1016-00001 · Dunmore Energy Holdings · CID Response

cid-response-cover-letter.docx DOCUMENT Antitrust

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CALDERWOOD & HARKNESS LLP Attorneys at Law

1900 K Street NW, Suite 1100 Washington, DC 20006

November 3, 2025

VIA HAND DELIVERY AND EMAIL

Alicia Brennan, Esq. Assistant Attorney General Antitrust Division Office of the Attorney General 500 Capitol Avenue, Suite 300 Baxter City, Meridian 39201

Re: Response to Civil Investigative Demand No. AG-ANT-2025-04172 Dunmore Energy Holdings Ltd. and Dunmore Fuel Supply, Inc. C&H Matter No. 1016-00001

Dear Ms. Brennan:

This firm represents Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary Dunmore Fuel Supply, Inc. ("DFS," and together with DEH, the "Companies") in connection with Civil Investigative Demand No. AG-ANT-2025-04172 (the "CID") issued by the Office of the Attorney General of the State of Meridian, Antitrust Division, on August 22, 2025. This letter and the accompanying production of documents, interrogatory responses, and privilege log constitute the Companies' response to the CID. This response is submitted pursuant to the extended deadline of November 3, 2025, as granted by your office in its letter dated September 26, 2025, in which the Attorney General's office agreed to extend the original response date of October 6, 2025, by twenty-eight days to accommodate the volume and complexity of the responsive materials at issue. In addition, this response conforms in all respects to the agreed-upon scope narrowing of certain document requests, which was memorialized in the Attorney General's letter dated October 21, 2025, following the meet-and-confer conference held on October 17, 2025, between undersigned counsel and Senior Assistant Attorney General Derek Montague and yourself.

The Companies have endeavored in good faith to respond to each of the CID's demands in a thorough and timely manner, consistent with their obligations under Meridian law. Nothing in this response, however, should be construed as a waiver of any objection, right, or privilege that DEH or DFS may assert now or in the future with respect to the CID or this investigation. The Companies' specific responses, objections, and reservations are set forth in detail below.

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 DFS, and have produced all non-privileged documents identified as responsive to the Document Requests, subject to the General Objections and specific objections set forth herein.

The production consists of a total of 18,742 documents, comprising 87,316 pages, bearing Bates numbers DEH-MERID-000001 through DEH-MERID-087316. The documents are produced in the following format:

• All documents, with the exception of spreadsheets and databases, are produced in single-page TIFF image format, accompanied by extracted text files (.txt) for each document, a metadata load file in Ashgrove Technologies format (.dat), and an image load file (.opt). These files are organized by custodian and document family, and the load files contain all standard metadata fields, including but not limited to document date, author, recipient(s), carbon-copy recipients, file name, file path, file type, and custodian.

• Spreadsheets (including Ashbury Holdings Excel files and CSV files) and databases (including Ridgeway Data Systems databases) have been produced in their native format to preserve formulas, embedded data, macros, and other functionality that would be lost or materially degraded if converted to TIFF image format. Each native-format file has been assigned a unique Bates number for tracking purposes, and the corresponding metadata has been included in the Ashgrove Technologies load file.

The production is delivered on two encrypted USB drives, designated as Drive A and Drive B, both of which are password-protected using AES-256 encryption. The password necessary to access the contents of Drives A and B will be transmitted separately to your office via telephone, in accordance with the parties' agreement regarding the secure handling of electronically stored information. Drive A contains documents bearing Bates numbers DEH-MERID-000001 through DEH-MERID-050000, and Drive B contains documents bearing Bates numbers DEH-MERID-050001 through DEH-MERID-087316, together with the complete Ashgrove Technologies load file, image load file, and extracted text files for the entire production.

The Companies reserve the right to supplement this production as additional responsive documents are identified through the ongoing collection and review process. In particular, DEH and DFS are continuing to process and review certain legacy electronic archives and backup tapes that were identified during the collection process. Should additional responsive, non-privileged documents be identified, the Companies will produce them on a rolling basis and will promptly notify your office of any supplemental production.

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 the failure to assert a General Objection with respect to any particular request constitute a waiver of that objection.

Objection 1 — Privilege. DEH and DFS object to each Document Request and Interrogatory to the extent it seeks, calls for, or would require the disclosure of information or documents protected by the attorney-client privilege, the work-product doctrine, the joint-defense privilege, or any other applicable privilege, immunity, or protection recognized under federal or Meridian state law. No production or disclosure of any privileged material is intended, and any inadvertent production of privileged material shall not constitute a waiver of any applicable privilege. The Companies have taken reasonable steps to identify and withhold privileged documents from production, and a privilege log describing such documents is enclosed as Exhibit B.

Objection 2 — Overbreadth and Burden. DEH and DFS object to each Document Request and Interrogatory to the extent it is overbroad, unduly burdensome, or disproportionate to the needs of the investigation. DEH is a multinational energy holding company with operations spanning twelve states and three Canadian provinces, and DFS is a substantial operating subsidiary with multiple business divisions and thousands of employees. Certain requests, as originally drafted, would have required the Companies to search, collect, review, and produce millions of documents across the entirety of their operations, including documents having no conceivable relevance to the subject matter of the investigation. The Companies have interpreted each request reasonably and in good faith, consistent with the scope narrowing agreed upon by the parties, and have limited their searches accordingly.

