CALDERWOOD & HARKNESS LLP 1900 K Street NW, Suite 1100 Washington, DC 20006

September 22, 2025

VIA EMAIL AND FIRST-CLASS MAIL

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

Re: Civil Investigative Demand No. AG-ANT-2025-04172 Dunmore Energy Holdings Ltd. and Dunmore Fuel Supply, Inc. Request for Extension of Time

Dear Ms. Brennan:

This firm represents Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary Dunmore Fuel Supply, Inc. ("DFS") (collectively, "Respondents") in connection with Civil Investigative Demand No. AG-ANT-2025-04172 (the "CID"), issued by the Antitrust Division of the Office of the Attorney General on August 22, 2025. We write on behalf of Respondents to respectfully request a thirty (30) day extension of the deadline to respond to the CID, from the current deadline of October 3, 2025 — forty calendar days from the date of issuance — to November 3, 2025. As set forth in detail below, this request is grounded in the substantial volume and complexity of the materials implicated by the CID, the good-faith efforts already being undertaken to ensure a complete and thorough response, and the absence of any prejudice to the Attorney General's investigation that would result from the requested extension.

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 December 2024 — and a review of organizational charts, reporting lines, and key personnel involved in DFS's fuel-supply contracting and pricing operations, the Respondents have identified five (5) key custodians whose files are likely to contain the most significant body of responsive materials:

(a) Terrence Kinloch, Vice President, Government Contracts, DFS — Mr. Kinloch's custodial data comprises approximately 42.7 gigabytes, representing an estimated 186,000 documents, including email correspondence, attachments, contract files, and bid-preparation materials;

(b) Sandra Ochoa, Director of Pricing & Analytics, DFS — Ms. Ochoa's custodial data comprises approximately 31.4 gigabytes, representing an estimated 142,000 documents, including pricing models, analytics workbooks, competitive intelligence memoranda, and related correspondence;

(c) Nolan Prescott, Regional Sales Manager, Southeastern United States, DFS — Mr. Prescott's custodial data comprises approximately 18.9 gigabytes, representing an estimated 95,000 documents, including sales reports, customer communications, territory planning documents, and field-level competitive analyses;

(d) Patricia Aldridge, Senior Vice President & General Counsel, DEH — Ms. Aldridge's custodial data comprises approximately 27.3 gigabytes, representing an estimated 118,000 documents, including legal memoranda, compliance files, board and committee materials, and related correspondence; and

(e) Malcolm Haverford, Chief Executive Officer, DEH — Mr. Haverford's custodial data comprises approximately 12.1 gigabytes, representing an estimated 63,000 documents, including executive correspondence, strategic planning documents, and board presentations.

In total, the custodial data identified to date amounts to approximately 132.4 gigabytes, comprising an estimated 604,000 documents. This figure does not account for a number of additional non-custodial data sources that are also under collection and that are reasonably expected to contain responsive materials. These non-custodial sources include shared network drives maintained by DFS's Government Contracts and Pricing & Analytics departments; the DFS FuelPricer proprietary pricing database, which houses transactional pricing data, cost-plus margin calculations, and contract-lot modeling outputs; the DEH/DFS Ashgrove Software tenant, encompassing Drayton Solutions mailboxes, Aldermere Systems document libraries, and Northgate Data Systems channels and chats; the DFS Quillon Data Systems instance, which contains customer relationship records, opportunity pipelines, and account-level communication logs; and archived email from the Brightwater Solutions system, which houses legacy email data for departed employees and mailboxes that have exceeded the active-retention window.

The scope of the CID further expands the universe of potentially responsive materials. The four-year investigative period from January 2021 through December 2024 spans five geographic contract lots — encompassing state and municipal fuel-supply contracts across the southeastern, mid-Atlantic, and Gulf Coast regions — and three distinct fiscal-year bidding cycles. Each of these contract lots and bidding cycles generated its own body of bid-preparation documents, pricing submissions, correspondence with contracting authorities, internal analyses, and related files. The breadth and depth of this data universe make it impracticable for Respondents to complete the collection, processing, review, and production of responsive materials within the current forty-day response window.

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 knowledge of the matters under investigation. A thorough and legally defensible response to these demands requires comprehensive, multi-layered review of the collected materials for relevance and responsiveness to each individual request, for attorney-client privilege, attorney work-product protection, and any other applicable protections, and for confidentiality designations that may be warranted with respect to commercially sensitive pricing data, trade secrets, and competitively sensitive business information.

