U.S. DEPARTMENT OF JUSTICE

NATIONAL SECURITY DIVISION Counterintelligence and Export Control Section

950 Pennsylvania Avenue NW Washington, D.C. 20530

April 28, 2022

Via Email and U.S. Mail

Victoria Chambers, Esq. Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006

Re: In the Matter of Grand Jury Subpoena No. GJ No. 22-418; Grand Jury 22-2; U.S. District Court for the District of Columbia — Extension of Return Date

Dear Ms. Chambers:

This letter is in response to your correspondence dated April 25, 2022, submitted on behalf of your client, Dunmore Energy Holdings Ltd. ("Dunmore"), in which you requested an extension of the return date for grand jury subpoena GJ No. 22-418 (the "Subpoena"), issued by the U.S. District Court for the District of Columbia on April 19, 2022, and returnable before Grand Jury 22-2. As you are aware, the Subpoena as originally issued established a return date of May 19, 2022. Your letter requested that the return date be extended to July 19, 2022, citing the breadth and complexity of the document collection required in connection with the Subpoena, including the need to collect and review materials maintained across multiple domestic and international jurisdictions.

Grant of Extension. The government has carefully considered the representations set forth in your April 25, 2022 letter regarding the breadth and complexity of the document collection required across multiple jurisdictions, including the need to coordinate with Dunmore's foreign subsidiaries and affiliates. Based on those representations, and in the interest of facilitating an orderly and thorough production of responsive materials, the government agrees to extend the return date of the Subpoena. Accordingly, the return date of grand jury subpoena GJ No. 22-418 is hereby extended from May 19, 2022 to July 19, 2022. As modified, the Subpoena requires the production of all responsive documents and materials on or before July 19, 2022. All documents responsive to the Subpoena must be delivered to the undersigned at the address listed above, or at such other location as may be agreed upon by the parties in writing, no later than the close of business on that date.

Scope of Subpoena Unchanged. Please be advised that the foregoing extension applies solely to the return date of the Subpoena and does not modify, limit, narrow, or otherwise alter the scope of the Subpoena in any respect. The full scope of the Subpoena, as set forth in the attachment thereto, remains in effect. As you are aware, the Subpoena calls for the production of all documents and electronically stored information, for the period from January 1, 2019 through the present, relating to or concerning the following:

(a) Petronova Trading FZE, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Petronova Trading FZE or any of its officers, directors, employees, or agents;

(b) Volkhov Industrial Group JSC, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Volkhov Industrial Group JSC or any of its officers, directors, employees, or agents;

(c) Zenith Petroleum DMCC, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Zenith Petroleum DMCC or any of its officers, directors, employees, or agents;

(d) Caspian Logistik GmbH, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Caspian Logistik GmbH or any of its officers, directors, employees, or agents;

(e) any transaction involving Russian-origin crude oil or refined petroleum products, including but not limited to purchases, sales, trades, swaps, or brokered transactions, regardless of the jurisdiction in which such transaction occurred or was facilitated; and

(f) any export, re-export, transfer, or proposed transfer of oilfield equipment, components, technology, or technical data to Russia, Belarus, or to any individual or entity appearing on the Office of Foreign Assets Control ("OFAC") Specially Designated Nationals and blocked Persons List ("SDN List"), the Bureau of Industry and Security Entity List, or the Bureau of Industry and Security Denied Persons List.

Dunmore Energy Holdings Ltd. and its subsidiaries, affiliates, and related entities remain fully obligated to preserve all potentially responsive documents, including all electronically stored information, pending full compliance with the Subpoena.

Preservation Obligations. The government takes this opportunity to remind counsel that Dunmore Energy Holdings Ltd. and all affiliated entities, including but not limited to subsidiaries, joint ventures, and entities under common ownership or control, must continue to preserve all documents and electronically stored information that are or may be potentially responsive to the Subpoena. This preservation obligation extends to all forms of communication and data, including but not limited to emails, text messages, instant messages, voicemails, memoranda, reports, presentations, spreadsheets, financial records, contracts, invoices, shipping records, customs documentation, trade compliance records, and any data maintained on servers, backup systems, personal devices, or cloud-based platforms. Any destruction, alteration, concealment, mutilation, or other tampering with responsive materials, whether intentional or through gross negligence, may constitute obstruction of justice in violation of 18 U.S.C. § 1519 and related federal statutes, and the government will not hesitate to pursue appropriate remedies in the event that any such conduct is identified.