Objection 3 — Confidentiality and Trade Secrets. DEH and DFS object to each Document Request and Interrogatory to the extent it seeks proprietary, confidential, or trade-secret information, the disclosure of which could cause competitive harm to the Companies. A significant portion of the documents produced herein contain commercially sensitive information, including but not limited to pricing strategies, margin analyses, cost structures, customer lists, and competitive-intelligence assessments. Pending the entry of an appropriate protective order governing the use and dissemination of confidential materials produced in this investigation, the Companies have designated certain documents as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY" in accordance with the confidentiality designations discussed during the October 17, 2025 meet-and-confer. DEH and DFS respectfully request that the Attorney General's office treat all materials bearing such designations in accordance with the terms of any protective order ultimately entered, and reserve the right to modify confidentiality designations at any time, including the right to upgrade or downgrade the designation of any particular document upon further review.

Objection 4 — Possession, Custody, or Control. DEH and DFS object to each Document Request and Interrogatory to the extent it seeks or purports to require the production of documents or information that is not in the possession, custody, or control of DEH or DFS. The Companies are not in a position to produce documents held exclusively by third parties, including but not limited to competitors, trade associations, government agencies, or unaffiliated vendors and suppliers. The Companies have limited their search and production to documents within their own possession, custody, or control, as those terms are understood under applicable law.

Objection 5 — Preservation of Rights. The assertion of these General Objections does not constitute a waiver of any specific objection, right, or privilege that DEH or DFS may assert herein or in any future response, proceeding, or court filing. The Companies expressly reserve the right to assert additional objections at any time, including objections based on grounds not specifically identified in this response.

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 DFS in connection with fuel-supply contracts issued by the Meridian Department of Transportation ("Meridian DOT") during Fiscal Years 2022 through 2024.

Subject to the General Objections stated above, DEH and DFS have conducted a reasonable and diligent search of their files, records, and electronically stored information for documents responsive to Requests 1 through 6. The search encompassed the electronic files and email accounts of all DFS personnel identified as having been involved in the preparation, review, approval, or submission of bids for Meridian DOT fuel-supply contracts during the relevant period, as well as relevant shared drives, document management systems, and physical files maintained by DFS's Government Contracts Division.

Responsive documents have been produced and bear Bates numbers DEH-MERID-000001 through DEH-MERID-034219. The produced documents include, without limitation, the following categories of materials:

• Copies of all bid submissions and price proposals submitted by DFS in response to Meridian DOT Requests for Proposals for fuel-supply contracts during Fiscal Years 2022, 2023, and 2024;

• Internal analyses, memoranda, and presentations prepared in support of each bid submission, including pricing models, cost-basis analyses, volume projections, and risk assessments;

• Bid/no-bid decision memoranda and related correspondence;

• Documents reflecting DFS's evaluation of the terms and conditions of each Meridian DOT Request for Proposals; and

• Post-bid analyses evaluating the outcome of each procurement.

The production covers all five geographic lots into which Meridian DOT fuel-supply contracts are organized: Lot A — Northern Meridian, Lot B — Central Meridian, Lot C — Southern Meridian, Lot D — Eastern Meridian, and Lot E — Western Meridian. DFS submitted bids for all five lots in Fiscal Years 2022 and 2024, and for Lots A, B, and C in Fiscal Year 2023.

B. Document Requests 7–12 (Communications with Competitors)

Requests 7 through 12 seek communications between DFS personnel and employees of Galloway Petroleum Corp. ("Galloway") and Ridgeline Energy Partners LLC ("Ridgeline") during the period January 2021 through December 2024.

Subject to the General Objections stated above, DEH and DFS specifically object to these requests as originally drafted. As issued, Requests 7 through 12 sought "all communications, whether written, electronic, or oral, regardless of subject matter" between any employee, officer, director, or agent of DFS and any employee, officer, director, or agent of Galloway or Ridgeline during the four-year period specified. DEH and DFS objected to these requests as facially overbroad and unduly burdensome, as they would have required the Companies to collect and review every communication between DFS personnel and employees of two large, publicly traded energy companies over a four-year period, including communications on subjects entirely unrelated to Meridian DOT fuel-supply contracts or any conceivable subject of this investigation, such as routine industry correspondence, safety bulletins, joint venture operations in other states, and personal communications.

These objections were raised during the meet-and-confer conference held on October 17, 2025, and the parties subsequently agreed to narrow the scope of Requests 7 through 12 as memorialized in the Attorney General's letter dated October 21, 2025. Pursuant to that agreement, the Companies have produced communications falling within the following narrowed categories:

(i) Communications that reference the Meridian Department of Transportation, any Meridian state fuel-supply contract, or any Meridian state procurement process;

(ii) Communications that concern fuel pricing, fuel supply, or bid strategy in the State of Meridian, whether or not a specific Meridian DOT procurement is identified;

(iii) Communications that relate to any meeting, telephone call, conference, gathering, or other event at which fuel pricing or bidding was discussed among competitors, whether formal or informal in nature; or

(iv) Communications that were exchanged within thirty (30) days before or after the submission deadline for any Meridian DOT Request for Proposals during the period January 2021 through December 2024, regardless of subject matter, to the extent such communications were between DFS personnel and Galloway or Ridgeline personnel who had any involvement in Meridian DOT fuel-supply bidding.

