1012-00003 · Stonefield Logistics Group · Engagement

conflict-check-memo.docx DOCUMENT Litigation

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CALDERWOOD & HARKNESS LLP 700 Louisiana Street, Suite 4500 Houston, Texas 77002 Telephone: (713) 555-8200

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT INTERNAL USE ONLY — NOT FOR DISTRIBUTION OUTSIDE THE FIRM

INTERNAL CONFLICT CHECK MEMORANDUM

Matter No. 1012-00003

1. Purpose and Summary of Request

This memorandum documents the results of the comprehensive conflicts search conducted on February 3–4, 2024, in connection with the proposed representation of Stonefield Logistics Group Inc. ("SLG"), a Texas corporation headquartered at 2900 Petroleum Tower Boulevard, Suite 400, Midland, Texas 79701, in an insurance coverage dispute arising from a cargo-loss event that occurred on November 17, 2023.

Calderwood & Harkness LLP ("C&H" or the "Firm") has been asked by SLG's management to serve as coverage counsel in connection with the denial by Meridian Surety & Indemnity Company ("Meridian" or "MSIC"), an Ohio-domiciled stock insurance company (NAIC No. 28471), with its principal office located at 600 Scioto Crossing, Suite 1200, Columbus, Ohio 43215, of SLG's first-party claim under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023. Meridian communicated its coverage denial by letter dated January 22, 2024, invoking two policy exclusions — Exclusion 4(f) (Improper Storage) and Exclusion 4(k) (Failure to Maintain) — as the bases for its denial of the approximately $4.78 million claim.

The proposed engagement would encompass coverage evaluation and analysis of the subject policy, preparation of a coverage opinion, issuance of a pre-suit demand to Meridian, negotiation toward a resolution of the coverage dispute, and, if necessary, the preparation and prosecution of coverage litigation under Texas law, including potential statutory claims under Texas Insurance Code Chapters 541 and 542.

Dale Engstrom, Vice President of Risk Management at SLG, is the primary client contact for this engagement. The engagement letter has been prepared and is expected to be executed by both the Firm and SLG on or about February 5, 2024, subject to satisfactory clearance of all conflicts.

The proposed engagement team consists of the following attorneys:

• Howard Bellamy — Responsible Partner

• Douglas Fairchild — Billing Partner

• Andrew Fitzpatrick — Lead Associate

• Naomi Petersen — Working Associate

This memorandum confirms that the comprehensive conflicts search has returned no conflicts, potential conflicts, or situations requiring a waiver, informed consent, or ethical screen, and recommends that the proposed engagement be cleared to proceed and that the matter be formally opened in the Firm's accounting and matter management systems.

2. Description of Proposed Engagement

2.1 Nature of the Matter

The proposed engagement concerns an insurance coverage dispute — specifically, a first-party claim under an all-risk inland marine cargo legal liability policy. SLG, a mid-market intermodal freight brokerage, trucking, and transload/warehousing company, suffered approximately $4,780,000 in cargo losses as the result of a warehouse fire that occurred at its Midland, Texas transload facility on November 17, 2023. The fire originated in Warehouse Building C, located at 4501 East County Road 130, Midland, Texas 79706, and destroyed a substantial volume of oilfield equipment, chemical supplies, and other goods stored on behalf of multiple shippers pending transload and delivery to various Permian Basin well sites.

SLG timely reported the loss to its insurer, Meridian Surety & Indemnity Company, under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023 (the "Policy"). After conducting an investigation over a period of approximately two months, Meridian issued a formal coverage denial letter dated January 22, 2024. In the denial letter, Meridian invoked two policy exclusions as the asserted bases for its refusal to pay the claim:

(a) Exclusion 4(f) — Improper Storage: Meridian contends that certain categories of cargo stored in Warehouse Building C were not stored in accordance with the manufacturer's specifications or applicable safety standards, and that this alleged improper storage contributed to the origin or severity of the fire.

(b) Exclusion 4(k) — Failure to Maintain: Meridian contends that the fire-suppression sprinkler system in Warehouse Building C was not properly maintained, that certain sprinkler heads were non-functional at the time of the fire, and that this failure to maintain the fire-suppression system contributed to the extent of the cargo losses.

Based on a preliminary review, both exclusionary arguments appear to present questions of fact that are subject to challenge. The proposed engagement will involve a thorough analysis of the Policy language, the factual circumstances of the loss, and the applicability (or inapplicability) of the cited exclusions under Texas law.

In addition to the contractual coverage dispute, the matter involves potential claims under Texas Insurance Code Chapter 541 (Unfair Methods of Competition and Unfair or Deceptive Acts or Practices in the Business of Insurance) and Chapter 542 (Processing and Settlement of Claims / Texas Prompt Payment of Claims Act). A preliminary assessment of the timeliness and sufficiency of Meridian's investigation and denial will be undertaken as part of the engagement.

2.2 Proposed Client

Stonefield Logistics Group Inc. is a Texas corporation, Federal Employer Identification Number 84-3291057, with its principal office located at 2900 Petroleum Tower Boulevard, Suite 400, Midland, Texas 79701. SLG is a mid-market intermodal freight brokerage, trucking, and transload/warehousing company that specializes in Permian Basin oilfield supply-chain logistics. The company currently operates fourteen (14) terminals across Texas, New Mexico, and Oklahoma, providing end-to-end logistics services including freight brokerage, dedicated trucking, intermodal drayage, transloading, and warehousing of oilfield equipment, drilling supplies, and completion chemicals.

Key financial and organizational data for SLG include the following:

• Annual Revenue (FY2023): $187.4 million

• EBITDA (FY2023): $29.1 million

• Number of Employees: Approximately 1,100

• CEO: Marcus D. Stonefield

• CFO: Leah Tran

• VP of Risk Management: Dale Engstrom (primary client contact)

SLG was founded in 2007 by Marcus D. Stonefield and grew organically through the 2010s before receiving a significant private equity investment in 2019, as described in Section 2.3 below. The company maintains a comprehensive insurance program overseen by its Vice President of Risk Management and placed through an external insurance broker (Calvert & Strauss Insurance Brokers, Inc.).

2.3 Private Equity Sponsor

SLG is a portfolio company of Irongate Capital Partners, LP, a Delaware limited partnership with its principal office at 200 Clarendon Street, 42nd Floor, Boston, Massachusetts 02116. Irongate Capital Partners is a middle-market private equity firm focused on investments in industrial services, logistics, and energy infrastructure businesses.

Irongate holds approximately 72% of the equity interests in SLG, acquired in August 2019 through Irongate Industrial Partners Fund IV, LP, a Delaware limited partnership that serves as the investment vehicle for the acquisition. The Managing Partner of Irongate Capital Partners, LP is Carolyn Reeves. The remaining approximately 28% of SLG's equity is held by members of SLG management and other minority investors.

By virtue of its majority equity ownership, Irongate exercises board-level oversight of SLG's operations, including its insurance and risk management program. Irongate appoints a majority of SLG's board of directors and has approval rights over material litigation, insurance placements, and risk management decisions, as set forth in the amended and restated limited liability company agreement governing SLG's equity structure.

While Irongate Capital Partners, LP is not the named client in the proposed engagement, and the engagement letter will identify SLG as the sole client, Irongate is a related party with a material economic interest in the outcome of the coverage dispute. Accordingly, Irongate Capital Partners, LP, Irongate Industrial Partners Fund IV, LP, and Carolyn Reeves were all included in the conflicts search conducted in connection with this proposed engagement. This approach is consistent with the Firm's internal policy requiring that known private equity sponsors, controlling shareholders, and affiliated fund entities be searched in connection with any engagement involving a portfolio company, regardless of whether the sponsor is the named client.

2.4 Adverse Party

The adverse party in the proposed engagement is Meridian Surety & Indemnity Company, an Ohio-domiciled stock insurance company. Key identifying information for Meridian is as follows:

• NAIC Number: 28471

• A.M. Best Rating: A (Excellent), Financial Size Category IX

• Principal Office: 600 Scioto Crossing, Suite 1200, Columbus, Ohio 43215

• Claims VP (Handling Adjuster): Patricia Ng

• Senior Claims Examiner: Brian Woolf

Meridian is the issuing carrier under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023, the policy under which SLG's coverage claim has been denied. For purposes of this conflicts check, Meridian was searched under its full legal name, common abbreviations (MSIC, Meridian Surety), and its NAIC number. The individual claims personnel identified above — Patricia Ng and Brian Woolf — were also searched.

2.5 Fee Arrangement

The proposed engagement will be conducted on an hourly-rate basis, with no contingency component. The applicable hourly rates for the proposed engagement team are as follows:

Based on a preliminary scoping of the engagement through the pre-litigation phase (coverage analysis, pre-suit demand, and initial negotiation), the estimated fee budget for the pre-litigation phase is $175,000 to $225,000. Should litigation become necessary, a separate budget will be developed and communicated to the client. These rates and the estimated budget will be reflected in the engagement letter to be executed on or about February 5, 2024.

3. Parties and Individuals Searched

The following sections set forth the complete list of all parties and individuals included in the conflicts search conducted on February 3–4, 2024. Parties and individuals are organized by category for clarity and ease of reference. All entities and individuals listed below were searched across the Firm's entire matter database, including active, closed, and prospective matters, across all offices and practice groups.

