Contract analysis

I. EXECUTIVE SUMMARY On August 22, 2025, the Office of the Attorney General of the State of Meridian, acting through its Antitrust Division (CID Reference No. AG-ANT-2025-04172), issued a Civil Investigative Demand ("CID") to Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted limited company with its operational headquarters located in Houston, Texas, and to its wholly owned subsidiary Dunmore Fuel Suppl

II. LEGAL AUTHORITY FOR THE CID A. Statutory Basis The CID was issued pursuant to Meridian Code Annotated § 75-21-39, which authorizes the Attorney General of the State of Meridian to issue civil investigative demands when the AG has "reason to believe" that a person has engaged in, or is engaging in, conduct that violates the Meridian Antitrust Act. The substantive prohibition at issue is set forth in Meridian Code

III. BACKGROUND — THE ALLEGED SCHEME A. Nature of the Allegations The CID sets forth the AG's preliminary theory of the alleged antitrust conspiracy in its prefatory "Statement of Investigative Basis." According to the AG, between approximately January 2021 and December 2024, DFS, Galloway Petroleum Corp., and Ridgeline Energy Partners LLC engaged in a scheme to rig bids on fuel-supply contracts issued by Meridian DO

IV. DETAILED ANALYSIS OF CID REQUESTS This section provides a request-by-request analysis of the CID's twenty-four document requests (organized into five categories), six interrogatories, and oral-examination demand. For each category or individual request, we assess the scope and relevance of the demand, identify available objections, and provide a recommended course of action. A. Document Requests (24 Total) Catego

V. PRIVILEGE CONSIDERATIONS A. Attorney-Client Privilege Certain documents responsive to the CID will be protected by the attorney-client privilege. This privilege protects confidential communications between DFS/DEH personnel and counsel — both in-house and outside — made for the purpose of seeking or providing legal advice. The following categories of communications are expected to fall within the scope of the atto

VI. PROPORTIONALITY AND BURDEN ANALYSIS A. Estimated Data Volumes Five key custodians have been identified for purposes of document preservation and collection. The estimated data volumes for each custodian, based on preliminary assessments conducted by DEH's Information Technology department in coordination with Brindoval Analytics LLC, are as follows: These estimates include email (Drayton Solutions mailboxes and a