Subject to the foregoing objections and the agreed-upon narrowing, DEH and DFS have conducted a reasonable and diligent search for responsive communications, including searches of email accounts, instant messaging platforms, text messages (where available from company-issued devices), and physical files. Responsive documents have been produced and bear Bates numbers DEH-MERID-034220 through DEH-MERID-062488.

C. Document Requests 13–18 (Pricing Analyses and Competitive intelligence)

Requests 13 through 18 seek internal pricing analyses, margin calculations, competitive-intelligence reports, and related documents prepared by or on behalf of DFS in connection with Meridian DOT fuel-supply bids.

Subject to the General Objections stated above, DEH and DFS have conducted a reasonable and diligent search of their files, records, and electronically stored information for documents responsive to Requests 13 through 18. The search encompassed the files and email accounts of DFS personnel in the Government Contracts Division, the Pricing and Analytics Group, and the Business Development Department, as well as relevant shared network drives and the DFS document management system.

Responsive documents have been produced and bear Bates numbers DEH-MERID-062489 through DEH-MERID-078104. The produced documents include, without limitation:

• Internal pricing analyses prepared by DFS's Pricing and Analytics Group in connection with each Meridian DOT fuel-supply bid during the period January 2021 through December 2024;

• Margin calculations, cost-of-goods-sold analyses, and profitability models for each geographic lot;

• Competitive-intelligence reports prepared by DFS's Business Development Department, including analyses of competitors' publicly available pricing, market-share estimates, and assessments of likely competitor bidding strategies; and

• Presentations and memoranda circulated to DFS management in connection with bid strategy discussions.

DEH and DFS note that many of the documents produced in response to Requests 13 through 18 contain highly sensitive commercial information, including proprietary pricing methodologies, cost structures, and competitive assessments. These documents have been designated as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY" pending the entry of an appropriate protective order, and the Companies respectfully request that the Attorney General's office accord these materials the highest degree of confidential treatment.

D. Document Requests 19–22 (Competitor Meetings and Contacts)

Requests 19 through 22 seek documents reflecting meetings, telephone calls, or other contacts between DFS personnel and representatives of competing firms concerning fuel pricing, customer allocation, or bid strategy in the State of Meridian.

Subject to the General Objections stated above, DEH and DFS have conducted a reasonable and diligent search for documents responsive to Requests 19 through 22. The search encompassed calendars, meeting notes, expense reports reflecting travel to industry events or meetings, call logs, and correspondence reflecting the scheduling or outcome of any contacts with competitors.

Responsive documents have been produced and bear Bates numbers DEH-MERID-078105 through DEH-MERID-083972. The produced documents include, without limitation:

• Calendar entries, meeting invitations, and related correspondence reflecting scheduled and actual meetings between DFS personnel and representatives of Galloway, Ridgeline, and other competitors;

• Notes, memoranda, and summaries of meetings, telephone calls, and other contacts at which fuel pricing, customer allocation, or bid strategy in the State of Meridian was discussed;

• Expense reports and travel records reflecting attendance at industry conferences, trade-association events, and other gatherings at which competitors were present; and

• Internal reports or summaries prepared by DFS personnel following contacts with competitors.

E. Document Requests 23–24 (Organizational Information)

Requests 23 and 24 seek organizational charts, reporting structures, and position descriptions for all DFS personnel involved in the Meridian DOT bidding process during the relevant period of January 2021 through December 2024.

Subject to the General Objections stated above, responsive documents have been produced and bear Bates numbers DEH-MERID-083973 through DEH-MERID-087316. The produced documents include the following:

• Organizational charts for the DFS Government Contracts Division, the Pricing and Analytics Group, the Business Development Department, and other DFS business units that participated in or supported the Meridian DOT bidding process, current as of each fiscal year during the relevant period;

• Reporting-structure diagrams showing the chain of command from individual bid-team members through divisional management to the DFS executive team and, where applicable, to DEH corporate officers with oversight responsibility;

• Position descriptions, job specifications, and role summaries for all DFS personnel identified as having participated in the preparation, review, approval, or submission of Meridian DOT fuel-supply bids; and

• Personnel rosters listing the names, titles, and departmental assignments of relevant DFS employees during each year of the relevant period.

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 address the following subjects:

Interrogatories 1 through 3 require the identification of all DFS employees who participated in the preparation or submission of bids for Meridian DOT fuel-supply contracts during the relevant period, including each such employee's role in the bidding process, their job title during the relevant period, and the identity of their direct supervisor(s). The Companies have identified a total of forty-seven (47) DFS employees who participated in the bidding process in one or more capacities during the period January 2021 through December 2024, and have provided the requested information for each individual.

