CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGED COMMUNICATION
CALDERWOOD & HARKNESS LLP Attorneys at Law 100 Southeast Second Street, Suite 3400 Miami, Florida 33131 Telephone: (305) 814-7600 Facsimile: (305) 814-7601 www.calderwoodharkness.com
February 7, 2026
Matter No.: 1021-00005
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA EMAIL (lbowman@pinnacleindemnity.com)
Lydia C. Bowman Senior Claims Examiner Pinnacle Indemnity Corp. One Constitution Plaza, 18th Floor Hartford, CT 06103
Re: Notice of Claim and Tender of Defense — Verimark Hospitality Group Inc.; Policy No. PIN-EPL-2025-44781; Threatened Wage-and-Hour Collective/Class Action
Dear Ms. Bowman:
This firm represents Verimark Hospitality Group Inc. ("VHG"), a Delaware corporation publicly traded on the Nasdaq Stock Market under the ticker symbol VMHG, with its principal offices located at 2400 Bayshore Boulevard, Suite 1100, Tampa, Florida 33629 (EIN: 84-3291076). We write to provide formal written notice of a potential claim under the Employment Practices Liability ("EPL") insurance policy issued by Pinnacle Indemnity Corp. ("Pinnacle") to VHG, bearing Policy No. PIN-EPL-2025-44781 (the "Policy"), and to tender the defense and indemnity obligation arising from a threatened wage-and-hour collective and class action to Pinnacle pursuant to the terms of the Policy.
The Policy is in full force and effect during the current policy period of July 1, 2025 through June 30, 2026. This notice is being provided "as soon as practicable" following VHG's receipt of a pre-litigation demand, and well within the sixty (60) day contractual deadline for notice following receipt of a demand or written assertion of a claim. Specifically, VHG's General Counsel, Devin K. Arroyo, received the underlying demand letter on January 16, 2026, establishing a contractual notice deadline of no later than March 15, 2026. This tender is being submitted on February 7, 2026—thirty-seven (37) days after receipt of the demand and well within the contractual notice period.
The following sections set forth the relevant factual background, the nature and scope of the threatened claims, a preliminary exposure assessment, the applicable policy provisions, the current status of VHG's internal investigation and preservation efforts, and the specific actions VHG respectfully requests Pinnacle to undertake in response to this tender.
I. DESCRIPTION OF THE INSURED
The insured under the Policy is Verimark Hospitality Group Inc., a corporation organized and existing under the laws of the State of Delaware, whose shares of common stock are listed and publicly traded on the Nasdaq Stock Market under the ticker symbol VMHG. VHG maintains its corporate headquarters and principal offices at 2400 Bayshore Boulevard, Suite 1100, Tampa, Florida 33629.
VHG operates in the hospitality and real estate sectors, with a primary focus on the ownership, management, and operation of branded hotel and resort properties throughout the State of Florida. As of the date of this letter, VHG owns or manages fourteen (14) hotel and resort properties across the state, generating fiscal year 2025 revenues of approximately $1.42 billion.
VHG's current senior leadership includes the following individuals:
• Chief Executive Officer: Theodore R. Langford
• Chief Financial Officer: Marguerite A. Dunning
• General Counsel: Devin K. Arroyo
VHG employs approximately 8,200 individuals across its fourteen properties in Florida, of whom approximately 5,900 are classified as non-exempt hourly workers. These hourly employees serve in a wide range of operational roles, including but not limited to front-desk associates, housekeeping staff, food and beverage personnel, concierge and guest services representatives, maintenance and facilities workers, and various supervisory positions within the hourly workforce. As described in greater detail below, it is a substantial subset of this non-exempt hourly workforce that forms the basis of the threatened collective and class claims.
II. DESCRIPTION OF THE CLAIM / DEMAND
A. The Demand Letter
On or about January 14, 2026, VHG received a pre-litigation demand letter (the "Demand Letter") from the law firm of Garza, Linden & Okafor LLP ("GLO"), located at 600 Brickell Avenue, Suite 2200, Miami, Florida 33131. The Demand Letter was authored by Marco A. Garza, named partner at GLO, with associate Priya N. Chandrasekaran identified as co-counsel on the matter. The Demand Letter was received at VHG's corporate headquarters in Tampa and came to the attention of VHG General Counsel Devin K. Arroyo on January 16, 2026.
