Contract analysis

1. Volume of Potentially Responsive Materials Counsel's preliminary analysis of the CID's twenty-four (24) document requests indicates that they implicate a substantial volume of electronically stored information ("ESI") spanning multiple custodians, data sources, and information systems maintained by both DEH and DFS. Based on the scope of the CID — which covers conduct during the period from January 2021 through De

2. Complexity of the Review Required Beyond the sheer volume of potentially responsive materials, the CID's substantive demands present significant analytical and review challenges. The CID encompasses twenty-four (24) document requests, six (6) interrogatories, and a demand for the oral examination of one or more corporate representatives designated pursuant to the Respondents' obligation to identify persons with kn

3. Good-Faith Efforts Already Underway The Respondents wish to emphasize that this request for an extension is not made for purposes of delay, and that DEH and DFS take their obligations under the CID with the utmost seriousness. From the outset, Respondents have been committed to providing a thorough, complete, and timely response to the Attorney General's investigation, and they have taken concrete, demonstrable st

4. Absence of Prejudice to the Attorney General's Investigation Respondents respectfully submit that the requested thirty-day extension will not prejudice the Attorney General's investigation in any respect. The CID concerns conduct alleged to have occurred during the period from January 2021 through December 2024. The relevant conduct period therefore ended approximately nine months before the CID was issued on Augu