Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 1 of 14

EXHIBIT B
 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 2 of 14

U.S. SECURITIES AND EXCHANGE COMMISSION

ATLANTA REGIONAL OFFICE
3475 Lenox Road, N.E . Suite 500
Atlanta, GA 30326-1232
.

PENNY J. MORGAN D irect Line . (404) 842-7639

Senior Counsel Facsimile (404) 842-7633

July 2 7, 2010

DUPLICATE ORIGINAL DUPLICAT E ORIGINAL

VIA OVERNIGHT MAIL VIA OVERNIGHT MAIL

Anthony K . Welsh, President Anthony K . Welch, President

eHydrogen Solutions, Inc . eHydrogen Solutions, Inc.
c/o Corporate Service Center, Inc . 1231 State Road 30
Registered Agent Etta, MS 38627
5190 Neil Road, Suite 430
Reno, NV 89502

Re: In the Matter of eHydrogen Solutions, Inc . (A-03251)

Dear Mr. Welsh:

The staff of the Securities and Exchange Commission (the "Commission") is conducting
a formal, non-public investigation in the matter identified above . The enclosed subpoena has
been issued to you as part of this investigation . The subpoena requires you to give us documents
and provide sworn testimony .

Please read the subpoena and this letter carefully . This letter answers some questions you
may have about the subpoena You should also read the enclosed SEC Form 1662 . You must
comply with the subpoena. You may be subject to a fine and/or imprisonment if you do not .

Producing Doc ume n ts

"at materials do I have to produce?

The subpoena requires you to give us the documents described in the attachment to the
subpoena . You must provide these documents by August 11, 2010 . The attachment to the
subpoena defines some terms (such as "document"} before listing what you must provide .

Please note that if copies of a document differ in any way, they are considered separate
documents and you must send each one . For example, if you have two copies of the same letter,
but only one of them has handwritten notes on it, you must send both the clean copy and the one
with notes .
 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 3 of 14
Anthony K. Welch, President
eHydrogen Solutions, Inc .
July 27, 2010
Page 2

If you prefer, you may send us photocopies of the originals . The Commission cannot
reimburse you for the copying costs . The copies must be identical to the originals, including
even faint marks or print . If you choose to send copies, you must keep the originals in a safe
place. The staff will accept the copies for now, but may require you to produce the originals
later.

If you do send us photocopies, please put an identifying notation on each page of each
document to indicate that it was produced by you, and number the pages of all the documents
submitted . (For example, if Jane Doe sends documents to the staff, she may number the pages
JD-1, JD-2, JD-3, etc., in a blank corner of the documents .) Please make sure the notation and
number do not conceal any writing or marking on the document . If you send us originals, please
do not add any identifying notations .

We request that you, on a voluntary basis, submit documents in paper format as

well as electron ic format if available, preferably using a Concordance database or Concordance
loadable file with optical character recognit ion (OCR) text and including any metadata assoc iated
with the document . Please comply with the attached SEC Data Delivery Standards .

Do I need to send anything else?

You should enclose a list briefly describing each item you send . The list should state
which paragraph(s) in the subpoena attachment each item responds to .

Please include a cover letter stating whether you believe you have met your obligations
under the subpoena by searching carefully and thoroughly for everything called for by the
subpoena, and sending it all to us.

What rf t do not send everything described in the attachment to the subpoena?

The subpoena requires you to send all the materials described in it . If, for any reason --
including a claim of attorney-client privilege -- you do not produce something called for b y the
subpoena, you should submit a list of what you are not producing. The list should describe each
item separately, noting :

• its author(s) ;
• its date;
• its subject matter;
• the name of the person who has the item now, or the last person known to have it;
• the names of everyone who ever had the item or a copy of it, and the names of everyone
who was told the item's contents ; and
• the reason you did not produce the item .
 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 4 of 14
Anthony K . Welch, President
eHydrogen Solutions, Inc .
July 27, 2010
Page 3

If you withhold anything on the basis of a claim of attorney-client privilege or attorney

work product protection, you should also identify the attorney and client involved .

Where should I send the materials?

