1 DICKINSON WRIGHT PLLC Brooks T. Westergard 2 Nevada Bar No. 14300 Email: [email protected] 3 100 West Liberty Street, Suite 940 4 Reno, Nevada 89501-1991 Tel: 775-343-7500 5 Fax: 844-670-6009 6 SIMMS SHOWERS LLP 7 J.Stephen Simms (pro hac vice) Email: [email protected] 8 Gary C. Murphy (pro hac vice) Email: [email protected] 9 201 International Circle, Suite 230 10 Baltimore, Maryland 21030 Telephone: 410-783-5795 11 Attorneys for Plaintiff Lauritzen Bulkers A/S 12 13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA 14 15 Lauritzen Bulkers A/S, 16 Plaintiff, Civil Action No.: 3:25-cv-00280-MMD-CLB 17 v. ORDER GRANTING JOINT 18 STIPULATION, REQUEST FOR STAY Twin Pines Minerals, LLC, PENDING OUTCOME OF LONDON 19 ARBITRATION Defendant, 20 IN ADMIRALTY, Rule 9(h) and 21 U S Mine Corp, 22 Garnishee. 23 24 WHEREAS Plaintiff Lauritzen Bulkers A/S (“Lauritzen”) filed its Verified Complaint 25 (Dkt. 1) and Motion and Supporting Memorandum for Order Authorizing Issue of Process of 26 Marine Attachment and Writ of Garnishment (Dkt. 3) on June 4, 2025. Lauritzen’s complaint 27 28 1 generally seeks security for its ongoing London arbitration against Defendant Twin Pines 2 Minerals, LLC (“TPM”). 3 WHEREAS on June 5, 2025, this Court Ordered Clerk of the Court (Dkt. 10) to issue 4 pursuant to Supplemental Rule B, the requested writs of maritime attachment and garnishment 5 requested by Lauritzen. 6 7 WHEREAS on June 5, 2025, the Clerk issue a writ (Dkt. 11) to Garnishee U S Mine 8 Corp (“US Mine”). 9 WHEREAS on August 11, 2025, US Mine filed an answer to Lauritzen’s Verified 10 Complaint. Dkt. 20. US Mine admitted in its answer that it entered an “Asset Purchase 11 Agreement with Defendant ‘related to TPM’s Ione, California operations and plant.’” 12 13 WHEREAS on September 5, 2025, US Mine provided supplemental responses to 14 Lauritzen’s Request for Interrogatories served pursuant to Supplemental Rule B. Exhibit 1 15 hereto. 16 WHEREAS in US Mine’s September 5, 2025, Supplemental Response to Lauritzen’s 17 Interrogatory Number 11, (Exhibit 1) US Mine admits that it entered into an Asset Purchase 18 19 Agreement (“APA”) with TPM on December 31, 2024. US Mine also admits that it did not make 20 the May 3, 2024 installment payment to TPM provided for under the APA. 21 WHEREAS Lauritzen and US Mine dispute whether the May 3, 2024 installment 22 payment to TPM provided for under the APA is attached and/or subject to attachment. 23 Specifically, Lauritzen contends that the May 3, 2024 installment payment to TPM provided for 24 25 under the APA is property of TPM and is attached pursuant to the writ (Dkt. 11). US Mine 26 contends that TPM is in breach of the APA, and that US Mine’s obligation to make the May 3, 27 2024 installment payment never arose and/or was excused. As such, US Mine does not owe 28 1 TPM the May 3, 2024, installment payment under the APA, and there is no account payable 2 from US Mine to TPM to attach. 