CONFIDENTIAL — LEGAL HOLD NOTICE
DUNMORE ENERGY HOLDINGS LTD. Office of the General Counsel 4100 Westchase Boulevard, Suite 1200 Houston, Texas 77042
September 5, 2025
CONFIDENTIAL — LEGAL HOLD NOTICE
TO: _______ (Custodian Name)
FROM: Patricia Aldridge, Senior Vice President & General Counsel, Dunmore Energy Holdings Ltd.
RE: MANDATORY Document Preservation — Immediate Action Required
You have been identified as a custodian of documents and information that are potentially relevant to a pending government investigation involving Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary, Dunmore Fuel Supply, Inc. ("DFS"). This investigation was initiated by the Office of the Attorney General of the State of Meridian, Antitrust Division (the "AG's Office"), which issued Civil Investigative Demand No. AG-ANT-2025-04172 (the "CID") on August 22, 2025. DEH and DFS have retained the law firm of Calderwood & Harkness LLP ("C&H") to represent the companies in connection with this matter. The engagement is tracked internally at C&H under Matter No. 1016-00001.
The investigation concerns allegations of bid rigging in connection with fuel-supply contracts awarded by the Meridian State Department of Transportation ("Meridian DOT") during the period from 2021 through 2024. The CID requests, among other things, the production of documents and information relating to fuel-supply bids submitted by DEH and DFS during the relevant period, as well as communications between DEH/DFS personnel and employees or representatives of certain competing fuel suppliers.
Because you have been identified as a person who may possess, have access to, or have control over documents or information that are relevant to this matter, you are receiving this Legal Hold Notice. Please read this notice carefully and in its entirety. It describes your obligations to preserve documents and information, the categories of materials covered by this hold, and the steps you must take immediately.
THIS IS A MANDATORY LEGAL HOLD. YOU MUST PRESERVE ALL POTENTIALLY RELEVANT DOCUMENTS AND INFORMATION IMMEDIATELY. COMPLIANCE WITH THIS NOTICE IS NOT OPTIONAL.
Section 1: What You Must Do — Immediate Obligations
Upon receipt of this Legal Hold Notice, you are required to take the following actions immediately. Failure to do so may expose both the company and you personally to serious legal consequences, as described further in Section 9 below.
1. STOP deleting, discarding, overwriting, or altering any documents — whether in electronic or hard-copy form — that may relate to the subject areas described in Section 2 of this notice. This obligation takes effect immediately upon your receipt of this notice and applies regardless of any prior document-retention or destruction schedules that may have been in effect.
2. PRESERVE all emails, text messages, instant messages (including communications sent or received via Northgate Data Systems, Meridian Solutions, Meridian Services Inc., Harborline Technologies, or any other messaging platform), voicemails, calendar entries, notes, memoranda, spreadsheets, presentations, contracts, pricing models, bid submissions, handwritten notes, and any other materials — in whatever format or medium — in your possession, custody, or control that relate to the subject areas described in Section 2.
3. IDENTIFY and set aside any paper files, whether located in your office, cubicle, home office, or any other location, that relate to the subjects described in Section 2. This includes, but is not limited to, notebooks, folders, binders, printed reports, handwritten notes, and business cards. Do not discard any such materials. If you are uncertain whether a particular document falls within the scope of this hold, err on the side of preservation and contact the undersigned for guidance.
4. DO NOT move, reorganize, rename, or alter the filing structure of any electronic or paper files that may be relevant to this hold. The e-discovery team and outside counsel will need to review and collect these materials in their current state. Any reorganization or relocation of files — even if well-intentioned — may compromise the integrity of the collection process and could result in the loss of relevant metadata.
5. NOTIFY the undersigned, Patricia Aldridge, if you become aware of any other individuals — whether current or former employees of DEH or DFS, contractors, consultants, or third parties — who may possess relevant information or documents relating to the subject areas covered by this hold. You should provide such notification as promptly as possible by emailing paldridge@dunmore.com or by calling (713) 555-0288.
