1016-00001 · Dunmore Energy Holdings · Document Collection

litigation-hold-memo.docx DOCUMENT Antitrust

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PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION / WORK PRODUCT

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

MEMORANDUM

TO: Patricia Aldridge, SVP & General Counsel Dunmore Energy Holdings Ltd. 4100 Westchase Boulevard, Suite 1200 Houston, TX 77042

FROM: Monica Reyes, Senior Associate, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006

DATE: September 3, 2025

RE: Document Preservation / Litigation Hold — CID No. AG-ANT-2025-04172 (C&H Matter No. 1016-00001)

I. Purpose

This memorandum outlines the document-preservation obligations of Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary, Dunmore Fuel Supply, Inc. ("DFS"), arising from the Civil Investigative Demand ("CID") issued by the Office of the Attorney General of the State of Meridian, Antitrust Division, on August 22, 2025 (CID Reference No. AG-ANT-2025-04172). The CID was issued pursuant to the authority vested in the Meridian Attorney General under Meridian Code Ann. § 75-21-39, which empowers the Attorney General to issue investigative demands in connection with suspected violations of the Meridian Antitrust Act.

The CID concerns an investigation into alleged bid rigging in connection with fuel-supply contracts awarded by the Meridian State Department of Transportation ("Meridian DOT") during the period from January 2021 through December 2024. The Attorney General's investigation appears to focus on whether DEH and DFS, together with other market participants, coordinated pricing, allocated contract lots, or otherwise engaged in anticompetitive conduct in connection with these publicly procured fuel-supply contracts.

DEH and DFS are named as respondents in the CID. The CID also identifies two co-respondents: Galloway Petroleum Corp. ("GPC"), a Delaware corporation headquartered at 2255 Commerce Park Drive, Suite 800, Birmingham, Alabama 35244; and Ridgeline Energy Partners LLC ("REP"), a Georgia limited liability company headquartered at 600 Peachtree Industrial Blvd, Suite 450, Duluth, Georgia 30097. The inclusion of multiple respondents in a single CID is consistent with the Attorney General's apparent theory of a multi-party conspiracy, and it underscores the seriousness and breadth of the ongoing investigation.

This memorandum is intended to serve as the basis for the litigation-hold notices that DEH's legal department will distribute to relevant custodians and IT personnel. The timely issuance of such notices is a critical first step in ensuring that DEH and DFS satisfy their preservation obligations and avoid any allegation that potentially relevant evidence was destroyed or allowed to degrade after the duty to preserve attached.

Calderwood & Harkness LLP was formally engaged to represent DEH and DFS in connection with this matter on August 27, 2025, pursuant to the executed engagement letter signed by Ms. Aldridge on behalf of both entities. This memorandum constitutes attorney work product and a privileged attorney-client communication. It should be treated as strictly confidential and should not be disclosed to any person outside of DEH's and DFS's authorized legal and management personnel without the prior written consent of Calderwood & Harkness LLP.

II. Preservation Obligation

Upon receipt of the CID on August 22, 2025, DEH and DFS assumed an affirmative legal duty to preserve all documents and electronically stored information ("ESI") that are or may be relevant to the subject matter of the Attorney General's investigation. This preservation obligation is triggered by the receipt of the CID itself and attaches immediately upon such receipt. It is not contingent upon, and does not await, the deadline for substantive compliance with the CID's document requests.

The original CID response deadline is October 3, 2025 — forty (40) calendar days from the date of issuance. However, the duty to preserve is independent of, and precedes, any deadline for the production of responsive documents. From the moment the CID was received, DEH and DFS have been under a continuing obligation to take all reasonable steps to identify, locate, and preserve potentially relevant information, and to ensure that no such information is destroyed, deleted, altered, overwritten, or otherwise rendered inaccessible.

This preservation obligation extends to all forms of information, whether in physical or electronic form, and regardless of the medium or location in which the information resides. Without limitation, the categories of information subject to preservation include:

• Emails, including attachments, headers, and associated metadata

• Text messages (SMS and MMS)

• Instant messages, including communications transmitted through Northgate Data Systems, Meridian Solutions, Meridian Services Inc., Harborline Technologies, and any other messaging platform

• Calendar entries and scheduling records

• Voicemails, whether stored locally on devices or in cloud-based voicemail systems

• Internal and external memoranda, letters, and correspondence

• Spreadsheets, databases, and data exports

• Presentations, including Ashbury Holdings Northgate Services Inc. files and similar formats

• Contracts, agreements, amendments, and related transactional documents

• Pricing models, cost analyses, and margin calculations

• Bid submissions, proposals, and related supporting documentation

• Handwritten notes, including notes taken during meetings, telephone calls, or conferences

• Metadata associated with any of the foregoing categories of information

It is essential that all personnel understand the gravity of these obligations. Spoliation of evidence — that is, the destruction, alteration, or failure to preserve relevant evidence when a duty to preserve exists — may result in severe consequences. Courts may impose sanctions for spoliation, which can include adverse-inference instructions (permitting a fact-finder to infer that destroyed evidence was unfavorable to the spoliating party), monetary penalties, issue preclusion, or, in extreme cases, default judgment. Moreover, the destruction of evidence in the context of a government antitrust investigation may give rise to separate criminal liability under both federal and state obstruction-of-justice statutes. The potential for criminal exposure is particularly acute in this matter given the involvement of the Attorney General's Antitrust Division and the nature of the alleged conduct.

The investigation involves alleged violations of the Meridian Antitrust Act, codified at Meridian Code Ann. § 75-21-1 et seq., including the specific prohibition on bid rigging set forth in § 75-21-3. Violations of the Meridian Antitrust Act may result in substantial civil penalties and treble damages, as well as potential criminal penalties for willful violations. The preservation of all potentially relevant evidence is therefore not merely a procedural obligation — it is a fundamental component of DEH's and DFS's ability to mount an effective defense and to maintain credibility with the Attorney General's office throughout the course of the investigation.

III. Scope of the Hold

The litigation hold encompasses a defined temporal scope, subject-matter scope, set of key custodians, and set of non-custodial data sources, each of which is described in detail below.

A. Temporal Scope

All documents and ESI created, sent, received, modified, or stored during the period from January 1, 2020 through the present must be preserved. This preservation obligation is continuing in nature and will remain in effect until the hold is formally lifted in writing by the Office of the General Counsel of DEH, in consultation with Calderwood & Harkness LLP. No custodian, IT personnel member, or other individual is authorized to terminate or modify this hold absent such express written authorization.

The rationale for the selected preservation period is as follows. Although the CID identifies the alleged conduct period as January 2021 through December 2024, Calderwood & Harkness LLP recommends preserving documents from January 1, 2020 forward in order to capture any pre-conspiracy planning communications, market-intelligence exchanges, preliminary discussions, or preparatory conduct that may have predated the formal alleged conspiracy period. In antitrust investigations of this nature, enforcement authorities frequently seek evidence of initial contacts, exploratory conversations, and early-stage coordination that set the groundwork for the alleged anticompetitive conduct. Communications and documents from the period immediately preceding the alleged conspiracy are therefore highly relevant and must be preserved.

Additionally, the relevant Meridian DOT contracts at issue in the investigation cover Fiscal Year 2022, Fiscal Year 2023, and Fiscal Year 2024. The request-for-proposals ("RFP") and bidding process for the FY 2022 contracts would likely have commenced in late 2020 or early 2021, with market assessments, competitive analyses, and strategic planning potentially occurring even earlier. Preserving documents from January 1, 2020 forward therefore ensures that the full lifecycle of the bidding process for the earliest relevant contracts is captured.

B. Subject-Matter Scope

The litigation hold applies to all documents and ESI relating to the following categories of subject matter:

1. Fuel-Supply Bids and Proposals Submitted to Meridian DOT. This category encompasses all documents relating to fuel-supply bids or proposals submitted to Meridian DOT, including but not limited to RFP documents received from Meridian DOT, internal analyses of RFP requirements, draft and final bid submissions, award notifications, contract execution documents, contract performance records, delivery schedules, compliance certifications, and pricing proposals. This includes documents relating to all five geographic lots established by Meridian DOT for its fuel-supply procurement program:

• Lot A — Northern Meridian: Approximately 6.8 million gallons per year

• Lot B — Central Meridian: Approximately 9.2 million gallons per year

• Lot C — Southern Meridian: Approximately 7.5 million gallons per year

• Lot D — Eastern Meridian: Approximately 8.1 million gallons per year

• Lot E — Western Meridian: Approximately 6.4 million gallons per year

• Total volume across all lots: Approximately 38 million gallons per year

2. Communications with or about Co-Respondents. All communications with or concerning Galloway Petroleum Corp. ("GPC") or any of its employees, officers, directors, agents, or representatives, including but not limited to Richard "Rick" Ellerbee, CEO of GPC, and Constance Barlow, Vice President of Sales at GPC. Similarly, all communications with or concerning Ridgeline Energy Partners LLC ("REP") or any of its employees, members, officers, agents, or representatives, including but not limited to Jonas Hartwick, Managing Partner of REP, and Elaine Pruitt, Director of Business Development at REP. This category includes both formal and informal communications, regardless of the medium or channel through which they were transmitted.

