FILED: NEW YORK COUNTY CLERK 10/14/2016 02:25 PM NYSCEF DOC. NO. 2 INDEX NO. 451962/2016 RECEIVED NYSCEF: 10/14/2016 By: WITNESS, The Honorable Eric T. Schneiderman, Attorney Geral of the State of New York, this 19th day ofAugust, 2016. I a} r; - ,2 By: Ka?aerine Mlgram :3 Deputy Bureau Chief Investor Protection Bureau 120 Broadway, 23rd Floor New York, New York 10271 (212) 416-8222 Jonathan eig Assistant ttorney General Investor Protection Bureau 120 Broadway, 23rd Floor New York, New York 10271 (212) 416-8954 SCHEDULE A. General De?nitions and Rules of Construction ?All? means each and every. ?Any? means any and all. ?And? and ?or? shall be construed either disjunctiver or conjunctiver as necessary to bring within the scope of the Subpoena all information or Documents that might otherwise be construed to be outside of its scope. ?Communication? means any conversation, discussion, letter, email, memorandum, meeting, note or other transmittal of information or message, whether transmitted in writing, orally, electronically or by any other means, and shall include any Document that abstracts, digests, transcribes, records or re?ects any of the foregoing. ?Concerning? means, directly or indirec?y, in whole or in part, relating to, referring to, describing, evidencing or constituting. ?Custodian? means any Person or Entity that, as. of the date of this Subpoena, maintained, possessed, or otherwise kept or controlled such Document. ?Document? is used herein in the broadest sense of the term and means all records and other tangible media of expression of whatever nature however and wherever created, produced or stored (manually, mechanically, electronically or otherwise), including without limitation all versions whether draft or ?nal, all annotated or nonconforming or other copies, electronic mail instant messages, text messages, Blackberry or other wireless device messages, voicemail, calendars, date books, appointment books, diaries, books, papers, work papers, ?les, desk ?les, permanent ?les, temporary ?les, notes, con?rmations, account statements, correspondence, memoranda, reports, records, journals, registers, analyses, plans, manuals, policies, telegrams, faxes, telexes, wires, telephone logs, telephone messages, message slips, minutes, notes or records or transcriptions of conversations or Communications or meetings, tape recordings, videotapes, disks, other electronic media, micro?lm, micro?che, storage devices, press releases, contracts, agreements, notices and summaries. Any non-identical version of a Document constitutes a separate Document within this de?nition, including without limitation drafts or copies bearing any notation, edit, comment, marginalia, underscoring, highlighting, marking, or any other alteration of any kind resulting in any difference between two or more otherwise identical Documents. In the case of Documents bearing any notation or other marking made by highlighting ink, the term Document means the original version bearing the highlighting ink, which original must be produced as opposed to any copy thereof. ?Entity? means without limitation any corporation, company, limited liability company or corporation, partnership, limited partnership, association, or other ?rm or similar body, or any unit, division, agency, department, or similar subdivision thereof. 10. ll. 12. 13. 14. 15. 16. ?Idtify? or ?Identity,? as applied to any Document, means the provision in writing of information suf?ciently particular to enable the Attorney General to request the Document?s production through subpoena or otherwise, including but not limited to: Document type (letter, memorandum, etc.); Document subject matter; (0) Document date; and Document author(s), addressee(s) and recipient(s). In lieu of identifying a Document, the Attorney General will accept production of the Document, together with designation of the Document?s Custodian, and identi?cation of each Person You believe to have received a copy of the Document. ?Identify? or ?Identity,? as applied to any Entity, means the provision in writing of such Entity?s legal name, any dfb/a, former, or other names, any parent, subsidiary, of?cers, employees, or agents thereof, and any address(es) and any telephone number(s) thereof. ?Identify? or ?Identity,? as applied to any natural person, means and includes the provision in writing of the natural person?s name, tit1e(s), any aliases, p1ace(s) of employment, telephone number(s), e-mail address(es), mailing addresses and physical address(es). ?Person? means any natural person, or any Entity. ?Sent? or ?received? as used herein means, in addition to their usual meanings, the transmittal or reception of a Document by physical, electronic or other delivery, whether by direct or indirect means. ?Subpoena? means this subpoena and any schedules or attachments thereto. The use of the singular form of any word used herein shall include the plural and vice versa. The