Section 2: Subject Areas Covered by the Hold
This legal hold covers all documents and communications from January 1, 2020 to the present relating to any of the following subject areas:
(a) Fuel-supply bids, proposals, or responses to requests for proposals ("RFPs") submitted by DEH or DFS to the Meridian State Department of Transportation ("Meridian DOT"), including bids or proposals relating to all five geographic lots established by Meridian DOT for fuel-supply procurement purposes:
• Lot A — Northern Meridian
• Lot B — Central Meridian
• Lot C — Southern Meridian
• Lot D — Eastern Meridian
• Lot E — Western Meridian
This includes, without limitation, all drafts, revisions, final submissions, cover letters, transmittal documents, compliance certifications, and any internal analyses or work papers prepared in connection with any such bid or proposal.
(b) Communications — whether by email, telephone, text message, instant message, in-person meeting, video conference, or any other means — with employees or representatives of Galloway Petroleum Corp. ("Galloway") or Ridgeline Energy Partners LLC ("Ridgeline"), including but not limited to the following individuals:
• Richard "Rick" Ellerbee
• Constance Barlow
• Jonas Hartwick
• Elaine Pruitt
This includes all communications, regardless of the stated topic or purpose, with any employee, officer, director, consultant, or agent of Galloway or Ridgeline during the relevant period.
(c) Fuel pricing, profit margins, cost analyses, competitive intelligence, or bidding strategies for any Meridian state contract, including but not limited to analyses prepared using the FuelPricer application or any other pricing tool, modeling software, or spreadsheet. This encompasses internal discussions or analyses regarding the pricing levels of competitors, anticipated competitor bid amounts, market-share allocation, customer allocation, or territory allocation.
(d) Industry meetings, trade-association events, conferences, conventions, seminars, or informal gatherings (including dinners, social events, golf outings, or similar occasions) at which fuel pricing, customer allocation, market division, or bidding strategy was discussed — or may have been discussed — with any representative of a competitor, including Galloway, Ridgeline, or any other fuel-supply company.
(e) Meridian DOT procurement processes, RFP documents, addenda or amendments to RFPs, pre-bid meeting materials, contract awards, award notification letters, debriefing materials, contract performance records, delivery records, invoices, change orders, and any correspondence or communications with Meridian DOT officials or personnel relating to fuel-supply contracts.
(f) Internal approvals of bid pricing for any Meridian state contract, including approval workflows, sign-off sheets, pricing committee minutes, management reviews, and any communications between or among DEH/DFS employees regarding the authorization or approval of pricing submitted in any bid or proposal.
Note on Temporal Scope: Although the CID identifies the period of alleged anticompetitive conduct as beginning in January 2021, this legal hold extends the preservation period back to January 1, 2020 in order to capture any communications, documents, or other materials that may pre-date the alleged conspiracy but that could provide context or background relevant to the investigation. This broader date range was established at the direction of outside counsel at Calderwood & Harkness LLP and must be observed in full.