3. Pricing Strategies and Competitive intelligence. All documents relating to pricing strategies, margin analyses, competitive-intelligence reports, cost models, or pricing models for bulk fuel supply in the State of Meridian. This includes, without limitation, any analyses, reports, models, or data exports prepared using or derived from the DFS proprietary pricing database known as "FuelPricer," as well as any benchmarking analyses, market-share estimates, or competitive assessments prepared by or for the DFS pricing and analytics team.

4. Industry Meetings and Competitor Interactions. All documents relating to any industry meetings, trade-association events, conferences, seminars, social gatherings, or informal meetings at which competitors discussed pricing, customers, bid strategy, market allocation, territories, capacity, or any other competitively sensitive topic. This includes agendas, attendance lists, presentation materials, expense reports, travel records, handwritten notes, and any communications before, during, or after such events.

5. Meridian DOT Correspondence and Procurement Records. All Meridian DOT RFP documents, bid solicitations, addenda, award notifications, contract performance records, audit reports, and any correspondence with Meridian DOT procurement officials, contract administrators, or other state personnel involved in the fuel-supply procurement process.

6. Internal Bid-Pricing Approvals. All documents reflecting internal approvals of bid pricing for any Meridian state contract, including emails, memoranda, approval workflows, sign-off sheets, management review materials, and any other records reflecting the process by which proposed bid prices were developed, reviewed, modified, and ultimately approved for submission.

7. Lot Allocation, Bid Rotation, and Cover Bidding. All documents relating to the allocation of contract lots among competitors, rotation of winning bids among market participants, or the submission of complementary bids (also known as "cover" bids, "courtesy" bids, or "phantom" bids). This category is of particular significance to the Attorney General's investigation and encompasses any communications, agreements, understandings, or arrangements — whether formal or informal, written or oral — pursuant to which competitors agreed to submit non-competitive bids, refrain from bidding on certain lots, or otherwise coordinate their bidding conduct.

8. Financial Records Relating to Meridian DOT Contracts. All financial records relating to revenue, costs, margins, profitability, and financial performance on Meridian DOT contracts, including income statements, cost-accounting records, job-cost reports, margin analyses, variance analyses, and any related financial data. It should be noted that DEH's independent auditors, Alderton & Knox, CPAs, LLP ("A&K"), located at 3 Greenway Plaza, Suite 600, Houston, Texas 77046 (engagement partner: Yolanda Matsuda, CPA), may hold bid-related financial records relevant to the investigation, including workpapers, audit schedules, and supporting documentation prepared in connection with A&K's annual audits of DEH. Coordination with A&K regarding the preservation and potential collection of such records should be considered, as discussed further in Section VII below.

C. Key Custodians

Calderwood & Harkness LLP has identified the following five individuals as key custodians whose documents and ESI must be preserved and collected as part of the initial phase of this investigation. These individuals have been selected based on their roles, responsibilities, and likely involvement with the subject matter of the Attorney General's investigation. The estimated data volumes and document counts set forth below are based on preliminary information provided by DEH IT and are subject to revision as additional information becomes available.

The rationale for each custodian's inclusion is as follows:

Terrence "Terry" Kinloch — VP, Government Contracts, DFS. Mr. Kinloch oversaw the Meridian DOT bidding process and served as the primary point of contact for all government contract submissions by DFS during the relevant period. In this capacity, he would have been responsible for coordinating the preparation and submission of DFS's bids for each of the five Meridian DOT geographic lots and would have had direct interactions with Meridian DOT procurement officials. Given the nature of his role, Mr. Kinloch likely communicated with counterparts at GPC and REP, and his files are expected to contain bid-related correspondence, RFP response materials, and internal strategy discussions of central relevance to the investigation.

Sandra Ochoa — Director of Pricing & Analytics, DFS. Ms. Ochoa prepared pricing analyses and competitive-intelligence reports used by DFS in formulating its bids for Meridian DOT contracts. She managed the FuelPricer database — the proprietary internal application used by DFS to model bid prices and analyze competitive positioning — and developed the bid pricing models for each of the Meridian DOT lots. Her files are expected to contain pricing models, cost analyses, margin calculations, competitive benchmarking reports, and related analytical materials that will be central to the Attorney General's investigation of whether bid prices were the product of independent competitive judgment or coordinated conduct.

Nolan Prescott — Regional Sales Manager, SE U.S., DFS. Mr. Prescott served as the regional sales manager covering the southeastern United States, including the State of Meridian. In this capacity, he had direct contact with Meridian DOT personnel and may have had contact with competitor personnel in the field. His files may contain market-level communications, customer correspondence, competitor observations, and field-level intelligence that could shed light on the nature and extent of competitor interactions in the Meridian fuel-supply market.

Patricia Aldridge — SVP & General Counsel, DEH. As General Counsel of DEH, Ms. Aldridge was likely both a recipient and author of legal advice regarding bidding strategy, antitrust compliance, and competitor interactions. Her files may contain privileged communications reflecting legal analysis of bidding practices, compliance guidance provided to DFS personnel, and internal discussions regarding the legal parameters of competitor contacts. Communications involving Ms. Aldridge may implicate the attorney-client privilege and the work-product doctrine, and privilege review of her files will require particular care.

Malcolm Haverford — CEO, DEH. As the chief executive officer of the parent entity, Mr. Haverford may have approved bid pricing and strategic direction at a high level. Based on preliminary information, Mr. Haverford may have had direct contact with competitor executives, including Rick Ellerbee, CEO of GPC, and Jonas Hartwick, Managing Partner of REP, in the context of industry events, trade-association meetings, or other settings. His files may contain high-level strategic communications, executive correspondence, and records of competitor interactions relevant to the investigation.

It should be noted that additional custodians may be identified as the investigation progresses and as the initial document review reveals other individuals with relevant knowledge. In particular, Deepa Narayan, Chief Financial Officer of DEH, should be considered as a potential supplemental custodian if financial records relating to Meridian DOT contracts — including revenue recognition, cost allocation, margin analyses, and related financial data — are not adequately captured through the files of the five primary custodians identified above. Calderwood & Harkness LLP will reassess the custodian list on a rolling basis and will advise DEH if additional custodians should be added to the hold.

D. Non-Custodial Data Sources

In addition to the custodial data associated with the five individuals identified above, the following non-custodial data sources have been identified for preservation and collection:

1. DFS Shared Network Drives. The shared network drive located at \\\\DFS-FILE01\\GovContracts\\ contains government contracts files, bid submissions, RFP materials, internal correspondence, and related documentation maintained by the DFS Government Contracts department. This drive is accessible to multiple users within the department and contains files that may not be duplicated within the custodial data of the five identified individuals. The contents of this drive must be preserved in their entirety for the preservation period.

2. DFS Pricing Database ("FuelPricer"). FuelPricer is an internal proprietary application used by the DFS pricing team to model bid prices, analyze competitive positioning, perform margin calculations, and generate pricing recommendations for bulk fuel-supply contracts. The application and its underlying database contain historical pricing data, model inputs, model outputs, audit trails, and user-activity logs that are directly relevant to the investigation. The FuelPricer database must be preserved in its current state, and all audit-trail and change-log data within the application must be retained.

3. DEH/DFS Ashgrove Software Tenant. The DEH/DFS Ashgrove Software environment includes Drayton Solutions (email), Aldermere Systems (document repositories and collaboration sites), and Northgate Data Systems (instant messages, channel communications, and shared files). Data from all three services for each of the five identified custodians must be preserved and collected. In addition, any Teams channels or Aldermere Systems sites associated with the DFS Government Contracts department, the DFS Pricing & Analytics team, or the DEH Executive Leadership team should be identified and preserved as non-custodial sources.

4. DFS CRM System (Pinnacle Health IT). The DFS Pinnacle Health IT instance, accessible at dfs.my.Pinnacle Health IT.com, contains customer records, account histories, opportunity records, activity logs, and potentially logged communications with Meridian DOT personnel and competitor contacts. Pinnacle Health IT records relating to Meridian DOT accounts, Meridian-related opportunities, and any accounts or contacts associated with GPC or REP must be preserved. This includes all associated metadata, audit trails, and Chatter communications.

5. Archived Email (Brightwater Solutions). Archived email messages for all five identified custodians covering the preservation period (January 1, 2020 through the present) are stored in DEH/DFS's Brightwater Solutions system. These archived messages must be preserved and made available for collection by the e-discovery vendor. Enterprise Vault retention policies that would result in the deletion of archived messages during the preservation period must be suspended immediately.

6. Mobile Devices. Company-issued and personal mobile devices (smartphones and tablets) assigned to or used by the custodians listed above for company business must be preserved. This includes all data stored on such devices, including text messages (SMS and MMS), Meridian Services Inc. messages, Harborline Technologies messages, and communications transmitted through any other messaging application. Custodians who use personal devices for company business should be instructed not to delete any data from such devices and to make them available for forensic imaging by the e-discovery vendor.

7. Backup Tapes. Quarterly backup tapes maintained by the DEH/DFS IT department must be preserved. This includes, at a minimum, the most recent quarterly backup cycle (Q2 2025, covering April through June 2025). All backup tapes within the preservation period should be identified, inventoried, and secured. Backup tapes must not be overwritten, recycled, or destroyed pending further instructions from Calderwood & Harkness LLP.