3 WHEREAS, there are a few items that US Mine purchased pursuant to the APA that 4 TPM misrepresented would be provided without debt. TPM failed to transfer title to these items 5 to US Mine. Subsequently, US Mine learned there is debt outstanding on these items and US 6 7 Mine is paying the third-party debt to prevent repossession. These payments are part of US 8 Mine’s damages from TPM’s conduct and do not reflect any account payable from US Mine to 9 TPM. 10 IT IS HEREBY STIPULATED AND AGREED, by Lauritzen and US Mine, 11 through their undersigned counsel, and subject to the approval of the Court, that: 12 13 1. US Mine will hold the May 3, 2024 installment payment provided for in the APA in 14 its hands subject to the further order of this Court. 15 2. This matter will be stayed pending final resolution of the London arbitration 16 proceedings between Lauritzen and TPM, defined as the tribunal issuing a Final 17 Award, which fully disposes of all claims, counterclaims, and issues submitted to 18 19 arbitration, or settlement between Lauritzen and TPM. 20 3. Lauritzen will provide a status report on the London arbitration every 180 days 21 beginning on February 27, 2026 to the Court and counsel for US Mine. 22 4. Lauritzen will notify this Court and counsel for US Mine within (30) days of Final 23 Resolution of the London arbitration or if Lauritzen and TPM enter into a settlement 24 25 agreement. 26 27 28 1 5. Upon lifting of the stay, Lauritzen and US Mine will seek court intervention 2 concerning the dispute between Lauritzen and US Mine related to that May 3, 2024 3 installment payment to TPM provided for under the APA, if necessary. 4 6. By entering this stipulation, Lauritzen and US Mine do not waive any defenses, 5 rights, claims, or otherwise, and expressly reserve all rights. 6 7 Dated: October 7, 2025 8 GUNERSON LAW FIRM DICKINSON WRIGHT PLLC 9 10 /s/ Courtney G. Sweet /s/ Brooks T. Westergard Courtney G. Sweet, Esq. Brooks T. Westergard 11 Nevada State Bar No. 10775 Nevada Bar No. 14300 3895 Warren Way Email: [email protected] 12 Reno, Nevada 89509 100 West Liberty Street, Suite 940 13 Telephone: 775.829.1222 Reno, Nevada 89501-1991 [email protected] Tel: 775-343-7500 14 Fax: 844-670-6009 SCHILLING LAW GROUP 15 Charity Gilbreth, Esq. (pro hac vice) 16 Linda Schilling, Esq. (pro have vice) SIMMS SHOWERS LLP 17 /s/ J. Stephen Simms 1100 Newport Center Drive J.Stephen Simms (pro hac vice) 18 Suite 250 Gary C. Murphy (pro hac vice) 19 Newport Beach, California 92660 201 International Circle, Suite 230 Telephone: 949.760.6120 Baltimore, Maryland 21030 20 [email protected] Telephone: 410-783-5795 [email protected] [email protected] 21 [email protected] 22 Attorneys for U S Mine Corp Attorneys for Plaintiff Lauritzen Bulkers A/S 23 24 25 26 27 28 1 || IT SO ORDERED this 8th day of October, 2025. ALR □ ; United States District Judge 5 7 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