3.1 Client-Side Parties

3.2 Client-Side Key Individuals

3.3 Adverse / Counterparties

3.4 Adverse-Side Key Individuals

3.5 Adverse Party's Known Counsel

Based on information provided by the client contact, Meridian has retained the following law firm as coverage defense counsel in this matter:

The individual attorneys identified as Meridian's likely litigation team were also searched:

3.6 Other Third Parties with Material Involvement

In addition to the principal parties and their counsel, the following third parties were identified as having a material involvement in the underlying facts, the claim, or the anticipated litigation. Each was included in the conflicts search to ensure comprehensive clearance.

Calvert & Strauss Insurance Brokers, Inc. is the insurance brokerage firm that procured the Meridian policy on SLG's behalf. The firm's account executive, Jason Muñoz, managed the placement of the Inland Marine Cargo Legal Liability Policy at issue. Calvert & Strauss's role in the placement of the policy, including any representations made to the underwriter, may be relevant to the coverage analysis.

Ridgeline Forensic Consultants LLC is a Texas-based fire investigation and forensic engineering firm that the engagement team expects to retain, under the direction of C&H, as a consulting and potentially testifying expert on the cause and origin of the warehouse fire. Dr. William Creech, P.E., CFEI, is the principal investigator at Ridgeline.

Whitlock & Associates, CPAs, P.C. is an accounting firm retained by SLG to assist with loss quantification and preparation of the formal proof of loss submitted to Meridian. Sandra Whitlock, CPA, CFF, is the engagement partner at Whitlock & Associates.

Lone Star Fire Protection Inc. is the independent contractor that held the sprinkler system maintenance contract for SLG's Midland transload facility, including Warehouse Building C. Because Meridian's denial relies in part on Exclusion 4(k) (Failure to Maintain), Lone Star Fire Protection's maintenance records, inspection reports, and personnel are likely to be material fact witnesses.

Permian Wellhead Services LLC, Cantera Chemical Supply Co., and Triton Subsurface Technologies Inc. are cargo owners whose freight was stored in Warehouse Building C at the time of the fire and was destroyed. These entities may have their own separate insurance claims or potential claims against SLG, but they are not parties to the insurance coverage dispute that is the subject of the proposed engagement. They are included in the conflicts search because of their potential roles as fact witnesses and because adversity could conceivably develop in future, unrelated proceedings.

Pinnacle National Bank is SLG's primary banking institution in Midland, Texas. The bank may be involved to the extent that any loss-payee provisions in the Policy reference the bank, or to the extent that SLG's financing arrangements are implicated by the insurance recovery.

3.7 Third-Party Key Individuals

4. Search Methodology

The conflicts searches documented in this memorandum were conducted on February 3–4, 2024, using Calderwood & Harkness's firm-wide conflicts database, known internally as the IntakeTracker system. IntakeTracker is the Firm's centralized electronic conflicts checking and new-matter intake platform, which maintains a comprehensive record of all current, closed, and prospective client matters, party names, adverse-party names, related entities, and key individuals across all of the Firm's offices and practice groups.

The following search methodology was employed:

(a) Entity Name Searches. Each entity identified in Section 3 of this memorandum was searched under all known variations of its name, including its full legal name, any short-form or abbreviated names, known d/b/a names, and common abbreviations. For example, "Stonefield Logistics Group Inc." was searched under "Stonefield Logistics Group Inc.," "Stonefield Logistics," "SLG," and "Stonefield." "Meridian Surety & Indemnity Company" was searched under "Meridian Surety & Indemnity Company," "Meridian Surety," "MSIC," "Meridian," and "Meridian Indemnity." "Kessler, Brandt & Howe LLP" was searched under its full name as well as "KBH" and "Kessler Brandt." Comparable variations were run for all other entities.

(b) Individual Name Searches. All individual names listed in Section 3 were searched, including first name, last name, and any known variations or phonetic equivalents. For example, "Patricia Ng" was also searched as "Pat Ng." "Jason Muñoz" was also searched as "Jason Munoz" (without diacritical). "Dr. William Creech" was also searched as "William Creech" and "Bill Creech."

(c) Numerical Identifier Searches. NAIC Number 28471 (Meridian) and Federal Employer Identification Number 84-3291057 (SLG) were searched as supplemental identifiers to capture any matter records that might reference these entities by identifier rather than by name.

(d) Office-Level Cross-Reference. In addition to the global IntakeTracker search, the search results were cross-referenced against the local matter databases maintained by the Houston, Dallas, Midland, Boston, and Columbus offices — the offices most likely to have touchpoints with the parties involved — to confirm consistency and completeness.

(e) Practice Group Review. The search encompassed all practice groups within the Firm, including Insurance Coverage, Mergers & Acquisitions, Real Estate, Antitrust & Competition, Commercial Litigation, Energy, Private Equity, and Banking & Finance. This broad scope was adopted to capture any relationship or engagement that might not be classified under the Insurance Coverage or Commercial Litigation practice group codes.

(f) Irongate-Specific Search. Given the significance of the private equity sponsor relationship, a targeted search was conducted for any prior or current engagement involving Irongate Capital Partners, LP, any Irongate-affiliated fund (including but not limited to Irongate Industrial Partners Fund IV, LP), or any known Irongate portfolio company. This search was performed to identify any representation that could give rise to a conflict, a positional conflict, or an issue requiring disclosure or informed consent.

(g) Active, Closed, and Prospective Matters. The search encompassed all matter statuses — active, closed, and prospective — to ensure that historical relationships and declined engagements were captured in addition to current representations.

The undersigned personally conducted all searches and reviewed all results. No automated screening alerts or flags were triggered by any of the search queries. The detailed search log, including all search terms used and results obtained, is set forth in Appendix A to this memorandum.

5. Search Results

The following sections set forth the results of the conflicts search for each party and individual identified in Section 3. The results are organized to correspond to the party categories established above.

5.1 Stonefield Logistics Group Inc. / SLG

The Firm has no prior or current representation of Stonefield Logistics Group Inc. in any capacity. No matter records — active, closed, or prospective — were identified in which SLG appears as a client, an adverse party, a witness, or an interested third party. The supplemental search of SLG's Federal Employer Identification Number (84-3291057) returned no matches. SLG is a new client to the Firm. If the engagement proceeds, SLG will be entered into the IntakeTracker system as a new client upon formal matter opening.

5.2 Irongate Capital Partners, LP / Irongate Industrial Partners Fund IV, LP

The Firm has no prior or current representation of Irongate Capital Partners, LP or Irongate Industrial Partners Fund IV, LP in any capacity. No matter records were identified in which either Irongate entity appears as a client, an adverse party, or an interested third party. The search for Carolyn Reeves, Managing Partner of Irongate Capital Partners, returned no matches.

It is noted, however, that Douglas Fairchild (Billing Partner on the proposed engagement, Real Estate practice group) maintains a general billing relationship with certain Irongate portfolio companies for real-estate-related matters, including lease negotiations and property acquisitions. This existing relationship is confirmatory of and consistent with the proposed engagement: Irongate is the majority equity owner of SLG, and representing SLG in a coverage dispute serves, rather than conflicts with, Irongate's interests. Mr. Fairchild's existing Irongate portfolio company relationships support the engagement rather than creating any conflict. This is further analyzed in Section 6.1 below.

No adverse engagements against Irongate Capital Partners, any Irongate-affiliated fund, or any known Irongate portfolio company were identified in the Firm's records.

5.3 Meridian Surety & Indemnity Company

The Firm has no current representation of Meridian Surety & Indemnity Company in any capacity. The Firm has no prior representation of Meridian identified in its matter records. The supplemental search of NAIC Number 28471 returned no matches. The searches for Patricia Ng (VP of Claims) and Brian Woolf (Senior Claims Examiner) returned no matches.

Specifically, the Firm has not at any time been engaged by Meridian as coverage counsel, defense counsel, reinsurance counsel, regulatory counsel, or in any advisory capacity. There is no attorney-client relationship, past or present, between the Firm and Meridian.

5.4 Kessler, Brandt & Howe LLP

The Firm has no current or prior co-counsel or joint engagement with Kessler, Brandt & Howe LLP ("KBH"). No matter records were identified in which KBH appears as co-counsel, opposing counsel, or in any other capacity in connection with a Firm matter. The searches for Victoria Kessler (Partner) and Samuel Okonkwo (Associate) returned no matches.

It is noted for context that KBH is a well-known Houston-based insurance coverage defense firm that regularly represents insurers in first-party and third-party coverage disputes in Texas state and federal courts. The Firm has encountered KBH as opposing counsel in past matters handled by other partners; however, no such matters are currently active, and the Firm's prior encounters with KBH in an adversarial capacity give rise to no professional-courtesy or ethical barrier to proceeding adversely against KBH or its clients in this engagement.

5.5 Calvert & Strauss Insurance Brokers, Inc.

The Firm has no current or prior representation of Calvert & Strauss Insurance Brokers, Inc. in any capacity. The search for Jason Muñoz, Account Executive at Calvert & Strauss, returned no matches. Calvert & Strauss is SLG's insurance broker and placed the Meridian policy; in the proposed engagement, Calvert & Strauss is expected to serve as a fact witness and cooperating third party rather than as a party to the dispute. No conflict arises from this anticipated role.

5.6 Ridgeline Forensic Consultants LLC

No prior engagements with Ridgeline Forensic Consultants LLC were identified in the Firm's matter records or in the Firm's expert/consultant database. The search for Dr. William Creech, P.E., CFEI, returned no matches. Ridgeline is expected to be retained by the engagement team, under the direction of C&H and at SLG's expense, as a consulting and potentially testifying expert on the cause and origin of the November 17, 2023 warehouse fire. The retention of a new forensic expert creates no conflict.