IV. Litigation Hold Notices — Distribution Plan

Written litigation-hold notices must be issued to each of the five custodians identified in Section III.C above no later than September 5, 2025. Given that the CID was received on August 22, 2025, and that the preservation obligation attached immediately upon receipt, the prompt issuance of formal hold notices is essential to ensure that all custodians are aware of their individual obligations and to create a documented record of compliance.

The hold notices should be issued under the signature of Patricia Aldridge, SVP & General Counsel, in her capacity as the senior legal officer responsible for legal compliance at DEH and DFS. Issuance by the General Counsel conveys the appropriate level of authority and seriousness, and reinforces the mandatory nature of the obligations described in the notice.

Each litigation-hold notice must contain the following elements:

1. Identification of the Legal Matter. The notice must identify the legal matter giving rise to the hold — specifically, the investigation by the Meridian Attorney General's Antitrust Division, and the CID bearing Reference No. AG-ANT-2025-04172. The notice should provide sufficient context for the custodian to understand the nature of the investigation without disclosing privileged strategy or legal analysis.

2. Categories of Documents and ESI Subject to the Hold. The notice must define the categories of documents and ESI that the custodian is required to preserve, consistent with the subject-matter scope set forth in Section III.B of this memorandum. The categories should be described with sufficient specificity to enable the custodian to identify potentially relevant materials in his or her possession, custody, or control.

3. Instruction to Cease Destruction. The notice must instruct the custodian to immediately cease all destruction, deletion, alteration, or modification of potentially relevant documents and ESI. This includes the cessation of routine document-management practices (such as periodic inbox cleaning, deletion of old files, or disposal of paper records) that might otherwise result in the loss of relevant materials.

4. Extension to Personal Devices and Accounts. The notice must make clear that the hold extends to personal devices and personal accounts (including personal email accounts, personal cloud storage services, and personal messaging applications) that the custodian has used for company business at any time during the preservation period.

5. Acknowledgment Requirement. The notice must require a signed written acknowledgment from each custodian confirming receipt and understanding of the hold, to be returned within 48 hours of receipt of the notice. These acknowledgments should be collected and maintained by the DEH Legal Department as part of the preservation compliance record.

6. Confidentiality Instruction. The notice must emphasize the confidential nature of the hold and the underlying investigation. Custodians must be instructed that they should not discuss the hold, the CID, or the investigation with anyone outside of DEH and DFS, except as directed by the Office of the General Counsel or Calderwood & Harkness LLP. This instruction is essential both to protect the integrity of the investigation and to avoid inadvertent waiver of privilege or disclosure of confidential information.

Calderwood & Harkness LLP will provide a template litigation-hold notice for DEH's use. The template will be transmitted to Ms. Aldridge under separate cover and should be customized as necessary to reflect the specific data sources and document categories applicable to each custodian.

Periodic reminders should be issued to all custodians at regular intervals — no less frequently than quarterly — to reinforce the continuing nature of the hold and to confirm ongoing compliance. Calderwood & Harkness LLP will advise DEH on the timing and content of reminder notices.

V. IT Department Instructions

The DEH/DFS IT department must be instructed to take the following actions immediately, and in no event later than September 5, 2025. These instructions should be communicated in writing by the Office of the General Counsel, with a copy provided to Calderwood & Harkness LLP for the compliance record.

1. Suspend Auto-Deletion Policies. All automated retention and deletion policies must be disabled immediately for the following systems and data sources, as they pertain to all custodians and non-custodial sources identified in Section III:

• Drayton Solutions email retention and deletion policies

• Brightwater Solutions retention and deletion schedules

• Northgate Data Systems message retention policies (including chat messages, channel messages, and shared files)

• Aldermere Systems document retention and lifecycle policies

• Backup-tape recycling and overwrite schedules

These policies must remain suspended for the duration of the litigation hold. No automated process should be permitted to delete, archive, or modify any data associated with the identified custodians or non-custodial data sources without the prior written approval of the Office of the General Counsel.

2. Preserve Backup Tapes. IT personnel must identify, collect, and secure backup tapes from the most recent quarterly backup cycle (Q2 2025, covering April through June 2025), as well as any other backup tapes within the preservation period that are readily identifiable. These tapes must be stored in a secure, climate-controlled location and must not be overwritten, recycled, degaussed, or otherwise rendered inaccessible. IT should prepare a written inventory of all preserved backup tapes, including tape identifiers, creation dates, and contents (to the extent known).

3. Disable Remote-Wipe Capabilities. For all mobile devices (company-issued and BYOD) assigned to or registered by the five identified custodians, remote-wipe and factory-reset capabilities must be disabled immediately. This includes disabling remote-wipe functionality in any mobile device management ("MDM") platform used by DEH/DFS (e.g., Northgate Systems, Ridgeway Software, or similar). This measure is necessary to ensure that custodial mobile devices are preserved in their current state pending forensic imaging by the e-discovery vendor.

4. Pinnacle Health IT Audit Trail. Full audit-trail logging must be enabled in the DFS Pinnacle Health IT instance to preserve a complete record of any changes to Meridian-related records, including modifications to account records, opportunity records, contact records, activity logs, and custom objects. If audit-trail logging is not currently enabled at the maximum level of granularity, IT should coordinate with the Pinnacle Health IT administrator to enable field-level history tracking for all relevant objects and fields.

5. Network Drive Snapshots. IT must create a point-in-time snapshot of the shared network drive located at \\\\DFS-FILE01\\GovContracts\\ and preserve the snapshot in read-only format. The snapshot should be stored on a separate, secure storage volume and should be accompanied by documentation recording the date and time of the snapshot, the method used, and the identity of the IT personnel who performed the operation. This snapshot will serve as a baseline preservation copy, ensuring that the contents of the drive as of the date of the snapshot are preserved even if subsequent modifications are made to the live drive.

6. Coordinate with E-discovery Vendor. IT personnel should be prepared to facilitate on-site access by Brindoval Analytics LLC, Calderwood & Harkness LLP's designated e-discovery vendor, for the purpose of forensic imaging of custodial devices (laptops, desktops, and mobile devices). Brindoval Analytics LLC is located at 8400 Leesburg Pike, Suite 320, Tysons Corner, Virginia 22182, and the designated project manager for this engagement is Daniel Furrow. On-site forensic imaging is expected to commence no later than September 19, 2025, pursuant to the e-discovery vendor statement of work to be executed on or about September 12, 2025. IT should ensure that appropriate workspace, network access, and administrative credentials are available to support the forensic imaging process, and should designate a primary IT point of contact to coordinate with Mr. Furrow and his team.

VI. E-discovery Vendor Engagement

Calderwood & Harkness LLP anticipates retaining Brindoval Analytics LLC ("Brindoval") as the e-discovery vendor for this matter. Brindoval will be responsible for forensic data collection, processing, hosting, and technology-assisted review ("TAR") services. Brindoval has extensive experience supporting complex antitrust investigations and government enforcement matters, and its technical capabilities are well suited to the data volumes and complexity anticipated in this engagement.

The estimated Phase 1 budget for Brindoval's services, covering all activities through the initial CID response (whether at the original October 3, 2025 deadline or the extended November 3, 2025 deadline, if granted), is approximately $385,000. This estimate is based on the preliminary data volume and custodian count identified in Section III.C and is subject to revision as additional custodians or data sources are identified. A detailed budget breakdown will be provided in the Brindoval statement of work.

Brindoval will be engaged directly by Calderwood & Harkness LLP. All vendor costs will be passed through to the client without markup, consistent with the fee arrangement described in the August 27, 2025 engagement letter.

The planned services to be performed by Brindoval include the following:

• Forensic Imaging. Forensic imaging of custodial laptops, desktops, and mobile devices with defensible chain-of-custody documentation. All forensic images will be verified using both MD5 and SHA-256 hash algorithms to ensure data integrity and to establish an unbroken chain of custody.

• Cloud-Hosted Data Collection. Collection of cloud-hosted data from the DEH/DFS Ashgrove Software tenant, including Drayton Solutions mailboxes, Aldermere Systems sites, and Northgate Data Systems data for all five identified custodians. Collection of archived email from the Brightwater Solutions system for the same custodians.

• Non-Custodial Data Collection. Collection of designated non-custodial data sources, including the shared network drive (\\\\DFS-FILE01\\GovContracts\\), FuelPricer database exports, and Pinnacle Health IT data exports.

• Processing and Deduplication. Processing of all collected data, including global deduplication by MD5 hash across the full data set, text extraction (including OCR of image-only files), and extraction and normalization of metadata fields.

• Hosting for Attorney Review. Hosting of all processed data on Brindoval's Kestrel Technologies platform for attorney review. The hosted environment will support full-text searching, metadata filtering, email threading, conceptual analytics, and technology-assisted review workflows.

• Technology-Assisted Review. Implementation of a TAR 2.0 (continuous active learning) protocol for document review, designed to prioritize the review of the most likely responsive documents and to improve review efficiency and consistency. Calderwood & Harkness LLP's review team will work collaboratively with Brindoval to train and validate the TAR model.

• Document Production. Production of responsive, non-privileged documents in TIFF format with extracted text and standard load files (Ashgrove Technologies .DAT and Opticon .OPT), with Bates numbering using the prefix DEH-MERID- (beginning at DEH-MERID-000001 and continuing sequentially).

The statement of work with Brindoval is expected to be executed no later than September 12, 2025. Calderwood & Harkness LLP will circulate the draft SOW to Ms. Aldridge for review prior to execution.

