Contract analysis

1. Purpose of Letter and Representation Calderwood & Harkness LLP represents Stonefield Logistics Group Inc. ("Stonefield" or "SLG") in connection with the above-referenced litigation, Delano v. Stonefield Logistics Group Inc., Case No. 3:25-cv-01847-RBC, currently pending before the United States District Court for the Northern District of Texas, Dallas Division. This letter serves as formal notice of a claim under

2. Policy Identification The following information identifies the relevant Policy under which coverage is being sought: The above-captioned litigation involves claims arising from alleged employment practices that fall squarely within the scope of the Policy's insuring agreement, as described in greater detail below. The underlying Complaint was filed on April 30, 2025, which is within the current Policy Period. Ston

3. Description of the Underlying Litigation 3.1 Case Caption and Court Information The following sets forth the identifying information for the underlying litigation: A complete copy of the Complaint, as filed, is enclosed with this letter for Broadleaf's review and records. 3.2 Parties. Plaintiff. The Plaintiff in this action is Marcus Delano, an individual residing in Fort Worth, Tarrant County, Texas. Mr. Delano i

4. Potential Exposure While Stonefield believes that meritorious defenses exist and intends to vigorously contest the claims asserted in the Complaint, we set forth below a summary of the potential financial exposure presented by this matter based on Plaintiff's damages theory as articulated in the Complaint. This summary is provided for Broadleaf's information in connection with its coverage evaluation and reserving

5. Procedural Status As of the date of this letter, the procedural status of the litigation is as follows: • Complaint Filed: The Complaint was filed on April 30, 2025 and served upon Stonefield on May 1, 2025. • Answer: Stonefield's Answer and Affirmative Defenses are currently being prepared by this firm and will be filed in accordance with all applicable deadlines under the Federal Rules of Civil Procedure and the

6. Request for Coverage Confirmation Stonefield Logistics Group Inc. respectfully requests that Broadleaf Insurance Company acknowledge and confirm coverage under Policy No. BIC-EPL-2024-07831 for the defense and indemnification of the claims asserted in Delano v. Stonefield Logistics Group Inc., Case No. 3:25-cv-01847-RBC. The claims asserted against Stonefield in the Complaint constitute a "claim" as that term is d

7. Defense Counsel Information Calderwood & Harkness LLP has been retained by Stonefield Logistics Group Inc. as defense counsel in this matter. The key personnel and contact information for the defense team are as follows: Calderwood & Harkness LLP has extensive experience in employment litigation and wage-and-hour defense, including FLSA collective actions and independent contractor misclassification disputes. The

8. Document Enclosures The following documents are enclosed with this letter for Broadleaf's review and records in connection with its coverage evaluation:

1. Complaint — Copy of the Complaint filed April 30, 2025, in Delano v. Stonefield Logistics Group Inc., Case No. 3:25-cv-01847-RBC, United States District Court for the Northern District of Texas, Dallas Division (with exhibits thereto);

2. EPLI Policy — Copy of the Employment Practices Liability Insurance Policy No. BIC-EPL-2024-07831, including all endorsements, amendments, and schedules thereto;

3. ICOA Templates — Copies of the Independent Contractor Operating Agreement templates utilized by Stonefield during the relevant period, in three versions: (a) ICOA Version 1.0 (original template, effective 2018); (b) ICOA Version 2.0 (revised template, effective August 2020); and (c) ICOA Version 3.0 (revised template, effective January 2023). These ICOA templates are provided for reference purposes to assist Broad

9. Request for Prompt Response and Point of Contact Given the significance and potential magnitude of this matter, Stonefield respectfully requests that Broadleaf take the following actions as promptly as practicable: (a) Designate a Claims Adjuster or Coverage Counsel. Stonefield requests that Broadleaf designate a specific claims adjuster or coverage counsel as the primary point of contact for all ongoing communica

10. Reservation of Rights This notification is provided pursuant to, and in accordance with, the terms and conditions of the Policy, including all provisions requiring prompt notice of claims, suits, or potential claims. This letter is not intended to, and shall not be construed to, limit, waive, modify, or otherwise affect any of Stonefield Logistics Group Inc.'s rights or any of Broadleaf Insurance Company's obliga

1. Complaint, Delano v. Stonefield Logistics Group Inc., Case No. 3:25-cv-01847-RBC (filed Apr. 30, 2025)

2. Employment Practices Liability Insurance Policy No. BIC-EPL-2024-07831

3. Independent Contractor Operating Agreement Templates (v1.0, 2018; v2.0, Aug. 2020; v3.0, Jan. 2023) Policy Detail | Information Policy Number | BIC-EPL-2024-07831 Named Insured | Stonefield Logistics Group Inc. Policy Period | January 1, 2025 – January 1, 2026 Self-Insured Retention (SIR) | $2,000,000 Policy Limit | $10,000,000 (aggregate) Type of Coverage | Employment Practices Liability Insurance Case Detail | I