_5-

1 CERTIFICATE OF SERVICE 2 I certify that I am an employee of Dickinson Wright PLLC and on October 7, 2025, I 3 caused a true and correct copy of the foregoing JOINT STIPULATION, REQUEST FOR 4 STAY PENDING OUTCOME OF LONDON ARBITRATION, AND [PROPOSED] 5 ORDER to be served by electronic mail through the Court’s CM/ECF filing system upon 6 counsel of record, addressed as follows: 7 GUNDERSON LAW FIRM 8 Courtney G. Sweet, Esq. 3895 Warren Way 9 Reno, NV 89509 Telephone: 775.829.1222 10 [email protected] 11 SCHILLING LAW GROUP 12 Charity Gilbreth, Esq. Linda Schilling, Esq. 13 1100 Newport Center Drive Suite 250 14 Newport Beach, CA 92660 Telephone: 949.760.6120 15 [email protected] [email protected] 16 Attorneys for U S Mine Corp 17 18 19 /s/ Kaitlin Snyder 20 An Employee of Dickinson Wright PLLC 21 22 23 24 25 26 27 28 EXHIBIT 1

US Mine provided supplemental responses to Lauritzen’s Request for Interrogatories on September 5, 2025

EXHIBIT 1 GUNDERSON LAW FIRM Courtney G. Sweet, Esq. Nevada State Bar No. 10775 3||3895 Warren Way Reno, Nevada 89509 4|| Telephone: 775.829.1222 5 [email protected] 6|| SCHILLING LAW GROUP Charity Gilbreth, Esq. (pro hac vice) Linda Schilling, Esq. (pro hac vice) 1100 Newport Center Drive Suite 250 8 Newport Beach, California 92660 9 Telephone: 949.760.6120 [email protected] 10|| [email protected] 11]| Attorneys for U S Mine Corp 12 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 15|| LAURITZEN BULKERS A/S, Case No.: 3:25-cv-00280-MMD-CL] 16 Plaintiff, U S MINE CORP’S 17 v. SUPPLEMENTAL RESPONSES 18 TO PLAINTIFF’S TWIN PINES MINERALS, LLC, INTERROGATORIES TO 19 GARNISHEE U S MINE CORP Defendant, 20 IN ADMIRALTY, Rule 9(h) and 22|| US MINE CORP, 23 Garnishee. / 24 TTS 25|| PROPOUNDING PARTY: Plaintiff Lauritzen Bulkers A/S 26|| RESPONDING PARTY: — Garnishee U S Mine Corp 27|| SET NO.: One (1) 28 Garnishee U S MINE CORP (“US Mine” or “Responding Party”), by and through its couns: LAW FIRM

1}| of record Courtney G. Sweet, Esq., of Gunderson Law Firm and Charity Gilbreth, Esq. and Lin 2|| Schilling, Esq. of Schilling Law Group, and pursuant to Supplemental Rule B of the Federal Rul 3}| of Civil Procedure, responds to Plaintiff Lauritzen Bulkers A/S (“Lauritzen” or “Plaintiff 4|| Interrogatories to Garnishee U S Mine Corp as follows: 5|| INTERROGATORY NO. 1: 6 Identify any relationship that US Mine has, or has had, with Defendant, Twin Pines Minera 7|| LLC, 2100 Southbridge Pkwy 540, Birmingham, AL 35209, FEIN 46-3514529 ("TPM"). 8|| RESPONSE TO INTERROGATORY NGO. 1: 9 Objection. Responding Party objects to the Interrogatory as the meaning of the ter 10]| “relationship” is vague and ambiguous. 11 Responding Party objects to the Interrogatory as overbroad in time and scope and therefo 12||not relevant to the Writ of Maritime Attachment and Garnishment (“Writ”) or any claims 13]| Plaintiff's Complaint, nor proportional to the needs of the case. The Interrogatory reque: 14]| information that is not limited to property in the District of Nevada, nor limited to the timefrar 15]| relevant to property that may be captured by the Writ, and therefore is beyond the scope of the Wr 16 Without waiving those objections, US Mine responds as follow: US Mine (“Garnishee” 17||“US Mine” or “Responding Party”) is not related to Twin Pines Minerals, LLC (“Defendant” “TPM”). 19|| INTERROGATORY NO. 2: 20 Identify all accounts, amounts or anything of value payable to, or held on behalf of TPM. RESPONSE TO INTERROGATORY NO. 2: 22 Objection. Responding Party objects to the Interrogatory as overbroad in time and sco’ 23]| because the Interrogatory is not limited to property in the District of Nevada, nor limited to t 24|| timeframe relevant to the Writ or any claims in the Complaint, and therefore beyond the scope 25|| the Writ and not proportional to the needs of the case. 26 Without waiving that objection, US Mine responds as follows: None. 27|| INTERROGATORY NO. 3: 28 Identify any agreements, including but not limited to contracts, between you, your affiliat

1|| and /or subsidiaries or agents, and TPM and/or any of its subsidiaries between January 1, 2022 ar 2|| the present. RESPONSE TO INTERROGATORY NO. 3: 4 Objection. Responding Party objects to the Interrogatory as overbroad as to scope a1 5|| therefore not relevant to the Writ or any claims in the Complaint, nor proportional to the needs | the case. The Interrogatory requests information that is not limited to property in the District □ 7|| Nevada and is therefore beyond the scope of the Writ. 8 Without waiving that objection, US Mine responds as follows: There are no agreemen pursuant to which property of Defendant’s located in the District of Nevada was ever held, nor w be held, by Garnishee. INTERROGATORY NO. 4: 12 State whether anyone associated with US Mine has notified TPM of the litigation from whic this garnishment action stemmed and, if so, identify the individual(s) making the notification ar 14]| the individual(s) notified. 15|| RESPONSE TO INTERROGATORY NO, 4: 16 No. 17|| INTERROGATORY NO. 5: 18 Identify all individuals at TPM with whom or which US Mine has communicated betwe: 19}| January 1, 2022 and the present including, but not limited to, each contact's name, job title, telepho: 20]| number, cell phone number, fax number, mailing address, and e-mail address. RESPONSE TO INTERROGATORY NO. 5: 22 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 23|| time and scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, n 24|| proportional to the needs of the case. 25 Without waiving that objection, US Mine responds as follows: US Mine’s main point 26|| contact for communication at TPM was: 7 Steven R. Ingle President, Twin Pines Minerals, LLC 28 2100 Southbridge Parkway, Suite 540 LAWFIRM Birmingham, AL 35209