VII. Coordination with Third Parties

The following third-party considerations are relevant to the preservation and investigation response efforts and require attention from DEH's legal team.

Alderton & Knox, CPAs, LLP. As noted in Section III.B.8, DEH's independent auditors, Alderton & Knox, CPAs, LLP ("A&K"), may hold bid-related financial records relevant to the investigation. The A&K engagement partner is Yolanda Matsuda, CPA, and A&K is located at 3 Greenway Plaza, Suite 600, Houston, Texas 77046. Depending on the scope of responsive financial records, it may be necessary to issue a separate preservation request to A&K to ensure that relevant workpapers, audit schedules, and supporting documentation are not destroyed pursuant to A&K's standard document-retention policies. DEH should consider whether such a preservation request is warranted once the scope of responsive financial records is better understood through the initial custodial and non-custodial data collection. Calderwood & Harkness LLP will advise on the appropriate timing and form of any such request.

Pinnacle National Bank, N.A. Pinnacle National Bank, N.A. ("Pinnacle") serves as the administrative agent under DEH's $750 million senior secured revolving credit facility, dated March 15, 2023. The credit agreement governing the facility contains a "material litigation" reporting covenant under Section 6.01(h), which requires DEH to notify the administrative agent of any governmental investigation, proceeding, or action that could reasonably be expected to result in liability exceeding the material adverse effect ("MAE") threshold of $25 million. Given the potential financial exposure in this matter — which, based on preliminary analysis, includes statutory penalties of up to $15 million and treble damages estimated in the range of $90.29 million to $135.43 million — DEH should promptly assess its notification obligation to Pinnacle under the credit agreement. The potential triggering of the reporting covenant is a significant corporate governance consideration that may also implicate disclosure obligations under DEH's insurance policies and other contractual arrangements. This issue is addressed separately in the liability-exposure analysis to be prepared by Howard Bellamy, Partner, Antitrust & Competition, Calderwood & Harkness LLP.

Co-Respondents' Counsel. The following law firms represent the co-respondents identified in the CID:

• Galloway Petroleum Corp. is represented by Whitfield, Strauss & DeVane LLP (lead partner: Gregory Whitfield), located at 420 20th Street North, Suite 1600, Birmingham, Alabama 35203.

• Ridgeline Energy Partners LLC is represented by Archer Colby LLP (lead partner: Diane Colby), located at 191 Peachtree Street NE, Suite 3200, Atlanta, Georgia 30303.

Any coordination with co-respondents' counsel on preservation matters, production protocols, or other aspects of the investigation response will require prior authorization from the client. Such coordination may be governed by a joint-defense agreement or common-interest agreement, which would define the terms under which privileged communications and work product may be shared among the co-respondents' respective counsel without waiver. The advisability and terms of any such agreement will be discussed with Ms. Aldridge separately. Calderwood & Harkness LLP cautions that any joint-defense or common-interest arrangement must be carefully evaluated in light of the possibility that one or more co-respondents may seek to cooperate with the Attorney General's office, which could create conflicts and undermine the protections of a joint-defense arrangement.

VIII. Key Deadlines and Action Items

The following table sets forth the key deadlines and action items for the initial phase of the preservation and investigation response effort. All deadlines are firm unless otherwise indicated.

Calderwood & Harkness LLP will provide regular status updates to Ms. Aldridge and will maintain a detailed tracking log of all preservation and collection activities for the compliance record.

IX. Consequences of Non-Compliance

The preservation obligations described in this memorandum are mandatory and must be treated with the utmost seriousness and urgency by every custodian, IT personnel member, and other individual to whom they apply. Failure to comply with these obligations — whether through affirmative destruction, negligent loss, or passive failure to prevent the deletion of relevant information — may result in severe and potentially irreversible consequences for DEH, DFS, and the individuals involved.

The potential consequences of non-compliance include the following:

Court-Imposed Sanctions. Courts possess broad inherent authority and, in many jurisdictions, statutory authority to impose sanctions for the spoliation of evidence. Available sanctions include adverse-inference instructions (permitting the trier of fact to infer that destroyed evidence was unfavorable to the spoliating party), monetary penalties assessed against the organization and/or responsible individuals, issue preclusion (precluding the spoliating party from contesting certain issues of fact), exclusion of evidence, or, in the most egregious cases, default judgment or dismissal.

Criminal Liability. Spoliation of evidence in the context of a government antitrust investigation may give rise to separate criminal liability under obstruction-of-justice statutes, both at the federal level (including 18 U.S.C. § 1519, which criminalizes the knowing destruction of documents with intent to obstruct a federal investigation) and under Meridian state law. The potential for criminal prosecution is a distinct and independent risk that exists regardless of the outcome of the underlying antitrust investigation.

Reputational Harm and Loss of Cooperation Credit. The destruction or loss of relevant evidence would cause significant reputational harm to DEH and DFS in the eyes of the Attorney General's office and would undermine the companies' credibility throughout the course of the investigation. Evidence of spoliation may affect the AG's willingness to extend cooperation credit, negotiate favorable resolution terms, or exercise prosecutorial discretion in a manner favorable to the respondents. In antitrust investigations, the tone and quality of a respondent's cooperation with the enforcement authority can have a material impact on the ultimate outcome of the matter.

Breach of Fiduciary Duties. Corporate officers and directors who fail to take reasonable steps to preserve evidence in the face of a known legal obligation to do so may be found to have breached their fiduciary duties of care and loyalty to the corporation and its shareholders. Such a breach could expose individual officers and directors to personal liability in derivative litigation or regulatory proceedings.

Every custodian and IT personnel member must understand that the litigation hold is a mandatory legal obligation, not a discretionary guideline. Compliance is not optional. Any questions, concerns, or uncertainties regarding the scope or application of the hold should be directed immediately to the contacts listed in Section X below.

X. Contact Information

All questions regarding this memorandum, the litigation hold, or the preservation obligations described herein should be directed to one of the following individuals:

Monica Reyes Senior Associate, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Tel: (202) 555-0147

Email: mreyes@calderwoodharkness.com

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

Email: hbellamy@calderwoodharkness.com

Patricia Aldridge SVP & General Counsel Dunmore Energy Holdings Ltd. 4100 Westchase Boulevard, Suite 1200 Houston, TX 77042 Tel: (713) 555-0288

Email: paldridge@dunmore.com

Custodians and IT personnel should not attempt to resolve preservation questions independently. When in doubt, preserve the document or data in question and seek guidance from one of the contacts listed above.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Monica Reyes Senior Associate, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Tel: (202) 555-0147

Email: mreyes@calderwoodharkness.com

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION / WORK PRODUCT This memorandum is protected by the attorney-client privilege and the work-product doctrine. It is intended solely for the use of the addressee and other authorized personnel of Dunmore Energy Holdings Ltd. and Dunmore Fuel Supply, Inc. Any unauthorized disclosure, copying, or distribution of this memorandum or its contents is strictly prohibited.

#	Name	Title	Entity	Estimated Data Volume (GB)	Estimated Document Count
1	Terrence "Terry" Kinloch	VP, Government Contracts	Dunmore Fuel Supply, Inc.	42.7 GB	~186,000
2	Sandra Ochoa	Director of Pricing & Analytics	Dunmore Fuel Supply, Inc.	31.4 GB	~142,000
3	Nolan Prescott	Regional Sales Manager, SE U.S.	Dunmore Fuel Supply, Inc.	18.9 GB	~95,000
4	Patricia Aldridge	SVP & General Counsel	Dunmore Energy Holdings Ltd.	27.3 GB	~118,000
5	Malcolm Haverford	CEO	Dunmore Energy Holdings Ltd.	12.1 GB	~63,000
Total	132.4 GB	~604,000
#	Action Item	Responsible Party	Deadline
1	Issue written litigation-hold notices to each of the five identified custodians (Kinloch, Ochoa, Prescott, Aldridge, Haverford)	Patricia Aldridge / DEH Legal Dept.	September 5, 2025
2	Instruct DEH/DFS IT department to suspend all auto-deletion policies and preserve backup tapes, per Section V	Patricia Aldridge / DEH IT	September 5, 2025
3	Collect and confirm signed acknowledgments from all five custodians	Patricia Aldridge / DEH Legal Dept.	September 7, 2025 (48 hrs after notice)
4	Execute e-discovery vendor SOW with Brindoval Analytics LLC	Monica Reyes / Calderwood & Harkness LLP	September 12, 2025
5	Facilitate on-site forensic imaging of custodial laptops and mobile devices by Brindoval Analytics	DEH IT / Brindoval Analytics	Commencing September 19, 2025
6	Complete forensic collection of all custodial and non-custodial data sources	Brindoval Analytics	Target: September 26, 2025
7	Submit request for 30-day extension of CID response deadline (from October 3 to November 3, 2025)	Howard Bellamy / Calderwood & Harkness LLP	September 22, 2025
8	Original CID response deadline (40 calendar days from August 22, 2025 issuance)	—	October 3, 2025
9	Commence TAR model training on processed data set	Brindoval Analytics / Calderwood & Harkness LLP	October 10, 2025
10	Extended CID response deadline (if 30-day extension is granted)	—	November 3, 2025