Please send the materials to :

Penny J . Morgan, Senior Counsel

U.S. Securities and Exchange Commission
Atlanta Regional Office
3475 Lenox Road, N .E ., Suite 500
Atlanta, GA 30326-1232

Testifying

Where and when do I testify?

The subpoena requires you to come to the Commiss ion's offices at 3475 Lenox Road,
N .E., Suite 500, Atlanta, GA 30326 on August 11, 2010 at 9:00 a.m., to testify under oath in
the 'matter identified on the subpoena .

Other Important Information

May I have a lawyer help me respond to the subpoena?

Yes . You have the right to consult with and be represented by your own lawyer in this
matter . We cannot give you legal advice .

What will the Commission do with the materials I send?

The enclosed SEC Form 1662 includes a List of Routine Uses of information provided to
the Commission . This form has other important information for you . Please read it carefully .

Has the Commission determined that anyone has done anything wrong?

This investigation is a non-public, fact-findi ng inquiry. We are trying to determine

whether there have been any violat ions of the federal securities laws . The investigation and the
subpoena do not mean that we have concluded that you or anyone else has broken the law . Also,
the investigation does not mean that we have a negative opinion of any person, entity or security .

Important Policy Concerning Settlements

Please note that, in any matter in which enforcement action is ultimately deemed to be
warranted, the Division of Enforcement will not recommend any settlement to the Commission
 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 5 of 14
Anthony K . Welch, President
eHydrogen Solutions, Inc.
July 27, 2010
Page 4

unless the party wishing to settle certifies, under penalty of perjury, that all documents responsive
to Commission subpoenas and formal and informal document requests in this matter have been
produced .

I have read this letter, the subpoena, and the SEC Form 1662, but I still have questions . What
should I do?

If you have any other questions, please call me at (404) 842-7639 . If you are represented
by a lawyer, you should have your lawyer contact me.

Penny J. Morgan
Senior Counsel

Enclosures : Subpoena (with attachment)

SEC Form 1662
SEC Data Delivery Standards
 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 6 of 14

SUBPOENA

UNITED STATES OF A M ERICA

SECURITIES AND EXCHANGE COMMISSION
In the Matter of eHvdrogen Solutions, Inc . A-03251

To: Anthony K. Welsh, President Anthony K. Welsh, President

eHydrogen Solutions, Inc. eHydrogen Solutions, Inc.
c/o Corporate Service Center, Inc . 1231 State Road 30
Registered Agent Etta, MS 38627
5190 Neil Road, Suite 430
Reno, NV 89502

X YOU MUST PRODUCE everything specified in the Attachment to this subpoena to officers of
the Securities and Exchange Commission, at the place, date and time specified below .
3475 L enox Road, N .E., S uite 500 , Atlanta, GA, 30326, August 11 , 2010 at 9: 00 a.m.

X Y OU MUST TEST IFY before officers of the Securities and Exchange Commission, at the
place, date and time specified below .
3475 Lenox Road, N.E ., Suite 500, A tlanta, GA 3 0326, August 11, 2010 at 9: 00 a.m.

FED W REQUIRES YOU TO COMPLY WITH THIS SUBPOENA .

to comply may subject you to a fine and/or imprisonment.

By: Date: July 27, 2010

Pep fy J. Morgan
-senior Counsel
U.S . Securities and Exchange Commission
Atlanta Regional Office
3475 Lenox Road, N .E ., Suite 1000
Atlanta, GA 30326-1232

I am an officer of the Securities and Exchange Commission authorized to issue subpoenas in this
matter . The Securities and Exchange Commission has issued a formal order authorizing this
investigation under Section 20(a) of the Securities Act of 1 933 and Section 21(a) of the Securities
Exchange Act of 1934 .

NOT I CE TO W I TNESS : If you cl aim a witness fee or mi leage, submit this subpoena with the c laim voucher.
 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 7 of 14

SECURITIES AND EXCHANGE COMMISSION

SUBPOENA ATTACHMENT

eHydrogen Solut ions, Inc . (A-0325. 1)

L INSTRUCTIONS AND DEFINITIONS

This subpoena calls for the production of documents, in accordance with the following
general requirements:

A. DUPLICATES

Unless otherwise specified, each request for documents or other materials calls for the
production of the original and all copies and drafts of the same document . However, if two
documents or other items are exact duplicates, you are required to produce only one of them .
Documents that contain written comments, notes, corrections or to which have been attached or
appended additional material are not to be construed as exact duplicates and, therefore, must be
produced . Similarly, documents that are preceded by facsimile transmission cover sheets or
which contain facsimile confirmations of receipt are not to be construed as exact duplicates .