5.7 Whitlock & Associates, CPAs, P.C.

No prior engagements with Whitlock & Associates, CPAs, P.C. were identified in the Firm's records. The search for Sandra Whitlock, CPA, CFF, returned no matches. Whitlock & Associates has been separately engaged by SLG for loss quantification and proof-of-loss preparation. The Firm's engagement team may coordinate with Whitlock & Associates in connection with the coverage dispute, but no conflict arises from this coordination.

5.8 Lone Star Fire Protection Inc.

No matches were identified in the Firm's records for Lone Star Fire Protection Inc. Lone Star Fire Protection is the independent contractor that maintained the fire-suppression sprinkler system at SLG's Midland facility, including Warehouse Building C. Lone Star Fire Protection's maintenance records and personnel may be central to the factual dispute concerning Exclusion 4(k) (Failure to Maintain). Lone Star Fire Protection is expected to be a fact witness; no conflict arises from this role. To the extent that separate claims against Lone Star Fire Protection may be contemplated by SLG or other parties in the future, such claims are outside the scope of the proposed coverage engagement and would require a separate conflicts analysis at the appropriate time.

5.9 Cargo Owners (Permian Wellhead Services LLC, Cantera Chemical Supply Co., Triton Subsurface Technologies Inc.)

No current or prior representation of Permian Wellhead Services LLC, Cantera Chemical Supply Co., or Triton Subsurface Technologies Inc. was identified in the Firm's records. No adversity against any of these three entities was identified in any pending matter. These parties are cargo owners whose freight was stored in Warehouse Building C and was destroyed in the fire. They may have separate claims against SLG for loss of their cargo, and they may also have claims under their own property or cargo insurance policies. However, these potential claims are not within the scope of the proposed engagement, which is limited exclusively to the SLG-Meridian insurance coverage dispute under the Meridian Policy. These cargo owners are identified as potential fact witnesses and are included in the conflicts search for completeness and prudence.

5.10 Pinnacle National Bank

No current or prior representation of Pinnacle National Bank was identified in the Firm's records. No adverse matters involving Pinnacle National Bank were identified. Pinnacle National Bank is SLG's primary banking institution in Midland, Texas, and may appear in connection with any loss-payee endorsements on the Meridian Policy or SLG's broader financing arrangements.

5.11 Proposed Engagement Team Members

Each member of the proposed engagement team was reviewed for individual conflicts, including any personal relationships, prior employment, or financial interests that might create a conflict or the appearance of a conflict in connection with the proposed engagement. The results are as follows:

(a) Howard Bellamy (Responsible Partner). Mr. Bellamy is a partner in the Firm's Antitrust & Competition practice group who is cross-staffed for insurance coverage matters in regulated industries. Mr. Bellamy has no personal or professional relationship with any party identified in Section 3. No individual conflicts were identified.

(b) Douglas Fairchild (Billing Partner). Mr. Fairchild is a partner in the Firm's Real Estate practice group. As noted in Section 5.2 above, Mr. Fairchild maintains a billing relationship with certain Irongate Capital Partners portfolio companies for real-estate-related matters. This relationship is aligned with the client side of the proposed engagement and supports the engagement rather than creating a conflict. No individual conflicts were identified. This relationship is further analyzed in Section 6.1.

(c) Andrew Fitzpatrick (Lead Associate). Mr. Fitzpatrick is an associate in the Firm's Mergers & Acquisitions practice group with experience in post-acquisition insurance recovery matters. Mr. Fitzpatrick has no personal or professional relationship with any party identified in Section 3. No individual conflicts were identified.

(d) Naomi Petersen (Working Associate). Ms. Petersen is an associate in the Firm's Mergers & Acquisitions practice group. Ms. Petersen has no personal or professional relationship with any party identified in Section 3. No individual conflicts were identified.

6. Analysis of Potential Issues

Although the conflicts search returned no conflicts or disqualifying relationships, the following issues were identified as warranting analysis and documentation to ensure a complete record.

6.1 Irongate Capital Partners Relationship

As described in Section 5.2 above, Douglas Fairchild maintains a billing relationship with certain Irongate Capital Partners portfolio companies in connection with real-estate-related matters (lease negotiations, property acquisitions, and related transactional work). This existing relationship was evaluated for any potential conflict or issue.

The analysis is straightforward. Irongate Capital Partners, LP, through Irongate Industrial Partners Fund IV, LP, is the 72% equity owner of Stonefield Logistics Group Inc. Representing SLG in an insurance coverage dispute against Meridian — in which SLG seeks to compel its insurer to honor its contractual obligation to pay a covered loss — directly serves Irongate's economic interests as SLG's majority equity holder. A successful recovery on SLG's insurance claim would enhance SLG's financial position and, by extension, the value of Irongate's investment. There is no scenario in which the proposed engagement would place the Firm in a position adverse to Irongate or any Irongate fund.

Moreover, Mr. Fairchild's existing relationship with Irongate portfolio companies involves real-estate-related matters, not insurance coverage or commercial litigation. No representation of Irongate or any Irongate entity has been identified in any matter adverse to SLG or in any insurance-coverage context. The Firm has not been retained by Irongate on any matter that could create a positional conflict, a confidentiality concern, or a duty-of-loyalty issue with respect to the proposed engagement.

Conclusion: The Irongate relationship presents no conflict, no potential conflict, and no situation requiring a waiver, informed consent, or ethical screen. Mr. Fairchild's existing billing relationship with Irongate portfolio companies is confirmatory and supportive of the proposed engagement.

6.2 No Representation of Meridian

The conflicts search confirmed that the Firm has no current or historical attorney-client relationship with Meridian Surety & Indemnity Company. The Firm has never represented Meridian as coverage counsel, defense counsel, regulatory counsel, or in any advisory capacity. The Firm has never received any confidential information from Meridian.

Because there is no attorney-client relationship — and no former attorney-client relationship — with Meridian, the Firm owes no duty of loyalty, duty of confidentiality, or any other ongoing obligation to Meridian. The Firm is free to accept an engagement adverse to Meridian without restriction.

Conclusion: No conflict exists. No waiver is required.

6.3 No Relationship with Adverse Counsel

The conflicts search confirmed that the Firm has no current or prior co-counsel or joint engagement relationship with Kessler, Brandt & Howe LLP. While KBH is a well-known firm in the Houston insurance coverage defense bar, and attorneys at C&H have encountered KBH as opposing counsel in prior matters, no professional, ethical, or courtesy-based barrier to proceeding adversely against KBH or its client exists. No individual at KBH identified in Section 3.5 has any connection to any Firm attorney or matter.

Conclusion: No conflict exists. No professional-courtesy or ethical barrier is present.

6.4 Third-Party Witnesses / Brokers

Two categories of third parties warrant brief analysis:

(a) Calvert & Strauss Insurance Brokers, Inc. Calvert & Strauss is SLG's insurance broker and placed the Meridian Policy. In the proposed engagement, Calvert & Strauss is not a party to the coverage dispute. Rather, Calvert & Strauss and its account executive, Jason Muñoz, are expected to be cooperative fact witnesses whose testimony and records will support SLG's position regarding the underwriting of the Policy, the disclosures made to Meridian at the time of placement, and the scope of coverage intended. The Firm's role is to represent SLG against Meridian; the Firm does not represent Calvert & Strauss and will not be asked to do so. To the extent that any broker-liability claim against Calvert & Strauss is later contemplated by SLG, such a claim would be outside the scope of the present engagement and would require a separate conflicts analysis.

(b) Cargo Owners (Permian Wellhead Services LLC, Cantera Chemical Supply Co., Triton Subsurface Technologies Inc.). These cargo owners may have independent claims arising from the fire — either against SLG (for loss of their cargo), against their own insurers, or both. However, the proposed engagement is limited exclusively to the SLG-Meridian insurance coverage dispute. The Firm is not being asked to represent or to take a position adverse to any cargo owner. Should any cargo owner assert a claim against SLG, such a claim would be a separate matter requiring its own intake and conflicts analysis. At this time, no conflict exists with respect to any identified cargo owner.

Conclusion: No conflict exists with respect to any third party identified in the conflicts search.

7. Conclusion and Recommendation

Based on the comprehensive conflicts search conducted on February 3–4, 2024, and the analysis set forth above, the undersigned confirms the following:

(a) All parties, entities, and individuals identified in connection with proposed Matter No. 1012-00003 have been searched across the Firm's entire conflicts database (IntakeTracker system), including all offices, practice groups, and matter statuses (active, closed, and prospective).

(b) The search has returned no conflicts, no potential conflicts, and no situations requiring a waiver, informed consent, or ethical screen.

(c) The Firm has no current or prior attorney-client relationship with the adverse party, Meridian Surety & Indemnity Company, and owes no duty of loyalty, confidentiality, or other obligation to Meridian.

(d) The existing relationship between Douglas Fairchild and Irongate Capital Partners portfolio companies is aligned with and supportive of the proposed engagement and creates no conflict.

(e) No member of the proposed engagement team has any individual conflict.

Accordingly, the proposed representation of Stonefield Logistics Group Inc. against Meridian Surety & Indemnity Company in connection with the insurance coverage dispute under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023 is cleared to proceed.

The engagement letter may be issued to Dale Engstrom, VP of Risk Management at SLG, for execution. The target execution date is February 5, 2024.

It is recommended that the matter be opened in the Firm's accounting and matter management systems under the following parameters:

8. Certification and Approval

This memorandum was prepared by the undersigned on the date indicated below, based on a comprehensive search of the Firm's conflicts database and a review of all relevant records and relationships. The undersigned certifies that the search methodology described in Section 4 was followed in full, that all parties and individuals identified in Section 3 were searched, and that the results and analysis set forth in Sections 5 and 6 are accurate and complete as of the date hereof.

