Contract analysis

I. PURPOSE AND SCOPE This memorandum provides a detailed chronological timeline of all material events from the inception of the Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 (the "Treaty") between Quorum Casualty & Surety Company ("QC&S"), as cedent, and Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"), as reinsurer, through the opening of the Calderwood & Harkness LLP engagement on Ma

II. KEY TO DOCUMENT CITATIONS The following abbreviations are used throughout this memorandum to identify the source documents cited in the timeline. All document identification numbers correspond to the preliminary document collection index maintained by Calderwood & Harkness LLP. Unless otherwise indicated, all document references are to the original or best available copy in the possession of QIH or QC&S. Document

III. DETAILED CHRONOLOGICAL TIMELINE A. Treaty Inception and Initial Period (2019–2020) July 1, 2019 — Treaty Inception Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 becomes effective as of 12:01 a.m. Eastern Time on July 1, 2019. The parties and key terms of the Treaty are as follows: Cedent: Quorum Casualty & Surety Company (NAIC No. 24891), a New York-domiciled stock property and casualty in

1. Late Notice (Article 7): Pinnacle Atlantic contends that QC&S failed to provide timely notice of the Meridian Docks mass tort cluster. The letter emphasizes the 14-month, 7-day delay between QC&S's initial reserving of the Meridian Docks claims (March 15, 2021) and the transmission of formal notice to Pinnacle Atlantic (May 22, 2022). Pinnacle Atlantic argues that Article 7 required QC&S to notify the reinsurer of

2. Misallocation of Loss Development (Article 5): Pinnacle Atlantic contends that $22,300,000 in IBNR reserve strengthening was improperly allocated to Treaty Year 2022 instead of Treaty Year 2021. Pinnacle Atlantic asserts that the underlying exposures giving rise to the IBNR relate to accident-year 2021 occurrences and should be allocated accordingly. If the $22,300,000 were reallocated to Treaty Year 2021, the eff

3. Failure to Follow the Fortunes / Settlements (Article 11): Pinnacle Atlantic contends that the Veridian E&O cluster settlement of $34,500,000 was not made in the ordinary course of business, was not characterized by good faith and businesslike conduct as required by Article 11, and was motivated by a desire to inflate aggregate losses above the $120,000,000 retention for Treaty Year 2023. Pinnacle Atlantic asserts

4. Inaccurate Premium Reporting (Article 3): Pinnacle Atlantic contends that QC&S underreported ceded earned premium for Treaty Year 2022 by $6,800,000, reporting $38,400,000 rather than the $45,200,000 that Pinnacle Atlantic calculates based on its own analysis. At the provisional rate of 42%, this discrepancy results in an alleged treaty premium underpayment of approximately $2,856,000 (42% × $6,800,000). Pinnacle

IV. SUMMARY OF KEY INTERVALS AND GAPS The following table summarizes the critical time intervals referenced in the dispute. These intervals are expected to feature prominently in the parties' respective legal arguments regarding late notice, waiver, estoppel, and laches. The intervals above should be correlated with the contractual notice and cure periods under the Treaty, as well as any applicable statutes of limita

V. INDEX OF REFERENCED DOCUMENTS The following is a master index of all documents cited in this timeline, organized by document identification number. For each document, the index provides a brief description, the identified custodian, and the current production and preservation status as of the date of this memorandum. Litigation Hold Notice. A comprehensive litigation hold notice was issued by Calderwood & Harkness