Interrogatory 4 requires the identification of all DFS employees who had communications with personnel of Galloway Petroleum Corp. or Ridgeline Energy Partners LLC during the relevant period, and a description of the substance of those communications. The Companies have identified all such employees to the best of their knowledge and belief, based on the document review conducted in connection with this response, and have described the substance of the identified communications to the extent such substance is known or can be reasonably ascertained from available documents and the recollections of the identified employees.

Interrogatory 5 requires a description of DFS's pricing methodology for fuel-supply bids submitted to the Meridian Department of Transportation. The Companies have provided a narrative description of DFS's general pricing methodology, including the inputs, models, and approval processes utilized by DFS in developing price proposals for Meridian DOT fuel-supply contracts.

Interrogatory 6 requires the identification of all trade-association memberships held by DFS and its employees during the relevant period. The Companies have identified all trade-association memberships maintained by DFS at the corporate level, as well as individual memberships held by DFS employees in their professional capacities, to the extent such memberships are reflected in DFS's corporate records.

The Companies reserve the right to supplement or amend the interrogatory responses as additional information becomes available.

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 End: The ending Bates number assigned to the withheld document.

• Date: The date of the document, or the approximate date if the precise date cannot be determined.

• Author: The author or originator of the document.

• Recipient(s): The recipient(s) of the document.

• CC: Any individuals copied on the document.

• Document Type: The type of document (e.g., email, memorandum, letter, presentation, notes).

• Subject/Description: A general description of the subject matter of the document, stated with sufficient specificity to enable the Attorney General's office to assess the applicability of the claimed privilege, without disclosing the substance of the privileged communication or mental impressions of counsel.

• Basis for Privilege: The specific privilege or protection asserted (i.e., attorney-client privilege, work-product doctrine, or both).

Individual privilege log entries have been provided for all unique privileged documents. In certain limited instances, categorical entries have been used where groups of documents share common characteristics, such as recurring legal-department distribution lists through which privileged legal advice was disseminated on a periodic basis. The use of categorical entries is consistent with the format discussed and agreed upon by the parties during the October 17, 2025 meet-and-confer conference with Senior Assistant Attorney General Derek Montague. Should the Attorney General's office require additional detail with respect to any categorical entry, the Companies are prepared to discuss such entries and to provide individualized log entries upon request.

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 document production and interrogatory responses enclosed herewith.

The Companies respectfully request that the Attorney General's office provide at least thirty (30) days' advance notice of any scheduled corporate representative examination, together with a description of the subject-matter areas on which testimony will be sought, so that the Companies may identify and prepare the most knowledgeable representative(s) for each designated topic. This request is consistent with the representation made by Senior Assistant Attorney General Derek Montague during the October 17, 2025 meet-and-confer conference, at which Mr. Montague indicated that the Attorney General's office would provide reasonable advance notice and would identify the subject-matter areas in advance of any scheduled examination.

During the meet-and-confer, Mr. Montague further indicated that the Attorney General's office anticipates scheduling oral examinations in January 2026, and the Companies are prepared to accommodate that timeline, subject to the availability of appropriate witnesses and counsel. The Companies look forward to working cooperatively with the Attorney General's office to schedule the examinations at a mutually agreeable time and location.

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, or further negotiation with the Attorney General's office regarding the scope of the CID;

(b) The right to assert additional objections to any Document Request, Interrogatory, or other demand contained in the CID, including objections not previously raised, whether based on grounds of privilege, relevance, overbreadth, burden, proportionality, or any other legally recognized basis;

(c) The right to challenge the legal sufficiency of the CID, including the statutory authority under which the CID was issued, the scope of the investigation, and the relevance and materiality of the information demanded;

(d) The right to move to quash, modify, or limit the CID in any court of competent jurisdiction in the State of Meridian or elsewhere, including the right to seek judicial review of any determination by the Attorney General's office regarding the sufficiency of the Companies' response or the validity of any privilege claim.

Nothing in this response, in the production of documents, in the interrogatory responses, or in any other action taken by DEH or DFS in connection with this investigation constitutes, or shall be construed as, an admission or acknowledgment by DEH, DFS, or any of their officers, directors, employees, or agents of any wrongdoing, liability, or violation of any federal, state, or local law, regulation, or statute, including but not limited to the Meridian Antitrust Act, the Meridian Unfair Trade Practices Act, or any other antitrust or competition law.

Nothing in this response constitutes a waiver of the attorney-client privilege, the work-product doctrine, the joint-defense privilege, or any other applicable privilege, immunity, or protection. Any inadvertent disclosure of privileged or protected materials shall not operate as a waiver of any privilege or protection, and DEH and DFS reserve the right to seek the return of any inadvertently produced privileged materials pursuant to applicable law and rules of procedure.

