Contract analysis

I. Executive Summary The purpose of this memorandum is to outline a comprehensive discovery strategy for the pre-suit reinsurance recoverable dispute between our client, Quorum Casualty & Surety Company ("QC&S"), a wholly owned subsidiary of Quorum Insurance Holdings, Inc. ("QIH"), as cedent, and Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"), as reinsurer, concerning $78,400,000 in disputed reinsurance rec

II. Procedural Framework for discovery A. Arbitration-Track discovery (Treaty Article 22 / ARIAS-U.S. Rules) Treaty Article 22 — titled "Arbitration" — mandates that "any dispute arising out of, or in connection with, this Treaty, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by arbitration" before a three-member arbitration panel sitting in New Yo

1. Dual-Format discovery Requests. We will design document requests and interrogatories that can be served as formal discovery demands in litigation (CPLR §§ 3120, 3130) or submitted to the arbitration panel as proposed discovery orders. The substantive content of the requests will be identical; only the procedural framing will differ.

2. Prioritized Core Document Exchange. Regardless of forum, we will prioritize the early exchange of core treaty documentation, billing records, claims files, and actuarial workpapers. These categories of documents form the foundation of the dispute on all four grounds and are necessary for substantive legal and financial analysis irrespective of whether the matter proceeds in arbitration or litigation.

3. Scalable discovery Plan. The discovery plan set forth in this memorandum is designed to be scalable. In the arbitration track, the panel may narrow the scope of discovery — and we will be prepared to argue for the broadest permissible scope — but the underlying work product (drafted requests, identified custodians, collected and reviewed client documents) will be fully usable in litigation if the forum shifts.

4. Parallel Preparation. We will proceed with client document collection, privilege review, and witness interview preparation immediately, without waiting for resolution of the arbitration-clause dispute. These activities are necessary and appropriate regardless of forum and will ensure that we are not disadvantaged by delays in the threshold procedural dispute.

III. Document discovery — Categories and Targets This section identifies the specific categories of documents to be requested from Pinnacle Atlantic and collected from QC&S/QIH. The categories are organized to track the four dispute grounds raised by Pinnacle Atlantic, supplemented by additional categories addressing the treaty relationship, the parties' course of dealing, and the pre-suit demand. A. Documents to Be

IV. Interrogatories — Proposed Topics A. Interrogatories to Pinnacle Atlantic (First Set) The following ten interrogatories are proposed for service on Pinnacle Atlantic. Each interrogatory is designed to elicit specific factual and methodological information bearing on the four dispute grounds, the interest claim, the arbitration-clause dispute, and the identity of witnesses and experts. In the litigation track, the

V. Deposition Targets This section identifies the witnesses we intend to depose (adverse party and third-party witnesses) and the QC&S witnesses we anticipate Pinnacle Atlantic will seek to depose (requiring preparation by our team). The witnesses are listed in priority order within each category. A. Party Witnesses — Pinnacle Atlantic

1. Conrad Hesse, SVP, Treaty Disputes & Recoveries, Pinnacle Atlantic Reinsurance Ltd. Subject Matter: Mr. Hesse is the senior Pinnacle Atlantic executive who led the investigation and analysis of the disputed Treaty cessions. Based on information available to us, Mr. Hesse directed the internal review that culminated in the December 12, 2025 reservation-of-rights letter and coordinated with HFC on the development an

2. Lorraine Metcalf, Chief Claims Officer, Pinnacle Atlantic Reinsurance Ltd. Subject Matter: Ms. Metcalf, as Pinnacle Atlantic's Chief Claims Officer, has oversight responsibility for Pinnacle Atlantic's claims handling functions, including the review of ceded losses under the Treaty. She is expected to have direct knowledge of Pinnacle Atlantic's assessment of the Meridian Docks late notice issue and the evaluation

3. James "Jamie" Castellano, Account Executive, Broadreach Intermediaries Inc. Subject Matter: Broadreach Intermediaries Inc. served as the designated intermediary under Treaty Article 9 and handled all premium and claims-settlement transmittals between QC&S and Pinnacle Atlantic throughout the Treaty period. Mr. Castellano is the Broadreach account executive responsible for the QC&S/Pinnacle Atlantic Treaty and has

4. Dr. Stephen Tanaka, FCAS, MAAA, Principal Actuary, Velthorn Actuarial Advisors LLC Subject Matter: Dr. Tanaka prepared the loss development and reserve analyses underlying the disputed Treaty cessions, including the actuarial certificates for the TY 2022 and TY 2023 billings. He is the central witness on the IBNR allocation methodology that Pinnacle Atlantic challenges and is therefore critical to the defense of t

5. Tobias Engström, SVP, Reinsurance & Capital Markets, QIH Anticipated Subject Matter if Deposed by HFC: Mr. Engström is the QIH executive responsible for reinsurance strategy and treaty management. HFC is likely to seek his deposition on the negotiation and execution of the Treaty, including the parties' intent with respect to key provisions (Articles 3, 5, 7, 11, and 22); treaty renewal and extension decisions; ov

6. Diana Kessler-Hoff, VP, Claims & Reinsurance Recoveries, QC&S Anticipated Subject Matter if Deposed by HFC: Ms. Kessler-Hoff is the QC&S claims executive with direct responsibility for claims handling, reserving practices, and reinsurance recovery billings. HFC is likely to focus her deposition on: the timeline of Meridian Docks claims reserving (first reserved March 15, 2021) and the decision regarding when to no