Prepared by:

________________________________________

Andrew Fitzpatrick Lead Associate Calderwood & Harkness LLP

Date: February 4, 2024

Reviewed and Approved:

________________________________________

Howard Bellamy Responsible Partner Calderwood & Harkness LLP

Date: ________

________________________________________

Douglas Fairchild Billing Partner Calderwood & Harkness LLP

Date: ________

General Counsel / Conflicts Committee:

________________________________________

Name: ________

Title: ________

Date: ________

Notes: ________

APPENDIX A — CONFLICTS SEARCH LOG

Matter No.: 1012-00003 Search Dates: February 3–4, 2024 Database: IntakeTracker (Firm-Wide Conflicts Database) Search Conducted By: Andrew Fitzpatrick, Lead Associate

The following table sets forth each party and individual searched, the search terms employed, and the result obtained for each query.

A.1 Entity Searches

A.2 Individual Searches

END OF MEMORANDUM Matter No. 1012-00003 — Internal Conflict Check Memorandum Calderwood & Harkness LLP — Privileged and Confidential — Attorney Work Product

TO:

Douglas Fairchild, Billing Partner

FROM:	Andrew Fitzpatrick, Lead Associate
DATE:	February 4, 2024
RE:	New Matter Conflicts Check — Proposed Representation of Stonefield Logistics Group Inc. in Insurance Coverage Dispute with Meridian Surety & Indemnity Company
MATTER NO.:	1012-00003
PRACTICE GROUP:	Insurance Coverage / Commercial Litigation
OFFICE:	Houston
Attorney	Role	Hourly Rate
Howard Bellamy	Responsible Partner	$1,050/hr
Douglas Fairchild	Billing Partner	$975/hr
Andrew Fitzpatrick	Lead Associate	$725/hr
Naomi Petersen	Working Associate	$575/hr
Party Searched	Type	Jurisdiction	Identifiers
Stonefield Logistics Group Inc.	Corporation	Texas	FEIN 84-3291057
Irongate Capital Partners, LP	Limited Partnership	Delaware	—
Irongate Industrial Partners Fund IV, LP	Limited Partnership	Delaware	—
Name	Title	Organization
Marcus D. Stonefield	CEO	Stonefield Logistics Group Inc.
Leah Tran	CFO	Stonefield Logistics Group Inc.
Dale Engstrom	VP of Risk Management	Stonefield Logistics Group Inc.
Carolyn Reeves	Managing Partner	Irongate Capital Partners, LP
Party Searched	Type	Jurisdiction	Identifiers
Meridian Surety & Indemnity Company	Stock Insurance Company	Ohio	NAIC No. 28471
Name	Title	Organization
Patricia Ng	VP of Claims	Meridian Surety & Indemnity Co.
Brian Woolf	Senior Claims Examiner	Meridian Surety & Indemnity Co.

Party Searched	Type	Jurisdiction
Kessler, Brandt & Howe LLP	Limited Liability Partnership	Texas (Houston)
Name	Title	Organization
Victoria Kessler	Partner	Kessler, Brandt & Howe LLP
Samuel Okonkwo	Associate	Kessler, Brandt & Howe LLP
Party Searched	Role	Type	Jurisdiction
Calvert & Strauss Insurance Brokers, Inc.	SLG's insurance broker; placed the Meridian policy	Corporation	Texas
Ridgeline Forensic Consultants LLC	Potential forensic expert (fire investigation)	LLC	Texas
Whitlock & Associates, CPAs, P.C.	Loss quantification / proof of loss	Professional Corporation	Texas
Lone Star Fire Protection Inc.	Sprinkler maintenance contractor	Corporation	Texas
Permian Wellhead Services LLC	Cargo owner (shipper) — potential witness	LLC	Texas
Cantera Chemical Supply Co.	Cargo owner (shipper) — potential witness	Corporation	Texas
Triton Subsurface Technologies Inc.	Cargo owner (shipper) — potential witness	Corporation	Oklahoma
Pinnacle National Bank	SLG's bank (Midland, TX)	National Banking Association	Texas
Name	Title	Organization
Jason Muñoz	Account Executive	Calvert & Strauss Insurance Brokers, Inc.
Dr. William Creech, P.E., CFEI	Lead Investigator	Ridgeline Forensic Consultants LLC
Sandra Whitlock, CPA, CFF	Engagement Partner	Whitlock & Associates, CPAs, P.C.
Field	Value
Matter No.	1012-00003
Client	Stonefield Logistics Group Inc.
Matter Description	Insurance Coverage Dispute — Cargo Loss (Meridian Surety & Indemnity Co. Policy No. IML-TX-0039821-2023)
Responsible Partner	Howard Bellamy
Billing Partner	Douglas Fairchild
Practice Group	Insurance Coverage / Commercial Litigation

Office	Houston
No.	Party / Entity Searched	Search Terms Used	Search Date	Database	Result
1	Stonefield Logistics Group Inc.	"Stonefield Logistics Group Inc."; "Stonefield Logistics"; "SLG"; "Stonefield"	Feb. 3, 2024	IntakeTracker	No Match / Clear
2	Stonefield Logistics Group Inc. (FEIN)	"84-3291057"	Feb. 3, 2024	IntakeTracker	No Match / Clear
3	Irongate Capital Partners, LP	"Irongate Capital Partners"; "Irongate Capital"; "Irongate"	Feb. 3, 2024	IntakeTracker	No Match / Clear
4	Irongate Industrial Partners Fund IV, LP	"Irongate Industrial Partners Fund IV"; "Irongate Fund IV"; "Irongate Industrial"	Feb. 3, 2024	IntakeTracker	No Match / Clear
5	Meridian Surety & Indemnity Company	"Meridian Surety & Indemnity Company"; "Meridian Surety"; "MSIC"; "Meridian Indemnity"; "Meridian"	Feb. 3, 2024	IntakeTracker	No Match / Clear
6	Meridian Surety & Indemnity Company (NAIC)	"28471"	Feb. 3, 2024	IntakeTracker	No Match / Clear
7	Kessler, Brandt & Howe LLP	"Kessler, Brandt & Howe"; "Kessler Brandt Howe"; "KBH"; "Kessler Brandt"	Feb. 3, 2024	IntakeTracker	No Match / Clear
8	Calvert & Strauss Insurance Brokers, Inc.	"Calvert & Strauss"; "Calvert Strauss"; "Calvert & Strauss Insurance"	Feb. 3, 2024	IntakeTracker	No Match / Clear
9	Ridgeline Forensic Consultants LLC	"Ridgeline Forensic Consultants"; "Ridgeline Forensic"; "Ridgeline"	Feb. 3, 2024	IntakeTracker	No Match / Clear
10	Whitlock & Associates, CPAs, P.C.	"Whitlock & Associates"; "Whitlock Associates"; "Whitlock CPA"	Feb. 3, 2024	IntakeTracker	No Match / Clear
11	Lone Star Fire Protection Inc.	"Lone Star Fire Protection"; "Lone Star FP"; "Lone Star Fire"	Feb. 4, 2024	IntakeTracker	No Match / Clear
12	Permian Wellhead Services LLC	"Permian Wellhead Services"; "Permian Wellhead"	Feb. 4, 2024	IntakeTracker	No Match / Clear
13	Cantera Chemical Supply Co.	"Cantera Chemical Supply"; "Cantera Chemical"; "Cantera"	Feb. 4, 2024	IntakeTracker	No Match / Clear
14	Triton Subsurface Technologies Inc.	"Triton Subsurface Technologies"; "Triton Subsurface"; "Triton"	Feb. 4, 2024	IntakeTracker	No Match / Clear
15	Pinnacle National Bank	"Pinnacle National Bank"; "Pinnacle Bank"; "Pinnacle National"	Feb. 4, 2024	IntakeTracker	No Match / Clear
No.	Individual Searched	Affiliation	Search Terms Used	Search Date	Database	Result
1	Marcus D. Stonefield	CEO, SLG	"Marcus Stonefield"; "Marcus D. Stonefield"; "M. Stonefield"	Feb. 3, 2024	IntakeTracker	No Match / Clear
2	Leah Tran	CFO, SLG	"Leah Tran"; "L. Tran"	Feb. 3, 2024	IntakeTracker	No Match / Clear
3	Dale Engstrom	VP of Risk Management, SLG	"Dale Engstrom"; "D. Engstrom"	Feb. 3, 2024	IntakeTracker	No Match / Clear
4	Carolyn Reeves	Managing Partner, Irongate Capital Partners	"Carolyn Reeves"; "C. Reeves"	Feb. 3, 2024	IntakeTracker	No Match / Clear
5	Patricia Ng	VP of Claims, Meridian	"Patricia Ng"; "Pat Ng"; "P. Ng"	Feb. 3, 2024	IntakeTracker	No Match / Clear
6	Brian Woolf	Senior Claims Examiner, Meridian	"Brian Woolf"; "B. Woolf"; "Brian Wolf"	Feb. 3, 2024	IntakeTracker	No Match / Clear
7	Victoria Kessler	Partner, KBH	"Victoria Kessler"; "V. Kessler"	Feb. 3, 2024	IntakeTracker	No Match / Clear