We trust that the enclosed production, interrogatory responses, and privilege log are responsive to the CID. Should you have any questions regarding this response or wish to discuss any aspect of the production, please do not hesitate to contact the undersigned.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Howard Bellamy Partner, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-0132

Email: hbellamy@calderwoodharkness.com

Enclosures:

1. Production Drives A and B (encrypted USB drives, password-protected)

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)

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 LLC

CALDERWOOD & HARKNESS LLP Attorneys at Law
1900 K Street NW, Suite 1100 Washington, DC 20006
November 3, 2025
VIA HAND DELIVERY AND EMAIL
Alicia Brennan, Esq. Assistant Attorney General Antitrust Division Office of the Attorney General 500 Capitol Avenue, Suite 300 Baxter City, Meridian 39201
Re: Response to Civil Investigative Demand No. AG-ANT-2025-04172 Dunmore Energy Holdings Ltd. and Dunmore Fuel Supply, Inc. C&H Matter No. 1016-00001
Dear Ms. Brennan:
This firm represents Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary Dunmore Fuel Supply, Inc. ("DFS," and together with DEH, the "Companies") in connection with Civil Investigative Demand No. AG-ANT-2025-04172 (the "CID") issued by the Office of the Attorney General of the State of Meridian, Antitrust Division, on August 22, 2025. This letter and the accompanying production of documents, interrogatory responses, and privilege log constitute the Companies' response to the CID. This response is submitted pursuant to the extended deadline of November 3, 2025, as granted by your office in its letter dated September 26, 2025, in which the Attorney General's office agreed to extend the original response date of October 6, 2025, by twenty-eight days to accommodate the volume and complexity of the responsive materials at issue. In addition, this response conforms in all respects to the agreed-upon scope narrowing of certain document requests, which was memorialized in the Attorney General's letter dated October 21, 2025, following the meet-and-confer conference held on October 17, 2025, between undersigned counsel and Senior Assistant Attorney General Derek Montague and yourself.
The Companies have endeavored in good faith to respond to each of the CID's demands in a thorough and timely manner, consistent with their obligations under Meridian law. Nothing in this response, however, should be construed as a waiver of any objection, right, or privilege that DEH or DFS may assert now or in the future with respect to the CID or this investigation. The Companies' specific responses, objections, and reservations are set forth in detail below.
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 DFS, and have produced all non-privileged documents identified as responsive to the Document Requests, subject to the General Objections and specific objections set forth herein.
The production consists of a total of 18,742 documents, comprising 87,316 pages, bearing Bates numbers DEH-MERID-000001 through DEH-MERID-087316. The documents are produced in the following format:
•  All documents, with the exception of spreadsheets and databases, are produced in single-page TIFF image format, accompanied by extracted text files (.txt) for each document, a metadata load file in Ashgrove Technologies format (.dat), and an image load file (.opt). These files are organized by custodian and document family, and the load files contain all standard metadata fields, including but not limited to document date, author, recipient(s), carbon-copy recipients, file name, file path, file type, and custodian.
•  Spreadsheets (including Ashbury Holdings Excel files and CSV files) and databases (including Ridgeway Data Systems databases) have been produced in their native format to preserve formulas, embedded data, macros, and other functionality that would be lost or materially degraded if converted to TIFF image format. Each native-format file has been assigned a unique Bates number for tracking purposes, and the corresponding metadata has been included in the Ashgrove Technologies load file.
The production is delivered on two encrypted USB drives, designated as Drive A and Drive B, both of which are password-protected using AES-256 encryption. The password necessary to access the contents of Drives A and B will be transmitted separately to your office via telephone, in accordance with the parties' agreement regarding the secure handling of electronically stored information. Drive A contains documents bearing Bates numbers DEH-MERID-000001 through DEH-MERID-050000, and Drive B contains documents bearing Bates numbers DEH-MERID-050001 through DEH-MERID-087316, together with the complete Ashgrove Technologies load file, image load file, and extracted text files for the entire production.
The Companies reserve the right to supplement this production as additional responsive documents are identified through the ongoing collection and review process. In particular, DEH and DFS are continuing to process and review certain legacy electronic archives and backup tapes that were identified during the collection process. Should additional responsive, non-privileged documents be identified, the Companies will produce them on a rolling basis and will promptly notify your office of any supplemental production.
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 the failure to assert a General Objection with respect to any particular request constitute a waiver of that objection.
Objection 1 — Privilege. DEH and DFS object to each Document Request and Interrogatory to the extent it seeks, calls for, or would require the disclosure of information or documents protected by the attorney-client privilege, the work-product doctrine, the joint-defense privilege, or any other applicable privilege, immunity, or protection recognized under federal or Meridian state law. No production or disclosure of any privileged material is intended, and any inadvertent production of privileged material shall not constitute a waiver of any applicable privilege. The Companies have taken reasonable steps to identify and withhold privileged documents from production, and a privilege log describing such documents is enclosed as Exhibit B.
Objection 2 — Overbreadth and Burden. DEH and DFS object to each Document Request and Interrogatory to the extent it is overbroad, unduly burdensome, or disproportionate to the needs of the investigation. DEH is a multinational energy holding company with operations spanning twelve states and three Canadian provinces, and DFS is a substantial operating subsidiary with multiple business divisions and thousands of employees. Certain requests, as originally drafted, would have required the Companies to search, collect, review, and produce millions of documents across the entirety of their operations, including documents having no conceivable relevance to the subject matter of the investigation. The Companies have interpreted each request reasonably and in good faith, consistent with the scope narrowing agreed upon by the parties, and have limited their searches accordingly.
