Contract analysis

I. Purpose and Legal Obligation Calderwood & Harkness LLP ("C&H") has been retained by Quorum Insurance Holdings Corp. ("QIH") and its wholly owned subsidiary Quorum Casualty & Surety Company ("QC&S," and together with QIH, the "Company") in connection with a pre-suit demand dated February 14, 2026, received from Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"), transmitted through Pinnacle Atlantic's counsel

II. Scope of the Dispute To assist in identifying the categories of materials that must be preserved, we provide the following summary of the dispute and the principal grounds asserted by Pinnacle Atlantic in its February 14, 2026 demand letter. This summary is provided solely for purposes of delineating the scope of the preservation obligation and does not constitute a concession or acknowledgment regarding the meri

1. Late Notice Under Treaty Article 7 — Meridian Docks Mass Tort Cluster. Pinnacle Atlantic contends that QC&S failed to provide timely notice under Treaty Article 7 with respect to a cluster of thirty-one (31) related commercial general liability ("CGL") bodily injury claims arising from toxic contamination at the Meridian Docks industrial waterfront redevelopment site in Newark, New Jersey (the "Meridian Docks Clai

2. Misallocation of IBNR Reserve Development Under Treaty Article 5. Pinnacle Atlantic alleges that QC&S improperly allocated Twenty-Two Million Three Hundred Thousand Dollars ($22,300,000) in incurred-but-not-reported ("IBNR") reserve development to Treaty Year 2022 (July 1, 2022 – June 30, 2023) rather than to Treaty Year 2021 (July 1, 2021 – June 30, 2022), where such development allegedly should have been reporte

3. Challenge to Follow-the-Fortunes Doctrine Under Treaty Article 11 — Veridian Financial Services E&O Cluster Settlement. Pinnacle Atlantic challenges the application of the follow-the-fortunes doctrine under Treaty Article 11 with respect to QC&S's settlement of three related professional liability ("errors and omissions") claims against Veridian Financial Services Inc. under QC&S Policy No. PL-2021-15327 (collecti

4. Alleged Underreporting of Ceded Earned Premium Under Treaty Article 3. Pinnacle Atlantic alleges that QC&S underreported ceded earned premium by a total of Six Million Eight Hundred Thousand Dollars ($6,800,000) during the relevant treaty years, in violation of the premium reporting obligations set forth in Treaty Article 3. Pinnacle Atlantic contends that QC&S improperly excluded certain premium categories from t

III. Categories of Materials to Be Preserved The following is a detailed, but non-exhaustive, description of the categories of documents, ESI, and tangible things that must be preserved under this hold. If there is any doubt as to whether a particular document or category of information falls within the scope of this hold, the presumption must be in favor of preservation, and the question should be directed to C&H fo

I. Financial and Regulatory Records All financial and regulatory filings and records relating to the Treaty and the disputed amounts must be preserved: • QC&S statutory financial statements, including annual statements filed with the Connecticut Insurance Department and the NAIC, for calendar years 2021 through 2025, inclusive, together with all supporting schedules, exhibits, and notes. • QIH consolidated GAAP finan

IV. Identified Custodians The following individuals are identified as custodians whose files, email accounts, personal devices, and system data must be preserved in accordance with this notice. Each custodian will receive a copy of this notice and must execute the accompanying Litigation Hold Acknowledgment Form and return it to Calderwood & Harkness LLP within five (5) business days of receipt. QIH / QC&S Custodians

1. Martin Galbraith — Chief Executive Officer, Quorum Insurance Holdings Corp.

2. Rachel Sondergaard — General Counsel, Quorum Insurance Holdings Corp.

3. Tobias Engström — Senior Vice President, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp.

4. Diana Kessler-Hoff — Vice President, Claims & Reinsurance Recoveries, Quorum Casualty & Surety Company.

5. All QC&S claims adjusters and claims managers who handled, supervised, or had material involvement in the Meridian Docks mass tort cluster claims or the Veridian Financial Services E&O cluster claims. Diana Kessler-Hoff is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.

6. All QC&S actuarial staff members who participated in reserve setting, IBNR development analyses, or loss development factor analyses for TY 2021, TY 2022, or TY 2023 in connection with the Treaty or the underlying claims at issue. Tobias Engström is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of

7. All QC&S reinsurance accounting personnel who prepared, reviewed, approved, or transmitted treaty billings, ceded earned premium calculations, sliding-scale premium adjustment calculations, or reinsurance recoverable balance computations in connection with the Treaty for TY 2021, TY 2022, or TY 2023. Tobias Engström is requested to identify these individuals by name, title, and department and provide the list to R

8. All members of the QIH Board Audit Committee who received materials relating to the Pinnacle Atlantic dispute, including but not limited to materials distributed in connection with the February 24, 2026 Board Audit Committee meeting. Rachel Sondergaard is requested to identify these individuals and provide the list to C&H within five (5) business days of the date of this notice. Third-Party Custodians (Notificatio

V. Preservation Instructions A. Immediate Actions Required The following steps must be taken immediately, and in no event later than two (2) business days from the date of this notice:

1. Suspend Routine Destruction. Suspend all routine document destruction, recycling, shredding, or overwriting schedules, whether applied to paper documents or ESI, as applied to all materials within the scope of this hold. This includes the suspension of any records retention or disposition schedules that would otherwise authorize the destruction of materials falling within the categories described in Section III ab

2. Notify the IT Department. Direct the Company's Information Technology department to immediately suspend all auto-deletion policies, mailbox size limitations that trigger automatic archiving or purging, and any other automated processes that could result in the deletion or alteration of email, files, or data on the accounts, devices, and systems of all identified custodians. The IT department should confirm in writ

3. Preserve Backup Tapes and Archives. Direct the IT department to identify and preserve all backup tapes, disaster recovery archives, system snapshots, and cloud storage backups that contain or may contain data of identified custodians or materials within the scope of this hold. All scheduled tape rotation, overwriting, or degaussing must be halted until further notice from C&H.

4. Instruct All Custodians. Distribute a copy of this notice to each identified custodian and instruct them, clearly and unequivocally, that they must not delete, discard, alter, modify, conceal, or remove any documents, files, ESI, or other materials within the scope of this hold. Custodians must be informed that this obligation extends to materials on personal devices used for business purposes, including personal

5. Collect and Segregate Physical Files. Identify and collect all physical files, paper documents, and tangible materials related to the Treaty, the Meridian Docks Claims, the Veridian Claims, the IBNR analyses, premium reporting, and the Pinnacle Atlantic dispute. These materials should be segregated in a secure, designated location with restricted access, and an inventory of the collected materials should be prepar

VI. Consequences of Non-Compliance We wish to emphasize in the strongest possible terms the seriousness of the preservation obligation and the consequences that may follow from a failure to comply. Courts and arbitration panels impose severe sanctions for the spoliation of evidence, whether the destruction or alteration of relevant materials occurs intentionally or through negligence. Such sanctions may include, with

VII. Contact Information Questions regarding this notice, including questions about its scope, the identification of custodians, the implementation of preservation measures, or any other aspect of the litigation hold, should be directed to the following members of the C&H litigation team: Douglas Carmichael, Partner Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7150 E