Reservation of Rights. The government expressly reserves all rights to seek further process in connection with this matter, including but not limited to the issuance of additional grand jury subpoenas, requests for voluntary production, and any other lawful investigative means. The government further reserves the right to narrow or expand the scope of its inquiry as the investigation proceeds. The grant of the extension set forth herein does not constitute a waiver of any right, privilege, or authority of the United States, nor does it represent any agreement, understanding, or commitment by the government beyond the modification of the return date as specified above. In the event that production is not made by the extended return date of July 19, 2022, the government reserves the right to seek enforcement of the Subpoena through appropriate proceedings before the U.S. District Court for the District of Columbia, including but not limited to a motion to compel compliance and an application for an order to show cause why Dunmore should not be held in contempt.

Rolling Production. The government recognizes that the scope of the Subpoena is substantial and that collection efforts across multiple jurisdictions may present logistical challenges. Accordingly, the government is open to discussing a reasonable rolling production schedule in the event that Dunmore is unable to complete a full production of all responsive materials by the extended return date of July 19, 2022. Should Dunmore wish to explore such an arrangement, the government invites Ms. Chambers to contact the undersigned at her earliest convenience to discuss a proposed timeline and format for rolling productions. Please be advised, however, that any such arrangement would need to be memorialized in a separate written agreement executed by both parties, and the absence of such a written agreement shall not relieve Dunmore of its obligation to comply fully with the Subpoena by the extended return date.

DOJ Team Members and Contact Information. In addition to the undersigned, Trial Attorney Samuel Kovacs and Trial Attorney Diana Pressman of the Counterintelligence and Export Control Section, National Security Division, are assigned to this matter. The government requests that all future correspondence, filings, and communications relating to grand jury subpoena GJ No. 22-418, Grand Jury 22-2, or any related matter be directed to all three of the following attorneys:

Meredith Calloway Assistant United States Attorney National Security Division Counterintelligence and Export Control Section Telephone: (202) 514-1057

Email: meredith.calloway@usdoj.gov

Samuel Kovacs Trial Attorney National Security Division Counterintelligence and Export Control Section Telephone: (202) 514-2893

Email: samuel.kovacs@usdoj.gov

Diana Pressman Trial Attorney National Security Division Counterintelligence and Export Control Section Telephone: (202) 514-3641

Email: diana.pressman@usdoj.gov

FBI Case Agent. Please also be advised that Special Agent Paul Reinhardt of the Federal Bureau of Investigation, Counterintelligence Division, Washington Field Office, is the assigned case agent for this matter. Special Agent Reinhardt may contact Calderwood & Harkness LLP or representatives of Dunmore directly for purposes of coordinating document collection logistics, including arrangements relating to the format, method of delivery, and technical specifications for electronically stored information. It is understood, however, that all substantive communications regarding the Subpoena, the investigation, or any legal issues arising therefrom shall be directed through counsel. Should Special Agent Reinhardt contact Dunmore personnel directly, the government expects that such contacts will be limited to logistical matters and that counsel will be promptly notified.

Please do not hesitate to contact me should you have any questions regarding this matter or the terms of the extension set forth herein. We appreciate counsel's cooperation and look forward to working with your office to facilitate the timely production of responsive materials.

Sincerely,

Meredith Calloway Assistant United States Attorney National Security Division Counterintelligence and Export Control Section U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, D.C. 20530 Telephone: (202) 514-1057

Email: meredith.calloway@usdoj.gov

cc: Samuel Kovacs, Trial Attorney, Counterintelligence and Export Control Section, National Security Division cc: Diana Pressman, Trial Attorney, Counterintelligence and Export Control Section, National Security Division cc: Special Agent Paul Reinhardt, FBI Counterintelligence Division, Washington Field Office

CALDERWOOD & HARKNESS LLP — INTERNAL FILING NOTATION

RECEIVED April 28, 2022

Filed: Matter No. 1016-00009 Client: Dunmore Energy Holdings Ltd. Subpoena: GJ No. 22-418 (Grand Jury 22-2, U.S. District Court for the District of Columbia) Description: DOJ/NSD Correspondence — Grant of Extension of Return Date to July 19, 2022 Filed by: E. Vasquez, Paralegal Manager