Objection 3 — Confidentiality and Trade Secrets. DEH and DFS object to each Document Request and Interrogatory to the extent it seeks proprietary, confidential, or trade-secret information, the disclosure of which could cause competitive harm to the Companies. A significant portion of the documents produced herein contain commercially sensitive information, including but not limited to pricing strategies, margin analyses, cost structures, customer lists, and competitive-intelligence assessments. Pending the entry of an appropriate protective order governing the use and dissemination of confidential materials produced in this investigation, the Companies have designated certain documents as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY" in accordance with the confidentiality designations discussed during the October 17, 2025 meet-and-confer. DEH and DFS respectfully request that the Attorney General's office treat all materials bearing such designations in accordance with the terms of any protective order ultimately entered, and reserve the right to modify confidentiality designations at any time, including the right to upgrade or downgrade the designation of any particular document upon further review.
Objection 4 — Possession, Custody, or Control. DEH and DFS object to each Document Request and Interrogatory to the extent it seeks or purports to require the production of documents or information that is not in the possession, custody, or control of DEH or DFS. The Companies are not in a position to produce documents held exclusively by third parties, including but not limited to competitors, trade associations, government agencies, or unaffiliated vendors and suppliers. The Companies have limited their search and production to documents within their own possession, custody, or control, as those terms are understood under applicable law.
Objection 5 — Preservation of Rights. The assertion of these General Objections does not constitute a waiver of any specific objection, right, or privilege that DEH or DFS may assert herein or in any future response, proceeding, or court filing. The Companies expressly reserve the right to assert additional objections at any time, including objections based on grounds not specifically identified in this response.
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 DFS in connection with fuel-supply contracts issued by the Meridian Department of Transportation ("Meridian DOT") during Fiscal Years 2022 through 2024.
Subject to the General Objections stated above, DEH and DFS have conducted a reasonable and diligent search of their files, records, and electronically stored information for documents responsive to Requests 1 through 6. The search encompassed the electronic files and email accounts of all DFS personnel identified as having been involved in the preparation, review, approval, or submission of bids for Meridian DOT fuel-supply contracts during the relevant period, as well as relevant shared drives, document management systems, and physical files maintained by DFS's Government Contracts Division.
Responsive documents have been produced and bear Bates numbers DEH-MERID-000001 through DEH-MERID-034219. The produced documents include, without limitation, the following categories of materials:
•  Copies of all bid submissions and price proposals submitted by DFS in response to Meridian DOT Requests for Proposals for fuel-supply contracts during Fiscal Years 2022, 2023, and 2024;
•  Internal analyses, memoranda, and presentations prepared in support of each bid submission, including pricing models, cost-basis analyses, volume projections, and risk assessments;
•  Bid/no-bid decision memoranda and related correspondence;
•  Documents reflecting DFS's evaluation of the terms and conditions of each Meridian DOT Request for Proposals; and
•  Post-bid analyses evaluating the outcome of each procurement.
The production covers all five geographic lots into which Meridian DOT fuel-supply contracts are organized: Lot A — Northern Meridian, Lot B — Central Meridian, Lot C — Southern Meridian, Lot D — Eastern Meridian, and Lot E — Western Meridian. DFS submitted bids for all five lots in Fiscal Years 2022 and 2024, and for Lots A, B, and C in Fiscal Year 2023.
B. Document Requests 7–12 (Communications with Competitors)
Requests 7 through 12 seek communications between DFS personnel and employees of Galloway Petroleum Corp. ("Galloway") and Ridgeline Energy Partners LLC ("Ridgeline") during the period January 2021 through December 2024.
Subject to the General Objections stated above, DEH and DFS specifically object to these requests as originally drafted. As issued, Requests 7 through 12 sought "all communications, whether written, electronic, or oral, regardless of subject matter" between any employee, officer, director, or agent of DFS and any employee, officer, director, or agent of Galloway or Ridgeline during the four-year period specified. DEH and DFS objected to these requests as facially overbroad and unduly burdensome, as they would have required the Companies to collect and review every communication between DFS personnel and employees of two large, publicly traded energy companies over a four-year period, including communications on subjects entirely unrelated to Meridian DOT fuel-supply contracts or any conceivable subject of this investigation, such as routine industry correspondence, safety bulletins, joint venture operations in other states, and personal communications.
These objections were raised during the meet-and-confer conference held on October 17, 2025, and the parties subsequently agreed to narrow the scope of Requests 7 through 12 as memorialized in the Attorney General's letter dated October 21, 2025. Pursuant to that agreement, the Companies have produced communications falling within the following narrowed categories:
(i) Communications that reference the Meridian Department of Transportation, any Meridian state fuel-supply contract, or any Meridian state procurement process;
(ii) Communications that concern fuel pricing, fuel supply, or bid strategy in the State of Meridian, whether or not a specific Meridian DOT procurement is identified;
(iii) Communications that relate to any meeting, telephone call, conference, gathering, or other event at which fuel pricing or bidding was discussed among competitors, whether formal or informal in nature; or
