Contract analysis

I. Purpose and Scope This memorandum identifies and evaluates the key fact witnesses likely to be relevant in the dispute between our client, Quorum Casualty & Surety Company ("QC&S"), a wholly owned subsidiary of Quorum Insurance Holdings Corp. ("QIH"), and Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"), concerning $78,400,000 in disputed reinsurance recoverables under Treaty No. PA-QCS-2019-EXL-0044 (the

II. Summary Witness Table The following table provides a high-level overview of all six witnesses currently designated for formal interview or deposition. Additional potential witnesses who have not yet been prioritized for formal interview are discussed in Section IV below. Several observations are warranted regarding this preliminary witness list. First, all six witnesses have been designated as either High or Medi

III. Detailed Witness Memoranda A. Friendly Witnesses (QC&S / QIH)

1. Tobias Engström — SVP, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp. a. Identity and Background. Tobias Engström currently holds the position of Senior Vice President, Reinsurance & Capital Markets, at Quorum Insurance Holdings Corp., headquartered at 200 Constitution Plaza, Suite 3400, Hartford, Connecticut 06103. In this capacity, Mr. Engström oversees QIH's entire reinsurance purchasing program

Article 3.4 and the Premium Underreporting Dispute (Issue 4). Mr. Engström is the best-positioned witness to testify regarding the Article 3.4 exclusion for run-off portfolio transfer premiums. He can explain the commercial rationale for the exclusion, the specific negotiations that led to its inclusion in the Treaty, and why the exclusion properly supports QC&S's reported ceded earned premium of $38.4 million for TY

2. Diana Kessler-Hoff — VP, Claims & Reinsurance Recoveries, Quorum Casualty & Surety Company a. Identity and Background. Diana Kessler-Hoff currently holds the position of Vice President, Claims & Reinsurance Recoveries, at Quorum Casualty & Surety Company (NAIC No. 24891), located at 200 Constitution Plaza, Suite 3200, Hartford, Connecticut 06103. In this role, Ms. Kessler-Hoff is responsible for QC&S's claims hand

3. James "Jamie" Castellano — Account Executive, Broadreach Intermediaries Inc. a. Identity and Background. James "Jamie" Castellano is an Account Executive at Broadreach Intermediaries Inc. ("Broadreach"), a New York-licensed reinsurance intermediary with offices at 100 Wall Street, 18th Floor, New York, New York 10005. Broadreach is designated as the intermediary broker under Article 9 of the Treaty and, in that ca

4. Dr. Stephen Tanaka, FCAS, MAAA — Principal Actuary, Velthorn Actuarial Advisors LLC a. Identity and Background. Dr. Stephen Tanaka is a Principal Actuary at Velthorn Actuarial Advisors LLC ("Velthorn"), located at 75 Ashbury Asset Advisors, Suite 1400, Boston, Massachusetts 02109. Dr. Tanaka holds the designation of Fellow of the Casualty Actuarial Society (FCAS) and is a Member of the American Academy of Actuarie

Article 5.2 Application. Dr. Tanaka can explain how the Treaty's definition of "losses incurred" under Article 5.2 interacts with standard actuarial methodology for IBNR estimation. His testimony will connect the actuarial analysis to the contractual framework, helping the arbitrators or court understand why the Velthorn methodology is consistent with the Treaty's allocation provisions. Quantitative Impact. Dr. Tanak

5. Conrad Hesse — SVP, Treaty Disputes & Recoveries, Pinnacle Atlantic Reinsurance Ltd. a. Identity and Background. Conrad Hesse is the Senior Vice President, Treaty Disputes & Recoveries, at Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"). Pinnacle Atlantic's U.S. office is located at 1285 Avenue of the Americas, 28th Floor, New York, New York 10019. Pinnacle Atlantic's registered office is at Clarendon Hou