Extract to table

It must be emphasized that the OPDP Inquiry raises significant potential enforcement risk for Penterra

All members of the Calderwood & Harkness LLP engagement team, together with any co-counsel, consultants, or other persons engaged under counsel's direction, must adhere strictly to the protocols set forth in this memorandum

Both federal and New Jersey privilege law recognize that the privilege must be strictly construed and that the party asserting the privilege bears the burden of establishing each of its elements

All decisions regarding potential voluntary or strategic waiver of privilege must be made by Penterra's General Counsel in consultation with the Responsible Partner, Leonard Cross

Any additional Calderwood & Harkness attorneys, paralegals, or support staff who may need to be involved in the matter — whether for document review, research, administrative support, or any other purpose — must be approved in advance by Leonard Cross before receiving access to matter files, communications, or any privileged or work-product materials

Privileged Document Marking and Labeling All memoranda, draft analyses, legal research memoranda, investigation notes, interview memoranda, correspondence, and other communications prepared by or at the direction of the Calderwood & Harkness engagement team in connection with this matter must bear the following privilege legend, prominently displayed at the top of the first page and, where practicable, in the header or footer of each subsequent page: PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION AND/OR ATTORNEY WORK PRODUCT — PREPARED AT THE DIRECTION OF COUNSEL IN ANTICIPATION OF LITIGATION In addition, all documents must be marked with the matter number 1018-00002 to ensure proper identification, tracking, and filing within Calderwood & Harkness's document management system