use of any tense of any verb includes all other tenses of the verb. The references to Communications, Custodians, Documents, Persons, and Entities in this Subpoena encompass all such relevant ones worldwide. B. Particular De?nitions ?You,? ?Your,? or means PricewaterhouseCoopers LLP and Any present or former parents, subsidiaries, af?liates, directors, of?cers, partners, employees, agents, representatives, attorneys or other Persons acting on its behalf, and including predecessors or successors or Any af?liates of the foregoing. ?Exxon? means ExxonMobil Corporation, ExxonMobil Oil Corporation, and Any present or former parents, subsidiaries, af?liates, directors, of?cers, partners, employees, agents, representatives, attorneys or other Persons acting on its behalf, and including predecessors or successors or Any af?liates of the foregoing. means the organization formerly called Carbon Disclosure Project and Any present or former parents, subsidiaries, af?liates, directors, of?cers, partners, employees, agents, representatives, attorneys or other Persons acting on its behalf, including predecessors or successors or Any af?liates of the foregoing, and All associated reports, publications, and analysis. . ?Climate Change? means climate and environmental system impacts, weather-related events, and Any other effect on the earth?s physical, biological, and human systems communities and built in?astructure) that may be related to anthropogenic emissions of carbon dioxide and other Greenhouse Gases, including but not limited to increasing air or water temperatures, global warming, rising sea levels, melting of sea ice and land-based ice including glaciers and ice sheets, ocean acidi?cation, permafrost thawing, changes in precipitation patterns, intensity or frequency, droughts, coastal and riverine ?ooding, and extreme storms. means the exploration and production segment of the energy industry, including but not limited to discovering, augmenting, extracting, producing, recovering, and merchandising oil, gas, and other hydrocarbons, together with All other upstream activities and assets, and including but not limited to oil, gas, and other hydrocarbon reserves, resource base, and potential resource base. ?Fossil Fue means All energy somces formed ?om fossilized remains of dead organisms, including oil, gas, bitumen and natural gas. For purposes of this Subpoena, the de?nition includes also fossil fuels blended with biofuels, such as corn ethanol blends of gasoline. The de?nition excludes renewable sources of energy production, such as hydroelectric, geothermal, solar, tidal, wind, and biomass. ?Greenhouse Gases? means carbon dioxide, methane, nitrous oxide, hydro?uorocarbons, perfluorocarbons, and sulfur hexa?uoride. ?Renewable Energy? means renewable sources of energy production, such as hydroelectric, geothermal, solar, tidal, wind, and biomass. C. Instructions Preservation of Relevant Documents and Information; Snoliation. You are reminded of Your obligations under law to preserve Documents and information relevant or potentially relevant to this Subpoena ?om destruction or loss, and of the consequences of, and penalties available for, spoliation of evidence. No agreement, written or otherwise, purporting to modify, limit or otherwise vary the terms of this Subpoena, shall be construed in any way to narrow, qualify, eliminate or otherwise diminish Your aforementioned preservation obligations. Nor shall You act, in reliance upon any such agreement or otherwise, in any manner inconsistent with Your preservation obligations under law. No agreement purporting to modify, limit or otherwise vary Your preservation obligations under law shall be construed as in any way narrowing, qualifying, eliminating or otherwise diminishing such aforementioned preservation obligations, nor shall You act in reliance upon any such agreement, unless an Assistant Attorney General con?rms or acknowledges such agreement in writing, or makes such agreement a matter of record in Open court. Possession. Custody. and Control. The Subpoena calls for all responsive Documents or information in Your possession, custody or control. This includes, without limitation, Documents or information possessed or held by any of Your of?cers, directors, employees, agents, representatives, divisions, af?liates, subsidiaries or Persons ?om whom You could request Documts or information. IfDocuments or information responsive to a request in this Subpoena are in Your control, but not in Your possession or custody, You shall Identify the Person with possession or custody. Documents No Longer in Your Possession. If any Document requested herein was formerly in Your possession, custody or control but is no longer ava?able, or no longer exists, shall submit a statement in writing under oath that: describes in detail the nature of such Document and its contents; Identi?es the Person(s) who prepared such Document and its