To manage this complex and data-intensive review, DEH and DFS have retained Brindoval Analytics LLC, an electronic discovery and digital forensics vendor headquartered in Tysons Corner, Virginia, with recognized expertise in large-scale government-investigation matters. Brindoval Analytics has been engaged to perform forensic collection of custodial and non-custodial data, processing and deduplication of the collected dataset, hosting of the review platform, and quality-control and production-management services.

Brindoval Analytics is in the process of implementing a technology-assisted review ("TAR") protocol utilizing a continuous active learning ("CAL") methodology. The CAL workflow requires iterative training of a predictive-coding model by subject-matter-expert attorneys who review and code sample documents in successive rounds until the model achieves acceptable precision, recall, and F1-score metrics. Statistical validation must then be performed — using either a random-sample-based elusion test or a coverage analysis — before the model can be applied to the broader document population and production-quality first-pass review can commence. This process, while ultimately more efficient and defensible than linear review for a dataset of this magnitude, is inherently iterative and requires a meaningful investment of time at the front end.

Forensic collection from custodial devices — including laptop hard drives, mobile devices, and cloud-hosted mailboxes and data repositories — commenced on September 19, 2025. Processing, deduplication, and ingestion into the review platform are ongoing. TAR model training cannot begin in earnest until processing is complete and search-term culling has been applied to the deduplicated document population, which Brindoval Analytics currently estimates will be finalized no earlier than October 1, 2025. Thereafter, multiple rounds of TAR training, model validation, first-pass substantive review, second-pass privilege review, and preparation of a detailed privilege log meeting the specifications we anticipate will be required by the Attorney General's office must be completed before a production can responsibly be made.

A thirty-day extension of the response deadline will provide sufficient time for these critical review phases to be completed in a thorough and defensible manner, ensuring that the production is comprehensive, that all applicable privileges and protections are properly asserted, and that the privilege log meets the level of specificity and completeness that the Attorney General's office expects and is entitled to receive.

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 steps to advance that objective. Among the measures already undertaken are the following:

(a) Engagement of Outside Counsel. Calderwood & Harkness LLP was formally engaged to represent DEH and DFS in connection with the CID on August 27, 2025, just two business days after DEH's General Counsel, Patricia Aldridge, first contacted the firm on August 25, 2025. Since engagement, a dedicated team of partners, counsel, and associates has been working full-time on the matter.

(b) Issuance of Litigation-Hold Notices. Written litigation-hold notices were issued to all identified custodians and to relevant information-technology personnel at both DEH and DFS on September 5, 2025. These notices require the immediate preservation of all potentially relevant documents and ESI, including email, electronic files, instant messages, text messages, voicemail, and any other communications or data that may be responsive to the CID. Recipients were instructed to suspend any routine deletion, overwriting, or modification of potentially relevant materials and to confirm receipt and compliance in writing.

(c) Retention of E-discovery Vendor. Brindoval Analytics LLC was retained pursuant to a detailed statement of work executed on September 12, 2025. The Phase 1 engagement — encompassing forensic collection, processing, deduplication, hosting, TAR implementation, and production management — carries an estimated budget of approximately $385,000, reflecting the Respondents' commitment to investing the resources necessary to ensure a defensible and comprehensive response.

(d) Commencement of Forensic Collection. Forensic imaging of custodial laptops, mobile devices, and cloud-hosted data commenced on September 19, 2025. All collections are being performed with defensible chain-of-custody documentation, including detailed collection logs, hash verification (using both MD5 and SHA-256 algorithms) to confirm data integrity, and secure transfer and storage protocols.

(e) Suspension of Auto-Deletion Policies. Automated data-retention and deletion policies — including email-retention policies governing mailbox-size management, Northgate Data Systems retention policies governing chat and channel message expiration, and backup-tape recycling schedules — have been suspended for all identified custodians and non-custodial data sources to prevent any inadvertent destruction or loss of potentially responsive materials during the pendency of the investigation.

These steps reflect Respondents' earnest and ongoing commitment to meeting their discovery obligations in full. The requested extension will enable Respondents to build upon these efforts and deliver a production that is complete, accurate, and responsive to the Attorney General's investigative needs.

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 August 22, 2025. Neither DEH nor DFS is aware of any pending statute-of-limitations concerns, imminent filing deadlines, or other time-sensitive matters that would be adversely affected by a thirty-day extension of the response deadline.

Moreover, all potentially responsive documents and ESI are presently subject to the comprehensive litigation hold described above and are being preserved in their current state with full chain-of-custody documentation. There is no risk that the passage of an additional thirty days will result in the loss, degradation, or alteration of any responsive materials. The integrity of the evidentiary record is fully secured.

