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Contract analysis / cid-response-cover-letter.docx
cid-response-cover-letter.docx
High · 1
Medium · 4
Standard · 1
I. DOCUMENT PRODUCTION
Medium
⚑ Liability cap to check against exposure
I. DOCUMENT PRODUCTION Enclosed herewith is the Companies' first production of documents responsive to Document Requests 1 through 24 of the CID, as narrowed by the agreement of the parties memorialized in the Attorney General's letter dated October 21, 2025. The Companies have undertaken a reasonable and diligent search for responsive documents in the files, records, and electronically stored information of DEH and
II. GENERAL OBJECTIONS
High
⚑ Non-compete / exclusivity restraint
II. GENERAL OBJECTIONS DEH and DFS assert the following General Objections to each and every Document Request and Interrogatory contained in the CID. These General Objections are incorporated by reference into each specific response set forth below, as though fully stated therein. The assertion of a General Objection does not constitute a representation that the objection applies to any particular request, nor does t
III. SPECIFIC RESPONSES TO DOCUMENT REQUESTS
Medium
⚑ Confidentiality undertaking
III. SPECIFIC RESPONSES TO DOCUMENT REQUESTS Subject to and without waiving the foregoing General Objections, which are incorporated herein by reference, DEH and DFS respond to the specific Document Requests contained in the CID as follows: A. Document Requests 1–6 (Bid Submissions and Analyses) Requests 1 through 6 seek documents relating to bids, price proposals, and supporting analyses prepared by or on behalf of
IV. INTERROGATORY RESPONSES
Standard
⚑ Commercial term
IV. INTERROGATORY RESPONSES Enclosed as Exhibit A are the Companies' verified responses to Interrogatories 1 through 6 of the CID. The interrogatory responses have been executed under oath by Terrence "Terry" Kinloch, Vice President, Government Contracts, Dunmore Fuel Supply, Inc., on behalf of DFS, in accordance with the verification requirements of the CID and applicable Meridian law. The interrogatory responses ad
V. PRIVILEGE LOG
V. PRIVILEGE LOG Enclosed as Exhibit B is a privilege log identifying all documents withheld from production on the basis of the attorney-client privilege, the work-product doctrine, or both. A total of 1,247 documents have been withheld as privileged. The privilege log provides the following information for each withheld document: • Bates Begin: The beginning Bates number assigned to the withheld document. • Bates E
VI. CORPORATE REPRESENTATIVE EXAMINATION
Medium
⚑ Notice / time limit to track
VI. CORPORATE REPRESENTATIVE EXAMINATION DEH and DFS acknowledge the CID's demand for the production of designated corporate representatives for oral examination pursuant to the investigative authority of the Attorney General of the State of Meridian. The Companies are prepared to make appropriate representatives available for examination at a mutually convenient time following the Attorney General's review of the do
VII. RESERVATION OF RIGHTS
Medium
⚑ Liability cap to check against exposure
VII. RESERVATION OF RIGHTS DEH and DFS expressly reserve all rights, objections, defenses, and privileges not specifically addressed in this response, including but not limited to the following: (a) The right to supplement or amend the document production, interrogatory responses, and privilege log set forth herein, whether in response to the identification of additional responsive materials, changes in circumstances
1. Production Drives A and B (encrypted USB drives, password-protected)
1. Production Drives A and B (encrypted USB drives, password-protected)
2. Exhibit A — Verified Interrogatory Responses (executed by Terrence "Terry" Kinloch, VP
2. Exhibit A — Verified Interrogatory Responses (executed by Terrence "Terry" Kinloch, VP, Government Contracts, Dunmore Fuel Supply, Inc.)
3. Exhibit B — Privilege Log (1,247 entries)
3. Exhibit B — Privilege Log (1,247 entries) cc (via email): Patricia Aldridge, SVP & General Counsel, Dunmore Energy Holdings Ltd. Derek Montague, Senior Assistant Attorney General, Chief, Antitrust Division, Office of the Attorney General, State of Meridian Gregory Whitfield, Whitfield, Strauss & DeVane LLP — Counsel for Galloway Petroleum Corp. Diane Colby, Archer Colby LLP — Counsel for Ridgeline Energy Partners