(iv) Communications that were exchanged within thirty (30) days before or after the submission deadline for any Meridian DOT Request for Proposals during the period January 2021 through December 2024, regardless of subject matter, to the extent such communications were between DFS personnel and Galloway or Ridgeline personnel who had any involvement in Meridian DOT fuel-supply bidding.
Subject to the foregoing objections and the agreed-upon narrowing, DEH and DFS have conducted a reasonable and diligent search for responsive communications, including searches of email accounts, instant messaging platforms, text messages (where available from company-issued devices), and physical files. Responsive documents have been produced and bear Bates numbers DEH-MERID-034220 through DEH-MERID-062488.
C. Document Requests 13–18 (Pricing Analyses and Competitive intelligence)
Requests 13 through 18 seek internal pricing analyses, margin calculations, competitive-intelligence reports, and related documents prepared by or on behalf of DFS in connection with Meridian DOT fuel-supply bids.
Subject to the General Objections stated above, DEH and DFS have conducted a reasonable and diligent search of their files, records, and electronically stored information for documents responsive to Requests 13 through 18. The search encompassed the files and email accounts of DFS personnel in the Government Contracts Division, the Pricing and Analytics Group, and the Business Development Department, as well as relevant shared network drives and the DFS document management system.
Responsive documents have been produced and bear Bates numbers DEH-MERID-062489 through DEH-MERID-078104. The produced documents include, without limitation:
•  Internal pricing analyses prepared by DFS's Pricing and Analytics Group in connection with each Meridian DOT fuel-supply bid during the period January 2021 through December 2024;
•  Margin calculations, cost-of-goods-sold analyses, and profitability models for each geographic lot;
•  Competitive-intelligence reports prepared by DFS's Business Development Department, including analyses of competitors' publicly available pricing, market-share estimates, and assessments of likely competitor bidding strategies; and
•  Presentations and memoranda circulated to DFS management in connection with bid strategy discussions.
DEH and DFS note that many of the documents produced in response to Requests 13 through 18 contain highly sensitive commercial information, including proprietary pricing methodologies, cost structures, and competitive assessments. These documents have been designated as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY" pending the entry of an appropriate protective order, and the Companies respectfully request that the Attorney General's office accord these materials the highest degree of confidential treatment.
D. Document Requests 19–22 (Competitor Meetings and Contacts)
Requests 19 through 22 seek documents reflecting meetings, telephone calls, or other contacts between DFS personnel and representatives of competing firms concerning fuel pricing, customer allocation, or bid strategy in the State of Meridian.
Subject to the General Objections stated above, DEH and DFS have conducted a reasonable and diligent search for documents responsive to Requests 19 through 22. The search encompassed calendars, meeting notes, expense reports reflecting travel to industry events or meetings, call logs, and correspondence reflecting the scheduling or outcome of any contacts with competitors.
Responsive documents have been produced and bear Bates numbers DEH-MERID-078105 through DEH-MERID-083972. The produced documents include, without limitation:
•  Calendar entries, meeting invitations, and related correspondence reflecting scheduled and actual meetings between DFS personnel and representatives of Galloway, Ridgeline, and other competitors;
•  Notes, memoranda, and summaries of meetings, telephone calls, and other contacts at which fuel pricing, customer allocation, or bid strategy in the State of Meridian was discussed;
•  Expense reports and travel records reflecting attendance at industry conferences, trade-association events, and other gatherings at which competitors were present; and
•  Internal reports or summaries prepared by DFS personnel following contacts with competitors.
E. Document Requests 23–24 (Organizational Information)
Requests 23 and 24 seek organizational charts, reporting structures, and position descriptions for all DFS personnel involved in the Meridian DOT bidding process during the relevant period of January 2021 through December 2024.
Subject to the General Objections stated above, responsive documents have been produced and bear Bates numbers DEH-MERID-083973 through DEH-MERID-087316. The produced documents include the following:
•  Organizational charts for the DFS Government Contracts Division, the Pricing and Analytics Group, the Business Development Department, and other DFS business units that participated in or supported the Meridian DOT bidding process, current as of each fiscal year during the relevant period;
•  Reporting-structure diagrams showing the chain of command from individual bid-team members through divisional management to the DFS executive team and, where applicable, to DEH corporate officers with oversight responsibility;
•  Position descriptions, job specifications, and role summaries for all DFS personnel identified as having participated in the preparation, review, approval, or submission of Meridian DOT fuel-supply bids; and
•  Personnel rosters listing the names, titles, and departmental assignments of relevant DFS employees during each year of the relevant period.
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 address the following subjects:
Interrogatories 1 through 3 require the identification of all DFS employees who participated in the preparation or submission of bids for Meridian DOT fuel-supply contracts during the relevant period, including each such employee's role in the bidding process, their job title during the relevant period, and the identity of their direct supervisor(s). The Companies have identified a total of forty-seven (47) DFS employees who participated in the bidding process in one or more capacities during the period January 2021 through December 2024, and have provided the requested information for each individual.
Interrogatory 4 requires the identification of all DFS employees who had communications with personnel of Galloway Petroleum Corp. or Ridgeline Energy Partners LLC during the relevant period, and a description of the substance of those communications. The Companies have identified all such employees to the best of their knowledge and belief, based on the document review conducted in connection with this response, and have described the substance of the identified communications to the extent such substance is known or can be reasonably ascertained from available documents and the recollections of the identified employees.