8	Samuel Okonkwo	Associate, KBH	"Samuel Okonkwo"; "S. Okonkwo"; "Sam Okonkwo"	Feb. 3, 2024	IntakeTracker	No Match / Clear
9	Jason Muñoz	Account Executive, Calvert & Strauss	"Jason Muñoz"; "Jason Munoz"; "J. Muñoz"; "J. Munoz"	Feb. 4, 2024	IntakeTracker	No Match / Clear
10	Dr. William Creech, P.E., CFEI	Lead Investigator, Ridgeline	"William Creech"; "Bill Creech"; "W. Creech"; "Dr. Creech"	Feb. 4, 2024	IntakeTracker	No Match / Clear
11	Sandra Whitlock, CPA, CFF	Engagement Partner, Whitlock & Associates	"Sandra Whitlock"; "S. Whitlock"	Feb. 4, 2024	IntakeTracker	No Match / Clear

CALDERWOOD & HARKNESS LLP 700 Louisiana Street, Suite 4500 Houston, Texas 77002 Telephone: (713) 555-8200 | Facsimile: (713) 555-8201 www.calderwoodharkness.com
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT INTERNAL USE ONLY — NOT FOR DISTRIBUTION OUTSIDE THE FIRM
INTERNAL CONFLICT CHECK MEMORANDUM
Matter No. 1012-00003
1. Purpose and Summary of Request
This memorandum documents the results of the comprehensive conflicts search conducted on February 3–4, 2024, in connection with the proposed representation of Stonefield Logistics Group Inc. ("SLG"), a Texas corporation headquartered at 2900 Petroleum Tower Boulevard, Suite 400, Midland, Texas 79701, in an insurance coverage dispute arising from a cargo-loss event that occurred on November 17, 2023.
Calderwood & Harkness LLP ("C&H" or the "Firm") has been asked by SLG's management to serve as coverage counsel in connection with the denial by Meridian Surety & Indemnity Company ("Meridian" or "MSIC"), an Ohio-domiciled stock insurance company (NAIC No. 28471), with its principal office located at 600 Scioto Crossing, Suite 1200, Columbus, Ohio 43215, of SLG's first-party claim under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023. Meridian communicated its coverage denial by letter dated January 22, 2024, invoking two policy exclusions — Exclusion 4(f) (Improper Storage) and Exclusion 4(k) (Failure to Maintain) — as the bases for its denial of the approximately $4.78 million claim.
The proposed engagement would encompass coverage evaluation and analysis of the subject policy, preparation of a coverage opinion, issuance of a pre-suit demand to Meridian, negotiation toward a resolution of the coverage dispute, and, if necessary, the preparation and prosecution of coverage litigation under Texas law, including potential statutory claims under Texas Insurance Code Chapters 541 and 542.
Dale Engstrom, Vice President of Risk Management at SLG, is the primary client contact for this engagement. The engagement letter has been prepared and is expected to be executed by both the Firm and SLG on or about February 5, 2024, subject to satisfactory clearance of all conflicts.
The proposed engagement team consists of the following attorneys:
•  Howard Bellamy — Responsible Partner
•  Douglas Fairchild — Billing Partner
•  Andrew Fitzpatrick — Lead Associate
•  Naomi Petersen — Working Associate
This memorandum confirms that the comprehensive conflicts search has returned no conflicts, potential conflicts, or situations requiring a waiver, informed consent, or ethical screen, and recommends that the proposed engagement be cleared to proceed and that the matter be formally opened in the Firm's accounting and matter management systems.
2. Description of Proposed Engagement
2.1 Nature of the Matter
The proposed engagement concerns an insurance coverage dispute — specifically, a first-party claim under an all-risk inland marine cargo legal liability policy. SLG, a mid-market intermodal freight brokerage, trucking, and transload/warehousing company, suffered approximately $4,780,000 in cargo losses as the result of a warehouse fire that occurred at its Midland, Texas transload facility on November 17, 2023. The fire originated in Warehouse Building C, located at 4501 East County Road 130, Midland, Texas 79706, and destroyed a substantial volume of oilfield equipment, chemical supplies, and other goods stored on behalf of multiple shippers pending transload and delivery to various Permian Basin well sites.
SLG timely reported the loss to its insurer, Meridian Surety & Indemnity Company, under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023 (the "Policy"). After conducting an investigation over a period of approximately two months, Meridian issued a formal coverage denial letter dated January 22, 2024. In the denial letter, Meridian invoked two policy exclusions as the asserted bases for its refusal to pay the claim:
(a) Exclusion 4(f) — Improper Storage: Meridian contends that certain categories of cargo stored in Warehouse Building C were not stored in accordance with the manufacturer's specifications or applicable safety standards, and that this alleged improper storage contributed to the origin or severity of the fire.
(b) Exclusion 4(k) — Failure to Maintain: Meridian contends that the fire-suppression sprinkler system in Warehouse Building C was not properly maintained, that certain sprinkler heads were non-functional at the time of the fire, and that this failure to maintain the fire-suppression system contributed to the extent of the cargo losses.
Based on a preliminary review, both exclusionary arguments appear to present questions of fact that are subject to challenge. The proposed engagement will involve a thorough analysis of the Policy language, the factual circumstances of the loss, and the applicability (or inapplicability) of the cited exclusions under Texas law.
In addition to the contractual coverage dispute, the matter involves potential claims under Texas Insurance Code Chapter 541 (Unfair Methods of Competition and Unfair or Deceptive Acts or Practices in the Business of Insurance) and Chapter 542 (Processing and Settlement of Claims / Texas Prompt Payment of Claims Act). A preliminary assessment of the timeliness and sufficiency of Meridian's investigation and denial will be undertaken as part of the engagement.
2.2 Proposed Client
Stonefield Logistics Group Inc. is a Texas corporation, Federal Employer Identification Number 84-3291057, with its principal office located at 2900 Petroleum Tower Boulevard, Suite 400, Midland, Texas 79701. SLG is a mid-market intermodal freight brokerage, trucking, and transload/warehousing company that specializes in Permian Basin oilfield supply-chain logistics. The company currently operates fourteen (14) terminals across Texas, New Mexico, and Oklahoma, providing end-to-end logistics services including freight brokerage, dedicated trucking, intermodal drayage, transloading, and warehousing of oilfield equipment, drilling supplies, and completion chemicals.
Key financial and organizational data for SLG include the following:
•  Annual Revenue (FY2023): $187.4 million
•  EBITDA (FY2023): $29.1 million
•  Number of Employees: Approximately 1,100
•  CEO: Marcus D. Stonefield
•  CFO: Leah Tran
•  VP of Risk Management: Dale Engstrom (primary client contact)
SLG was founded in 2007 by Marcus D. Stonefield and grew organically through the 2010s before receiving a significant private equity investment in 2019, as described in Section 2.3 below. The company maintains a comprehensive insurance program overseen by its Vice President of Risk Management and placed through an external insurance broker (Calvert & Strauss Insurance Brokers, Inc.).
2.3 Private Equity Sponsor
SLG is a portfolio company of Irongate Capital Partners, LP, a Delaware limited partnership with its principal office at 200 Clarendon Street, 42nd Floor, Boston, Massachusetts 02116. Irongate Capital Partners is a middle-market private equity firm focused on investments in industrial services, logistics, and energy infrastructure businesses.
Irongate holds approximately 72% of the equity interests in SLG, acquired in August 2019 through Irongate Industrial Partners Fund IV, LP, a Delaware limited partnership that serves as the investment vehicle for the acquisition. The Managing Partner of Irongate Capital Partners, LP is Carolyn Reeves. The remaining approximately 28% of SLG's equity is held by members of SLG management and other minority investors.
By virtue of its majority equity ownership, Irongate exercises board-level oversight of SLG's operations, including its insurance and risk management program. Irongate appoints a majority of SLG's board of directors and has approval rights over material litigation, insurance placements, and risk management decisions, as set forth in the amended and restated limited liability company agreement governing SLG's equity structure.
While Irongate Capital Partners, LP is not the named client in the proposed engagement, and the engagement letter will identify SLG as the sole client, Irongate is a related party with a material economic interest in the outcome of the coverage dispute. Accordingly, Irongate Capital Partners, LP, Irongate Industrial Partners Fund IV, LP, and Carolyn Reeves were all included in the conflicts search conducted in connection with this proposed engagement. This approach is consistent with the Firm's internal policy requiring that known private equity sponsors, controlling shareholders, and affiliated fund entities be searched in connection with any engagement involving a portfolio company, regardless of whether the sponsor is the named client.
2.4 Adverse Party
The adverse party in the proposed engagement is Meridian Surety & Indemnity Company, an Ohio-domiciled stock insurance company. Key identifying information for Meridian is as follows:
•  NAIC Number: 28471
•  A.M. Best Rating: A (Excellent), Financial Size Category IX
•  Principal Office: 600 Scioto Crossing, Suite 1200, Columbus, Ohio 43215
•  Claims VP (Handling Adjuster): Patricia Ng
•  Senior Claims Examiner: Brian Woolf
Meridian is the issuing carrier under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023, the policy under which SLG's coverage claim has been denied. For purposes of this conflicts check, Meridian was searched under its full legal name, common abbreviations (MSIC, Meridian Surety), and its NAIC number. The individual claims personnel identified above — Patricia Ng and Brian Woolf — were also searched.
2.5 Fee Arrangement
The proposed engagement will be conducted on an hourly-rate basis, with no contingency component. The applicable hourly rates for the proposed engagement team are as follows:
Based on a preliminary scoping of the engagement through the pre-litigation phase (coverage analysis, pre-suit demand, and initial negotiation), the estimated fee budget for the pre-litigation phase is $175,000 to $225,000. Should litigation become necessary, a separate budget will be developed and communicated to the client. These rates and the estimated budget will be reflected in the engagement letter to be executed on or about February 5, 2024.
