Contract analysis

I. PREAMBLE THE PEOPLE OF THE STATE OF NEW YORK TO: Broadreach Intermediaries Inc., a New York corporation and licensed reinsurance intermediary, with principal office at 100 Wall Street, 18th Floor, New York, New York 10005, Attention: James "Jamie" Castellano, Account Executive. GREETINGS: YOU ARE HEREBY COMMANDED, pursuant to Article 31 of the New York Civil Practice Law and Rules ("CPLR"), including without limit

II. COMPLIANCE INSTRUCTIONS A. Date, Time, and Place for Production Production of the documents and ESI described in the Schedule of Documents Requested below shall be made on or before the following date and time: Date: ______ [To be inserted — at least twenty (20) days from service, in accordance with CPLR 3120(2)] Time: 10:00 a.m. (Eastern Time) Place: Calderwood & Harkness LLP, One Liberty Plaza, 55th Floor, New

III. SCHEDULE OF DOCUMENTS REQUESTED Category 1: Treaty Placement Records Broadreach Intermediaries Inc. is directed to produce all documents related to the placement, negotiation, binding, and execution of Treaty No. PA-QCS-2019-EXL-0044, including but not limited to the following: 1.1. All treaty slips, cover notes, binders, and signed or initialed placement documents reflecting the terms upon which the Treaty was

IV. STATEMENT OF RELEVANCE (CPLR 3101(a)(4)) The documents and ESI sought by this Subpoena Duces Tecum are material and necessary to the prosecution and defense of claims and counterclaims in this action, within the meaning of CPLR 3101(a)(4), for the following reasons: A. Broadreach's Role as Designated Intermediary. Broadreach Intermediaries Inc. served as the designated intermediary broker under Article 9 of Treat

V. DUTY TO PRESERVE Broadreach Intermediaries Inc. is hereby directed, effective immediately upon receipt of this subpoena, to take all steps necessary to preserve all documents and electronically stored information responsive to this subpoena, and to prevent the destruction, alteration, spoliation, deletion, overwriting, or loss of any such documents and ESI, from the date of receipt of this subpoena until further o

VI. REIMBURSEMENT OF REASONABLE PRODUCTION COSTS QC&S, through its counsel Calderwood & Harkness LLP, will reimburse Broadreach Intermediaries Inc. for the reasonable costs of production incurred in complying with this subpoena, as required by CPLR 3122(d). Such reimbursement shall be made upon submission by Broadreach Intermediaries Inc. (or its counsel) of an itemized statement of costs, which shall identify with r

VII. PENALTIES FOR NON-COMPLIANCE PLEASE TAKE NOTICE that failure to comply with this subpoena may subject Broadreach Intermediaries Inc. to penalties and sanctions as provided by law. Pursuant to CPLR 2308(a), if this subpoena is not complied with and the subpoenaed party fails to move to quash or modify the subpoena pursuant to CPLR 2304, the issuing party may move before the Court for an order compelling complianc

VIII. SIGNATURE BLOCK AND ATTESTATION This Subpoena Duces Tecum is issued by the undersigned attorney, an attorney admitted to practice in the courts of the State of New York, pursuant to CPLR 2302(a). DATED: New York, New York ________________________________________ (Date to be inserted) CALDERWOOD & HARKNESS LLP Attorneys for Defendant/Respondent Quorum Casualty & Surety Company By: ________ Jeffrey Park, Esq. Lea

1. I am over the age of eighteen (18) years and not a party to this action.

2. On ______ (date), I served a true and correct copy of the Subpoena Duces Tecum to Non-Party Broadreach Intermediaries Inc. Pursuant to CPLR 3120, together with the witness fee and mileage required by CPLR 2303(a), upon: Broadreach Intermediaries Inc. 100 Wall Street, 18th Floor New York, New York 10005 Attention: James "Jamie" Castellano, Account Executive

3. Service was effected by the following method (check one): Personal Service (CPLR 308(1)): by delivering a true and correct copy of the subpoena and accompanying documents to ______ (name of individual served), who identified himself/herself as ____ (title/position) of Broadreach Intermediaries Inc., at the above address, at approximately _ (time), on _____ (date). Service by Certified Mail, Return Receipt Requeste