializing the terms of the proposed rolling production agreement for your review in advance of the meeting.
**Individual Counsel Notifications**
For the record, we wish to advise the government that certain current and former Dunmore employees have retained personal counsel in connection with this matter:
- **Gerald Fisk** (former Chief Compliance Officer) — represented by Catherine Blackthorn of Blackthorn & Associates LLP (Houston, Texas) - **Derek Hargrave** — represented by James Overstreet of Overstreet & McClain PLLC (Dallas, Texas)
We provide these notifications so that the DOJ is aware of these separate representations.
**Logistics**
We would appreciate confirmation of the July 15 date and your preferred meeting location at your earliest convenience. Should July 15 not be available, we are happy to accommodate an alternative date, though we do believe an early meeting is important given the current pace of the investigation.
Please do not hesitate to contact me directly with any questions or to discuss scheduling. I can be reached at the contact information below.
Thank you for your time and consideration, Meredith. We look forward to hearing from you.
Respectfully,
**Victoria Chambers** Partner, White Collar Defense & Investigations Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Tel: (202) 555-4180 vchambers@calderwoodharkness.com
Matter Reference: 1016-00009
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