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SCHEDULE A to Federal Subpoena to Doug Von Allmen

1.
DOCUMENT has the full meaning ascribed to it in Rule 34 of the Federal
Rules of Civil Procedure and shall include all originals of any nature whatsoever and all nonidentical copies thereof, whether different from the originals by reason of any notation made on
such copies or otherwise, including but not limited to all writings in any form, notes,
memoranda, manuals, reports, records, correspondence, drawings, graphs, charts, photographs,
phone records, data compilations of whatever nature (including those from which information
can be obtained or translated if necessary), audio tapes, electronic mail messages, and electronic
data (including any exchange of information between computers, all information stored in an
electronic form or computer database, and all forms and formats of storage).
2.
DRUMMOND includes, without limitation, Drummond Company, Inc. and
Drummond Ltd. The term also includes any officer, employee or agent of Drummond Company,
Inc. or Drummond Ltd.
3.
RELATED TO, RELATING TO, IN RELATION TO, REGARDING
and CONCERNING means in relation to, related to, consisting of, referring to, reflecting,
concerning, discussing, evidencing, commenting on, describing, constituting, supporting,
contradicting or having any logical or factual connection with the matter identified, in whole or
in part.
4.
WITNESS means any person claiming to have knowledge of Drummonds
alleged collaboration with paramilitaries and includes people of any nationality, regardless of
whether they have testified or plan to testify in any legal proceeding in either Colombia or the
United States. It is not limited to witnesses who are citizens or residents of Colombia.
5.
YOU means Doug Von Allmen. It also includes any agents or representatives
of Mr. Von Allmen and any corporation, company, partnership, trust, or other entity in which
Doug Von Allmen currently is or has ever been a shareholder, officer, partner, employee, trustee
or agent thereof.
6.
The term PAYMENTS, in connection with Requests referring to payments to
witnesses or paramilitaries, is meant to encompass in the broadest sense possible any
documents or communications that relate to witness payments or any form of assistance to
witnesses. This includes all documents relating to requests for payment, offers of payment,
refusals to pay, actual payments, contemplated payments, suggestions of payment, proposals of
payment, the logistics of effectuating payments, problems (legal, logistical, or otherwise) with
payments, amounts of payments, and rejections of offers of payments. Payments is not in any
way limited to security payments; rather it encompasses any payment or benefit (monetary or
non-monetary) whatsoever to any witness, whether contemplated or completed, regardless of
what any party contends was the purpose of the payment. Additionally, payments is not limited
to direct payments, but also includes any benefit or thing of value offered or provided to, or
requested by, witnesses lawyers, family members, contacts, intermediaries, friends,
girlfriends, paramours, associates or agents, or payments actually made to a security firm or
some other person or entity providing security.

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7.
LLANOS OIL means Llanos Oil Exploration Ltd., and any subsidiary thereof.
It also includes all successor and predecessor corporations or entities.
Instructions
1.
These requests are governed by Rules 26 and 45 of the Federal Rules of Civil
Procedure and any applicable law and Local Rule.
2.
You are requested to produce all DOCUMENTS and things described below to
Brett Barfield, c/o Holland & Knight, LLP, 701 Brickell Avenue, Suite 3300, Miami, FL
33131, on or before March 18, 2016 at 9:00 a.m.
3.
In answering and responding to these document requests, you are requested to
produce all DOCUMENTS that are in you possession, custody, or control, or that are in the
possession, custody, or control of your principals, agents, employees, attorneys, representatives,
insurers, and any other persons or entities, acting on your behalf.
4.
If any of the information or DOCUMENTS supplied in response to these
document requests does not come from your records, please specify the source of the
DOCUMENTS or information.
5.
If you refuse to produce any requested DOCUMENT under a claim of attorneyclient privilege, work product privilege, or any other privilege or protection, it is requested that
you submit for each DOCUMENT withheld a written statement that: specifies the privilege or
other asserted basis for withholding the DOCUMENT; summarizes the substance of the
DOCUMENT; identifies the person or entity who prepared the DOCUMENT and any persons or
entities to which the DOCUMENT was sent or disclosed; and specifies the date on which the
DOCUMENT was prepared, transmitted, and/or received.
6.
The time period covered by the document requests runs from January 1, 2009 to
the present. This is a continuing request. Any DOCUMENT obtained or located after the date
of production that would have been produced had it been available or had its existence been
known at that time should be produced immediately.
7.
If an objection is made to any numbered request, or any subpart thereof, state with
specificity all grounds for the objection.
8.
All responsive and potentially responsive documents and tangible things should
be preserved and maintained pending the outcome of this matter.