Reviewed and confirmed: VC __

Date: 4/28/2022

U.S. DEPARTMENT OF JUSTICE
NATIONAL SECURITY DIVISION Counterintelligence and Export Control Section
950 Pennsylvania Avenue NW Washington, D.C. 20530
April 28, 2022
Via Email and U.S. Mail
Victoria Chambers, Esq. Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006
Re: In the Matter of Grand Jury Subpoena No. GJ No. 22-418; Grand Jury 22-2; U.S. District Court for the District of Columbia — Extension of Return Date
Dear Ms. Chambers:
This letter is in response to your correspondence dated April 25, 2022, submitted on behalf of your client, Dunmore Energy Holdings Ltd. ("Dunmore"), in which you requested an extension of the return date for grand jury subpoena GJ No. 22-418 (the "Subpoena"), issued by the U.S. District Court for the District of Columbia on April 19, 2022, and returnable before Grand Jury 22-2. As you are aware, the Subpoena as originally issued established a return date of May 19, 2022. Your letter requested that the return date be extended to July 19, 2022, citing the breadth and complexity of the document collection required in connection with the Subpoena, including the need to collect and review materials maintained across multiple domestic and international jurisdictions.
Grant of Extension. The government has carefully considered the representations set forth in your April 25, 2022 letter regarding the breadth and complexity of the document collection required across multiple jurisdictions, including the need to coordinate with Dunmore's foreign subsidiaries and affiliates. Based on those representations, and in the interest of facilitating an orderly and thorough production of responsive materials, the government agrees to extend the return date of the Subpoena. Accordingly, the return date of grand jury subpoena GJ No. 22-418 is hereby extended from May 19, 2022 to July 19, 2022. As modified, the Subpoena requires the production of all responsive documents and materials on or before July 19, 2022. All documents responsive to the Subpoena must be delivered to the undersigned at the address listed above, or at such other location as may be agreed upon by the parties in writing, no later than the close of business on that date.
Scope of Subpoena Unchanged. Please be advised that the foregoing extension applies solely to the return date of the Subpoena and does not modify, limit, narrow, or otherwise alter the scope of the Subpoena in any respect. The full scope of the Subpoena, as set forth in the attachment thereto, remains in effect. As you are aware, the Subpoena calls for the production of all documents and electronically stored information, for the period from January 1, 2019 through the present, relating to or concerning the following:
(a) Petronova Trading FZE, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Petronova Trading FZE or any of its officers, directors, employees, or agents;
(b) Volkhov Industrial Group JSC, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Volkhov Industrial Group JSC or any of its officers, directors, employees, or agents;
(c) Zenith Petroleum DMCC, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Zenith Petroleum DMCC or any of its officers, directors, employees, or agents;
(d) Caspian Logistik GmbH, including all communications, agreements, invoices, shipping records, financial records, and any other documents referencing or relating to Caspian Logistik GmbH or any of its officers, directors, employees, or agents;
(e) any transaction involving Russian-origin crude oil or refined petroleum products, including but not limited to purchases, sales, trades, swaps, or brokered transactions, regardless of the jurisdiction in which such transaction occurred or was facilitated; and
(f) any export, re-export, transfer, or proposed transfer of oilfield equipment, components, technology, or technical data to Russia, Belarus, or to any individual or entity appearing on the Office of Foreign Assets Control ("OFAC") Specially Designated Nationals and blocked Persons List ("SDN List"), the Bureau of Industry and Security Entity List, or the Bureau of Industry and Security Denied Persons List.
Dunmore Energy Holdings Ltd. and its subsidiaries, affiliates, and related entities remain fully obligated to preserve all potentially responsive documents, including all electronically stored information, pending full compliance with the Subpoena.
Preservation Obligations. The government takes this opportunity to remind counsel that Dunmore Energy Holdings Ltd. and all affiliated entities, including but not limited to subsidiaries, joint ventures, and entities under common ownership or control, must continue to preserve all documents and electronically stored information that are or may be potentially responsive to the Subpoena. This preservation obligation extends to all forms of communication and data, including but not limited to emails, text messages, instant messages, voicemails, memoranda, reports, presentations, spreadsheets, financial records, contracts, invoices, shipping records, customs documentation, trade compliance records, and any data maintained on servers, backup systems, personal devices, or cloud-based platforms. Any destruction, alteration, concealment, mutilation, or other tampering with responsive materials, whether intentional or through gross negligence, may constitute obstruction of justice in violation of 18 U.S.C. § 1519 and related federal statutes, and the government will not hesitate to pursue appropriate remedies in the event that any such conduct is identified.