Section 3: Types of Information and Documents Covered
To ensure comprehensive preservation, this legal hold applies to all of the following categories of information and documents, in whatever format or medium they exist:
Electronic Documents and Data:
• Emails (including all attachments, embedded images, and inline content), whether stored in Hollowell Systems, webmail interfaces, or any other email client or platform
• Calendar entries, meeting invitations, and scheduling records
• Instant messages and chat communications, including those sent or received via Northgate Data Systems, Meridian Solutions, Meridian Services Inc., Harborline Technologies, text/SMS, Westmark Software, or any other messaging platform or application
• Voicemail messages, whether stored on company phone systems, mobile devices, or voicemail-to-email systems
• Word-processing documents (including Ashbury Holdings Word, Stonefield Health IT, and similar formats)
• Spreadsheets (including Ashbury Holdings Excel, Stonefield Services Inc., and similar formats)
• Presentations (including Ashbury Holdings Northgate Services Inc., Pemberton Services Inc., and similar formats)
• PDF documents, whether native or scanned
• Databases and database extracts
• Customer-relationship management ("CRM") records, including records stored in Pinnacle Health IT or any successor or alternative CRM platform
• Pricing-application data, including data stored in or generated by the FuelPricer application or any other pricing or bidding tool
• Documents stored on Aldermere Systems sites, shared network drives, cloud-based storage platforms (e.g., Cobalt Ridge Systems, Hollowell Health IT, Larkspur Technologies, box), or USB/external storage devices
• Social media posts, direct messages, or other communications relating to the subject areas described above
Hard-Copy Documents:
• Business correspondence and letters
• Internal memoranda and reports
• Contracts, agreements, and amendments
• Handwritten notes, notebooks, journals, and sticky notes
• Business cards
• Meeting agendas, meeting minutes, and sign-in sheets
• Printed spreadsheets, analyses, charts, or graphs
• Any other physical documents or tangible items that relate to the subject areas described in Section 2
Metadata:
• All metadata associated with electronic documents described above must be preserved. Metadata includes, but is not limited to, file creation dates, modification dates, author information, recipient information, file paths, and version histories. You must not take any action that would alter or destroy metadata associated with relevant documents.
Archived and Backup Materials:
• This hold extends to archived or backup copies of any of the foregoing, including materials stored in Brightwater Solutions, legacy backup tapes, or other archival or backup systems. The IT department has been separately instructed to preserve all relevant archived and backup materials; however, if you are aware of any archived materials in your personal possession or under your personal control, you must preserve those materials as well.
Section 4: Personal Devices and Accounts
This legal hold extends beyond company-issued equipment and company-managed systems. Specifically:
• Personal Devices. If you have used any personal device — including a personal cell phone, tablet, home computer, or personal laptop — for company business at any time during the relevant period (January 1, 2020 to the present), all documents and communications stored on such devices that relate to the subject areas described in Section 2 are covered by this hold and must be preserved. You must not delete any such documents or communications from your personal devices.
• Personal Email Accounts. If you have used any personal email account — including, by way of example, accounts hosted by Northgate Software, Cascade Health IT, Ridgeline Technologies, Greaves Solutions, or any other provider — for any communications relating to the subject areas described in Section 2, all such communications must be preserved. You must not delete any emails, attachments, or other materials from such accounts that fall within the scope of this hold.
• Personal Messaging Applications. If you have used any personal messaging application — including Meridian Services Inc., Harborline Technologies, Kestrel Data Systems, Dunmore Software, Westmark Software, or any other application — for any communications relating to the subject areas described in Section 2, all such communications must be preserved. You must disable any auto-delete or disappearing-message features on such applications to the extent they apply to relevant communications.
• Availability for Collection. You must preserve all documents and information stored on personal devices and in personal accounts and make them available for collection if requested by the Office of the General Counsel or outside counsel at Calderwood & Harkness LLP. Any collection from personal devices will be conducted in a manner designed to minimize disruption and to protect the privacy of personal materials that fall outside the scope of this hold.
Section 5: Prohibition on Destruction or Alteration
The preservation obligations set forth in this notice are absolute and must be strictly observed. The following specific prohibitions apply:
• No Deletion or Destruction. You must not delete, destroy, discard, shred, overwrite, modify, encrypt, or alter any document or electronically stored information ("ESI") that falls within the scope of this hold. This prohibition applies regardless of whether you believe the document to be duplicative, immaterial, or otherwise unimportant.
• No Delegation of Destruction. You must not instruct, request, suggest, or encourage any other person — including administrative assistants, IT staff, subordinates, colleagues, or any third party — to delete, destroy, discard, or alter any potentially relevant materials. If you supervise other employees, you must ensure that those employees are not taking any actions that would result in the destruction of relevant documents.
• Auto-Delete Settings. You should not manually alter any auto-delete or retention settings on your email account, messaging platforms, or any other systems. The Information Technology department has been separately instructed to suspend all auto-deletion policies and retention schedule purges for custodians covered by this hold. If you become aware that auto-deletion or purging continues to operate on any system containing your documents, you must immediately notify Patricia Aldridge.
