SCHEDULE

In accordance with the attached De?nitions and Instructions, you, Igor Fruman, are hereby
required to produce, for the period of January 20, 2017, to the present, all documents and
communications in your custody, possession, or control referring or relating to:

1.

Paul Manafort, Hunter Biden, Mykola Zlochevsky, Burisma Holdings Ltd.-
(?Burisma?), or any employee or agent of Burisma;

Efforts, including but not limited to those by you, Rudolph (?Rudy?) Giuliani,
Lev Parnas, Vitaly Pruss, Semyon Kislin, Joseph diGenova, or Victoria
Toensing, to induce, compel, petition, press, solicit, suggest, or otherwise pressure
current or former Ukrainian government of?cials, politicians, or any persons or
entities associated with or acting in any capacity as a representative, agent, or
proxy for any such individuals, to investigate matters related to Burisma, or any
US. persons or entities, including but not limited to Paul Manafort, Hunter Biden,
Joseph Biden, the Democratic National Committee, or Hillary Clinton, as well as

. any responses by current or former Ukrainian government of?cials, politicians, or

other persons of in?uence, or any persons or entities associated with or acting in
any capacity as a representative, agent, or proxy for any such individuals,
concerning the same;

Serhiy Leshchenko, Igor Kolomoisky, or any persons or entities associated with
or acting in any capacity as a representative, agent, or proxy for these individuals,
including but not limited to efforts to induce, compel, petition, press, solicit,
Sliggest, or otherwise pressure current or former Ukrainian of?cials, politicians, or
any persons or entities associated with or acting in any capacity as a
representative, agent, or proxy for any such individuals, to investigate matters
related to Leshchenko and Kolomoisky, and any documents, communications, or
meetings with former ProseCutor General Yuri Lutsenko related to these matters;

The White House, President Donald Trump, Attorney General William Barr,
Donald Trump Jr., Rudolph (?Rudy?) Giuliani, former Ambassador Kurt Volker,
State Department Counselor T. Ulrich Brechbuhl, State Department Deputy
Assistant Secretary George Kent, Assistant Secretary of State for European
Affairs A. Wess Mitchell, or anyone in or associated with the Trump
Administration;

Former Congressman Pete Sessions, including but not limited to a meeting in or
about May 2018;

Former United States Ambassador to Ukraine Marie ?Masha? Yovanovitch,
including but not limited to the former Ambassador?s recall or dismissal;

Petro Poroshenko, Zelensky, Nazar Kholodnitsky, Andriy
Telizhenko, Andriy Yermak, Yuri Lutsenko, Serhiy She?r, Ivan Bakanov, Ruslan
Ryaboshapka, Andriy Bogdan, Kostiantyn Kulyk, Victor Shokin, Lena (?Olena?)
Zerkal, Andriy Favorov, Gennady Bogolyubov, or anyone who is or has been

10.

associated with Ukrainian law enforcement or anti-corruption organizations or
entities, including but not limited to the of?ce of the Prosecutor General, the
Special Anti-Corruption Prosecutor?s Of?ce, or the National Anti-Corruption
Bureau of Ukraine 

United States foreign assistance to Ukraine, including but not limited to the
Ukraine Security Assistance Initiative and any efforts to withhold, delay, or
release security assistance to Ukraine;

Monies, funds, gifts, contributions, donations, or offers of anything of value made 
directly or indirectly to US. political campaigns, candidates, parties, political
action committees (PACs) and super PACs?including but not limited to America
First Action, Inc.??by any foreign individuals or entities of any type 
government, business, organization, etc.), individuals or entities on the Of?ce of
Foreign Assets Control?s (OF AC) list of Specially Designated Nationals and
Blocked Persons (SDNs) or Sectoral Sanctions Identi?cations List, or any persons
or entities associated with or acting in any capacity as a representative, agent, or

- proxy for any such individuals or entities; and

The source of any monies, funds, gifts, contributions, donations, or offers of
anything of value made by Global Energy Producers, LLC or Aaron Investments
I, LLC to America First Action, Inc., including but not limited to a $325,0'0
donation in May 2018. 

You are also required to produce:

11.

Any and all documents supplied in response to any subpoena, search warrant,
seizure warrant, summons, or other legal writ, notice, investigation or order or
request forinformation, property, or material, made by any US. federal or state
agency.