contents; Identi?es all Persons who have seen or had possession of such Document; speci?es the date(s) on which such Document was prepared, transmitted or received; speci?es the date(s) on which such Document became unavailable; (1) speci?es the reason why such Document is unavailable, including without limitation whether it was misplaced, lost, destroyed or transferred; and if such Document has be destroyed or transferred, the conditions of and reasons for such destruction or transfer and the Identity of the Person(s) requesting and performing such destruction or transfer; and Identi?es all Persons with knowledge of any portion of the contents of the Document. No Documents Responsive to Subpoena Requests. Ifthere are no Documents responsive to any particular Subpoena request, You shall so state in writing under oath in the Af?davit of Compliance attached hereto, identifying the paragraph number(s) of the Subpoena request concerned. Format of Production. You shall produce Documents and information reSponsive to this Subpoena in the format requested by the Of?ce of the New York State Attorney General. Productions in electronic format shall meet the speci?cations set out in Attachments 1 and 2 hereof. Existing Organization of Documents to be Preserved. Regardless of whether a production is in electronic or paper format, each Document shall be produced in the same form, sequence, organization or other order or layout in which it was maintained before production, including but not limited to production of any Document or other material indicating ?ling or other organization. Such production shall include without limitation any ?le folder, ?le jacket, cover or similar organizational material, as well as any folder bearing any title or legend that contains no Document. Likewise, all Documents that are physically attached to each other in Your ?les shall remain so attached in any production; or if such production is electronic, shall be accompanied by notation or information suf?cient to indicate clearly such physical attachment. Document Numbering. All Documents responsive to this Subpoena, regardless of whether produced or withheld on ground of privilege or other legal doctrine, and regardless of whether production is in electronic or paper format, shall be numbered in the lower right corner of each page of such Document, without disrupting or altering the 10. ll. 12. 13. form, sequence, organization or other order or layout in which such Documents were maintained before production. Such number shall comprise a pre?x containing the producing Person?s name or an abbreviation thereof, followed by a unique, sequential, identi?ring document control number. Privilege Placeholders. For each Document withheld from production on ground of privilege or other legal doctrine, regardless of whether a production is electronic or in hard copy, You shall insert one or more placeholder page(s) in the production bearing the same document control number(s) borne by the Document withheld; in the sequential place(s) originally occupied by the Document before it was removed ?om the production. Privilege. If You withhold any Document responsive to this Subpoena on ground of privilege or other legal doctrine, You shall submit with the Documents produced a statement in writing under oath, stating: the document control number(s) of the Document withheld; the type of Document; the date of the Document; the author(s) and recipient(s) of the Document; the general subject matter of the Document; and the legal ground for withholding the Document. Ifthe legal ground for withholding the Document is attomey-client privilege, You shall indicate the name of the attorney(s) whose legal advice is sought or provided in the Document. Your Production Instructions to be Produced. You shall produce a copy of all written or otherwise recorded instructions prepared by You concerning the steps taken to respond to this Subpoena. For any unrecorded instructions given, You shall provide a written statement under oath from the Person(s) who gave such instructions that details the speci?c content of ?re instructions and any Person(s) to whom the instructions were given. Cover Letter. Accompanying any production(s) made pursuant to this Subpoena, You shall include a cover letter that shall at a minimum provide an index containing the following: a description of the type and content of each Document produced therewith; the paragraph number(s) of the Subpoena request to which each such Document is responsive; the Identity of the Custodian(s) of each such Document; and the document control number(s) of each such Document. Af?davit of Compliance. A copy of the Af?davit of Compliance provided herewith shall be completed and executed by all natural persons supervising or participating in compliance with this Subpoena, and You shall submit such executed of Compliance with Your response to this Subpoena. Identi?cation of Persons Preparing Production. In a schedule attached to the Af?davit of Compliance provided herewith, You shall Identify the natural person(s) who prepared or assembled any productions or responses to this Subpoena. You shall further Identify the natural person(s) under whose personal supervision the preparation and assembly of productions and responses to this Subpoena occurred. You shall further Identify all other natural person(s) able competently to testify: that such productions and responses are complete and correct to the best of such person?s knowledge and belief; and that any Documents produced are authentic, genuine and what they purport to be. 14. 