1}| INTERROGATORY NO. 6: 2 Identify all contacts you have, whether directly or through any agent or attorney, at TP. including, but not limited to, each contact's name, job title, telephone. 4|| RESPONSE TO INTERROGATORY NO. 6: 5 Objection. Responding Party objects to the Interrogatory as the meaning of the ter “contacts” is vague and ambiguous. 7 Responding Party objects to the Interrogatory as overbroad and burdensome as to time ar 8|| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportion to the needs of the case. 10 Without waiving those objections, US Mine responds as follows: See Response Interrogatory No. 5. 12|| INTERROGATORY NO. 7: 13 Please describe in detail all property, tangible or intangible, of or which could be or claimed by TPM which you hold, control, or over which you otherwise have custody. 15|| RESPONSE TO INTERROGATORY NO. 7: 16 Objection. Responding Party objects to the Interrogatory as the meaning of the phrase “cou 17]| be or is claimed by TPM” is vague and ambiguous. 18 Responding Party objects to the Interrogatory as it calls for speculation. Responding Par 19]| does not know, nor can it guess, what property “could be...claimed by TPM.” 20 Responding Party objects to the Interrogatory as overbroad as in scope and therefore n 21|| relevant to the Writ or any claims in the Complaint, nor proportional to the needs of the case. □□ 22|| Interrogatory requests information that is not limited to property in the District of Nevada, a therefore beyond the scope of the Writ. 24 Without waiving those objections, US Mine responds as follows: Garnishee has no tangit 25|| or intangible property of TPM in the District of Nevada. 26|| INTERROGATORY NO. 8: 27 Identify any invoice or demand for payment issued to you by TPM and/or any of its ager 28]| or subsidiaries between January 1, 2022 and the present.

RESPONSE TO INTERROGATORY NO. 8: 2 Objection. Responding Party objects to the Interrogatory as overbroad as to time and sco 3}| and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportional to tl 4||needs of the case. The Interrogatory requests information that is not limited to property in t District of Nevada, nor limited in time to the time period of property that may be captured by tl Writ, and therefore beyond the scope of the Writ. 7 Without waiving that objection, US Mine responds as follows: See Response to Interrogato No. 11, below. 9|| SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 8: 10 Objection. Responding Party objects to the Interrogatory as overbroad as to time and sco and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportional to t 12]}needs of the case. The Interrogatory requests information that is not limited to property in t 13]| District of Nevada, nor limited in time to the time period of property that may be captured by t 14]j Writ, and therefore beyond the scope of the Writ. 15 Without waiving that objection, US Mine responds as follows: US Mine does not hold in | 16|| possession, custody or control, assets, cash, funds, credits, wire transfers, accounts, letters of cred 17}| electronic fund transfers, freights, sub-freights, charter hire, sub-charter hire, or any other tangit 18|| and/or intangible assets belonging to, due, claimed by, being held for or on behalf of or bei 19|| transferred for the benefit of Defendant TPM located in the District of Nevada. 20|| INTERROGATORY NO. 9: 21 Identify any communication between you and TPM and/or any of its subsidiaries or affiliat 22}| between January 1, 2024 and the present. 23|| RESPONSE TO INTERROGATORY NO. 9: 24 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome 25|| time and scope because the communications requested are not related to property that Garnish 26|| may currently be holding of Defendant’s in the District of Nevada. As such, the Interrogatory is r 27]|| relevant to the Writ or any claims in Plaintiff's Complaint, nor proportional to the needs of the ca: 28)| ///

SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 9: 2 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome 3}| time and scope because the communications requested are not related to property that Garnish 4|| may currently be holding of Defendant’s in the District of Nevada. As such, the Interrogatory is n 5|| relevant to the Writ or any claims in Plaintiff's Complaint, nor proportional to the needs of the cas 6 Without waiving that objection, US Mine responds as follows: US Mine does not hold in | 7|| possession, custody or control, assets, cash, funds, credits, wire transfers, accounts, letters of cred 8|| electronic fund transfers, freights, sub-freights, charter hire, sub-charter hire, or any other tangit 9]| and/or intangible assets belonging to, due, claimed by, being held for or on behalf of or bei 10}| transferred for the benefit of Defendant TPM located in the District of Nevada. INTERROGATORY NO. 10: 12 Please describe in detail any outstanding obligations - due now or that will come due in 13]| the future, including those obligations subject to any contingency, that US Mine has to TPM. 14]| RESPONSE TO INTERROGATORY NO. 10: 15 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 16]| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 17]| to the needs of the case. 18 Without waiving that objection, US Mine responds as follows: None. 19|| INTERROGATORY NO. 11: 20 Please describe in detail any obligations that US Mine had to TPM under the Asset Purcha Agreement between TPM and US Mine effective on or about December 31, 2023. 22|| RESPONSE TO INTERROGATORY NO. 11: 23 Objection. Responding Party objects to the Interrogatory as the meaning of the phrase “ai 24|| obligations” is vague and ambiguous. 25 Responding Party objects to the Interrogatory as overbroad and burdensome as to scope a. 26]| therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportional to the nee 27]|| of the case, because the Asset Purchase Agreement (“APA”) does not involve any property locat 28]| in the District of Nevada.

1 Without waiving those objections, US Mine responds as follows: On December 31, 202 2|| TPM and US Mine entered into the APA, by which TPM sold to US Mine three mining plants, alo: 3|| with other assets needed to operate the plants, in exchange for payment to be made in installmer 4|| and assumption of certain of TPM’s debts as follows: 5 (1) Some of the purchase price was paid by US Mine to TPM before execution of the APA; 6 (2) At execution, US Mine assumed certain debt of TPM’s; 7 (3) Four additional payments were due between January and April 2024; 8 (4) A final installment was due on or before May 3, 2024; and 9 (5) If certain production goals were met, additional payment would become due. 10 US Mine fulfilled its obligations for Nos. 1-3. TPM breached the contract in numerous wa 11]| and as a result US Mine did not fully pay the final installment by May 3, 2024. The obligation 12|| pay additional payments was never triggered. 13 On or about October 31, 2024, US Mine made its final payment to TPM pursuant to the AP. 14|| for $130,000. This payment was made by wire, and was never present in the District of Nevada. 15 US Mine has no obligation to make any future payments to TPM and is not indebted to TP 16]| in any way. On the contrary, TPM is indebted to US Mine. 17|| SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 11: 18 Objection. Responding Party objects to the Interrogatory as the meaning of the phrase “a 19]| obligations” is vague and ambiguous. 20 Responding Party objects to the Interrogatory as overbroad and burdensome as to scope a: 21]| therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportional to the nee 22]| of the case, because the Asset Purchase Agreement (““APA”) does not involve any property locat 23|) in the District of Nevada. 24 Responding Party objects that a Nevada Court has jurisdiction over any dispute involvi 25|| the APA because the APA expressly provides that “[a]ny suit involving any dispute or matter arisi 26|| under this Agreement may only be brought in the California courts having jurisdiction over t 27|| subject matter of the dispute or matter.” Since US Mine could not be sued by TPM in Nevada 28]|| enforce the APA, Plaintiff who steps into TPM’s shoes cannot force an adjudication of rigl