Finally, the extended deadline of November 3, 2025, would still afford the Attorney General's office ample time to review the Respondents' production and to schedule any follow-up proceedings it deems appropriate, including the oral examination of corporate representatives referenced in the CID. Respondents are prepared to work cooperatively with the Attorney General's office to schedule any such proceedings at a mutually convenient time following the production.

Meet and Confer

Calderwood & Harkness welcomes the opportunity to discuss this extension request at the Attorney General's office's earliest convenience, whether by telephone or videoconference. We are available at your discretion and will accommodate any schedule that works for your team.

Additionally, and separately from the extension request, Calderwood & Harkness would welcome the opportunity to meet and confer with your office regarding the scope of certain document requests contained in the CID. In particular, Requests 7 through 12 seek "all communications" between DFS and DEH personnel, on the one hand, and employees of Galloway Petroleum Corp. and Ridgeline Energy Partners LLC, on the other, "regardless of subject matter." We believe that these requests, as currently drafted, may sweep in a substantial volume of materials that bear no relevance to the subject matter of the investigation — including, for example, routine industry-association correspondence, social communications, and unrelated commercial transactions — and that the requests may be narrowed in ways that would facilitate a more efficient and focused production without in any way compromising the Attorney General's investigative objectives. We raise this point in a spirit of cooperation and with the goal of ensuring that the Respondents' production is as useful and targeted as possible for the Attorney General's review team.

We thank the Attorney General's office for its consideration of this request. Should your office require any additional information or documentation in connection with this matter, please do not hesitate to contact the undersigned directly. We look forward to working cooperatively with your office throughout this investigation.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Howard Bellamy Partner, Antitrust & Competition Telephone: (202) 555-0132

Email: hbellamy@calderwoodharkness.com

cc: Patricia Aldridge, SVP & General Counsel, Dunmore Energy Holdings Ltd. (via email) Derek Montague, Senior Assistant Attorney General, Chief, Antitrust Division, Office of the Attorney General (via email)

