Contract analysis

From: Yuki Nakamura <ynakamura@calderwoodharkness.com> To: Tobias Engström <tengstrom@quoruminsurance.com> Cc: Jeffrey Park <jpark@calderwoodharkness.com> Date: Sat, 07 Mar 2026 10:23:00 -0000 Subject: Ceded Earned Premium Calculations — Treaty No. PA-QCS-2019-EXL-0044 (TY 2022) [PRIVILEGED & CONFIDENTIAL]

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I hope this message finds you well. My name is Yuki Nakamura, and I am an associate at Calderwood & Harkness LLP working with Douglas Carmichael and Jeffrey Park on Matter No. 1025-00005, in which we represent Quorum Insurance Holdings Corp. and Quorum Casualty & Surety Company ("QC&S") in connection with the dispute with Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"). I am writing to request detailed workp

As you are aware, one of the four grounds asserted in Pinnacle Atlantic's February 14, 2026 pre-suit demand letter (sent by counsel at Hargrove, Fitch & Calloway LLP, previously circulated) involves an alleged underreporting of ceded earned premium for TY 2022 under Article 3 of the Treaty. QC&S reported ceded earned premium of $38,400,000 for TY 2022, whereas Pinnacle Atlantic asserts the correct figure is $45,200,0

1. **Complete workpapers** supporting QC&S's calculation of ceded earned premium of $38,400,000 for TY 2022, including all underlying premium bordereaux, cession statements, and quarterly or monthly premium reports submitted to Pinnacle Atlantic through Broadreach Intermediaries Inc.

2. **Detailed identification and quantification of all amounts excluded** from ceded earned premium under Article 3.4 of the Treaty (run-off portfolio transfer premiums). Specifically, we request the dollar amount of run-off portfolio transfer premiums excluded, the underlying policies or portfolios to which those exclusions relate, and any supporting documentation or internal memoranda explaining the basis for each

3. **Line-by-line reconciliation** between QC&S's reported figure of $38,400,000 and Pinnacle Atlantic's asserted figure of $45,200,000. To the extent QC&S has already performed such a reconciliation or has identified the specific items accounting for the $6,800,000 difference, we would appreciate receiving those materials.

4. **Any correspondence or communications** between QC&S (or Broadreach Intermediaries Inc. on QC&S's behalf) and Pinnacle Atlantic regarding ceded earned premium calculations, premium adjustments, or premium disputes for TY 2022, including any communications in connection with the sliding-scale premium adjustment mechanism under the Treaty (minimum rate of 35%, maximum rate of 52%).

5. **Internal analyses, memoranda, or emails** within QC&S or between QC&S and Broadreach Intermediaries Inc. (including communications with Jamie Castellano) discussing the proper treatment of run-off portfolio transfer premiums under Article 3.4, or any prior disputes or discussions regarding the scope of the Article 3.4 exclusion.

6. **QC&S's premium accounting records** for TY 2022 showing gross written premium, net earned premium, and ceded earned premium broken down by covered line (commercial general liability, excess/umbrella liability, and professional liability), to the extent such breakdowns exist.

7. **Any prior treaty year premium reports** (TY 2019, TY 2020, and TY 2021) to the extent they reflect similar exclusions under Article 3.4, which would help establish a course of dealing or consistent treatment of such items.

We would be grateful if you could provide these materials by **Friday, March 14, 2026**, so that our team can complete the premium reporting analysis memorandum and incorporate the findings into the broader case assessment. We recognize this is a tight turnaround, and if you anticipate any difficulty meeting that date, please let us know as soon as possible so we can discuss priorities. Additionally, if it would be h

As a brief reminder, all documents responsive to the litigation hold notice issued on March 4, 2026 (previously circulated) must continue to be preserved, including drafts and internal communications relating to premium calculations for the Treaty. Please ensure that any relevant custodians within QC&S and any applicable third parties are maintaining compliance with the hold.

Thank you very much for your assistance with this matter, Mr. Engström. Please do not hesitate to reach out if you have any questions.

**Yuki Nakamura** Associate Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Tel: (212) 448-7623 Email: ynakamura@calderwoodharkness.com

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