The Demand Letter was sent on behalf of Daniela M. Serrano ("Serrano"), a former hourly, non-exempt front-desk associate at the Verimark Regency Tampa property, located at 1200 North Westshore Boulevard, Tampa, Florida 33607. According to VHG's internal personnel records, Ms. Serrano was employed by VHG from March 14, 2022 through August 22, 2025 (Employee ID: VHG-EMP-20220314-5587). Ms. Serrano is identified in the Demand Letter as the putative lead plaintiff and class representative in the threatened action.
The Demand Letter establishes a response deadline of February 28, 2026, and states that if VHG does not engage in meaningful pre-litigation settlement discussions by that date, GLO intends to file a collective and class action complaint in the United States District Court for the Middle District of Florida, Tampa Division.
A complete copy of the Demand Letter, including all attachments thereto, is enclosed herewith as Exhibit A.
B. Nature of the Allegations
The Demand Letter alleges five (5) distinct categories of systemic wage-and-hour violations purportedly committed by VHG across seven (7) Verimark-branded hotel and resort properties located in the Tampa Bay, Orlando, and South Florida metropolitan markets. The specific allegations are summarized as follows:
1. Overtime Violations. The Demand Letter alleges that VHG has systematically failed to pay overtime compensation at a rate of one-and-one-half (1.5) times the regular rate of pay for all hours worked in excess of forty (40) hours per workweek, in violation of Section 207(a) of the Fair Labor Standards Act ("FLSA"), 29 U.S.C. § 207(a). According to the Demand Letter, VHG's timekeeping systems and payroll practices have resulted in the systematic underpayment of overtime wages, including through the manipulation or rounding of recorded work hours and the failure to include certain categories of non-discretionary compensation (including shift differentials and non-discretionary bonuses) in the regular-rate calculation.
2. Illegal Automatic Meal-Break Deductions. The Demand Letter alleges that VHG's payroll system automatically deducts thirty (30) minutes per shift for meal break periods regardless of whether employees actually received bona fide, uninterrupted, duty-free meal breaks. According to the allegations, employees—particularly front-desk associates, concierge staff, and certain food and beverage personnel—were routinely required to remain on-call, respond to guest inquiries, and perform other work-related duties during their designated meal periods, rendering the automatic deductions impermissible under the applicable provisions of 29 C.F.R. § 785.19 and violating the FLSA's requirement that all hours worked be compensated.
3. Uncompensated Pre-Shift and Post-Shift Work. The Demand Letter alleges that VHG fails to compensate hourly, non-exempt employees for pre-shift and post-shift activities that are integral and indispensable to their principal work activities. These activities are alleged to include, among other things, donning and doffing required uniforms, booting up and logging into computer and point-of-sale systems, attending shift-handover briefings, and completing post-shift checkout procedures. According to the Demand Letter, these uncompensated activities total an estimated fifteen (15) to twenty-five (25) minutes per shift per employee, resulting in significant aggregate underpayments across the putative class.
4. Tipped-Employee Minimum Wage Violations. The Demand Letter alleges that VHG has failed to pay the applicable Florida minimum wage for tipped employees in accordance with Article X, Section 24 of the Florida Constitution. This allegation pertains specifically to certain front-desk and concierge roles that participate in pooled tip arrangements. The Demand Letter asserts that the current Florida minimum wage is $14.00 per hour, with the tipped-employee minimum wage set at $10.98 per hour (reflecting the statutory $3.02 tip credit), and that VHG has failed to properly apply the tip credit, has failed to provide adequate notice to employees of the tip-credit provisions, or has otherwise failed to satisfy the prerequisites for claiming the tip credit under Florida law.
5. Willful Misclassification. The Demand Letter alleges that VHG has willfully misclassified certain "lead" and "senior" hourly positions as exempt from the FLSA's overtime requirements under the administrative exemption, 29 U.S.C. § 213(a)(1), and the corresponding regulations at 29 C.F.R. Part 541. According to the allegations, these positions do not satisfy the duties test or the salary-basis test required for application of the administrative exemption, and VHG's classification of these employees as exempt was not made in good faith but was instead a deliberate strategy to avoid overtime obligations.