B . POSSESSION, CUSTODY OR CONTROL

You are required to submit all subpoenaed items that are in your possession or in your
custody, or under your control . Items under your control or in your custody, but not in your
immediate possession, are required to be obtained and submitted by you .

C. DEFINITIONS

The following definitions apply to this attachment :

1 . "Document" means ail preserved matter of any kind and however created,
produced, and stored, whether it be manually, mechanically, electronically, or otherwise, in an
original form or a true copy of the same, together with each and every nonconforming version
and copy, in your actual or constructive possession, custody, or control . The term "document"
includes, but is not limited to hard disk, diskette, CD-ROM, DVD or other disc, . microfilm,
microfiche, magnetic tape, videotape, audiotape, film, or any other electronic media, magnetic
media, or laser media;

2. "Relates" and "Related" means regarding, involving, or concerning, such

that it connects one to another to any degree, however remote ;

3 . "And" and "or" mean both connectors collectively . Therefore, you should
interpret each as "and/or" ;

4. "Communications" mean any transmission of information ; and

 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 8 of 14

5 . eHydrogen or "you" means eHydrogen Solutions, Inc . as well as any

holding companies, parents, predecessors, successors, subsidiaries, related corporations,
partnerships, professional associations, affiliates, principals, officers, directors, partners,
associates, employees, agents, independent contractors, persons acting on its behalf, and any
aliases, code names, or trade or business names used by any of the foregoing, including, but in no
way limited to eHydrogen .

D. RULES OF CONSTRUCTION

The following rules of construction apply to this attachment :

1 . the terms "all" and "each" shall be construed as all and each ;

2. the connectives "and" and "or" shall be construed either disjunctively or

conjunctively as necessary to bring within the scope of the attachment all responses that might
otherwise be construed to be outside of its scope ; and

3 . the use of the singular form of any word includes the plural and vice versa.

IL DOCUMENTS TO BE PRODUCED

Produce the following original documents that are in your possession or in your custody,
or under your control, for the period January 1, 201 0, through the date of your response (the
"Relevant Period"), unless a different time period is specified below :

A . Producee the following documents for eHydrogen Solutions, Inc .

("eHydrogen"), from the date of its incorporation through the date of your response : (1) articles
of incorporation and by-laws, including amendments ; and (2) all organizational, shareholder, and
board of director minutes and consents, and any other corporate resolutions ;

B . Produce documents sufficient to identify the names, addresses, telephone

numbers, titles, and dates of service of the officers and directors of eHydrogen, including officers
and directors of any subsidiaries of eHydrogen ;

C . Produce all domestic and foreign accounts statements in the name of or for the
benefit of eHydrogen, including bank, brokerage, and credit card account statements, and
produce all checks (front and back), wire transfer confirmations, and other similar documents
evidencing deposits and withdrawals from any such accounts in any individual amount of $500
or more ;

D. To the extent not otherwise produced pursuant to Subparagraph II .C . above,

produce all checks (front and back), payroll stubs, IRS Forms W-2 and 1099, stock certificates
(front and back), and other documents evidencing, relating to, or pertaining to any cash, stock, or
other payments made in connection with : (1) any eHydrogen shareholder, director, officer, or
employee; (2) any person involved in any marketing, investor awareness, or other promotional
activities relating to eHydrogen ; and (3) any other person who received total payments with a
value of $5,000 or more in connection with eHydrogen ;

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 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 9 of 14

E. Produce documents sufficient to identify the name, address, telephone number,

and period of service of each stock transfer agent used by eHydrogen, and all e-mails, letters,
faxes, transfer agent reports, shareholder listings, and other documents relating to any
communications with such transfer agent during the Relevant Period ;

F. Produce all documents evidencing, relating to, or pertaining to any securities

(including common stock, preferred stock, and options) issued by eHydrogen during the Relevant
Period, whether through public or private offerings, and including all stock certificates (front and
back), related legal opinions, and private placement memoranda ;