• Reporting Inadvertent Destruction. If you believe or suspect that any potentially relevant documents have already been inadvertently deleted, destroyed, overwritten, or lost — whether before or after receipt of this notice — you must immediately notify Patricia Aldridge at paldridge@dunmore.com or (713) 555-0288. Early notification of any such loss is critical, as it may be possible to recover deleted materials through forensic means if the loss is reported promptly.
Section 6: Duration of the Hold
This legal hold is effective immediately upon your receipt of this notice and will remain in effect until you receive written notice from the Office of the General Counsel of Dunmore Energy Holdings Ltd. that the hold has been lifted. There is no predetermined end date for this hold.
You must not assume that the hold has been lifted simply because a period of time has passed, because you have not received recent communications regarding the hold, or because your role, responsibilities, or reporting structure within the company have changed.
If you leave the employment of DEH or DFS — whether through resignation, retirement, termination, or any other reason — while this hold remains in effect, you must contact the Office of the General Counsel before disposing of any company-related documents, returning company-issued devices, or deleting any relevant materials from personal devices or personal accounts. Your preservation obligations survive the end of your employment and continue until you receive written notice that the hold has been released.
The Office of the General Counsel will periodically reissue or update this Legal Hold Notice to confirm that it remains in effect and to provide any updated instructions or guidance. Your receipt of a reminder or update does not change the scope or substance of your obligations unless the updated notice expressly states otherwise.
Section 7: Upcoming Forensic Collection
Calderwood & Harkness LLP has engaged Brindoval Analytics LLC ("Brindoval"), a third-party electronic discovery and forensic technology vendor, to perform forensic imaging and collection of custodial devices and data sources in connection with this matter.
Forensic collection is scheduled to commence on or about September 19, 2025. In connection with this process, you may be asked to make one or more of the following available for forensic imaging:
• Company-issued laptop computers
• Company-issued desktop computers
• Company-issued mobile devices (cell phones, tablets)
• Personal mobile devices or personal computers used for company business
• External storage media (USB drives, external hard drives, SD cards)
• Access credentials for cloud-based storage or messaging platforms
You must cooperate fully with any collection requests from Brindoval Analytics or the Office of the General Counsel. This includes making devices available at the scheduled time, providing any necessary passwords or access credentials, and answering questions about your document storage practices and habits.
Daniel Furrow, Project Manager at Brindoval Analytics, or a member of his team may contact you directly to schedule device collection and coordinate logistics. Before providing access to any device or data source in response to a request from Brindoval Analytics, you should confirm the request with Patricia Aldridge at the Office of the General Counsel or Monica Reyes at Calderwood & Harkness LLP to verify that the request is authorized. This verification step is intended to protect against unauthorized access and to ensure that all collections are properly documented and tracked.
Forensic imaging is a standard process that creates a complete, bit-for-bit copy of the data stored on a device. The process is designed to be non-destructive — your device will be returned to you after imaging, and your ability to use the device will not be affected. However, you should plan for your device to be unavailable for a period of approximately two to four hours during the imaging process.
Section 8: Confidentiality
The existence of this Legal Hold Notice, the Civil Investigative Demand (CID No. AG-ANT-2025-04172), and the underlying investigation by the Meridian Attorney General's Office are confidential. You are required to observe the following confidentiality obligations:
• External Communications. You must not discuss the legal hold, the CID, or the investigation with anyone outside of DEH and DFS, except as specifically directed by the Office of the General Counsel or outside counsel at Calderwood & Harkness LLP. This prohibition applies to all external parties, including personal friends, family members, former colleagues, industry contacts, and any other person not employed by DEH or DFS.
• Competitor Communications. You must not discuss the legal hold, the CID, or the investigation with any employee, officer, director, consultant, agent, or representative of Galloway Petroleum Corp., Ridgeline Energy Partners LLC, or any other competitor or third party. This prohibition is absolute and applies regardless of the context in which such a discussion might arise, including in the context of industry meetings, trade association events, or social gatherings.