3. Parties and Individuals Searched
The following sections set forth the complete list of all parties and individuals included in the conflicts search conducted on February 3–4, 2024. Parties and individuals are organized by category for clarity and ease of reference. All entities and individuals listed below were searched across the Firm's entire matter database, including active, closed, and prospective matters, across all offices and practice groups.
3.1 Client-Side Parties
3.2 Client-Side Key Individuals
3.3 Adverse / Counterparties
3.4 Adverse-Side Key Individuals
3.5 Adverse Party's Known Counsel
Based on information provided by the client contact, Meridian has retained the following law firm as coverage defense counsel in this matter:
The individual attorneys identified as Meridian's likely litigation team were also searched:
3.6 Other Third Parties with Material Involvement
In addition to the principal parties and their counsel, the following third parties were identified as having a material involvement in the underlying facts, the claim, or the anticipated litigation. Each was included in the conflicts search to ensure comprehensive clearance.
Calvert & Strauss Insurance Brokers, Inc. is the insurance brokerage firm that procured the Meridian policy on SLG's behalf. The firm's account executive, Jason Muñoz, managed the placement of the Inland Marine Cargo Legal Liability Policy at issue. Calvert & Strauss's role in the placement of the policy, including any representations made to the underwriter, may be relevant to the coverage analysis.
Ridgeline Forensic Consultants LLC is a Texas-based fire investigation and forensic engineering firm that the engagement team expects to retain, under the direction of C&H, as a consulting and potentially testifying expert on the cause and origin of the warehouse fire. Dr. William Creech, P.E., CFEI, is the principal investigator at Ridgeline.
Whitlock & Associates, CPAs, P.C. is an accounting firm retained by SLG to assist with loss quantification and preparation of the formal proof of loss submitted to Meridian. Sandra Whitlock, CPA, CFF, is the engagement partner at Whitlock & Associates.
Lone Star Fire Protection Inc. is the independent contractor that held the sprinkler system maintenance contract for SLG's Midland transload facility, including Warehouse Building C. Because Meridian's denial relies in part on Exclusion 4(k) (Failure to Maintain), Lone Star Fire Protection's maintenance records, inspection reports, and personnel are likely to be material fact witnesses.
Permian Wellhead Services LLC, Cantera Chemical Supply Co., and Triton Subsurface Technologies Inc. are cargo owners whose freight was stored in Warehouse Building C at the time of the fire and was destroyed. These entities may have their own separate insurance claims or potential claims against SLG, but they are not parties to the insurance coverage dispute that is the subject of the proposed engagement. They are included in the conflicts search because of their potential roles as fact witnesses and because adversity could conceivably develop in future, unrelated proceedings.
Pinnacle National Bank is SLG's primary banking institution in Midland, Texas. The bank may be involved to the extent that any loss-payee provisions in the Policy reference the bank, or to the extent that SLG's financing arrangements are implicated by the insurance recovery.
3.7 Third-Party Key Individuals
4. Search Methodology
The conflicts searches documented in this memorandum were conducted on February 3–4, 2024, using Calderwood & Harkness's firm-wide conflicts database, known internally as the IntakeTracker system. IntakeTracker is the Firm's centralized electronic conflicts checking and new-matter intake platform, which maintains a comprehensive record of all current, closed, and prospective client matters, party names, adverse-party names, related entities, and key individuals across all of the Firm's offices and practice groups.
The following search methodology was employed:
(a) Entity Name Searches. Each entity identified in Section 3 of this memorandum was searched under all known variations of its name, including its full legal name, any short-form or abbreviated names, known d/b/a names, and common abbreviations. For example, "Stonefield Logistics Group Inc." was searched under "Stonefield Logistics Group Inc.," "Stonefield Logistics," "SLG," and "Stonefield." "Meridian Surety & Indemnity Company" was searched under "Meridian Surety & Indemnity Company," "Meridian Surety," "MSIC," "Meridian," and "Meridian Indemnity." "Kessler, Brandt & Howe LLP" was searched under its full name as well as "KBH" and "Kessler Brandt." Comparable variations were run for all other entities.
(b) Individual Name Searches. All individual names listed in Section 3 were searched, including first name, last name, and any known variations or phonetic equivalents. For example, "Patricia Ng" was also searched as "Pat Ng." "Jason Muñoz" was also searched as "Jason Munoz" (without diacritical). "Dr. William Creech" was also searched as "William Creech" and "Bill Creech."
(c) Numerical Identifier Searches. NAIC Number 28471 (Meridian) and Federal Employer Identification Number 84-3291057 (SLG) were searched as supplemental identifiers to capture any matter records that might reference these entities by identifier rather than by name.
(d) Office-Level Cross-Reference. In addition to the global IntakeTracker search, the search results were cross-referenced against the local matter databases maintained by the Houston, Dallas, Midland, Boston, and Columbus offices — the offices most likely to have touchpoints with the parties involved — to confirm consistency and completeness.
(e) Practice Group Review. The search encompassed all practice groups within the Firm, including Insurance Coverage, Mergers & Acquisitions, Real Estate, Antitrust & Competition, Commercial Litigation, Energy, Private Equity, and Banking & Finance. This broad scope was adopted to capture any relationship or engagement that might not be classified under the Insurance Coverage or Commercial Litigation practice group codes.
(f) Irongate-Specific Search. Given the significance of the private equity sponsor relationship, a targeted search was conducted for any prior or current engagement involving Irongate Capital Partners, LP, any Irongate-affiliated fund (including but not limited to Irongate Industrial Partners Fund IV, LP), or any known Irongate portfolio company. This search was performed to identify any representation that could give rise to a conflict, a positional conflict, or an issue requiring disclosure or informed consent.
(g) Active, Closed, and Prospective Matters. The search encompassed all matter statuses — active, closed, and prospective — to ensure that historical relationships and declined engagements were captured in addition to current representations.
The undersigned personally conducted all searches and reviewed all results. No automated screening alerts or flags were triggered by any of the search queries. The detailed search log, including all search terms used and results obtained, is set forth in Appendix A to this memorandum.
5. Search Results
The following sections set forth the results of the conflicts search for each party and individual identified in Section 3. The results are organized to correspond to the party categories established above.
5.1 Stonefield Logistics Group Inc. / SLG
The Firm has no prior or current representation of Stonefield Logistics Group Inc. in any capacity. No matter records — active, closed, or prospective — were identified in which SLG appears as a client, an adverse party, a witness, or an interested third party. The supplemental search of SLG's Federal Employer Identification Number (84-3291057) returned no matches. SLG is a new client to the Firm. If the engagement proceeds, SLG will be entered into the IntakeTracker system as a new client upon formal matter opening.
5.2 Irongate Capital Partners, LP / Irongate Industrial Partners Fund IV, LP
The Firm has no prior or current representation of Irongate Capital Partners, LP or Irongate Industrial Partners Fund IV, LP in any capacity. No matter records were identified in which either Irongate entity appears as a client, an adverse party, or an interested third party. The search for Carolyn Reeves, Managing Partner of Irongate Capital Partners, returned no matches.
It is noted, however, that Douglas Fairchild (Billing Partner on the proposed engagement, Real Estate practice group) maintains a general billing relationship with certain Irongate portfolio companies for real-estate-related matters, including lease negotiations and property acquisitions. This existing relationship is confirmatory of and consistent with the proposed engagement: Irongate is the majority equity owner of SLG, and representing SLG in a coverage dispute serves, rather than conflicts with, Irongate's interests. Mr. Fairchild's existing Irongate portfolio company relationships support the engagement rather than creating any conflict. This is further analyzed in Section 6.1 below.
No adverse engagements against Irongate Capital Partners, any Irongate-affiliated fund, or any known Irongate portfolio company were identified in the Firm's records.
5.3 Meridian Surety & Indemnity Company
The Firm has no current representation of Meridian Surety & Indemnity Company in any capacity. The Firm has no prior representation of Meridian identified in its matter records. The supplemental search of NAIC Number 28471 returned no matches. The searches for Patricia Ng (VP of Claims) and Brian Woolf (Senior Claims Examiner) returned no matches.
Specifically, the Firm has not at any time been engaged by Meridian as coverage counsel, defense counsel, reinsurance counsel, regulatory counsel, or in any advisory capacity. There is no attorney-client relationship, past or present, between the Firm and Meridian.
5.4 Kessler, Brandt & Howe LLP
The Firm has no current or prior co-counsel or joint engagement with Kessler, Brandt & Howe LLP ("KBH"). No matter records were identified in which KBH appears as co-counsel, opposing counsel, or in any other capacity in connection with a Firm matter. The searches for Victoria Kessler (Partner) and Samuel Okonkwo (Associate) returned no matches.
It is noted for context that KBH is a well-known Houston-based insurance coverage defense firm that regularly represents insurers in first-party and third-party coverage disputes in Texas state and federal courts. The Firm has encountered KBH as opposing counsel in past matters handled by other partners; however, no such matters are currently active, and the Firm's prior encounters with KBH in an adversarial capacity give rise to no professional-courtesy or ethical barrier to proceeding adversely against KBH or its clients in this engagement.