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Documents Requested
1. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any loan, credit facility, line of credit or other financing provided by
YOU to Conrad & Scherer, LLP, including any officer, partner, employee or agent
thereof. This includes, but is not limited to, the credit facility YOU provided to Conrad
& Scherer, LLP on or about March 19, 2010. This also includes, but is not limited to, all
final and draft versions of any such loan, credit facility, line of credit or other financing
agreement. This also includes DOCUMENTS RELATING TO who financing was
sought from, what payments were received, how the need for money was characterized,
what the terms of the financing were, and information on actual money advanced or
loaned or provided to prosecute litigation against DRUMMOND.
2. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any loan, credit facility, or line of credit provided by any other person or
entity to Conrad & Scherer, LLP, and/or any current or former officer, partner, employee
or agent thereof. This request includes, but is not limited to, any loan, credit facility or
line of credit provided to Conrad & Scherer, LLP, and/or any current or former officer,
partner, employee or agent thereof, by SunTrust Bank, Stillwater Asset-Backed Fund, LP,
and ViaLegal Funding II, LLC.
3. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any financial interest YOU currently hold or previously held in any
litigation filed by Conrad & Scherer, LLP, including any current or former officer,
partner, employee or agent thereof, against DRUMMOND or any other multinational
corporation alleging human rights abuses. This includes, but is not limited to, all
DOCUMENTS RELATING TO any contingency interest YOU have or had in any such
litigation.
4. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any financial interest held by any other person or entity in any litigation
filed by Conrad & Scherer, LLP, including any officer, partner, employee or agent
thereof, against DRUMMOND or any other multinational corporation alleging human
rights abuses. This includes, but is not limited to, all DOCUMENTS RELATING TO
contingency interests held by Ivan Otero Mendoza, Francisco Ramirez, Carlos Toro,
Jarley Maya Sanchez or other financiers.
5. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any refusal to provide funds for use in any litigation against
DRUMMOND or any other multinational corporation alleging human rights abuses,
regardless of whether said funds were provided.
6. All written agreements between YOU and any of the following persons or entities:
Terrence P. Collingsworth
William R. Scherer, Jr.

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Richard Drath
Conrad & Scherer, LLP
International Rights Advocates
Llanos Oil
Albert van Bilderbeek
Parker Waichman, LLP
International Labor Rights Fund
Albert L. Frevola, Jr.
This request is not limited to current, executed and/or binding agreements, but rather
includes all draft agreements, preliminary agreements, cancelled agreements, and/or
agreements which are no longer in effect.
7. All DOCUMENTS which evidence, RELATE or refer to any investigation, vetting
process, research, or due diligence performed by YOU, regarding any litigation alleging
human rights violations against DRUMMOND or any other multinational corporation in
which Conrad & Scherer, LLP was or is counsel of record.
8. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any litigation alleging human rights violations against DRUMMOND or
any other multinational corporation in which Conrad & Scherer, LLP was or is counsel of
record.
9. All DOCUMENTS, including email communications with any person or entity, which
reflect money provided or paid by YOU to Conrad & Scherer, LLP, or any current or
former officer, partner, employee or agent of Conrad & Scherer, LLP.
10. All DOCUMENTS, including email communications with any person or entity, which
reflect money provided or paid to YOU by Conrad & Scherer, LLP, or any current or
former officer, partner, employee or agent of Conrad & Scherer, LLP.
11. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the disclosure, nature or ethical/legal propriety of any financial interest
YOU currently hold or have held in any litigation alleging human rights violations
against DRUMMOND or any other multinational corporation in which Conrad &
Scherer, LLP was or is counsel of record.
12. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the purpose of any litigation expenses incurred by Conrad & Scherer,
LLP, including any current or former officer, partner, employee or agent thereof, in any