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION / WORK PRODUCT
CALDERWOOD & HARKNESS LLP 1900 K Street NW, Suite 1100 Washington, DC 20006
MEMORANDUM
TO: Patricia Aldridge, SVP & General Counsel Dunmore Energy Holdings Ltd. 4100 Westchase Boulevard, Suite 1200 Houston, TX 77042
FROM: Monica Reyes, Senior Associate, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006
DATE: September 3, 2025
RE: Document Preservation / Litigation Hold — CID No. AG-ANT-2025-04172 (C&H Matter No. 1016-00001)
I. Purpose
This memorandum outlines the document-preservation obligations of Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary, Dunmore Fuel Supply, Inc. ("DFS"), arising from the Civil Investigative Demand ("CID") issued by the Office of the Attorney General of the State of Meridian, Antitrust Division, on August 22, 2025 (CID Reference No. AG-ANT-2025-04172). The CID was issued pursuant to the authority vested in the Meridian Attorney General under Meridian Code Ann. § 75-21-39, which empowers the Attorney General to issue investigative demands in connection with suspected violations of the Meridian Antitrust Act.
The CID concerns an investigation into alleged bid rigging in connection with fuel-supply contracts awarded by the Meridian State Department of Transportation ("Meridian DOT") during the period from January 2021 through December 2024. The Attorney General's investigation appears to focus on whether DEH and DFS, together with other market participants, coordinated pricing, allocated contract lots, or otherwise engaged in anticompetitive conduct in connection with these publicly procured fuel-supply contracts.
DEH and DFS are named as respondents in the CID. The CID also identifies two co-respondents: Galloway Petroleum Corp. ("GPC"), a Delaware corporation headquartered at 2255 Commerce Park Drive, Suite 800, Birmingham, Alabama 35244; and Ridgeline Energy Partners LLC ("REP"), a Georgia limited liability company headquartered at 600 Peachtree Industrial Blvd, Suite 450, Duluth, Georgia 30097. The inclusion of multiple respondents in a single CID is consistent with the Attorney General's apparent theory of a multi-party conspiracy, and it underscores the seriousness and breadth of the ongoing investigation.
This memorandum is intended to serve as the basis for the litigation-hold notices that DEH's legal department will distribute to relevant custodians and IT personnel. The timely issuance of such notices is a critical first step in ensuring that DEH and DFS satisfy their preservation obligations and avoid any allegation that potentially relevant evidence was destroyed or allowed to degrade after the duty to preserve attached.
Calderwood & Harkness LLP was formally engaged to represent DEH and DFS in connection with this matter on August 27, 2025, pursuant to the executed engagement letter signed by Ms. Aldridge on behalf of both entities. This memorandum constitutes attorney work product and a privileged attorney-client communication. It should be treated as strictly confidential and should not be disclosed to any person outside of DEH's and DFS's authorized legal and management personnel without the prior written consent of Calderwood & Harkness LLP.
II. Preservation Obligation
Upon receipt of the CID on August 22, 2025, DEH and DFS assumed an affirmative legal duty to preserve all documents and electronically stored information ("ESI") that are or may be relevant to the subject matter of the Attorney General's investigation. This preservation obligation is triggered by the receipt of the CID itself and attaches immediately upon such receipt. It is not contingent upon, and does not await, the deadline for substantive compliance with the CID's document requests.
The original CID response deadline is October 3, 2025 — forty (40) calendar days from the date of issuance. However, the duty to preserve is independent of, and precedes, any deadline for the production of responsive documents. From the moment the CID was received, DEH and DFS have been under a continuing obligation to take all reasonable steps to identify, locate, and preserve potentially relevant information, and to ensure that no such information is destroyed, deleted, altered, overwritten, or otherwise rendered inaccessible.
This preservation obligation extends to all forms of information, whether in physical or electronic form, and regardless of the medium or location in which the information resides. Without limitation, the categories of information subject to preservation include:
• Emails, including attachments, headers, and associated metadata
• Text messages (SMS and MMS)
• Instant messages, including communications transmitted through Northgate Data Systems, Meridian Solutions, Meridian Services Inc., Harborline Technologies, and any other messaging platform
• Calendar entries and scheduling records
• Voicemails, whether stored locally on devices or in cloud-based voicemail systems
• Internal and external memoranda, letters, and correspondence
• Spreadsheets, databases, and data exports
• Presentations, including Ashbury Holdings Northgate Services Inc. files and similar formats
• Contracts, agreements, amendments, and related transactional documents
• Pricing models, cost analyses, and margin calculations
• Bid submissions, proposals, and related supporting documentation
• Handwritten notes, including notes taken during meetings, telephone calls, or conferences
• Metadata associated with any of the foregoing categories of information
It is essential that all personnel understand the gravity of these obligations. Spoliation of evidence — that is, the destruction, alteration, or failure to preserve relevant evidence when a duty to preserve exists — may result in severe consequences. Courts may impose sanctions for spoliation, which can include adverse-inference instructions (permitting a fact-finder to infer that destroyed evidence was unfavorable to the spoliating party), monetary penalties, issue preclusion, or, in extreme cases, default judgment. Moreover, the destruction of evidence in the context of a government antitrust investigation may give rise to separate criminal liability under both federal and state obstruction-of-justice statutes. The potential for criminal exposure is particularly acute in this matter given the involvement of the Attorney General's Antitrust Division and the nature of the alleged conduct.
The investigation involves alleged violations of the Meridian Antitrust Act, codified at Meridian Code Ann. § 75-21-1 et seq., including the specific prohibition on bid rigging set forth in § 75-21-3. Violations of the Meridian Antitrust Act may result in substantial civil penalties and treble damages, as well as potential criminal penalties for willful violations. The preservation of all potentially relevant evidence is therefore not merely a procedural obligation — it is a fundamental component of DEH's and DFS's ability to mount an effective defense and to maintain credibility with the Attorney General's office throughout the course of the investigation.
III. Scope of the Hold
The litigation hold encompasses a defined temporal scope, subject-matter scope, set of key custodians, and set of non-custodial data sources, each of which is described in detail below.
A. Temporal Scope
All documents and ESI created, sent, received, modified, or stored during the period from January 1, 2020 through the present must be preserved. This preservation obligation is continuing in nature and will remain in effect until the hold is formally lifted in writing by the Office of the General Counsel of DEH, in consultation with Calderwood & Harkness LLP. No custodian, IT personnel member, or other individual is authorized to terminate or modify this hold absent such express written authorization.
The rationale for the selected preservation period is as follows. Although the CID identifies the alleged conduct period as January 2021 through December 2024, Calderwood & Harkness LLP recommends preserving documents from January 1, 2020 forward in order to capture any pre-conspiracy planning communications, market-intelligence exchanges, preliminary discussions, or preparatory conduct that may have predated the formal alleged conspiracy period. In antitrust investigations of this nature, enforcement authorities frequently seek evidence of initial contacts, exploratory conversations, and early-stage coordination that set the groundwork for the alleged anticompetitive conduct. Communications and documents from the period immediately preceding the alleged conspiracy are therefore highly relevant and must be preserved.
Additionally, the relevant Meridian DOT contracts at issue in the investigation cover Fiscal Year 2022, Fiscal Year 2023, and Fiscal Year 2024. The request-for-proposals ("RFP") and bidding process for the FY 2022 contracts would likely have commenced in late 2020 or early 2021, with market assessments, competitive analyses, and strategic planning potentially occurring even earlier. Preserving documents from January 1, 2020 forward therefore ensures that the full lifecycle of the bidding process for the earliest relevant contracts is captured.
B. Subject-Matter Scope
The litigation hold applies to all documents and ESI relating to the following categories of subject matter:
1. Fuel-Supply Bids and Proposals Submitted to Meridian DOT. This category encompasses all documents relating to fuel-supply bids or proposals submitted to Meridian DOT, including but not limited to RFP documents received from Meridian DOT, internal analyses of RFP requirements, draft and final bid submissions, award notifications, contract execution documents, contract performance records, delivery schedules, compliance certifications, and pricing proposals. This includes documents relating to all five geographic lots established by Meridian DOT for its fuel-supply procurement program:
• Lot A — Northern Meridian: Approximately 6.8 million gallons per year
• Lot B — Central Meridian: Approximately 9.2 million gallons per year
• Lot C — Southern Meridian: Approximately 7.5 million gallons per year
• Lot D — Eastern Meridian: Approximately 8.1 million gallons per year
• Lot E — Western Meridian: Approximately 6.4 million gallons per year
• Total volume across all lots: Approximately 38 million gallons per year
2. Communications with or about Co-Respondents. All communications with or concerning Galloway Petroleum Corp. ("GPC") or any of its employees, officers, directors, agents, or representatives, including but not limited to Richard "Rick" Ellerbee, CEO of GPC, and Constance Barlow, Vice President of Sales at GPC. Similarly, all communications with or concerning Ridgeline Energy Partners LLC ("REP") or any of its employees, members, officers, agents, or representatives, including but not limited to Jonas Hartwick, Managing Partner of REP, and Elaine Pruitt, Director of Business Development at REP. This category includes both formal and informal communications, regardless of the medium or channel through which they were transmitted.
3. Pricing Strategies and Competitive intelligence. All documents relating to pricing strategies, margin analyses, competitive-intelligence reports, cost models, or pricing models for bulk fuel supply in the State of Meridian. This includes, without limitation, any analyses, reports, models, or data exports prepared using or derived from the DFS proprietary pricing database known as "FuelPricer," as well as any benchmarking analyses, market-share estimates, or competitive assessments prepared by or for the DFS pricing and analytics team.