5.5 Calvert & Strauss Insurance Brokers, Inc.
The Firm has no current or prior representation of Calvert & Strauss Insurance Brokers, Inc. in any capacity. The search for Jason Muñoz, Account Executive at Calvert & Strauss, returned no matches. Calvert & Strauss is SLG's insurance broker and placed the Meridian policy; in the proposed engagement, Calvert & Strauss is expected to serve as a fact witness and cooperating third party rather than as a party to the dispute. No conflict arises from this anticipated role.
5.6 Ridgeline Forensic Consultants LLC
No prior engagements with Ridgeline Forensic Consultants LLC were identified in the Firm's matter records or in the Firm's expert/consultant database. The search for Dr. William Creech, P.E., CFEI, returned no matches. Ridgeline is expected to be retained by the engagement team, under the direction of C&H and at SLG's expense, as a consulting and potentially testifying expert on the cause and origin of the November 17, 2023 warehouse fire. The retention of a new forensic expert creates no conflict.
5.7 Whitlock & Associates, CPAs, P.C.
No prior engagements with Whitlock & Associates, CPAs, P.C. were identified in the Firm's records. The search for Sandra Whitlock, CPA, CFF, returned no matches. Whitlock & Associates has been separately engaged by SLG for loss quantification and proof-of-loss preparation. The Firm's engagement team may coordinate with Whitlock & Associates in connection with the coverage dispute, but no conflict arises from this coordination.
5.8 Lone Star Fire Protection Inc.
No matches were identified in the Firm's records for Lone Star Fire Protection Inc. Lone Star Fire Protection is the independent contractor that maintained the fire-suppression sprinkler system at SLG's Midland facility, including Warehouse Building C. Lone Star Fire Protection's maintenance records and personnel may be central to the factual dispute concerning Exclusion 4(k) (Failure to Maintain). Lone Star Fire Protection is expected to be a fact witness; no conflict arises from this role. To the extent that separate claims against Lone Star Fire Protection may be contemplated by SLG or other parties in the future, such claims are outside the scope of the proposed coverage engagement and would require a separate conflicts analysis at the appropriate time.
5.9 Cargo Owners (Permian Wellhead Services LLC, Cantera Chemical Supply Co., Triton Subsurface Technologies Inc.)
No current or prior representation of Permian Wellhead Services LLC, Cantera Chemical Supply Co., or Triton Subsurface Technologies Inc. was identified in the Firm's records. No adversity against any of these three entities was identified in any pending matter. These parties are cargo owners whose freight was stored in Warehouse Building C and was destroyed in the fire. They may have separate claims against SLG for loss of their cargo, and they may also have claims under their own property or cargo insurance policies. However, these potential claims are not within the scope of the proposed engagement, which is limited exclusively to the SLG-Meridian insurance coverage dispute under the Meridian Policy. These cargo owners are identified as potential fact witnesses and are included in the conflicts search for completeness and prudence.
5.10 Pinnacle National Bank
No current or prior representation of Pinnacle National Bank was identified in the Firm's records. No adverse matters involving Pinnacle National Bank were identified. Pinnacle National Bank is SLG's primary banking institution in Midland, Texas, and may appear in connection with any loss-payee endorsements on the Meridian Policy or SLG's broader financing arrangements.
5.11 Proposed Engagement Team Members
Each member of the proposed engagement team was reviewed for individual conflicts, including any personal relationships, prior employment, or financial interests that might create a conflict or the appearance of a conflict in connection with the proposed engagement. The results are as follows:
(a) Howard Bellamy (Responsible Partner). Mr. Bellamy is a partner in the Firm's Antitrust & Competition practice group who is cross-staffed for insurance coverage matters in regulated industries. Mr. Bellamy has no personal or professional relationship with any party identified in Section 3. No individual conflicts were identified.
(b) Douglas Fairchild (Billing Partner). Mr. Fairchild is a partner in the Firm's Real Estate practice group. As noted in Section 5.2 above, Mr. Fairchild maintains a billing relationship with certain Irongate Capital Partners portfolio companies for real-estate-related matters. This relationship is aligned with the client side of the proposed engagement and supports the engagement rather than creating a conflict. No individual conflicts were identified. This relationship is further analyzed in Section 6.1.
(c) Andrew Fitzpatrick (Lead Associate). Mr. Fitzpatrick is an associate in the Firm's Mergers & Acquisitions practice group with experience in post-acquisition insurance recovery matters. Mr. Fitzpatrick has no personal or professional relationship with any party identified in Section 3. No individual conflicts were identified.
(d) Naomi Petersen (Working Associate). Ms. Petersen is an associate in the Firm's Mergers & Acquisitions practice group. Ms. Petersen has no personal or professional relationship with any party identified in Section 3. No individual conflicts were identified.
6. Analysis of Potential Issues
Although the conflicts search returned no conflicts or disqualifying relationships, the following issues were identified as warranting analysis and documentation to ensure a complete record.
6.1 Irongate Capital Partners Relationship
As described in Section 5.2 above, Douglas Fairchild maintains a billing relationship with certain Irongate Capital Partners portfolio companies in connection with real-estate-related matters (lease negotiations, property acquisitions, and related transactional work). This existing relationship was evaluated for any potential conflict or issue.
The analysis is straightforward. Irongate Capital Partners, LP, through Irongate Industrial Partners Fund IV, LP, is the 72% equity owner of Stonefield Logistics Group Inc. Representing SLG in an insurance coverage dispute against Meridian — in which SLG seeks to compel its insurer to honor its contractual obligation to pay a covered loss — directly serves Irongate's economic interests as SLG's majority equity holder. A successful recovery on SLG's insurance claim would enhance SLG's financial position and, by extension, the value of Irongate's investment. There is no scenario in which the proposed engagement would place the Firm in a position adverse to Irongate or any Irongate fund.
Moreover, Mr. Fairchild's existing relationship with Irongate portfolio companies involves real-estate-related matters, not insurance coverage or commercial litigation. No representation of Irongate or any Irongate entity has been identified in any matter adverse to SLG or in any insurance-coverage context. The Firm has not been retained by Irongate on any matter that could create a positional conflict, a confidentiality concern, or a duty-of-loyalty issue with respect to the proposed engagement.
Conclusion: The Irongate relationship presents no conflict, no potential conflict, and no situation requiring a waiver, informed consent, or ethical screen. Mr. Fairchild's existing billing relationship with Irongate portfolio companies is confirmatory and supportive of the proposed engagement.
6.2 No Representation of Meridian
The conflicts search confirmed that the Firm has no current or historical attorney-client relationship with Meridian Surety & Indemnity Company. The Firm has never represented Meridian as coverage counsel, defense counsel, regulatory counsel, or in any advisory capacity. The Firm has never received any confidential information from Meridian.
Because there is no attorney-client relationship — and no former attorney-client relationship — with Meridian, the Firm owes no duty of loyalty, duty of confidentiality, or any other ongoing obligation to Meridian. The Firm is free to accept an engagement adverse to Meridian without restriction.
Conclusion: No conflict exists. No waiver is required.
6.3 No Relationship with Adverse Counsel
The conflicts search confirmed that the Firm has no current or prior co-counsel or joint engagement relationship with Kessler, Brandt & Howe LLP. While KBH is a well-known firm in the Houston insurance coverage defense bar, and attorneys at C&H have encountered KBH as opposing counsel in prior matters, no professional, ethical, or courtesy-based barrier to proceeding adversely against KBH or its client exists. No individual at KBH identified in Section 3.5 has any connection to any Firm attorney or matter.
Conclusion: No conflict exists. No professional-courtesy or ethical barrier is present.
6.4 Third-Party Witnesses / Brokers
Two categories of third parties warrant brief analysis:
(a) Calvert & Strauss Insurance Brokers, Inc. Calvert & Strauss is SLG's insurance broker and placed the Meridian Policy. In the proposed engagement, Calvert & Strauss is not a party to the coverage dispute. Rather, Calvert & Strauss and its account executive, Jason Muñoz, are expected to be cooperative fact witnesses whose testimony and records will support SLG's position regarding the underwriting of the Policy, the disclosures made to Meridian at the time of placement, and the scope of coverage intended. The Firm's role is to represent SLG against Meridian; the Firm does not represent Calvert & Strauss and will not be asked to do so. To the extent that any broker-liability claim against Calvert & Strauss is later contemplated by SLG, such a claim would be outside the scope of the present engagement and would require a separate conflicts analysis.
(b) Cargo Owners (Permian Wellhead Services LLC, Cantera Chemical Supply Co., Triton Subsurface Technologies Inc.). These cargo owners may have independent claims arising from the fire — either against SLG (for loss of their cargo), against their own insurers, or both. However, the proposed engagement is limited exclusively to the SLG-Meridian insurance coverage dispute. The Firm is not being asked to represent or to take a position adverse to any cargo owner. Should any cargo owner assert a claim against SLG, such a claim would be a separate matter requiring its own intake and conflicts analysis. At this time, no conflict exists with respect to any identified cargo owner.