G. Produce all documents evidencing, relating to, or pertaining to movements in the

price per share or trading volume of eHydrogen stock ;

H. Produce the following documents w ith respect to any actual , propos ed, or
contemplated busines s transactions or securities transactions relating to eHydrogen:

1 . All letters of intent and contracts executed by or for the benefit of

eHydrogen, and all contracts in effect with respect to eHydrogen, including employment
agreements, assignments, leases, and collateral security agreements, and all agreements relating
to any officers, directors, shareholders, creditors, or employees of eHydrogen ;

2. All promissory notes, stock warrants, stock certificates (front and back),
checks (front and back), wire transfer confirmations, and other documents relating to any loans or
other financing activities involving eHydrogen ;

3. All patents, trademarks, and licensing agreements maintained by

eHydrogen, including documents identifying the dates such permits and licenses were obtained ;

4 . All appraisals, valuations, and deeds relating to any assets held by

eHydrogen ;

5 . All revenue projections relating to eHydrogen, including documents that

support such projections and documents sufficient to identify who such revenue projections were
delivered to and the dates of such delivery;

6. All executive summaries, business plans, bonus plans, stock option plans,
and other summaries and plans relating to eHydrogen, including documents sufficient to identify
who such documents were delivered to and the dates of such delivery ; and

7. All deeds, titles, certificates, or other similar documents that evidence

eHydrogen's ownership of every item of real property and personal property with an estimated
value of $3,000 or more ;

I . Produce all documents posted by or on behalf of eHydrogen on the Internet or sent

via electronic mail, including all documents posted on eHydrogen's corporate website, and
produce documents sufficient to identify all Internet service providers used by eHydrogen ;

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 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 10 of 14

J. Produce all documents evidencing, relating to, or pertaining to any public trading
in the securities of eHydrogen by any officers, directors, employees, or shareholders of
eHydrogen, including all documents relating to any blackout periods or other restrictions on
public trading in eHydrogen securities, all account statements and other documents relating to
public trading in such securities, and all forms filed with the Securities and Exchange
Commission in connection with any public trading in the securities of eHydrogen ;

K. Produce all press releases, newsletters, investor and prospect ive investor alerts,
and other promotional documents dissem inated by or on behalf of eHydrogen (the "Investor
Communications"), preferably_in chronological order, including documents supporting the basis
for any factual assertions and projections (including revenue projections, bus iness op erations
projecti ons, and stock price projections) in such Investor Communi cations, and documents
identifying when and to whom such Investor Communications were dissem inated . In furtherance
and not in lim i tation of the foregoing, produce all documents supporting your basis for mak ing
the following assertions in the following Investor Communicat ions purportedly issued by
eHydrogen, and in addition produce such other documents as maybe specified below :

Press release issued on or about February 2, 2010 :

a. "eHydrogen Solutions, Inc . (eHS) is pleased to announce the
completion of bench testing and field trial relating to the adaptation
of its Hydrogen Enhancement Technology for the Light Truck
aftermarket . . . [t]he Light Truck aftermarket represents
178,933,000 vehicles worldwide and a projected 0 .8% market
share would represent $4,800,000,000 in revenue .": Provide
documents evidencing the bench testing and field trial conducted
and documents evidencing your basis for this revenue projection .

2 . Press release issued on or about February 4, 2010 :

a. "eHydrogen Solutions, inc . (eHS) (PINKSHEETS : EHYD), is
pleased to announce it has completed the necessary agreements,
which firm up its previously announced Letter of Intent (LOI)
which calls for Joint Development adaptation of the proprietary
eHs Hydrogen on Demand technology to the Home Heating
Market .": Produce all documents evidencing the completion of
these agreements between eHydrogen and outside parties . Also
produce documents identifying the parties to these agreements,
including, but not limited to, the names of the identified persons
(including, but not limited to, officers and senior management of
any identified organizations), the locations and/or principal places
of business of the parties, and the nature and duration of the
relationship between these parties and eHydrogen .