4. Industry Meetings and Competitor Interactions. All documents relating to any industry meetings, trade-association events, conferences, seminars, social gatherings, or informal meetings at which competitors discussed pricing, customers, bid strategy, market allocation, territories, capacity, or any other competitively sensitive topic. This includes agendas, attendance lists, presentation materials, expense reports, travel records, handwritten notes, and any communications before, during, or after such events.
5. Meridian DOT Correspondence and Procurement Records. All Meridian DOT RFP documents, bid solicitations, addenda, award notifications, contract performance records, audit reports, and any correspondence with Meridian DOT procurement officials, contract administrators, or other state personnel involved in the fuel-supply procurement process.
6. Internal Bid-Pricing Approvals. All documents reflecting internal approvals of bid pricing for any Meridian state contract, including emails, memoranda, approval workflows, sign-off sheets, management review materials, and any other records reflecting the process by which proposed bid prices were developed, reviewed, modified, and ultimately approved for submission.
7. Lot Allocation, Bid Rotation, and Cover Bidding. All documents relating to the allocation of contract lots among competitors, rotation of winning bids among market participants, or the submission of complementary bids (also known as "cover" bids, "courtesy" bids, or "phantom" bids). This category is of particular significance to the Attorney General's investigation and encompasses any communications, agreements, understandings, or arrangements — whether formal or informal, written or oral — pursuant to which competitors agreed to submit non-competitive bids, refrain from bidding on certain lots, or otherwise coordinate their bidding conduct.
8. Financial Records Relating to Meridian DOT Contracts. All financial records relating to revenue, costs, margins, profitability, and financial performance on Meridian DOT contracts, including income statements, cost-accounting records, job-cost reports, margin analyses, variance analyses, and any related financial data. It should be noted that DEH's independent auditors, Alderton & Knox, CPAs, LLP ("A&K"), located at 3 Greenway Plaza, Suite 600, Houston, Texas 77046 (engagement partner: Yolanda Matsuda, CPA), may hold bid-related financial records relevant to the investigation, including workpapers, audit schedules, and supporting documentation prepared in connection with A&K's annual audits of DEH. Coordination with A&K regarding the preservation and potential collection of such records should be considered, as discussed further in Section VII below.
C. Key Custodians
Calderwood & Harkness LLP has identified the following five individuals as key custodians whose documents and ESI must be preserved and collected as part of the initial phase of this investigation. These individuals have been selected based on their roles, responsibilities, and likely involvement with the subject matter of the Attorney General's investigation. The estimated data volumes and document counts set forth below are based on preliminary information provided by DEH IT and are subject to revision as additional information becomes available.
The rationale for each custodian's inclusion is as follows:
Terrence "Terry" Kinloch — VP, Government Contracts, DFS. Mr. Kinloch oversaw the Meridian DOT bidding process and served as the primary point of contact for all government contract submissions by DFS during the relevant period. In this capacity, he would have been responsible for coordinating the preparation and submission of DFS's bids for each of the five Meridian DOT geographic lots and would have had direct interactions with Meridian DOT procurement officials. Given the nature of his role, Mr. Kinloch likely communicated with counterparts at GPC and REP, and his files are expected to contain bid-related correspondence, RFP response materials, and internal strategy discussions of central relevance to the investigation.
Sandra Ochoa — Director of Pricing & Analytics, DFS. Ms. Ochoa prepared pricing analyses and competitive-intelligence reports used by DFS in formulating its bids for Meridian DOT contracts. She managed the FuelPricer database — the proprietary internal application used by DFS to model bid prices and analyze competitive positioning — and developed the bid pricing models for each of the Meridian DOT lots. Her files are expected to contain pricing models, cost analyses, margin calculations, competitive benchmarking reports, and related analytical materials that will be central to the Attorney General's investigation of whether bid prices were the product of independent competitive judgment or coordinated conduct.
Nolan Prescott — Regional Sales Manager, SE U.S., DFS. Mr. Prescott served as the regional sales manager covering the southeastern United States, including the State of Meridian. In this capacity, he had direct contact with Meridian DOT personnel and may have had contact with competitor personnel in the field. His files may contain market-level communications, customer correspondence, competitor observations, and field-level intelligence that could shed light on the nature and extent of competitor interactions in the Meridian fuel-supply market.
Patricia Aldridge — SVP & General Counsel, DEH. As General Counsel of DEH, Ms. Aldridge was likely both a recipient and author of legal advice regarding bidding strategy, antitrust compliance, and competitor interactions. Her files may contain privileged communications reflecting legal analysis of bidding practices, compliance guidance provided to DFS personnel, and internal discussions regarding the legal parameters of competitor contacts. Communications involving Ms. Aldridge may implicate the attorney-client privilege and the work-product doctrine, and privilege review of her files will require particular care.
Malcolm Haverford — CEO, DEH. As the chief executive officer of the parent entity, Mr. Haverford may have approved bid pricing and strategic direction at a high level. Based on preliminary information, Mr. Haverford may have had direct contact with competitor executives, including Rick Ellerbee, CEO of GPC, and Jonas Hartwick, Managing Partner of REP, in the context of industry events, trade-association meetings, or other settings. His files may contain high-level strategic communications, executive correspondence, and records of competitor interactions relevant to the investigation.
It should be noted that additional custodians may be identified as the investigation progresses and as the initial document review reveals other individuals with relevant knowledge. In particular, Deepa Narayan, Chief Financial Officer of DEH, should be considered as a potential supplemental custodian if financial records relating to Meridian DOT contracts — including revenue recognition, cost allocation, margin analyses, and related financial data — are not adequately captured through the files of the five primary custodians identified above. Calderwood & Harkness LLP will reassess the custodian list on a rolling basis and will advise DEH if additional custodians should be added to the hold.
D. Non-Custodial Data Sources
In addition to the custodial data associated with the five individuals identified above, the following non-custodial data sources have been identified for preservation and collection:
1. DFS Shared Network Drives. The shared network drive located at \\\\DFS-FILE01\\GovContracts\\ contains government contracts files, bid submissions, RFP materials, internal correspondence, and related documentation maintained by the DFS Government Contracts department. This drive is accessible to multiple users within the department and contains files that may not be duplicated within the custodial data of the five identified individuals. The contents of this drive must be preserved in their entirety for the preservation period.
2. DFS Pricing Database ("FuelPricer"). FuelPricer is an internal proprietary application used by the DFS pricing team to model bid prices, analyze competitive positioning, perform margin calculations, and generate pricing recommendations for bulk fuel-supply contracts. The application and its underlying database contain historical pricing data, model inputs, model outputs, audit trails, and user-activity logs that are directly relevant to the investigation. The FuelPricer database must be preserved in its current state, and all audit-trail and change-log data within the application must be retained.
3. DEH/DFS Ashgrove Software Tenant. The DEH/DFS Ashgrove Software environment includes Drayton Solutions (email), Aldermere Systems (document repositories and collaboration sites), and Northgate Data Systems (instant messages, channel communications, and shared files). Data from all three services for each of the five identified custodians must be preserved and collected. In addition, any Teams channels or Aldermere Systems sites associated with the DFS Government Contracts department, the DFS Pricing & Analytics team, or the DEH Executive Leadership team should be identified and preserved as non-custodial sources.
4. DFS CRM System (Pinnacle Health IT). The DFS Pinnacle Health IT instance, accessible at dfs.my.Pinnacle Health IT.com, contains customer records, account histories, opportunity records, activity logs, and potentially logged communications with Meridian DOT personnel and competitor contacts. Pinnacle Health IT records relating to Meridian DOT accounts, Meridian-related opportunities, and any accounts or contacts associated with GPC or REP must be preserved. This includes all associated metadata, audit trails, and Chatter communications.
5. Archived Email (Brightwater Solutions). Archived email messages for all five identified custodians covering the preservation period (January 1, 2020 through the present) are stored in DEH/DFS's Brightwater Solutions system. These archived messages must be preserved and made available for collection by the e-discovery vendor. Enterprise Vault retention policies that would result in the deletion of archived messages during the preservation period must be suspended immediately.
6. Mobile Devices. Company-issued and personal mobile devices (smartphones and tablets) assigned to or used by the custodians listed above for company business must be preserved. This includes all data stored on such devices, including text messages (SMS and MMS), Meridian Services Inc. messages, Harborline Technologies messages, and communications transmitted through any other messaging application. Custodians who use personal devices for company business should be instructed not to delete any data from such devices and to make them available for forensic imaging by the e-discovery vendor.
7. Backup Tapes. Quarterly backup tapes maintained by the DEH/DFS IT department must be preserved. This includes, at a minimum, the most recent quarterly backup cycle (Q2 2025, covering April through June 2025). All backup tapes within the preservation period should be identified, inventoried, and secured. Backup tapes must not be overwritten, recycled, or destroyed pending further instructions from Calderwood & Harkness LLP.