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litigation alleging human rights abuses against DRUMMOND or any other multinational
corporation.
13. All DOCUMENTS, including email communications with any person or entity,
RELATING TO DRUMMOND.
14. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any WITNESS or Colombian paramilitary, including without limitation
Edgar Ariel Cordoba Trujillo (57), Jairo Jesus Charris Castro (Charris), Libardo
Duarte (Duarte or Bam Bam), Jose Gelvez Albarracin (El Canoso), Javier Ernesto
Ochoa Quinonez (El Mecanico), Jhon Jairo Esquivel Cuadrado (El Tigre), Hernan de
Jesus Fontalvo Sanchez (Pajaro), Jose Aristides Peinado Martinez, Alcides Manuel
Mattos Tabares (Samario), Oscar David Perez Bertel (Yuca), Luis Leon, alias
Halcon, Edwin Guzman, Isnardo Ropero, Rafael Garcia, Jimmy Rubio, Raul Hasbun,
Jose Gregores Mangones Lugo (Carlos Tijeras), Oscar Jose Ospino Pacheco
(Tolemaida), Salvatore Mancuso, and Rodrigo Tovar Pupo (Jorge 40), Jairo Alfonso
Samper Cantillo (Lucho). This request includes communications with or RELATING
TO any relative, representative, lawyer, or agent of any WITNESS or Colombian
paramilitary.
15. All DOCUMENTS, including e-mail communications with any person or entity,
RELATING TO threats to or intimidation of any WITNESS.
16. All DOCUMENTS, including email communications with any person or entity,
RELATING TO (a) PAYMENTS to WITNESSES or Colombian paramilitaries, (b)
security for WITNESSES or Colombian paramilitaries, or (c) unethical, illegal, or
questionable conduct by Mr. Collingsworth or any other current or former officer,
partner, employee or agent of Conrad & Scherer, LLP.
17. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the employment (whether as employee or independent contractor) or
compensation of any WITNESS or Colombian paramilitary by Conrad & Scherer, LLP,
Terrence P. Collingsworth, IRAdvocates and/or International Labor Rights Fund.
18. All DOCUMENTS, including email communications with any person or entity,
RELATING TO LLANOS OIL, Albert van Bilderbeek, and/or Hendrik van Bilderbeek.
This request includes, but is not limited to, DOCUMENTS and email communications
RELATING TO PAYMENTS to any WITNESS or Colombian paramilitary or
Colombian lawyer by LLANOS OIL, Albert van Bilderbeek, and/or Hendrik van
Bilderbeek.
19. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the Asian Pacific Energy Corporation, or any principal, officer, agent or
employee thereof. This request includes, but is not limited to, DOCUMENTS and email
communications RELATING TO PAYMENTS to any WITNESS or Colombian
paramilitary or Colombian lawyer by the Asian Pacific Energy Corporation.