C. Putative Class and Collective
The Demand Letter threatens the filing of a dual-track collective action under Section 216(b) of the FLSA and a class action under the Florida Constitution. The putative class and collective is defined in the Demand Letter to encompass all current and former hourly, non-exempt employees at Verimark-branded hotel and resort properties in the State of Florida during the period from January 2023 to the present.
Based on VHG's internal employment records and the scope of the Demand Letter's allegations, the estimated size of the putative collective and class ranges from approximately 4,100 to 5,900 individuals. This estimate accounts for employee turnover across the relevant lookback period and includes both current employees and individuals whose employment with VHG has since terminated.
The seven (7) Verimark-branded properties specifically identified in the Demand Letter as the subject properties of the threatened claims are as follows:
1. Verimark Regency Tampa (Tampa, FL)
2. Verimark Grand Orlando (Orlando, FL)
3. Verimark Shores Clearwater (Clearwater, FL)
4. Verimark Bayfront St. Petersburg (St. Petersburg, FL)
5. Verimark Resort & Spa Boca Raton (Boca Raton, FL)
6. Verimark Oceanview Fort Lauderdale (Fort Lauderdale, FL)
7. Verimark Key West Collection (Key West, FL)
D. Demand Amount
The Demand Letter seeks total compensation of $18,500,000.00 (Eighteen Million Five Hundred Thousand Dollars), which GLO states is inclusive of back pay, liquidated damages under the FLSA, and attorneys' fees and costs. The Demand Letter indicates that GLO considers this figure to represent a "conservative pre-litigation resolution amount" and that the damages exposure will increase significantly if formal litigation is initiated and conditional certification is obtained.
III. PRELIMINARY EXPOSURE ASSESSMENT
VHG has engaged Calderwood & Harkness LLP (matter opened January 30, 2026, Matter No. 1021-00005) to conduct a pre-litigation wage-and-hour audit and to provide a preliminary assessment of VHG's potential financial exposure arising from the claims threatened in the Demand Letter. While this analysis is ongoing and necessarily preliminary in nature, we provide the following exposure summary for Pinnacle's benefit in evaluating the scope of the tendered claim.
Calderwood & Harkness's preliminary assessment identifies a range of potential exposure depending upon the scope of claims ultimately validated, the applicable statutory limitations periods, the size of the opt-in collective and certified class, and the availability and viability of various defenses. The analysis contemplates three scenarios:
A. Scenario A — Narrowest Exposure
Under the narrowest reasonable exposure scenario, which is limited to overtime claims only (Category 1 above), assumes a two (2) year non-willful lookback period under the FLSA, and encompasses only current hourly employees at the seven properties identified in the Demand Letter—approximately 1,895 individuals—Calderwood & Harkness estimates VHG's total potential exposure at approximately $8,147,700, inclusive of liquidated damages under the FLSA. This scenario does not include attorneys' fees or litigation costs, and it assumes no class certification of the Florida constitutional claims.
B. Demand Letter Amount
As noted above, GLO's Demand Letter seeks a total of $18,500,000, which GLO describes as inclusive of back pay, FLSA liquidated damages, and attorneys' fees. It is noted that this amount falls between our narrowest and broadest exposure estimates.
C. Scenario B — Broadest Theoretical Exposure
Under the broadest theoretical exposure scenario—which encompasses all five categories of alleged violations, applies a three (3) year willful lookback period under the FLSA and a five (5) year lookback period for claims arising under the Florida Constitution, and assumes the full putative collective and class of approximately 5,900 individuals—the theoretical ceiling for VHG's potential exposure is approximately $202,400,000, inclusive of FLSA liquidated damages but before attorneys' fees and litigation costs.
We emphasize that this figure represents a theoretical maximum and should not be construed as a likely outcome. Actual exposure will depend upon, among other factors, opt-in and participation rates in the FLSA collective, the outcome of class certification proceedings with respect to the Florida constitutional claims, individual proof requirements, the availability and strength of applicable affirmative defenses (including good-faith defenses under 29 U.S.C. § 259 and 29 U.S.C. § 260), the results of VHG's ongoing internal audit, and numerous other litigation variables.