IV. Litigation Hold Notices — Distribution Plan
Written litigation-hold notices must be issued to each of the five custodians identified in Section III.C above no later than September 5, 2025. Given that the CID was received on August 22, 2025, and that the preservation obligation attached immediately upon receipt, the prompt issuance of formal hold notices is essential to ensure that all custodians are aware of their individual obligations and to create a documented record of compliance.
The hold notices should be issued under the signature of Patricia Aldridge, SVP & General Counsel, in her capacity as the senior legal officer responsible for legal compliance at DEH and DFS. Issuance by the General Counsel conveys the appropriate level of authority and seriousness, and reinforces the mandatory nature of the obligations described in the notice.
Each litigation-hold notice must contain the following elements:
1. Identification of the Legal Matter. The notice must identify the legal matter giving rise to the hold — specifically, the investigation by the Meridian Attorney General's Antitrust Division, and the CID bearing Reference No. AG-ANT-2025-04172. The notice should provide sufficient context for the custodian to understand the nature of the investigation without disclosing privileged strategy or legal analysis.
2. Categories of Documents and ESI Subject to the Hold. The notice must define the categories of documents and ESI that the custodian is required to preserve, consistent with the subject-matter scope set forth in Section III.B of this memorandum. The categories should be described with sufficient specificity to enable the custodian to identify potentially relevant materials in his or her possession, custody, or control.
3. Instruction to Cease Destruction. The notice must instruct the custodian to immediately cease all destruction, deletion, alteration, or modification of potentially relevant documents and ESI. This includes the cessation of routine document-management practices (such as periodic inbox cleaning, deletion of old files, or disposal of paper records) that might otherwise result in the loss of relevant materials.
4. Extension to Personal Devices and Accounts. The notice must make clear that the hold extends to personal devices and personal accounts (including personal email accounts, personal cloud storage services, and personal messaging applications) that the custodian has used for company business at any time during the preservation period.
5. Acknowledgment Requirement. The notice must require a signed written acknowledgment from each custodian confirming receipt and understanding of the hold, to be returned within 48 hours of receipt of the notice. These acknowledgments should be collected and maintained by the DEH Legal Department as part of the preservation compliance record.
6. Confidentiality Instruction. The notice must emphasize the confidential nature of the hold and the underlying investigation. Custodians must be instructed that they should not discuss the hold, the CID, or the investigation with anyone outside of DEH and DFS, except as directed by the Office of the General Counsel or Calderwood & Harkness LLP. This instruction is essential both to protect the integrity of the investigation and to avoid inadvertent waiver of privilege or disclosure of confidential information.
Calderwood & Harkness LLP will provide a template litigation-hold notice for DEH's use. The template will be transmitted to Ms. Aldridge under separate cover and should be customized as necessary to reflect the specific data sources and document categories applicable to each custodian.
Periodic reminders should be issued to all custodians at regular intervals — no less frequently than quarterly — to reinforce the continuing nature of the hold and to confirm ongoing compliance. Calderwood & Harkness LLP will advise DEH on the timing and content of reminder notices.
V. IT Department Instructions
The DEH/DFS IT department must be instructed to take the following actions immediately, and in no event later than September 5, 2025. These instructions should be communicated in writing by the Office of the General Counsel, with a copy provided to Calderwood & Harkness LLP for the compliance record.
1. Suspend Auto-Deletion Policies. All automated retention and deletion policies must be disabled immediately for the following systems and data sources, as they pertain to all custodians and non-custodial sources identified in Section III:
• Drayton Solutions email retention and deletion policies
• Brightwater Solutions retention and deletion schedules
• Northgate Data Systems message retention policies (including chat messages, channel messages, and shared files)
• Aldermere Systems document retention and lifecycle policies
• Backup-tape recycling and overwrite schedules
These policies must remain suspended for the duration of the litigation hold. No automated process should be permitted to delete, archive, or modify any data associated with the identified custodians or non-custodial data sources without the prior written approval of the Office of the General Counsel.
2. Preserve Backup Tapes. IT personnel must identify, collect, and secure backup tapes from the most recent quarterly backup cycle (Q2 2025, covering April through June 2025), as well as any other backup tapes within the preservation period that are readily identifiable. These tapes must be stored in a secure, climate-controlled location and must not be overwritten, recycled, degaussed, or otherwise rendered inaccessible. IT should prepare a written inventory of all preserved backup tapes, including tape identifiers, creation dates, and contents (to the extent known).
3. Disable Remote-Wipe Capabilities. For all mobile devices (company-issued and BYOD) assigned to or registered by the five identified custodians, remote-wipe and factory-reset capabilities must be disabled immediately. This includes disabling remote-wipe functionality in any mobile device management ("MDM") platform used by DEH/DFS (e.g., Northgate Systems, Ridgeway Software, or similar). This measure is necessary to ensure that custodial mobile devices are preserved in their current state pending forensic imaging by the e-discovery vendor.
4. Pinnacle Health IT Audit Trail. Full audit-trail logging must be enabled in the DFS Pinnacle Health IT instance to preserve a complete record of any changes to Meridian-related records, including modifications to account records, opportunity records, contact records, activity logs, and custom objects. If audit-trail logging is not currently enabled at the maximum level of granularity, IT should coordinate with the Pinnacle Health IT administrator to enable field-level history tracking for all relevant objects and fields.
5. Network Drive Snapshots. IT must create a point-in-time snapshot of the shared network drive located at \\\\DFS-FILE01\\GovContracts\\ and preserve the snapshot in read-only format. The snapshot should be stored on a separate, secure storage volume and should be accompanied by documentation recording the date and time of the snapshot, the method used, and the identity of the IT personnel who performed the operation. This snapshot will serve as a baseline preservation copy, ensuring that the contents of the drive as of the date of the snapshot are preserved even if subsequent modifications are made to the live drive.
6. Coordinate with E-discovery Vendor. IT personnel should be prepared to facilitate on-site access by Brindoval Analytics LLC, Calderwood & Harkness LLP's designated e-discovery vendor, for the purpose of forensic imaging of custodial devices (laptops, desktops, and mobile devices). Brindoval Analytics LLC is located at 8400 Leesburg Pike, Suite 320, Tysons Corner, Virginia 22182, and the designated project manager for this engagement is Daniel Furrow. On-site forensic imaging is expected to commence no later than September 19, 2025, pursuant to the e-discovery vendor statement of work to be executed on or about September 12, 2025. IT should ensure that appropriate workspace, network access, and administrative credentials are available to support the forensic imaging process, and should designate a primary IT point of contact to coordinate with Mr. Furrow and his team.
VI. E-discovery Vendor Engagement
Calderwood & Harkness LLP anticipates retaining Brindoval Analytics LLC ("Brindoval") as the e-discovery vendor for this matter. Brindoval will be responsible for forensic data collection, processing, hosting, and technology-assisted review ("TAR") services. Brindoval has extensive experience supporting complex antitrust investigations and government enforcement matters, and its technical capabilities are well suited to the data volumes and complexity anticipated in this engagement.
The estimated Phase 1 budget for Brindoval's services, covering all activities through the initial CID response (whether at the original October 3, 2025 deadline or the extended November 3, 2025 deadline, if granted), is approximately $385,000. This estimate is based on the preliminary data volume and custodian count identified in Section III.C and is subject to revision as additional custodians or data sources are identified. A detailed budget breakdown will be provided in the Brindoval statement of work.
Brindoval will be engaged directly by Calderwood & Harkness LLP. All vendor costs will be passed through to the client without markup, consistent with the fee arrangement described in the August 27, 2025 engagement letter.
The planned services to be performed by Brindoval include the following:
• Forensic Imaging. Forensic imaging of custodial laptops, desktops, and mobile devices with defensible chain-of-custody documentation. All forensic images will be verified using both MD5 and SHA-256 hash algorithms to ensure data integrity and to establish an unbroken chain of custody.
• Cloud-Hosted Data Collection. Collection of cloud-hosted data from the DEH/DFS Ashgrove Software tenant, including Drayton Solutions mailboxes, Aldermere Systems sites, and Northgate Data Systems data for all five identified custodians. Collection of archived email from the Brightwater Solutions system for the same custodians.
• Non-Custodial Data Collection. Collection of designated non-custodial data sources, including the shared network drive (\\\\DFS-FILE01\\GovContracts\\), FuelPricer database exports, and Pinnacle Health IT data exports.
• Processing and Deduplication. Processing of all collected data, including global deduplication by MD5 hash across the full data set, text extraction (including OCR of image-only files), and extraction and normalization of metadata fields.
• Hosting for Attorney Review. Hosting of all processed data on Brindoval's Kestrel Technologies platform for attorney review. The hosted environment will support full-text searching, metadata filtering, email threading, conceptual analytics, and technology-assisted review workflows.
• Technology-Assisted Review. Implementation of a TAR 2.0 (continuous active learning) protocol for document review, designed to prioritize the review of the most likely responsive documents and to improve review efficiency and consistency. Calderwood & Harkness LLP's review team will work collaboratively with Brindoval to train and validate the TAR model.