15. 16. Continuing Obligation to Produce. This Subpoena imposes a continuing obligation to produce the Documents and information requested. Documents located, and information learned or acquired, at any time after Your response is due shall be produced at the place speci?ed in this Subpoena. No Oral Modi?cations. No agreement purporting to modify, limit or otherwise vary this Subpoena shall be valid or binding, and You shall not act in reliance upon any such agreement, unless an Assistant Attorney General con?rms or acknowledges such agreement in writing, or makes such agreement a matter of record in open court. Time Period Unless otherwise speci?ed, the time period for information, Documents, and Communications requested by this Subpoena is ?om January 1, 2010 PwC?s audits of ?nancial statements for 2010) through the date of the production. D. Requests for Information Identify All individuals and business groups or divisions at that were involved in PwC?s reviews and audits of Exxon?s ?nancial statements. Identify All individuals and business groups or divisions at PWC that were involved in PwC?s review of Exxon?s decisions Concerning its oil, gas, and other hydrocarbon reserves, resource base, and potential resource base. Identify All individuals and business groups or divisions at that were involved in PwC?s review of Exxon?s decisions Concerning actual or potential E&P?related write- downs, impairment charges, impairment testing or analysis, or triggers for impairment testing or analysis. Identify All individuals and business groups or divisions at PWC that were involved in PwC?s review of Exxon?s capital allocation and expendiun'e decisions based on actual or potential impacts of Climate Change or policies or regulations Concerning Climate Change. Identify All individuals and business groups or divisions at Exxon with which communicated Concerning Exxon?s oil, gas, and other hydrocarbon reserves, resource base, and potential resource base. Identify All individuals and business groups or divisions at Exxon with which communicated Concerning actual or potential E&P?related write-downs, impairment charges, impairment testing or analysis, and triggers for impairment testing or analysis. Identify All individuals and business groups or divisions at Exxon with which communicated concerning Exxon?s capital allocation and expenditure decisions based on actual or potential impacts of Climate Change or policies or regulations Concerning Climate Change. E. Documents to be Produced All Documts and Communications Concerning the valuation, accounting, booking, de- booking, and reporting of Exxon?s oil, gas, and other hydrocarbon reserves, resource base, and potential resource base, and the time period within which Exxon expects to produce its reserves, resource base, and potential resource base. All Documents and Communications Concerning the preparation or completion, or the potential preparation or completion, of Any audit of Exxon?s oil, gas, and other hydrocarbon reserves, resource base, and potential resource base. All Documents and Communications Concerning Exxon?s internal auditing of its database or system containing its estimates of oil, gas, and other hydrocarbon reserves, resource base, and potential resource base; the processes and controls used by Exxon in the preparation of its estimates of such reserves, resource base, and potential resource base; and the quali?cations of the technical personnel responsible for overseeing the preparation of such estimates. All Documents and Communications Concerning E&P?related write-downs, impairment charges, impairment testing or analysis, and triggers for impairment testing or analysis, actual or potential, with respect to Exxon, including but not limited to Exxon?s late 2015 effort to assess its major long-lived assets most at risk for potential impairment. All Documents and Communications Concerning Exxon?s outlook or projections of oil, gas, and other hydrocarbon prices, including but not limited to Any outlook or projections Concerning the duration of Any price changes (such as Any classi?cation of price changes as short-term, temporary, or long-term). All Documents and Communications Concerning Exxon?s consideration, analysis, determination, or application of a carbon