1}| involving the APA in a Nevada Court. See Harris v. Balk,

(1905) (“for t attachment of the debt, then if the garnishee be found in that State...we think the court therel 3}| acquires jurisdiction over him, and can garnish the debt due from him to the debtor of the plaint 4||and condemn it, provided the garnishee could himself be sued by his creditor in th 5|| State.”)(emphasis added). 6 Responding Party objects to the Interrogatory to the extent it seeks disclosure of confident 7|| or proprietary information in the APA, which is a confidential document. 8 Without waiving those objections, US Mine responds as follows: TPM fraudulently induc 9|| US Mine to enter into the APA. On December 31, 2023, TPM and US Mine entered into the AP. 10|| pursuant to which TPM was to provide US Mine three mining plants, along with other assets a 11}| personnel needed to operate the plants. TPM represented that the three mining plants, operated | 12|| TPM’s personnel, could and would produce certain amounts and qualities of heavy mineral produc 13}| and byproducts from US Mine ore within a certain timeframe. US Mine agreed to enter into t 14}| APA based on these representations, which included that TPM’s personnel would have one of t 15]| three plants operating and processing US Mine ore in January 2024, and the two other plants ful 16]| operational and processing US Mine ore by April 1, 2024, achieving certain product goals that sar 17|| month. In exchange for the three plants that were to be fully operational by April 2024, US Mi 18]| agreed to make installment payments and assume certain of TPM’s debts as follows: 19 (1) US Mine would pay some of the purchase price to TPM before execution of the APA; 20 (2) At execution, US Mine assumed certain debt of TPM; 21 (3) Four additional payments were due between January and April 2024; 22 (4) A final installment payment was due on or before May 3, 2024; and 23 (5) If certain production goals were met, additional payments would become due. 24 US Mine fulfilled its obligations described in Nos. 1-3. But TPM failed to configure the f 25|| plant by January 2024. TPM personnel spent months attempting to get the first plant to operate 26|| intended, without success. The other two plants were not built by April 2024. Having failec 27|| deliver three fully operational plants by April 2024, i.e. the core purpose of the APA, TPM materi 28]|| breached the agreement. As a result of this material breach, US Mine’s obligation to make the fi

installment payment (No. 4) never arose and/or was excused. TPM personnel tried for several m 2|| months to configure the plants to operate as promised. Over time it became clear that the three plz were not capable of performing the fundamental functions that TPM promised. Two of the ple 4|| were never capable of operating. The one plant that does operate does not perform in the □□□□ 5|| including providing the quality and quantity of heavy mineral products and byproducts, promised 6|| TPM. TPM was given ample time to remedy their material breach but could not. As a result, T] 7|| is not entitled to the final installment payment. 8 Moreover, the APA expressly gives US Mine the right to “offset any damages or los 9|| suffered by Buyer [US Mine], as a result of [Seller’s] breach or failure to perform, against any furt 10]| monies owed by Buyer to Seller under this Agreement.” US Mine not only overpaid for whe 11]| received, but further has suffered millions of dollars in damages because TPM failed to provide plz 12||that operated as promised. US Mine’s damages far outweigh and offset any amount that co 13]| possibly be due to TPM under the APA. 14 No money will ever become payable under No. 5 because the plants are not capable 15]| performing and therefore cannot meet the production goals. 16|| INTERROGATORY NO. 12: 17 Please describe in detail] any payments that will come due, and the date such payments w 18]| become due, from US Mine to TPM under the Asset Purchase Agreement between TPM and 1 19]| Mine effective on or about December 31, 2023. 20|}| RESPONSE TO INTERROGATORY NO. 12: 21 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 22|| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 23]| to the needs of the case. Garnishee does not hold any property of Defendant’s located in the Distr 24|| of Nevada pursuant to the APA, nor will it ever. 25 Without waiving that objection, US Mine responds as follows: None. See Response 26|| Interrogatory No. 11. 27|| SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 12: 28 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as

scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 2|| to the needs of the case. Garnishee does not hold any property of Defendant’s located in the Distr 3}| of Nevada pursuant to the APA, nor will it ever. 4 Responding Party objects that a Nevada Court has jurisdiction over any dispute involvi 5}| the APA because the APA expressly provides that “[a]ny suit involving any dispute or matter arisi: 6|| under this Agreement may only be brought in the California courts having jurisdiction over t 7|| subject matter of the dispute or matter.” Since US Mine could not be sued by TPM in Nevada 8|| enforce the APA, Plaintiff who steps into TPM’s shoes cannot force an adjudication of rigl 9||involving the APA in a Nevada Court. See Harris v. Balk,