D. Working Mid-Range Estimate
Based on the information presently available, Calderwood & Harkness's current working mid-range estimate of VHG's total potential exposure is $22,000,000 to $38,000,000, inclusive of liquidated damages but exclusive of attorneys' fees, litigation costs, and any potential penalties. This range reflects reasonable assumptions regarding opt-in rates, the likely scope of certified claims, and the application of certain defenses. We note that this estimate is preliminary and will be subject to material refinement upon completion of the comprehensive wage-and-hour audit and payroll data analysis currently underway.
We provide this preliminary exposure analysis to assist Pinnacle in evaluating the tendered claim and establishing appropriate reserves. Calderwood & Harkness will supplement this analysis as the audit progresses and additional data becomes available.
IV. POLICY TERMS AND COVERAGE REQUEST
A. Policy Identification
The following summarizes the key terms of the applicable insurance policy under which VHG tenders this claim:
A copy of the declarations page of the Policy is enclosed herewith as Exhibit B.
B. Tender of Defense and Indemnity
VHG hereby formally tenders the defense and indemnity of the claims threatened in the Demand Letter to Pinnacle Indemnity Corp. pursuant to the EPL coverage provisions of Policy No. PIN-EPL-2025-44781. VHG asserts that the allegations set forth in the Demand Letter, as described herein, constitute a "claim" or "potential claim" within the meaning of the Policy, and that the defense and potential indemnification of VHG with respect to such allegations falls within the scope of the EPL coverage afforded by the Policy.
VHG respectfully requests that Pinnacle promptly acknowledge coverage for the described claim and confirm Pinnacle's defense obligations, including specifically the advancement of defense costs incurred in excess of the $500,000 per-claim self-insured retention.
VHG acknowledges its contractual obligation to satisfy the $500,000 per-claim self-insured retention before Pinnacle's indemnity obligations are triggered under the Policy, and VHG intends to satisfy that obligation in the ordinary course as defense costs and expenses are incurred.
VHG reserves all rights under the Policy, including but not limited to all rights with respect to any coverage positions that may differ from Pinnacle's determination, any reservation of rights that Pinnacle may assert, and any interpretation of policy terms that may arise in connection with the adjustment of this claim. VHG's tender of defense and indemnity shall not be construed as a waiver of any right, defense, or position available to VHG under the Policy, applicable law, or otherwise.
C. Defense Costs
VHG requests that Pinnacle confirm in writing its position regarding the advancement of defense costs under the Policy, including but not limited to outside counsel fees, expert consultant fees, forensic audit and data analytics costs, court costs, and other litigation expenses. Specifically, VHG requests confirmation of whether defense costs incurred above the SIR are advanced by Pinnacle in addition to the per-occurrence limit, or whether such defense costs erode the $10,000,000 per-occurrence limit (i.e., whether the Policy provides for "defense outside the limits" or "defense within the limits").
VHG further notes that Calderwood & Harkness LLP has been engaged as outside counsel for this matter effective January 30, 2026. VHG respectfully requests Pinnacle's consent to the retention of Calderwood & Harkness LLP as defense counsel in this matter. In the alternative, if Pinnacle maintains panel-counsel requirements, rate guidelines, or other conditions applicable to the selection of defense counsel, VHG requests that Pinnacle promptly identify such requirements so that VHG may evaluate its options and ensure continuity of representation during this critical pre-litigation phase.
V. CURRENT STATUS OF THE MATTER
VHG and Calderwood & Harkness wish to apprise Pinnacle of the following with respect to the current procedural and investigative status of this matter:
Litigation Hold. VHG issued a comprehensive internal litigation-hold memorandum on January 17, 2026—one (1) day after General Counsel Devin K. Arroyo received the Demand Letter. A copy of the litigation-hold memorandum is enclosed herewith as Exhibit C. The litigation hold directs the preservation of all documents and electronically stored information ("ESI") potentially relevant to the claims threatened in the Demand Letter, including but not limited to payroll records, timekeeping data, employee handbooks and policies, scheduling records, manager communications, training materials, and employment agreements.
Custodian Identification. VHG has identified twenty-three (23) custodians whose files, records, and communications are subject to the litigation hold. These custodians include corporate-level human resources personnel, property-level general managers and department heads at each of the seven identified properties, payroll administrators, and members of VHG's legal and compliance teams.