CALDERWOOD & HARKNESS LLP 1900 K Street NW, Suite 1100 Washington, DC 20006
September 22, 2025
VIA EMAIL AND FIRST-CLASS MAIL
Alicia Brennan, Esq. Assistant Attorney General Antitrust Division Office of the Attorney General 500 Capitol Avenue, Suite 300 Baxter City, Meridian 39201
Re: Civil Investigative Demand No. AG-ANT-2025-04172 Dunmore Energy Holdings Ltd. and Dunmore Fuel Supply, Inc. Request for Extension of Time
Dear Ms. Brennan:
This firm represents Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary Dunmore Fuel Supply, Inc. ("DFS") (collectively, "Respondents") in connection with Civil Investigative Demand No. AG-ANT-2025-04172 (the "CID"), issued by the Antitrust Division of the Office of the Attorney General on August 22, 2025. We write on behalf of Respondents to respectfully request a thirty (30) day extension of the deadline to respond to the CID, from the current deadline of October 3, 2025 — forty calendar days from the date of issuance — to November 3, 2025. As set forth in detail below, this request is grounded in the substantial volume and complexity of the materials implicated by the CID, the good-faith efforts already being undertaken to ensure a complete and thorough response, and the absence of any prejudice to the Attorney General's investigation that would result from the requested extension.
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 December 2024 — and a review of organizational charts, reporting lines, and key personnel involved in DFS's fuel-supply contracting and pricing operations, the Respondents have identified five (5) key custodians whose files are likely to contain the most significant body of responsive materials:
(a) Terrence Kinloch, Vice President, Government Contracts, DFS — Mr. Kinloch's custodial data comprises approximately 42.7 gigabytes, representing an estimated 186,000 documents, including email correspondence, attachments, contract files, and bid-preparation materials;
(b) Sandra Ochoa, Director of Pricing & Analytics, DFS — Ms. Ochoa's custodial data comprises approximately 31.4 gigabytes, representing an estimated 142,000 documents, including pricing models, analytics workbooks, competitive intelligence memoranda, and related correspondence;
(c) Nolan Prescott, Regional Sales Manager, Southeastern United States, DFS — Mr. Prescott's custodial data comprises approximately 18.9 gigabytes, representing an estimated 95,000 documents, including sales reports, customer communications, territory planning documents, and field-level competitive analyses;
(d) Patricia Aldridge, Senior Vice President & General Counsel, DEH — Ms. Aldridge's custodial data comprises approximately 27.3 gigabytes, representing an estimated 118,000 documents, including legal memoranda, compliance files, board and committee materials, and related correspondence; and
(e) Malcolm Haverford, Chief Executive Officer, DEH — Mr. Haverford's custodial data comprises approximately 12.1 gigabytes, representing an estimated 63,000 documents, including executive correspondence, strategic planning documents, and board presentations.
In total, the custodial data identified to date amounts to approximately 132.4 gigabytes, comprising an estimated 604,000 documents. This figure does not account for a number of additional non-custodial data sources that are also under collection and that are reasonably expected to contain responsive materials. These non-custodial sources include shared network drives maintained by DFS's Government Contracts and Pricing & Analytics departments; the DFS FuelPricer proprietary pricing database, which houses transactional pricing data, cost-plus margin calculations, and contract-lot modeling outputs; the DEH/DFS Ashgrove Software tenant, encompassing Drayton Solutions mailboxes, Aldermere Systems document libraries, and Northgate Data Systems channels and chats; the DFS Quillon Data Systems instance, which contains customer relationship records, opportunity pipelines, and account-level communication logs; and archived email from the Brightwater Solutions system, which houses legacy email data for departed employees and mailboxes that have exceeded the active-retention window.
The scope of the CID further expands the universe of potentially responsive materials. The four-year investigative period from January 2021 through December 2024 spans five geographic contract lots — encompassing state and municipal fuel-supply contracts across the southeastern, mid-Atlantic, and Gulf Coast regions — and three distinct fiscal-year bidding cycles. Each of these contract lots and bidding cycles generated its own body of bid-preparation documents, pricing submissions, correspondence with contracting authorities, internal analyses, and related files. The breadth and depth of this data universe make it impracticable for Respondents to complete the collection, processing, review, and production of responsive materials within the current forty-day response window.
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 knowledge of the matters under investigation. A thorough and legally defensible response to these demands requires comprehensive, multi-layered review of the collected materials for relevance and responsiveness to each individual request, for attorney-client privilege, attorney work-product protection, and any other applicable protections, and for confidentiality designations that may be warranted with respect to commercially sensitive pricing data, trade secrets, and competitively sensitive business information.
To manage this complex and data-intensive review, DEH and DFS have retained Brindoval Analytics LLC, an electronic discovery and digital forensics vendor headquartered in Tysons Corner, Virginia, with recognized expertise in large-scale government-investigation matters. Brindoval Analytics has been engaged to perform forensic collection of custodial and non-custodial data, processing and deduplication of the collected dataset, hosting of the review platform, and quality-control and production-management services.
Brindoval Analytics is in the process of implementing a technology-assisted review ("TAR") protocol utilizing a continuous active learning ("CAL") methodology. The CAL workflow requires iterative training of a predictive-coding model by subject-matter-expert attorneys who review and code sample documents in successive rounds until the model achieves acceptable precision, recall, and F1-score metrics. Statistical validation must then be performed — using either a random-sample-based elusion test or a coverage analysis — before the model can be applied to the broader document population and production-quality first-pass review can commence. This process, while ultimately more efficient and defensible than linear review for a dataset of this magnitude, is inherently iterative and requires a meaningful investment of time at the front end.