• Document Production. Production of responsive, non-privileged documents in TIFF format with extracted text and standard load files (Ashgrove Technologies .DAT and Opticon .OPT), with Bates numbering using the prefix DEH-MERID- (beginning at DEH-MERID-000001 and continuing sequentially).
The statement of work with Brindoval is expected to be executed no later than September 12, 2025. Calderwood & Harkness LLP will circulate the draft SOW to Ms. Aldridge for review prior to execution.
VII. Coordination with Third Parties
The following third-party considerations are relevant to the preservation and investigation response efforts and require attention from DEH's legal team.
Alderton & Knox, CPAs, LLP. As noted in Section III.B.8, DEH's independent auditors, Alderton & Knox, CPAs, LLP ("A&K"), may hold bid-related financial records relevant to the investigation. The A&K engagement partner is Yolanda Matsuda, CPA, and A&K is located at 3 Greenway Plaza, Suite 600, Houston, Texas 77046. Depending on the scope of responsive financial records, it may be necessary to issue a separate preservation request to A&K to ensure that relevant workpapers, audit schedules, and supporting documentation are not destroyed pursuant to A&K's standard document-retention policies. DEH should consider whether such a preservation request is warranted once the scope of responsive financial records is better understood through the initial custodial and non-custodial data collection. Calderwood & Harkness LLP will advise on the appropriate timing and form of any such request.
Pinnacle National Bank, N.A. Pinnacle National Bank, N.A. ("Pinnacle") serves as the administrative agent under DEH's $750 million senior secured revolving credit facility, dated March 15, 2023. The credit agreement governing the facility contains a "material litigation" reporting covenant under Section 6.01(h), which requires DEH to notify the administrative agent of any governmental investigation, proceeding, or action that could reasonably be expected to result in liability exceeding the material adverse effect ("MAE") threshold of $25 million. Given the potential financial exposure in this matter — which, based on preliminary analysis, includes statutory penalties of up to $15 million and treble damages estimated in the range of $90.29 million to $135.43 million — DEH should promptly assess its notification obligation to Pinnacle under the credit agreement. The potential triggering of the reporting covenant is a significant corporate governance consideration that may also implicate disclosure obligations under DEH's insurance policies and other contractual arrangements. This issue is addressed separately in the liability-exposure analysis to be prepared by Howard Bellamy, Partner, Antitrust & Competition, Calderwood & Harkness LLP.
Co-Respondents' Counsel. The following law firms represent the co-respondents identified in the CID:
• Galloway Petroleum Corp. is represented by Whitfield, Strauss & DeVane LLP (lead partner: Gregory Whitfield), located at 420 20th Street North, Suite 1600, Birmingham, Alabama 35203.
• Ridgeline Energy Partners LLC is represented by Archer Colby LLP (lead partner: Diane Colby), located at 191 Peachtree Street NE, Suite 3200, Atlanta, Georgia 30303.
Any coordination with co-respondents' counsel on preservation matters, production protocols, or other aspects of the investigation response will require prior authorization from the client. Such coordination may be governed by a joint-defense agreement or common-interest agreement, which would define the terms under which privileged communications and work product may be shared among the co-respondents' respective counsel without waiver. The advisability and terms of any such agreement will be discussed with Ms. Aldridge separately. Calderwood & Harkness LLP cautions that any joint-defense or common-interest arrangement must be carefully evaluated in light of the possibility that one or more co-respondents may seek to cooperate with the Attorney General's office, which could create conflicts and undermine the protections of a joint-defense arrangement.
VIII. Key Deadlines and Action Items
The following table sets forth the key deadlines and action items for the initial phase of the preservation and investigation response effort. All deadlines are firm unless otherwise indicated.
Calderwood & Harkness LLP will provide regular status updates to Ms. Aldridge and will maintain a detailed tracking log of all preservation and collection activities for the compliance record.
IX. Consequences of Non-Compliance
The preservation obligations described in this memorandum are mandatory and must be treated with the utmost seriousness and urgency by every custodian, IT personnel member, and other individual to whom they apply. Failure to comply with these obligations — whether through affirmative destruction, negligent loss, or passive failure to prevent the deletion of relevant information — may result in severe and potentially irreversible consequences for DEH, DFS, and the individuals involved.
The potential consequences of non-compliance include the following:
Court-Imposed Sanctions. Courts possess broad inherent authority and, in many jurisdictions, statutory authority to impose sanctions for the spoliation of evidence. Available sanctions include adverse-inference instructions (permitting the trier of fact to infer that destroyed evidence was unfavorable to the spoliating party), monetary penalties assessed against the organization and/or responsible individuals, issue preclusion (precluding the spoliating party from contesting certain issues of fact), exclusion of evidence, or, in the most egregious cases, default judgment or dismissal.
Criminal Liability. Spoliation of evidence in the context of a government antitrust investigation may give rise to separate criminal liability under obstruction-of-justice statutes, both at the federal level (including 18 U.S.C. § 1519, which criminalizes the knowing destruction of documents with intent to obstruct a federal investigation) and under Meridian state law. The potential for criminal prosecution is a distinct and independent risk that exists regardless of the outcome of the underlying antitrust investigation.
Reputational Harm and Loss of Cooperation Credit. The destruction or loss of relevant evidence would cause significant reputational harm to DEH and DFS in the eyes of the Attorney General's office and would undermine the companies' credibility throughout the course of the investigation. Evidence of spoliation may affect the AG's willingness to extend cooperation credit, negotiate favorable resolution terms, or exercise prosecutorial discretion in a manner favorable to the respondents. In antitrust investigations, the tone and quality of a respondent's cooperation with the enforcement authority can have a material impact on the ultimate outcome of the matter.
Breach of Fiduciary Duties. Corporate officers and directors who fail to take reasonable steps to preserve evidence in the face of a known legal obligation to do so may be found to have breached their fiduciary duties of care and loyalty to the corporation and its shareholders. Such a breach could expose individual officers and directors to personal liability in derivative litigation or regulatory proceedings.
Every custodian and IT personnel member must understand that the litigation hold is a mandatory legal obligation, not a discretionary guideline. Compliance is not optional. Any questions, concerns, or uncertainties regarding the scope or application of the hold should be directed immediately to the contacts listed in Section X below.
X. Contact Information
All questions regarding this memorandum, the litigation hold, or the preservation obligations described herein should be directed to one of the following individuals:
Monica Reyes Senior Associate, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Tel: (202) 555-0147
Email: mreyes@calderwoodharkness.com
Howard Bellamy Partner, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Tel: (202) 555-0132
Email: hbellamy@calderwoodharkness.com
Patricia Aldridge SVP & General Counsel Dunmore Energy Holdings Ltd. 4100 Westchase Boulevard, Suite 1200 Houston, TX 77042 Tel: (713) 555-0288
Email: paldridge@dunmore.com
Custodians and IT personnel should not attempt to resolve preservation questions independently. When in doubt, preserve the document or data in question and seek guidance from one of the contacts listed above.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Monica Reyes Senior Associate, Antitrust & Competition Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Tel: (202) 555-0147
Email: mreyes@calderwoodharkness.com
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION / WORK PRODUCT This memorandum is protected by the attorney-client privilege and the work-product doctrine. It is intended solely for the use of the addressee and other authorized personnel of Dunmore Energy Holdings Ltd. and Dunmore Fuel Supply, Inc. Any unauthorized disclosure, copying, or distribution of this memorandum or its contents is strictly prohibited.
# | Name | Title | Entity | Estimated Data Volume (GB) | Estimated Document Count
1 | Terrence "Terry" Kinloch | VP, Government Contracts | Dunmore Fuel Supply, Inc. | 42.7 GB | ~186,000
2 | Sandra Ochoa | Director of Pricing & Analytics | Dunmore Fuel Supply, Inc. | 31.4 GB | ~142,000
3 | Nolan Prescott | Regional Sales Manager, SE U.S. | Dunmore Fuel Supply, Inc. | 18.9 GB | ~95,000
4 | Patricia Aldridge | SVP & General Counsel | Dunmore Energy Holdings Ltd. | 27.3 GB | ~118,000
5 | Malcolm Haverford | CEO | Dunmore Energy Holdings Ltd. | 12.1 GB | ~63,000
Total | 132.4 GB | ~604,000
# | Action Item | Responsible Party | Deadline
1 | Issue written litigation-hold notices to each of the five identified custodians (Kinloch, Ochoa, Prescott, Aldridge, Haverford) | Patricia Aldridge / DEH Legal Dept. | September 5, 2025
2 | Instruct DEH/DFS IT department to suspend all auto-deletion policies and preserve backup tapes, per Section V | Patricia Aldridge / DEH IT | September 5, 2025
3 | Collect and confirm signed acknowledgments from all five custodians | Patricia Aldridge / DEH Legal Dept. | September 7, 2025 (48 hrs after notice)
4 | Execute e-discovery vendor SOW with Brindoval Analytics LLC | Monica Reyes / Calderwood & Harkness LLP | September 12, 2025
5 | Facilitate on-site forensic imaging of custodial laptops and mobile devices by Brindoval Analytics | DEH IT / Brindoval Analytics | Commencing September 19, 2025
6 | Complete forensic collection of all custodial and non-custodial data sources | Brindoval Analytics | Target: September 26, 2025
7 | Submit request for 30-day extension of CID response deadline (from October 3 to November 3, 2025) | Howard Bellamy / Calderwood & Harkness LLP | September 22, 2025
8 | Original CID response deadline (40 calendar days from August 22, 2025 issuance) | — | October 3, 2025
9 | Commence TAR model training on processed data set | Brindoval Analytics / Calderwood & Harkness LLP | October 10, 2025
10 | Extended CID response deadline (if 30-day extension is granted) | — | November 3, 2025

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION / WORK PRODUCT

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CALDERWOOD & HARKNESS LLP

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