3 . Press release issued on or about March 2, 2010:

a. "eHydrogen Solutions, Inc . (eHS) (PINKSHEETS : EHYD)
announced today the completion of an Intellectual Property (IP)
Transfer Agreement substantially expanding its core On Demand

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Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 11 of 14

Hydrogen Production (ODHP) technologies . In addition to its

advanced electrolysis technologies, the Company has now acquired
new leading edge ODHP technologies, including real-time
hydrogen production utilizing a combination of Reactive Metals,
nanotechnology and plasma reformation . . . [t]he transaction is
valued at $2,000,000 purchased with a combination of Preferred
Stock and minority debt" : Produce all documents evidencing the
acquisition of intellectual property and evidencing your basis for
the valuation of the acquired intellectual property at $2,000,000 .
Also produce documents identifying the parties to this agreement,
including, but not limited to, the names of the identified persons
(including, but not limited to, officers and senior management of
any identified organizations), the locations and/or principal places
of business of the parties, and the nature and duration of the
relationship between these parties and eHydrogen .

4 . Press release issued on or about March 1 _1s 20I0 :

a. "eHydrogen Solutions, Inc . (eHs) (PINKSHEETS : EHYD) cites
Energy Secretary Steven Chu's March 2, 2010 funding
announcement as validation of the Company's recent strategy
announcements and expects its technology acquisition and recent
advances to accelerate the research and development cycle of its
Distributed Energy Initiatives .": Produce documents supporting
eHydrogen's expectation that the Department of Energy's funding
of ARPA-E would support eHydrogen's research .

5. Press release issued on or about March 19, 2010 :

a. " eHydrogen Solutions, Inc . (eHS), announced today it increased
its revenue outlook for its Residential Distributed Energy and
Combined Heating and Power (CHP) development projects based
on Pike Research's authoritative CleanTech Update, published
March 12, 2010 .": Produce documents detailing eHydrogen
solutions' revenue projections as of March 19, 2010 and
evidencing the basis for your increased revenue projections . Also
produce documents evidencing the revenue actually earned
between March 19, 2010 and the date of your response .

6 . Press release issued on or about May 20, 2010 :

a. "The Company has assembled experienced cross-functional teams
to guide each innovation acquisition, technological adaptation and
system integration through the required steps to successful
commercialization .": Produce documents identifying the members
of the cross-functional teams and the periods of service of such
teams and members of such teams .

b. "The Company believes its acqu i sition and growth-oriented

business plan w ill provide stockholders with consistent equity

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 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 12 of 14

growth and access to the multi-billion dollar alternative energy

industry through its licensing and distribution of hydrogen-
powered energy systems and solutions.": Produce documents
evidencing your basis for this equity growth projection . Also
produce documents detailing actual equity activity (growth or
otherwise) between May 20, 2010 and the date of your response.

7 . Press release issued on or about May 25, 2D10 :

a. "eHydrogen Solutions, Inc. (OTCPK: EHYD) announced today the
completion of an Intellectual Property (IP) Transfer Agreement that
include [sic] core Photoelectrolysis and artificial Photosynthesis
technologies for the energy efficient and environmentally friendly
on-demand hydrogen production .": Produce documents evidencing
the purchase and/or transfer of the intellectual property . Also
produce documents identifying the parties to this agreement,
including, but not limited to, the names of the identified persons
(including, but not limited to, officers and senior management of
any identified organizations), the locations and/or principal places
of business of the parties, and the nature and duration of the
relationship between these parties and eHydrogen .

b. "The transaction is valued at $1,500,000 purchased through an

equity-building issuance of Preferred Stock and will create no debt
for the Company.": Produce documents evidencing your basis for
the valuation of the acquired technologies at $1,500,000 .

Press, release issued on or about June 3, 2010 :

a. "Pursuant to the Company's policy of investor transparency, the
Company maintains regular public disclosures and filings with the
OTC Disclosure Service . Further disclosures will be filed detailing
the company's ongoing activities .": Produce all disclosures and
filings made with the OTC Disclosure Service from June 3, 2010
to the date of your response .

b. "The Company's portfolio possesses of core proprietary On

Demand Hydrogen Production (ODHP) technologies that have a
preliminary market valuation at least tenfold its acquisition
valuationn of $6,736,000 .": Produce documents evidencing your
basis for the valuation of these technologies at this amount .