Reservation of Rights. The government expressly reserves all rights to seek further process in connection with this matter, including but not limited to the issuance of additional grand jury subpoenas, requests for voluntary production, and any other lawful investigative means. The government further reserves the right to narrow or expand the scope of its inquiry as the investigation proceeds. The grant of the extension set forth herein does not constitute a waiver of any right, privilege, or authority of the United States, nor does it represent any agreement, understanding, or commitment by the government beyond the modification of the return date as specified above. In the event that production is not made by the extended return date of July 19, 2022, the government reserves the right to seek enforcement of the Subpoena through appropriate proceedings before the U.S. District Court for the District of Columbia, including but not limited to a motion to compel compliance and an application for an order to show cause why Dunmore should not be held in contempt.
Rolling Production. The government recognizes that the scope of the Subpoena is substantial and that collection efforts across multiple jurisdictions may present logistical challenges. Accordingly, the government is open to discussing a reasonable rolling production schedule in the event that Dunmore is unable to complete a full production of all responsive materials by the extended return date of July 19, 2022. Should Dunmore wish to explore such an arrangement, the government invites Ms. Chambers to contact the undersigned at her earliest convenience to discuss a proposed timeline and format for rolling productions. Please be advised, however, that any such arrangement would need to be memorialized in a separate written agreement executed by both parties, and the absence of such a written agreement shall not relieve Dunmore of its obligation to comply fully with the Subpoena by the extended return date.
DOJ Team Members and Contact Information. In addition to the undersigned, Trial Attorney Samuel Kovacs and Trial Attorney Diana Pressman of the Counterintelligence and Export Control Section, National Security Division, are assigned to this matter. The government requests that all future correspondence, filings, and communications relating to grand jury subpoena GJ No. 22-418, Grand Jury 22-2, or any related matter be directed to all three of the following attorneys:
Meredith Calloway Assistant United States Attorney National Security Division Counterintelligence and Export Control Section Telephone: (202) 514-1057
Email: meredith.calloway@usdoj.gov
Samuel Kovacs Trial Attorney National Security Division Counterintelligence and Export Control Section Telephone: (202) 514-2893
Email: samuel.kovacs@usdoj.gov
Diana Pressman Trial Attorney National Security Division Counterintelligence and Export Control Section Telephone: (202) 514-3641
Email: diana.pressman@usdoj.gov
FBI Case Agent. Please also be advised that Special Agent Paul Reinhardt of the Federal Bureau of Investigation, Counterintelligence Division, Washington Field Office, is the assigned case agent for this matter. Special Agent Reinhardt may contact Calderwood & Harkness LLP or representatives of Dunmore directly for purposes of coordinating document collection logistics, including arrangements relating to the format, method of delivery, and technical specifications for electronically stored information. It is understood, however, that all substantive communications regarding the Subpoena, the investigation, or any legal issues arising therefrom shall be directed through counsel. Should Special Agent Reinhardt contact Dunmore personnel directly, the government expects that such contacts will be limited to logistical matters and that counsel will be promptly notified.
Please do not hesitate to contact me should you have any questions regarding this matter or the terms of the extension set forth herein. We appreciate counsel's cooperation and look forward to working with your office to facilitate the timely production of responsive materials.
Sincerely,
Meredith Calloway Assistant United States Attorney National Security Division Counterintelligence and Export Control Section U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, D.C. 20530 Telephone: (202) 514-1057
Email: meredith.calloway@usdoj.gov
cc: Samuel Kovacs, Trial Attorney, Counterintelligence and Export Control Section, National Security Division cc: Diana Pressman, Trial Attorney, Counterintelligence and Export Control Section, National Security Division cc: Special Agent Paul Reinhardt, FBI Counterintelligence Division, Washington Field Office
CALDERWOOD & HARKNESS LLP — INTERNAL FILING NOTATION
RECEIVED April 28, 2022
Filed: Matter No. 1016-00009 Client: Dunmore Energy Holdings Ltd. Subpoena: GJ No. 22-418 (Grand Jury 22-2, U.S. District Court for the District of Columbia) Description: DOJ/NSD Correspondence — Grant of Extension of Return Date to July 19, 2022 Filed by: E. Vasquez, Paralegal Manager
Reviewed and confirmed: VC __
Date: 4/28/2022

U.S. DEPARTMENT OF JUSTICE

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