• Government and Media Contacts. If you are contacted by anyone from the Meridian Attorney General's Office, any other governmental authority (federal, state, or local), any law enforcement agency, or any media outlet regarding the investigation, you must take the following steps:
1. Do not provide any substantive response, information, or documents.
2. Politely inform the inquiring party that you are not authorized to discuss the matter.
3. Immediately notify Patricia Aldridge at paldridge@dunmore.com or (713) 555-0288.
4. Do not provide any substantive response without prior authorization from the Office of the General Counsel or outside counsel.
These confidentiality obligations are essential to protecting the company's legal interests and the integrity of the attorney-client privilege and work-product protections that attach to the company's defense of this matter.
Section 9: Consequences of Non-Compliance
Failure to comply with this Legal Hold Notice may result in serious consequences for DEH, DFS, and for you individually. These consequences include, but are not limited to, the following:
• Court-Imposed Sanctions. Courts have broad authority to impose sanctions for the spoliation or destruction of relevant evidence. Such sanctions may include adverse-inference instructions (whereby the court instructs the jury to presume that destroyed documents were unfavorable to the company), monetary penalties, exclusion of evidence, or, in extreme cases, default judgment against the company.
• Criminal Liability. Spoliation of evidence in a government antitrust investigation may give rise to separate criminal liability under federal and state obstruction-of-justice statutes. Obstruction of a government investigation is a serious criminal offense that may result in fines and imprisonment, and such liability may attach to the individual responsible for the destruction of evidence, not only to the company.
• Internal Disciplinary Action. Any employee who fails to comply with this Legal Hold Notice, whether through intentional destruction of documents, negligent failure to preserve materials, or failure to cooperate with collection efforts, will be subject to internal disciplinary action, up to and including termination of employment, in accordance with DEH's and DFS's applicable employment policies and procedures.
DEH and DFS take their document-preservation obligations with the utmost seriousness. Full and complete compliance with this Legal Hold Notice is mandatory. If you have any questions about the scope of the hold, the types of materials covered, or the steps you should take to ensure compliance, you should contact the Office of the General Counsel or outside counsel immediately rather than making assumptions or taking any action that could result in the loss of relevant materials.
Section 10: Questions and Contact Information
All questions regarding this Legal Hold Notice — including questions about the scope of the hold, the types of documents covered, your specific preservation obligations, or the upcoming forensic collection process — should be directed to one of the following individuals:
Patricia Aldridge Senior Vice President & General Counsel Dunmore Energy Holdings Ltd. 4100 Westchase Boulevard, Suite 1200 Houston, TX 77042
Email: paldridge@dunmore.com
Telephone: (713) 555-0288
Monica Reyes Senior Associate, Antitrust & Competition Practice Group Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006
Email: mreyes@calderwoodharkness.com
Telephone: (202) 555-0147
Do not hesitate to contact either Patricia Aldridge or Monica Reyes if you have any questions whatsoever about your obligations under this notice. It is far better to ask a question and receive guidance than to risk the inadvertent loss or destruction of relevant materials.
Acknowledgment of Receipt
By signing below, I acknowledge that I have received and read this Legal Hold Notice dated September 5, 2025, and that I understand my obligations to preserve all potentially relevant documents and information as described above. I further acknowledge that I understand the consequences of non-compliance as set forth in Section 9 of this notice and that I will comply fully with the preservation obligations described herein.
Name (Print): ________
Title / Position: ________
Signature: ________
Date: ________
Please return the signed acknowledgment to paldridge@dunmore.com within 48 hours of receipt.
You should retain a copy of this Legal Hold Notice for your personal records.
Distribution:
• Original (signed acknowledgment): Patricia Aldridge, Office of the General Counsel, Dunmore Energy Holdings Ltd.
• Copy: Custodian (for custodian's records)
• Copy: Calderwood & Harkness LLP, Matter File No. 1016-00001