Third-Party Data Preservation. Data preservation requests have been directed to VHG's outsourced payroll processor, Luminos Payroll Solutions Inc. ("Luminos"), under account number LTT-VHG-2022-0041. Luminos has maintained VHG's centralized payroll processing and timekeeping data since January 1, 2022, and VHG has confirmed with Luminos that all historical payroll and timekeeping data within the relevant lookback period remains available and intact.
Pre-Litigation Audit. Calderwood & Harkness is currently in the scoping phase of a comprehensive pre-litigation wage-and-hour audit encompassing all seven properties identified in the Demand Letter. The audit is designed to evaluate VHG's compliance with the FLSA, applicable Department of Labor regulations, and the Florida Constitution's minimum wage provisions, and to identify any areas of potential vulnerability or non-compliance.
Forensic Analytics. VHG is evaluating the engagement of Ridgepoint Advisory Group LLC, a forensic payroll analytics firm with specialized expertise in hospitality-sector wage-and-hour disputes, to assist with statistical sampling, damages modeling, and the analysis of payroll and timekeeping data across the relevant properties and time periods.
No Lawsuit Filed. As of the date of this letter, no lawsuit or formal legal proceeding has been filed in connection with the claims set forth in the Demand Letter. The Demand Letter response deadline is February 28, 2026, and VHG, through counsel, is evaluating its pre-litigation response strategy.
Joint-Employer Analysis. VHG notes that one of the seven properties identified in the Demand Letter—the Verimark Shores Clearwater—is owned by a third party, Palomar Realty Partners LLC, and is managed by VHG pursuant to a Hotel Management Agreement (HMA-2021-0601-PC, dated June 1, 2021). A joint-employer analysis under the FLSA and applicable Department of Labor guidance is currently underway to assess the allocation of liability and the potential involvement of Palomar Realty Partners LLC in any formal litigation.
VI. RESERVATION OF RIGHTS
VHG expressly reserves all of its rights under Policy No. PIN-EPL-2025-44781, including but not limited to the following:
(a) The right to challenge any coverage denial, disclaimer, or reservation of rights issued by Pinnacle in connection with this claim, whether based on policy exclusions, conditions, definitions, or any other basis;
(b) The right to seek reimbursement from Pinnacle for all defense costs incurred by VHG in excess of the $500,000 per-claim self-insured retention, to the extent such costs fall within the scope of coverage afforded by the Policy;
(c) The right to seek indemnification from Pinnacle for any settlement or judgment arising from the threatened claims, up to and including the full per-occurrence and aggregate limits of the Policy;
(d) All rights and remedies available to VHG under the laws of the State of Connecticut (as the domicile of the Policy) and the laws of the State of Florida (as the state in which the underlying claims arise and in which any formal litigation is expected to be filed), including all rights under applicable insurance codes, regulations, and common law doctrines; and
(e) All other rights, claims, and remedies available to VHG under the Policy, at law, or in equity, none of which are waived by the provision of this notice and tender.
VHG's provision of this notice of claim and tender of defense shall not be construed as an admission of liability, fault, or wrongdoing with respect to any of the allegations set forth in the Demand Letter. VHG expressly denies all allegations of wage-and-hour violations, misclassification, or any other form of non-compliance, and VHG reserves all defenses available to it in connection with the underlying claims, including but not limited to defenses based on applicable statutes of limitations, the good-faith defense under 29 U.S.C. §§ 259 and 260, individual opt-in and standing requirements under FLSA § 216(b), and the absence of commonality, typicality, and predominance prerequisites to class certification.
VII. REQUESTED ACTIONS FROM PINNACLE INDEMNITY CORP.
In light of the foregoing, VHG respectfully requests that Pinnacle Indemnity Corp. take the following actions on an expedited basis:
1. Acknowledge Receipt. Acknowledge receipt of this Notice of Claim and Tender of Defense in writing, confirming the date on which this submission was received by Pinnacle.
2. Assign a Claim Number. Assign a formal claim number to this matter and provide VHG and Calderwood & Harkness with the name, direct telephone number, and email address of the assigned claims handler, if different from Lydia C. Bowman.
3. Confirm Coverage. Confirm coverage under Policy No. PIN-EPL-2025-44781 for the claims described herein, or, in the alternative, issue a written reservation of rights specifically identifying each and every coverage defense, exclusion, or condition that Pinnacle intends to assert in connection with this claim.
