Contract analysis

1. Purpose and Identification of Counsel This firm, Calderwood & Harkness LLP, has been retained as defense counsel for Cascade Retail Holdings Inc. ("Cascade" or "CRH"), a Delaware corporation headquartered at 2200 Elliott Avenue West, Suite 1400, Seattle, Washington 98119, and publicly traded on the Nasdaq Stock Market under the ticker symbol "CRHI." We write on behalf of our client to provide formal notice of a cl

2. Description of the Lawsuit 2.1 Filing and Service On September 7, 2021, Vantor Holdings Corp. ("Vantor"), a California corporation headquartered at 18500 Von Karman Avenue, Suite 600, Irvine, California 92612, filed a civil complaint against Cascade in the Superior Court of the State of California, County of Los Angeles. The matter has been assigned Case No. 21STCV-34872 and is pending before the Honorable Judge a

3. Cascade's Preliminary Defenses In order to assist Pinnacle in evaluating coverage and the nature of the underlying claims, we provide the following brief summary of Cascade's anticipated defense theories. These theories are preliminary and subject to refinement as discovery proceeds: (a) Lack of Knowledge. Cascade contends that, at the time it entered into its supply agreements with Hemsworth, Tridale, and Orion,

4. Coverage Request 4.1 Defense Costs Cascade hereby formally requests that Pinnacle National Insurance Co. provide coverage for defense costs incurred in connection with the defense of Vantor Holdings Corp. v. Cascade Retail Holdings Inc., Case No. 21STCV-34872, under CGL Policy No. PNG-CGL-2021-04487. Defense of the matter is being conducted by Calderwood & Harkness LLP. The current members of the defense team, and

5. Request for Prompt Response Given the significant exposure at issue in this matter — $87.4 million in claimed damages, exclusive of potential statutory restitution and injunctive relief — and the aggressive litigation timeline that we anticipate will be imposed by the court, we respectfully request that Pinnacle respond promptly to this notice of claim. Specifically, we request the following: (a) Written Acknowled

6. Enclosures The following documents are enclosed with this letter for Pinnacle's review and records:

1. Copy of the Complaint filed September 7, 2021, in Vantor Holdings Corp. v. Cascade Retail Holdings Inc., Case No. 21STCV-34872, Superior Court of the State of California, County of Los Angeles (including all exhibits attached thereto);

2. Copy of Commercial General Liability Policy No. PNG-CGL-2021-04487 issued by Pinnacle National Insurance Co. to Cascade Retail Holdings Inc. (Cascade's copy, including all endorsements, schedules, and declarations pages); and

3. Copy of the Calderwood & Harkness LLP engagement letter dated September 13, 2021, between Calderwood & Harkness LLP and Cascade Retail Holdings Inc. We thank you for your prompt attention to this matter and look forward to receiving your timely response. Very truly yours, CALDERWOOD & HARKNESS LLP By: ________ Douglas Carmichael, Partner 600 South Grand Avenue, Suite 3200 Los Angeles, California 90071 Telephone: (