Conclusion: No conflict exists with respect to any third party identified in the conflicts search.
7. Conclusion and Recommendation
Based on the comprehensive conflicts search conducted on February 3–4, 2024, and the analysis set forth above, the undersigned confirms the following:
(a) All parties, entities, and individuals identified in connection with proposed Matter No. 1012-00003 have been searched across the Firm's entire conflicts database (IntakeTracker system), including all offices, practice groups, and matter statuses (active, closed, and prospective).
(b) The search has returned no conflicts, no potential conflicts, and no situations requiring a waiver, informed consent, or ethical screen.
(c) The Firm has no current or prior attorney-client relationship with the adverse party, Meridian Surety & Indemnity Company, and owes no duty of loyalty, confidentiality, or other obligation to Meridian.
(d) The existing relationship between Douglas Fairchild and Irongate Capital Partners portfolio companies is aligned with and supportive of the proposed engagement and creates no conflict.
(e) No member of the proposed engagement team has any individual conflict.
Accordingly, the proposed representation of Stonefield Logistics Group Inc. against Meridian Surety & Indemnity Company in connection with the insurance coverage dispute under Inland Marine Cargo Legal Liability Policy No. IML-TX-0039821-2023 is cleared to proceed.
The engagement letter may be issued to Dale Engstrom, VP of Risk Management at SLG, for execution. The target execution date is February 5, 2024.
It is recommended that the matter be opened in the Firm's accounting and matter management systems under the following parameters:
8. Certification and Approval
This memorandum was prepared by the undersigned on the date indicated below, based on a comprehensive search of the Firm's conflicts database and a review of all relevant records and relationships. The undersigned certifies that the search methodology described in Section 4 was followed in full, that all parties and individuals identified in Section 3 were searched, and that the results and analysis set forth in Sections 5 and 6 are accurate and complete as of the date hereof.
Prepared by:
________________________________________
Andrew Fitzpatrick Lead Associate Calderwood & Harkness LLP
Date: February 4, 2024
Reviewed and Approved:
________________________________________
Howard Bellamy Responsible Partner Calderwood & Harkness LLP
Date: ________
________________________________________
Douglas Fairchild Billing Partner Calderwood & Harkness LLP
Date: ________
General Counsel / Conflicts Committee:
________________________________________
Name: ________
Title: ________
Date: ________
Notes: ________
APPENDIX A — CONFLICTS SEARCH LOG
Matter No.: 1012-00003 Search Dates: February 3–4, 2024 Database: IntakeTracker (Firm-Wide Conflicts Database) Search Conducted By: Andrew Fitzpatrick, Lead Associate
The following table sets forth each party and individual searched, the search terms employed, and the result obtained for each query.
A.1 Entity Searches
A.2 Individual Searches
END OF MEMORANDUM Matter No. 1012-00003 — Internal Conflict Check Memorandum Calderwood & Harkness LLP — Privileged and Confidential — Attorney Work Product
TO: | Howard Bellamy, Responsible Partner
Douglas Fairchild, Billing Partner
FROM: | Andrew Fitzpatrick, Lead Associate
DATE: | February 4, 2024
RE: | New Matter Conflicts Check — Proposed Representation of Stonefield Logistics Group Inc. in Insurance Coverage Dispute with Meridian Surety & Indemnity Company
MATTER NO.: | 1012-00003
PRACTICE GROUP: | Insurance Coverage / Commercial Litigation
OFFICE: | Houston
Attorney | Role | Hourly Rate
Howard Bellamy | Responsible Partner | $1,050/hr
Douglas Fairchild | Billing Partner | $975/hr
Andrew Fitzpatrick | Lead Associate | $725/hr
Naomi Petersen | Working Associate | $575/hr
Party Searched | Type | Jurisdiction | Identifiers
Stonefield Logistics Group Inc. | Corporation | Texas | FEIN 84-3291057
Irongate Capital Partners, LP | Limited Partnership | Delaware | —
Irongate Industrial Partners Fund IV, LP | Limited Partnership | Delaware | —
Name | Title | Organization
Marcus D. Stonefield | CEO | Stonefield Logistics Group Inc.
Leah Tran | CFO | Stonefield Logistics Group Inc.
Dale Engstrom | VP of Risk Management | Stonefield Logistics Group Inc.
Carolyn Reeves | Managing Partner | Irongate Capital Partners, LP
Party Searched | Type | Jurisdiction | Identifiers
Meridian Surety & Indemnity Company | Stock Insurance Company | Ohio | NAIC No. 28471
Name | Title | Organization
Patricia Ng | VP of Claims | Meridian Surety & Indemnity Co.
Brian Woolf | Senior Claims Examiner | Meridian Surety & Indemnity Co.
Party Searched | Type | Jurisdiction
Kessler, Brandt & Howe LLP | Limited Liability Partnership | Texas (Houston)
Name | Title | Organization
Victoria Kessler | Partner | Kessler, Brandt & Howe LLP
Samuel Okonkwo | Associate | Kessler, Brandt & Howe LLP
Party Searched | Role | Type | Jurisdiction
Calvert & Strauss Insurance Brokers, Inc. | SLG's insurance broker; placed the Meridian policy | Corporation | Texas
Ridgeline Forensic Consultants LLC | Potential forensic expert (fire investigation) | LLC | Texas
Whitlock & Associates, CPAs, P.C. | Loss quantification / proof of loss | Professional Corporation | Texas
Lone Star Fire Protection Inc. | Sprinkler maintenance contractor | Corporation | Texas
Permian Wellhead Services LLC | Cargo owner (shipper) — potential witness | LLC | Texas
Cantera Chemical Supply Co. | Cargo owner (shipper) — potential witness | Corporation | Texas
Triton Subsurface Technologies Inc. | Cargo owner (shipper) — potential witness | Corporation | Oklahoma
Pinnacle National Bank | SLG's bank (Midland, TX) | National Banking Association | Texas
Name | Title | Organization
Jason Muñoz | Account Executive | Calvert & Strauss Insurance Brokers, Inc.
Dr. William Creech, P.E., CFEI | Lead Investigator | Ridgeline Forensic Consultants LLC
Sandra Whitlock, CPA, CFF | Engagement Partner | Whitlock & Associates, CPAs, P.C.
Field | Value
Matter No. | 1012-00003
Client | Stonefield Logistics Group Inc.
Matter Description | Insurance Coverage Dispute — Cargo Loss (Meridian Surety & Indemnity Co. Policy No. IML-TX-0039821-2023)
Responsible Partner | Howard Bellamy
Billing Partner | Douglas Fairchild
Practice Group | Insurance Coverage / Commercial Litigation
Office | Houston
No. | Party / Entity Searched | Search Terms Used | Search Date | Database | Result
1 | Stonefield Logistics Group Inc. | "Stonefield Logistics Group Inc."; "Stonefield Logistics"; "SLG"; "Stonefield" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
2 | Stonefield Logistics Group Inc. (FEIN) | "84-3291057" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
3 | Irongate Capital Partners, LP | "Irongate Capital Partners"; "Irongate Capital"; "Irongate" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
4 | Irongate Industrial Partners Fund IV, LP | "Irongate Industrial Partners Fund IV"; "Irongate Fund IV"; "Irongate Industrial" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
5 | Meridian Surety & Indemnity Company | "Meridian Surety & Indemnity Company"; "Meridian Surety"; "MSIC"; "Meridian Indemnity"; "Meridian" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
6 | Meridian Surety & Indemnity Company (NAIC) | "28471" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
7 | Kessler, Brandt & Howe LLP | "Kessler, Brandt & Howe"; "Kessler Brandt Howe"; "KBH"; "Kessler Brandt" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
8 | Calvert & Strauss Insurance Brokers, Inc. | "Calvert & Strauss"; "Calvert Strauss"; "Calvert & Strauss Insurance" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
9 | Ridgeline Forensic Consultants LLC | "Ridgeline Forensic Consultants"; "Ridgeline Forensic"; "Ridgeline" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
10 | Whitlock & Associates, CPAs, P.C. | "Whitlock & Associates"; "Whitlock Associates"; "Whitlock CPA" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
11 | Lone Star Fire Protection Inc. | "Lone Star Fire Protection"; "Lone Star FP"; "Lone Star Fire" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
12 | Permian Wellhead Services LLC | "Permian Wellhead Services"; "Permian Wellhead" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
13 | Cantera Chemical Supply Co. | "Cantera Chemical Supply"; "Cantera Chemical"; "Cantera" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
14 | Triton Subsurface Technologies Inc. | "Triton Subsurface Technologies"; "Triton Subsurface"; "Triton" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
15 | Pinnacle National Bank | "Pinnacle National Bank"; "Pinnacle Bank"; "Pinnacle National" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
No. | Individual Searched | Affiliation | Search Terms Used | Search Date | Database | Result
1 | Marcus D. Stonefield | CEO, SLG | "Marcus Stonefield"; "Marcus D. Stonefield"; "M. Stonefield" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
2 | Leah Tran | CFO, SLG | "Leah Tran"; "L. Tran" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
3 | Dale Engstrom | VP of Risk Management, SLG | "Dale Engstrom"; "D. Engstrom" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
4 | Carolyn Reeves | Managing Partner, Irongate Capital Partners | "Carolyn Reeves"; "C. Reeves" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
5 | Patricia Ng | VP of Claims, Meridian | "Patricia Ng"; "Pat Ng"; "P. Ng" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
6 | Brian Woolf | Senior Claims Examiner, Meridian | "Brian Woolf"; "B. Woolf"; "Brian Wolf" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
7 | Victoria Kessler | Partner, KBH | "Victoria Kessler"; "V. Kessler" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
8 | Samuel Okonkwo | Associate, KBH | "Samuel Okonkwo"; "S. Okonkwo"; "Sam Okonkwo" | Feb. 3, 2024 | IntakeTracker | No Match / Clear
9 | Jason Muñoz | Account Executive, Calvert & Strauss | "Jason Muñoz"; "Jason Munoz"; "J. Muñoz"; "J. Munoz" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
10 | Dr. William Creech, P.E., CFEI | Lead Investigator, Ridgeline | "William Creech"; "Bill Creech"; "W. Creech"; "Dr. Creech" | Feb. 4, 2024 | IntakeTracker | No Match / Clear
11 | Sandra Whitlock, CPA, CFF | Engagement Partner, Whitlock & Associates | "Sandra Whitlock"; "S. Whitlock" | Feb. 4, 2024 | IntakeTracker | No Match / Clear

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT INTERNAL USE ONLY — NOT FOR DISTRIBUTION OUTSIDE THE FIRM

INTERNAL CONFLICT CHECK MEMORANDUM

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