price, shadow price of carbon, or proxy cost of carbon. All Documents and Communications Concerning the impact or potential impact of Any of the following factors on Exxon?s ?nancial statements or its business generally, including operations and capital allocation and expenditures: a. changes or potential changes in the cost or price of carbon, including but not limited to Any proxy or shadow cost of carbon; b. actual or potential policies or regulations limiting or discouraging the emission of Greenhouse Gases; c. actual or potential policies or regulations limiting or discouraging the use or development of Fossil Fuels; d. actual or potential policies or regulations promoting or incentivizing the use or development of Renewable Energy; 10. ll. 12. e. actual or potential policies or regulations Concerning Climate Change; f. actual or potential effects of Climate Change; and/or g. changes or potential changes in the price of oil, gas, and other hydrocarbons. All Documents and Communications from PwC?s audit ?les for Exxon Concerning Exxon?s oil, gas, and other hydrocarbon reserves, resource base, and potential resource base; E&P?re1ated write-downs, impairment charges, impairment testing or analysis, and triggers for impairment testing or analysis, actual or potential; and capital expenditures or. allocation based on actual or potential impacts of Climate Change or policies or regulations Concerning Climate Change. Indices of PwC?s work papers, permanent ?les, and desk ?les Concerning PwC?s audits of Exxon?s ?nancial statements. All engagement letters Concerning Exxon?s retention of All management representation letters Concerning PwC?s audits of Enron?s ?nancial statements. All Documents and Communications Concerning Exxon?s CDP submissions and PwC?s analysis of Exxon?s CDP submissions. 10 1 Electronic Document Production Speci?cations Unless otherwise speci?ed and agreed to by the Of?ce of the Attorney General, all responsive documents must be produced in LexisNexis? Concordance? format in accordance with the following instructions. Any questions regarding electronic document production should be directed to the Assistant Attorney General whose telephone number appears on the subpoena. 1. Concordance Production Components. A Concordance production consists of the following component ?les, which must be produced in accordance with the speci?cations set forth below in Section 7. A. Native Files. Native format versions of produced documents that are not redacted, named by their ?rst Bates number. B. Single-Page Image Files. Individual petri?ed page images of the produced documents in tagged image format with page-level Bates number endorsements. C. Extracted or OCR Text Files. Document-level extracted text for each produced document or documt?level optical character recognition text where extracted text is not available. D. Metadata Load File. A delimited text ?le that lists in columnar format the required metadata for each produced document. - E. Opticon Load File. A delimited text ?le that lists the single?page TIF ?les for each produced document and de?nes the relative location of the TIF ?les on the production media and (ii) each document break. Production Folder Structure. The production must be organized according to the following standard folder structure: 0 data\ (contains production load ?les) II images\ (contains single-page TIF ?les, with subfolder organization) \0001, \0002, \0003 . . . - natives\ (containsnative ?les, with subfolder organization) \0001, \0002, \0003 . . . 0 text\ (contains text ?les, with subfolder organization) \0001, \0002, \0003 . . . De-Duplication. You must perform global de-duplication of stand-alone documents and email families against any prior productions pursuant to this or previously related subpoenas. Paper or Scanned Documents. Documents that exist only in paper format must be scanned to single?page TIF ?les and'OCR?d. The resulting electronic ?les should be pursued in Concordance format pursuant to these instructions. You must contact the 11 Assistant Attorney General whose telephone number appears on the subpoena to discuss any documents that cannot be scanned, and (ii) how information for scanned documents should be represented in the metadata load ?le. Structured Data. Structured data includes but is not limited to relational databases, transactional data, and pages. Spreadsheets are not considered structured data. You must ?rst speak to the Assistant Attorney General whose telephone number appears on the subpoena. I - A. Relational Databases 1. Database tables should be provided in comma-separated or other machine-readable, non-proprietary format, with each table in a separate data ?le. Each data ?le must have an accompanying data dictionary that explains the meaning of each column name and explains the values of any codes used. 2. Dates and numbers must be clearly and consisten?y formatted and, where relevant, units