(1905) (“for t 10}| attachment of the debt, then if the garnishee be found in that State...we think the court there 11]| acquires jurisdiction over him, and can garnish the debt due from him to the debtor of the plaint 12||and condemn it, provided the garnishee could himself be sued by his creditor in th 13]|| State.”)(emphasis added). 14 Responding Party objects to the Interrogatory to the extent it seeks disclosure of confident 15]| or proprietary information in the APA, which is a confidential document. 16 Without waiving those objections, US Mine responds as follows: None. 17|| INTERROGATORY NO. 13: 18 Identify the date and amount of US Mine's last payment to TPM under the Asset Purcha 19/| Agreement between TPM and US Mine effective on or about December 31, 2023. 20|}| RESPONSE TO INTERROGATORY NO. 13: 21 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 22|| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 23)| to the needs of the case. Garnishee does not hold any property of Defendant’s located in the Distr 24|| of Nevada pursuant to the APA, nor will it ever. 25 Without waiving that objection, US Mine responds as follows: October 31, 2024 1 26|| $130,000. 27|| INTERROGATORY NO. 14: 28 Identify the date and amount of US Mine's next payment to TPM under the Asset Purcha

1}| Agreement between TPM and US Mine effective on or about December 31, 2023. 2|| RESPONSE TO INTERROGATORY NO. 14: 3 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 4]| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 5|| to the needs of the case. Payments made pursuant to the APA were never present in the District 6|| Nevada. 7 Without waiving that objection, US Mine responds as follows: None. 8|| INTERROGATORY NO. 15: 9 Identify any property of TPM's that remains at US Mine's Ione, California facility. 10}] RESPONSE TO INTERROGATORY NO. 15: 1] Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 12]| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 13]|to the needs of the case. Property in California, if any, is not relevant to a Writ in the District 14|| Nevada. 15|| INTERROGATORY NO. 16: 16 Detail any interest or rights TPM has in US Mine's Ione, California facility or mater: 17]| produced from or at US Mine's lone, California facility. 18}| RESPONSE TO INTERROGATORY NO. 16: 19 Objection. Responding Party objects to the Interrogatory as overbroad and burdensome as 20]| scope and therefore not relevant to the Writ or any claims in Plaintiff's Complaint, nor proportior 21]| to the needs of the case. Property in California, if any, is not relevant to a Writ in the District 22|| Nevada. 23 DATED this 5th day of September, 2025. . 24 GYNDERSON LAW FIRM 25 By: 26 CourtneyG. Sweet-Esq. Nevada State Bar No. 10775 27 and Charity Gilbreth, Esq. (pro hac vice) 28 Linda Schilling, Esq. (pre hac vice) LAW CORPORATION Atinvnove far TI Mine Carn

l VERIFICATION 2 I, Bradford Barto, Chief Executive Officer of U S Mine Corp, declare under penalty of 3}| perjury under the laws of the United States of America that the U S MINE CORP’S 4||SUPPLEMENTAL RESPONSES TO PLAINTIFF’S INTERROGATORIES TO 5|] GARNISHEE U S MINE CORP are true and correct to the best of my knowledge and belief. 6 DATED this? _ day of September, 2025. 7 Signed by: ; | brady Dorte Bradford Barto 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ArRORSSIORAL

I CERTIFICATE OF SERVICE 2 Pursuant to FRCP 5(b), I certify that I am an employee of the law office of GUNDERSC 3|| LAW FIRM, and on the day of September, 2025 I deposited for mailing in Reno, Nevade 4||true and correct copy of the U S MINE CORP’S SUPPLEMENTAL RESPONSES T 5|| PLAINTIFF’S INTERROGATORIES TO GARNISHEE U S MINE CORP to the following 6 Brooks Todd Westergard, Esq. 7 DICKINSON WRIGHT PLLC 100 W Liberty St., Ste. 940 8 Reno, NV 89501 [email protected] 9 Attorneys for Lauritzen Bulkers A/S 10 Gary C. Murphy, Esq. Li SIMMS SHOWERS LLP 201 International Circle 12 Suite 230 3 Baltimore, MD 21030 410-783-5795 14 gcmurphy(@simmsshowers.com Attorneys for Lauritzen Bulkers A/S 15 16 J. Stephens Simms, Esq. SIMMS SHOWERS LLP 17 201 International Circle Baltimore, MD 21030 18 4107835795 [email protected] 19 Attorneys for Lauritzen Bulkers A/S 20 21 ; 22 Cinnamon C. Konietzka 23 24 25 26 27 28 NDERSON LAW FIRM