9. Press release issued on or about June 4, 201 0:

a . "eHydrogen Solutions, Inc . ~(PINKSHEETS : EHYD) announced
today the completion of an additional Intellectual Property (IP)
Transfer Agreement that includes core Reactive Metal Hydrogen
Production technologies that economically and environmentally
produce hydrogen on demand, utilizing only water and reactive
~~ metal alloys including aluminium [sic] or magnesium . . .the

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Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 13 of 14

transaction is valued at $1,775,000, purchased through an equity-

building issuance of Preferred Stock and will create no debt for the
Company." Produce documents evidencing the transfer of the
intellectual property . Also produce documents identifying the
parties to this agreement, including, but not limited to, the names
of the identified persons (including, but not limited to, officers and
senior management of any identified organizations), the locations
and/or principal places of business of the parties, and the nature
and duration of the relationship between these parties and
eHydrogen.

10 . Press release issued on or about June 14 , 2010 :

a. "eHydrogen Solut ions , Inc . (eHS) reports $3 .6 million income
earned today upon the completion of the Development phase o f the
Joint Development Agreement for the US Home Heating and
Power Market .": Produce documents evidencing the receipt of .
$3.6 million in income, including, but not limited to , documents
evidencing that thi s amount was earned and realizable by
eHydrogen as of June 14, 2010 and documents evidencing receipt
of this amount between June 14, 2010 and the date of your
response .

F1. Press release issued on or about June 15, 2010:

a. "The Company has started the design and integrat i on of its core
On-Demand Hydrogen Production (ODHP) technologies with HFC
and HICE applications . . . [p]hase II of this project will be the
announcement of a -fully functioning water-fueled vehicle,
converted from gasol ine, to use hydrogen as the combustion
medium .": Produce documents evidenci ng that eHydrogen
engaged in the design of such technologies between June 15, 2010
and the date of your response .

12 . Press release issued on or about July 6, 201 0:

a. "eHydrogen Solutions, Inc . {PINKSHEETS : EHYD) announced
today the signing of a $12,000,000 Technology License Agreement
with VX Marketing Group (VXMG) . The Agreement calls for
VXMG to develop and distribute a range of products and solutions
utilizing the Company's H-Solaris technologies . . . VXMG is
obliged under the terms of the agreement to enhance and continue
development, establish international distribution, build sales
networks with revenue minimums, and meet minimum royalty
payments.": Produce documents evidencing this agreement,
including, but not limited to, the Agreement itself. Also produce
documents identifying VX Marketing Group, any persons
associated with VX Marketing Group, VX Marketing Group's
principal place of business, and the duration of VX Marketing
Group's relationship with eHydrogen . re

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 Case 1:11-mi-00012-TWT Document 1-2 Filed 02/10/11 Page 14 of 14

L. Produce all federal and state tax returns filed by or on behalf of eHydrogen, with
all schedules and related filed materials, for eHydrogen's tax years 2009 through 2010 ;

M. Produce documents sufficient to identify the names, addresses, telephone

numbers, and periods of service of all accountants, independent auditors, and attorneys used by
eHydrogen for the purpose of obtaining accounting services or legal advice, and all engagement
letters for any such accountants, independent auditors, and attorneys ;

N. Produce documents sufficient to identify every bankruptcy and every criminal

conviction of any current or former officer of eHydrogen who served during the Relevant Period,
including documents sufficient to identify the date of the bankruptcy or criminal conviction and
any resolution of the bankruptcy or criminal conviction (i .e., Chapter 7 bankruptcy discharge,
Chapter 11 bankruptcy reorganization, criminal restitution order, prison sentence, etc .) ;

O . Produce all financial statements (audited, unaudited, and pro forma), balance
sheets, profit-and-loss statements, and auditor's reports of eHydrogen (including each of its
subsidiaries) during the Relevant Period ;

P . Produce all documents evidencing, relating to, or pertaining to any domestic or

foreign threatened or pending litigation or regulatory actions involving eHydrogen, and any
investor complaints regarding eHydrogen ; and

Q. Produce all e-mails sent to or from any officer, director, shareholder, or creditor of
eHydrogen for the period January 1, 201 0, through the present .

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