of measure should be explained in the data dictionary. Records must contain clear, unique identi?ers, and the data dictionary must include explanations of how the ?les and records relate to one another. Media and Engption. All document sets over 2 GB must be produced on CD, DVD, or hard-drive media. All production media must be with a strong password, which must be delivered independently from the production media. Document sets under 2 GB may be delivered electronically. The OAG offers a secure cloud storage Option that can be set up to receive media on a one-time basis, or the OAG will download media from the providing party?s server. Production File Requirements. A. Native Files 0 Documents that do not contain redacted information must be produced in their native format. 0 The ?lename of each native ?le must match the document?s beginning Bates number (BEGDOC) in the metadata load ?le and retain the original ?le extension. 0 For documents produced only in native format, and not additionally as single- page image ?les, you must assign a single document-level Bates number and optionally provide an image ?le placeholder that states ?Document produced only in native forma I The relative paths to all native ?les on the production media must be listed in the NATIVEFILE ?eld of the metadata load ?le. I Native ?les that are password-protected must be prior to conversion and produced in form. It You may be required to supply a soitware license for proprietary documents 12 produced only in native format. Single-Page Image Files (Petri?ed Page Images) Where possible, all produced documents must be converted into single-page tagged image format ?les. Image documents that exist only in non-TIP formats must be converted into TIF ?les. For documents produced only in native format, you may provide a single, TIF placeholder that states ?Document produced only in native format.? Each single-page TIF ?le must be endorsed with a unique Bates number. I The ?lename for each single-page TIF ?le must match the unique page-level Bates number (or document-level Bates number for documents produced only in native format). Required image ?le format: 0 CCITT Group 4 compression 0 2-Bit black and White 0 300 dpi 0 Either .tif or .tiff ?le extension. TIF ?les must be divided into subfolders containing no more than 5000 ?les. Documents should not span multiple subfolders, a document with more than 5000 pages should be kept in a single folder. Extracted or OCR Text Files You must produce individual document-level text ?les containing the full extracted text for each produced document. When extracted text is not available (for instance, for image-only documents) you must provide individual document-level text ?les containing the document?s full OCR text. The ?lename for each text ?le must match the document?s beginning Bates number (BEGDOC) listed in the metadata load ?le. Text ?les must be divided into subfolders containing no more than 5000 ?les. Metadata Load File Required ?le format: 0 UTF-8 0 .dat ?le extension 0 Field delimiter: (ASCII decimal character 20) 0 Text Quali?er: (ASCH decimal character 254). Multiple value ?eld delimiter: (ASCII decimal character 59) The ?rst line of the metadata load ?le must list all included ?elds. All required ?elds are listed in Attachment 2. Fields with no values must be represented by empty columns maintaining delimiters and quali?ers. Note: All documents must have page-level Bates numbering (except documents produced only in native format, which must be assigned a document-level Bates number). The metadata load ?le must list the beginning and ending Bates numbers (BEGDOC and ENDDOC) for each document. Accepted date formats: l3 0 Accepted time formats: 0 (if not in 24-hour format, you must indicate am/pm) E. Opticon Load File Required ?le format: 0 0 Field delimiter: (ASCII decimal character 44) No Text Quali?er .opt ?le extension The comma-delimited Opticon load ?le must contain the following seven ?elds (as indicated below, values for certain ?elds may be left blank): 0 ALIAS or IMAGEKEY the unique Bates number assigned to each page of the production. VOLUME this value is optional and may be left blank. RELATIVE PATH the ?le path to each single-page image ?le on the production media. . BREAK de?nes the ?rst page of a document. The only possible values for this ?eld are or blank. FOLDER BREAK de?nes the ?rst page of a folder. The only possible values for this ?eld are or blank. BOX BREAK de?nes the ?rst page of a box. The only possible values for this ?eld are or blank. PAGE COUNT this value is optional and may be left blank. Example: 14 ATTACHMENT 2 Required Fields for Metadata Load File FIELD NAME FIELD DESCRIPTION FIELD VALUE BEGDOC Bates number assigned to the ?rst page of the document. ENDDOC Bates number assigned to the last page of the ABC0002 document. BEGATTACH Bates number assigned to the ?rst page of the parent document in a document