Interrogatory 5 requires a description of DFS's pricing methodology for fuel-supply bids submitted to the Meridian Department of Transportation. The Companies have provided a narrative description of DFS's general pricing methodology, including the inputs, models, and approval processes utilized by DFS in developing price proposals for Meridian DOT fuel-supply contracts.
Interrogatory 6 requires the identification of all trade-association memberships held by DFS and its employees during the relevant period. The Companies have identified all trade-association memberships maintained by DFS at the corporate level, as well as individual memberships held by DFS employees in their professional capacities, to the extent such memberships are reflected in DFS's corporate records.
The Companies reserve the right to supplement or amend the interrogatory responses as additional information becomes available.
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 End: The ending Bates number assigned to the withheld document.
•  Date: The date of the document, or the approximate date if the precise date cannot be determined.
•  Author: The author or originator of the document.
•  Recipient(s): The recipient(s) of the document.
•  CC: Any individuals copied on the document.
•  Document Type: The type of document (e.g., email, memorandum, letter, presentation, notes).
•  Subject/Description: A general description of the subject matter of the document, stated with sufficient specificity to enable the Attorney General's office to assess the applicability of the claimed privilege, without disclosing the substance of the privileged communication or mental impressions of counsel.
•  Basis for Privilege: The specific privilege or protection asserted (i.e., attorney-client privilege, work-product doctrine, or both).
Individual privilege log entries have been provided for all unique privileged documents. In certain limited instances, categorical entries have been used where groups of documents share common characteristics, such as recurring legal-department distribution lists through which privileged legal advice was disseminated on a periodic basis. The use of categorical entries is consistent with the format discussed and agreed upon by the parties during the October 17, 2025 meet-and-confer conference with Senior Assistant Attorney General Derek Montague. Should the Attorney General's office require additional detail with respect to any categorical entry, the Companies are prepared to discuss such entries and to provide individualized log entries upon request.
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 document production and interrogatory responses enclosed herewith.
The Companies respectfully request that the Attorney General's office provide at least thirty (30) days' advance notice of any scheduled corporate representative examination, together with a description of the subject-matter areas on which testimony will be sought, so that the Companies may identify and prepare the most knowledgeable representative(s) for each designated topic. This request is consistent with the representation made by Senior Assistant Attorney General Derek Montague during the October 17, 2025 meet-and-confer conference, at which Mr. Montague indicated that the Attorney General's office would provide reasonable advance notice and would identify the subject-matter areas in advance of any scheduled examination.
During the meet-and-confer, Mr. Montague further indicated that the Attorney General's office anticipates scheduling oral examinations in January 2026, and the Companies are prepared to accommodate that timeline, subject to the availability of appropriate witnesses and counsel. The Companies look forward to working cooperatively with the Attorney General's office to schedule the examinations at a mutually agreeable time and location.
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, or further negotiation with the Attorney General's office regarding the scope of the CID;
(b) The right to assert additional objections to any Document Request, Interrogatory, or other demand contained in the CID, including objections not previously raised, whether based on grounds of privilege, relevance, overbreadth, burden, proportionality, or any other legally recognized basis;
(c) The right to challenge the legal sufficiency of the CID, including the statutory authority under which the CID was issued, the scope of the investigation, and the relevance and materiality of the information demanded;
(d) The right to move to quash, modify, or limit the CID in any court of competent jurisdiction in the State of Meridian or elsewhere, including the right to seek judicial review of any determination by the Attorney General's office regarding the sufficiency of the Companies' response or the validity of any privilege claim.
Nothing in this response, in the production of documents, in the interrogatory responses, or in any other action taken by DEH or DFS in connection with this investigation constitutes, or shall be construed as, an admission or acknowledgment by DEH, DFS, or any of their officers, directors, employees, or agents of any wrongdoing, liability, or violation of any federal, state, or local law, regulation, or statute, including but not limited to the Meridian Antitrust Act, the Meridian Unfair Trade Practices Act, or any other antitrust or competition law.
Nothing in this response constitutes a waiver of the attorney-client privilege, the work-product doctrine, the joint-defense privilege, or any other applicable privilege, immunity, or protection. Any inadvertent disclosure of privileged or protected materials shall not operate as a waiver of any privilege or protection, and DEH and DFS reserve the right to seek the return of any inadvertently produced privileged materials pursuant to applicable law and rules of procedure.
We trust that the enclosed production, interrogatory responses, and privilege log are responsive to the CID. Should you have any questions regarding this response or wish to discuss any aspect of the production, please do not hesitate to contact the undersigned.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Howard Bellamy Partner, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-0132
Email: hbellamy@calderwoodharkness.com
Enclosures:
1.  Production Drives A and B (encrypted USB drives, password-protected)
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)
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 LLC