4. Confirm Defense Counsel. Confirm Pinnacle's acceptance of Calderwood & Harkness LLP as defense counsel for this matter, or, in the alternative, identify any panel-counsel requirements, billing rate guidelines, or litigation management protocols applicable to VHG's selection and retention of defense counsel.
5. Advise on Defense Costs. Advise on Pinnacle's position regarding the advancement of defense costs above the SIR, and specifically confirm whether defense costs erode the $10,000,000 per-occurrence limit or are paid in addition to the limit.
6. Provide Reporting Requirements. Provide VHG and Calderwood & Harkness with any reporting requirements, litigation guidelines, or claims-handling protocols that Pinnacle requires VHG to follow in connection with the defense of this matter, including the frequency and format of status reports, budget submissions, and pre-authorization requirements for significant defense expenditures.
Given the February 28, 2026 response deadline established in the Demand Letter, VHG respectfully requests that Pinnacle provide its initial written response to this tender no later than February 21, 2026, to allow adequate time for VHG and counsel to incorporate Pinnacle's coverage position into VHG's pre-litigation strategy.
VIII. ENCLOSURES
The following documents are enclosed with this letter for Pinnacle's review and file:
Exhibit A: Demand letter from Garza, Linden & Okafor LLP, dated January 14, 2026, including all attachments thereto (25 pages).
Exhibit B: Copy of EPL Policy No. PIN-EPL-2025-44781, declarations page (4 pages).
Exhibit C: VHG internal litigation-hold memorandum, dated January 17, 2026 (8 pages).
IX. CONTACT INFORMATION FOR ONGOING COMMUNICATIONS
All communications from Pinnacle regarding this claim, including but not limited to coverage determinations, claim assignments, defense counsel approvals, and reporting requirements, should be directed to the following individuals:
Primary Contact — Outside Counsel: Bernard Crawford, Partner Calderwood & Harkness LLP 100 Southeast Second Street, Suite 3400 Miami, Florida 33131 Telephone: (305) 814-7612
Email: bcrawford@calderwoodharkness.com
With copies to — In-House Counsel: Devin K. Arroyo, General Counsel Verimark Hospitality Group Inc. 2400 Bayshore Boulevard, Suite 1100 Tampa, Florida 33629 Telephone: (813) 472-3300
Email: darroyo@verimarkgroup.com
We appreciate your prompt attention to this matter and wish to emphasize VHG's commitment to cooperating fully with Pinnacle's investigation and claims process. VHG understands and acknowledges its obligations under the Policy with respect to the provision of information, the coordination of defense strategy, and the cooperation with Pinnacle's claims personnel, and VHG intends to fulfill those obligations in good faith throughout the pendency of this matter.
Given the approaching February 28, 2026 deadline for response to the Demand Letter, we respectfully urge Pinnacle to prioritize its review of this submission and to communicate its initial coverage position at the earliest practicable date. VHG and Calderwood & Harkness stand ready to participate in an introductory conference call with Pinnacle's claims team at Pinnacle's convenience.
Please do not hesitate to contact the undersigned directly with any questions or to discuss this matter further.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Bernard Crawford Partner
On behalf of Verimark Hospitality Group Inc.
Date: February 7, 2026
Enclosures:
Exhibit A — Demand Letter from Garza, Linden & Okafor LLP (January 14, 2026) Exhibit B — EPL Policy No. PIN-EPL-2025-44781 (Declarations Page) Exhibit C — VHG Internal Litigation-Hold Memorandum (January 17, 2026)
cc:
Devin K. Arroyo, General Counsel, Verimark Hospitality Group Inc. Renata Vasquez, Billing Partner, Calderwood & Harkness LLP Theodore R. Langford, Chief Executive Officer, Verimark Hospitality Group Inc. Marguerite A. Dunning, Chief Financial Officer, Verimark Hospitality Group Inc.
| Policy Element | Detail |
| Carrier | Pinnacle Indemnity Corp. |
| Policy Number | PIN-EPL-2025-44781 |
| Policy Period | July 1, 2025 through June 30, 2026 |
| Policy Type | Employment Practices Liability (EPL) |
| Per-Occurrence Limit | $10,000,000 |
| Aggregate Limit | $25,000,000 |
| Self-Insured Retention (SIR) | $500,000 per claim |