family . should be the same as BEGDOC of the parent document, or PARENTDOC). ENDATTACH Bates number assigned to the last page of the last child document in a family (12a, should be the same as ENDDOC of the last child document). PARENTDOC BEGDOC of parent document. List of BEGDOCs of all child documents, delimited by when ?eld has multiple values. COMMENTS Additional document comments, such as passwords for ?les. NATIVEFILE Relative ?le path of the native ?le on the production media. TEXTFILE Relative ?le path of the plain text ?le on the production media. SOURCE For scanned paper records this should be a Company Name, Department Name, description of the physical location of the Location, Box original paper record. For loose electronic ?les this should be the name of the ?le server or workstation where the ?les were gathered. CUSTODIAN Owner of the document or ?le. Firstname Lastname, Lastname, Firstname, User Name; Company Name, Department FROM Sender of the email. Firstname Lastname FLastname @domain TO All to: members or recipients, delimited by irstname Lastname FLastname when ?eld has multiple values. @domain Firstname Lastname FLastname @domain . .. 1 Examples represent possible values and not required format unless the ?eld format is speci?ed in Attachment 1. 15 CC All cc: members, delimited by when ?eld has Firstname Lastname FLastname multiple values. @domain Firstname Laslname . FLaslname @domain . . . BCC All bcc: members, delimited by when ?eld Firstname Lastname FLastname has multiple values @domain Firstname Lastname FLastname @domain . . . SUBJECT Subject line of the email' . DATERCVD Date and time that an email was received. or hh:mm:ss . DATESENT Date and time that an email was sent. or or CALBEGDATE Date that a meeting begins. or or CALENDDATE Date that a meeting ends. or hh:mm:ss or hh:mm:ss ATTACHMENTS List of ?lenames of all attachments, delimited by AttachmentFileName.; when ?eld has multiple values. AttachmentFileName.docx; AttachmentFileName.pdf; . . . NUMATTACH Number of attachments. General type of record. LOOSE IMAGE LOOSE E- MAIL ATTACHMENT FOLDERLOC Original folder path of the produced document. FILENAME Original ?lename of the produced document. Filename.ext DOCEXT Original ?le extension. html, xls, DOCTYPE Name of the program that created the produced Adobe Acrobat, Microso? Word, document Microsoft Excel, Corel WordPerfect. . . TITLE Document title (if entered). AUTHOR Name of the document author. REVISION Number of revisions to a document. 18 DATECREATED Date and time that a document was created. or or hh:mm:ss 16 DATEMOD Date and time that a document was last modi?ed. or or FILESIZE Original ?le size in bytes. PGCOUNT Number of pages per document. IMPORTANCE Email priority level if set. Low, Normal, High MDSI-IASH MDS hash value computed from native ?le (a/k/a ?le ?ngerprint). SHAIHASH SHAI hash value MSGINDEX Email message CONVERSATIO Email Conversation Index 17 AFFIDAVIT OF COMPLIANCE WITH SUBPOENA State of 1 County of I, being duly sworn, state as follows: . I am employed by Respondent in the position of 3 . Respondent's productions and responses to the Subpoena of the Attorney General of the State of New York, dated 20 assembled under my personal supervision; (the ?Subpoena?) were prepared and . I made or caused to bemade a diligent, complete and comprehensive search for all Documents and information requested by the Subpoena, in full accordance with the instructions and de?nitions set forth in the Subpoena; . Respondent?s productions and responses to the Subpoena are complete and correct to the best of my knowledge and belief; . No Documents or information responsive to the Subpoena have been withheld from Respondent?s production and response, other than responsive Documents or information withheld on the basis of a legal privilege or doctrine; . All responsive Documents or information withheld on the basis of a legal privilege or doctrine have been identi?ed on a privilege log; . The Documents contained in Respondent?s productions and responses to the Subpoena are authentic, genuine and what they purport to be; . Attached is a true and accurate record of all persons who prepared and assembled any productions and responses to the Subpoena, all persons under whose personal supervision the preparation and assembly of productions and responses to the Subpoena occurred, and all persons able competently to testify: that such productions and responses are complete and correct to the best of such person's knowledge and belief; and that any Documents produced are authentic, genuine and what they purport to be; and 18 9. Attached is a true and accurate statement of those requests under the Subpoena as to which no responsive Documents were located in the course of the aforementioned search. Signature of Af?ant Date Printed Name of Af?ant - a: a: a: Subscribed and sworn to before me this . day of 20 Notary Public My commission expires: 19