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20. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the withdrawal, transportation, or use of cash in Colombia by Mr.
Collingsworth, any current or former Conrad & Scherer, LLP officer, partner, employee
or agent, and/or any current or former Parker Waichman, LLP employee officer, partner,
employee or agent.
21. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any Colombian lawyer. This request includes, but is not limited to,
DOCUMENTS RELATING TO Ivan Otero Mendoza, Jarley Maya Sanchez, Carlos Toro
and Francisco Ramirez Cuellar.
22. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the disclosure or non-disclosure of PAYMENTS to WITNESSES in the
case captioned Claudia Balcero, et al. v. Drummond Company, Inc., et al., 2:09-cv-1041RDP (N.D. Ala.).
23. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any reports or updates provided by Mr. Collingsworth or any current or
former Conrad & Scherer, LLP officer, partner, employee or agent REGARDING the
case captioned Claudia Balcero, et al. v. Drummond Company, Inc., et al., 2:09-cv-1041RDP (N.D. Ala.).
24. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any reports or updates provided by Mr. Collingsworth, any current or
former Conrad & Scherer, LLP officer, partner, employee or agent, and/or any insurance
company REGARDING this litigation, which is captioned Drummond Company, Inc. v.
Terrence P. Collingsworth, et al., 2:11-cv-3695-RDP (N.D. Ala.).
25. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the disclosure or non-disclosure of PAYMENTS to WITNESSES in this
litigation, which is captioned Drummond Company, Inc. v. Terrence P. Collingsworth, et
al., 2:11-cv-3695-RDP (N.D. Ala.).
26. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any document to be filed or served in this litigation, which is captioned
Drummond Company, Inc. v. Terrence P. Collingsworth, et al., 2:11-cv-3695-RDP (N.D.
Ala.). This request includes, but is not limited to, communications REGARDING
pleadings, briefs, declarations, affidavits, or discovery responses, either in draft form
before they were filed or copies of the same once they had been filed or served.
27. All DOCUMENTS, including email communications with any person or entity,
REGARDING the case captioned Drummond Company, Inc., et al. v. Terrence P.
Collingsworth, et al., 2:15-cv-00506-RDP (N.D. Ala.).
28. All DOCUMENTS, including email communications with any person or entity,
RELATING to International Rights Advocates and/or International Labor Rights Fund.

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29. All DOCUMENTS, including email communications with any person or entity,
RELATING TO Parker Waichman, LLP, including any current or former officer, partner,
employee or agent thereof.
30. All DOCUMENTS, including email communications with any person or entity,
RELATING TO Andre Lasserre.
31. All DOCUMENTS, including email communications with any person or entity,
RELATING TO Lee Bialostok.
32. All DOCUMENTS, including email communications with any person or entity,
RELATING TO the retention of, scope of work by, or PAYMENT to any consultant by
Terrence P. Collingsworth, by any current or former Conrad & Scherer, LLP officer,
partner, employee or agent, and/or by any current or former Parker Waichman, LLP
officer, partner, employee or agent. This request includes, but is not limited to, all
DOCUMENTS and email communications RELATING TO the PAYMENT of $100,000
by Mr. Collingsworth to a consultant in approximately October 2011 who was retained
in litigation against DRUMMOND.
33. All DOCUMENTS, including email communications with any person or entity,
RELATING TO anything of value offered or provided to any Colombian governmental
official by YOU or any current or former officer, partner, employee or agent of Conrad &
Scherer, LLP.
34. All DOCUMENTS, including email communications with any person or entity,
RELATING TO Secure Pointe Partners International, LLC, or its principals, including
Joseph Carrera and Mark Carlson.
35. All DOCUMENTS, including email communications with any person or entity,
RELATING TO William R. (Billy) Scherer, IIIs and/or Richard Draths respective
departures from the firm of Conrad & Scherer, LLP. This request includes, but is not
limited to, all DOCUMENTS and communications RELATING TO any final or draft
indemnity agreements, nondisclosure agreements, resignation letters, and/or severance
packages.
36. All photographs of YOU and any current or former partner, officer, employee or agent of
Conrad & Scherer, LLP. This request includes, but is not limited to, all photographs of
YOU and William R. (Bill) Scherer, Jr.
37. All DOCUMENTS, including email communications with any person or entity,
RELATING TO any business ventures involving William R. (Bill) Scherer, Jr. This
includes, but is not limited to, all DOCUMENTS RELATING TO Dever, Inc.

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