Forensic collection from custodial devices — including laptop hard drives, mobile devices, and cloud-hosted mailboxes and data repositories — commenced on September 19, 2025. Processing, deduplication, and ingestion into the review platform are ongoing. TAR model training cannot begin in earnest until processing is complete and search-term culling has been applied to the deduplicated document population, which Brindoval Analytics currently estimates will be finalized no earlier than October 1, 2025. Thereafter, multiple rounds of TAR training, model validation, first-pass substantive review, second-pass privilege review, and preparation of a detailed privilege log meeting the specifications we anticipate will be required by the Attorney General's office must be completed before a production can responsibly be made.
A thirty-day extension of the response deadline will provide sufficient time for these critical review phases to be completed in a thorough and defensible manner, ensuring that the production is comprehensive, that all applicable privileges and protections are properly asserted, and that the privilege log meets the level of specificity and completeness that the Attorney General's office expects and is entitled to receive.
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 steps to advance that objective. Among the measures already undertaken are the following:
(a) Engagement of Outside Counsel. Calderwood & Harkness LLP was formally engaged to represent DEH and DFS in connection with the CID on August 27, 2025, just two business days after DEH's General Counsel, Patricia Aldridge, first contacted the firm on August 25, 2025. Since engagement, a dedicated team of partners, counsel, and associates has been working full-time on the matter.
(b) Issuance of Litigation-Hold Notices. Written litigation-hold notices were issued to all identified custodians and to relevant information-technology personnel at both DEH and DFS on September 5, 2025. These notices require the immediate preservation of all potentially relevant documents and ESI, including email, electronic files, instant messages, text messages, voicemail, and any other communications or data that may be responsive to the CID. Recipients were instructed to suspend any routine deletion, overwriting, or modification of potentially relevant materials and to confirm receipt and compliance in writing.
(c) Retention of E-discovery Vendor. Brindoval Analytics LLC was retained pursuant to a detailed statement of work executed on September 12, 2025. The Phase 1 engagement — encompassing forensic collection, processing, deduplication, hosting, TAR implementation, and production management — carries an estimated budget of approximately $385,000, reflecting the Respondents' commitment to investing the resources necessary to ensure a defensible and comprehensive response.
(d) Commencement of Forensic Collection. Forensic imaging of custodial laptops, mobile devices, and cloud-hosted data commenced on September 19, 2025. All collections are being performed with defensible chain-of-custody documentation, including detailed collection logs, hash verification (using both MD5 and SHA-256 algorithms) to confirm data integrity, and secure transfer and storage protocols.
(e) Suspension of Auto-Deletion Policies. Automated data-retention and deletion policies — including email-retention policies governing mailbox-size management, Northgate Data Systems retention policies governing chat and channel message expiration, and backup-tape recycling schedules — have been suspended for all identified custodians and non-custodial data sources to prevent any inadvertent destruction or loss of potentially responsive materials during the pendency of the investigation.
These steps reflect Respondents' earnest and ongoing commitment to meeting their discovery obligations in full. The requested extension will enable Respondents to build upon these efforts and deliver a production that is complete, accurate, and responsive to the Attorney General's investigative needs.
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 August 22, 2025. Neither DEH nor DFS is aware of any pending statute-of-limitations concerns, imminent filing deadlines, or other time-sensitive matters that would be adversely affected by a thirty-day extension of the response deadline.
Moreover, all potentially responsive documents and ESI are presently subject to the comprehensive litigation hold described above and are being preserved in their current state with full chain-of-custody documentation. There is no risk that the passage of an additional thirty days will result in the loss, degradation, or alteration of any responsive materials. The integrity of the evidentiary record is fully secured.
Finally, the extended deadline of November 3, 2025, would still afford the Attorney General's office ample time to review the Respondents' production and to schedule any follow-up proceedings it deems appropriate, including the oral examination of corporate representatives referenced in the CID. Respondents are prepared to work cooperatively with the Attorney General's office to schedule any such proceedings at a mutually convenient time following the production.
Meet and Confer
Calderwood & Harkness welcomes the opportunity to discuss this extension request at the Attorney General's office's earliest convenience, whether by telephone or videoconference. We are available at your discretion and will accommodate any schedule that works for your team.
Additionally, and separately from the extension request, Calderwood & Harkness would welcome the opportunity to meet and confer with your office regarding the scope of certain document requests contained in the CID. In particular, Requests 7 through 12 seek "all communications" between DFS and DEH personnel, on the one hand, and employees of Galloway Petroleum Corp. and Ridgeline Energy Partners LLC, on the other, "regardless of subject matter." We believe that these requests, as currently drafted, may sweep in a substantial volume of materials that bear no relevance to the subject matter of the investigation — including, for example, routine industry-association correspondence, social communications, and unrelated commercial transactions — and that the requests may be narrowed in ways that would facilitate a more efficient and focused production without in any way compromising the Attorney General's investigative objectives. We raise this point in a spirit of cooperation and with the goal of ensuring that the Respondents' production is as useful and targeted as possible for the Attorney General's review team.
We thank the Attorney General's office for its consideration of this request. Should your office require any additional information or documentation in connection with this matter, please do not hesitate to contact the undersigned directly. We look forward to working cooperatively with your office throughout this investigation.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Howard Bellamy Partner, Antitrust & Competition Telephone: (202) 555-0132
Email: hbellamy@calderwoodharkness.com
cc: Patricia Aldridge, SVP & General Counsel, Dunmore Energy Holdings Ltd. (via email) Derek Montague, Senior Assistant Attorney General, Chief, Antitrust Division, Office of the Attorney General (via email)

CALDERWOOD & HARKNESS LLP 1900 K Street NW, Suite 1100 Washington, DC 20006

VIA EMAIL AND FIRST-CLASS MAIL

CALDERWOOD & HARKNESS LLP

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