Dear Diana,
I hope this email finds you well. My name is Jeffrey Park, and I am the lead associate at Calderwood & Harkness LLP working under Douglas Carmichael (Responsible Partner) on the Pinnacle Atlantic reinsurance recoverable dispute (Matter No. 1025-00005). Our firm was engaged on March 2, 2026, following authorization by the QIH Board Audit Committee on February 24, 2026.
I am writing to request the complete claims files for the two underlying claim clusters that are at the center of Pinnacle Atlantic Reinsurance Ltd.'s pre-suit demand letter dated February 14, 2026, which was transmitted by Hargrove, Fitch & Calloway LLP on Pinnacle Atlantic's behalf in connection with Treaty No. PA-QCS-2019-EXL-0044. Our team needs to conduct a thorough review of these files in order to assess QC&S's defenses and prepare the initial privileged case assessment memorandum for Rachel Sondergaard, General Counsel.
I have organized our requests into two sections below corresponding to each claim cluster.
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**A. Meridian Docks Mass Tort Cluster (31 Claims)**
We are requesting the complete claims file for all 31 related commercial general liability bodily injury claims arising from alleged toxic contamination at the Meridian Docks industrial waterfront redevelopment project in Newark, New Jersey. Specifically, we need the following:
**1. Policy Information** The complete policy file for QC&S Policy No. CGL-2020-09844, issued to Meridian Docks Development LLC, including all endorsements, amendments, and binders.
**2. Individual Claim Files (All 31 Claims)** For each of the 31 individual claims, we request: - Initial claim reports and intake documentation; - All coverage analyses and coverage opinions; - All reserve-setting documentation, including initial reserves established on or about March 15, 2021, and all subsequent reserve changes through the present, with supporting memoranda and actuarial inputs; and - In particular, we need documentation of the reserve increases in Q1 2022 that triggered the individual claim reporting threshold of $1,000,000 per claim under Article 7 of the Treaty. We need documentation showing precisely when each claim crossed that threshold.
**3. Internal Claims Committee Materials** - Minutes of all internal claims committee meetings at which the Meridian Docks claims were discussed; and - Any presentations, loss summaries, or recommendations prepared for claims committee review in connection with these claims.
**4. Reinsurance Notice Documentation** This is a key area of focus for our assessment: - All documentation relating to the decision to notify Pinnacle Atlantic of the Meridian Docks claims; - The actual notice transmitted to Pinnacle Atlantic via Broadreach Intermediaries Inc. on May 22, 2022; - Any internal correspondence or memoranda discussing the timing of notice and the approximately 14-month, 7-day gap between initial reserving (March 15, 2021) and notice (May 22, 2022); and - Any prior correspondence with Broadreach Intermediaries (Jamie Castellano) regarding whether and/or when to report these claims.
**5. Correspondence** - All correspondence with the policyholder, Meridian Docks Development LLC; - All correspondence with claimants' counsel; - All correspondence with defense counsel retained on behalf of QC&S or the policyholder; and - All correspondence with Broadreach Intermediaries Inc. regarding these claims.
**6. Current Status** We understand the current net incurred stands at approximately $41.2 million across all 31 claims. Please provide the most current loss summary and reserve breakdown on a claim-by-claim basis.
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**B. Veridian Financial Services E&O Cluster (3 Claims)**
We are requesting the complete claims file for the three related errors & omissions / professional liability claims brought by investors against Veridian Financial Services Inc. alleging misrepresentation in structured-product sales. Specifically:
**1. Policy Information** The complete policy file for QC&S Policy No. PL-2021-15327, issued to Veridian Financial Services Inc., including all endorsements and amendments.
**2. Individual Claim Files (Claims A, B, and C)** For each of the three claims: - Initial claim reports and coverage analyses; - All reserve-setting documentation and complete reserve change histories; and - All litigation exposure analyses and evaluation memoranda.
**3. Settlement Documentation — Critical Priority** This category is of the highest priority for our assessment. Pinnacle Atlantic alleges that QC&S settled these claims without meaningful litigation exposure analysis and at inflated amounts in order to push aggregate losses above the TY 2023 retention under the Treaty. We need to evaluate these allegations thoroughly and therefore request: - All settlement evaluation memoranda prepared in connection with the September 8, 2023 settlement; - Documentation of settlement authority obtained internally, including claims committee approvals and management sign-offs; - The executed settlement agreements for all three claims (Claim A: $14.2 million; Claim B: $12.8 million; Claim C: $7.5 million; total: $34.5 million); - Any third-party settlement analyses, mediator proposals, or expert valuations; and - Any analysis comparing QC&S's litigation exposure to the settlement values.
**4. Allocation of Losses** - Documentation showing QC&S's net retained amount after application of other reinsurance ($26.1 million); and - All workpapers showing the allocation of $8.7 million in ceded losses to TY 2023 under the Treaty.
**5. Correspondence** - All correspondence with Veridian Financial Services Inc.; - All correspondence with claimants' counsel; - All correspondence with defense counsel; and - All correspondence with Broadreach Intermediaries Inc. and/or Pinnacle Atlantic regarding billing of the Veridian settlement under the Treaty.
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**Logistics and Timeline**
We would appreciate production of these materials as soon as practicable, and ideally within 7–10 business days, to support the timeline for our initial case assessment memorandum. We suggest secure electronic delivery via encrypted file transfer or a document review platform; we are happy to coordinate with QC&S IT to set up an appropriate transfer mechanism if that would be helpful.
Additionally, I would ask that you identify any other custodians within the QC&S claims department who may have relevant files or who should be included in our information-gathering process. As a reminder, all materials responsive to these requests should be treated as subject to the litigation hold notice issued on March 4, 2026.
These files will be reviewed by me and Yuki Nakamura, the working associate on the matter, and we may have follow-up questions as our review progresses. Please do not hesitate to reach out if you have any questions about the scope or prioritization of these requests — I am happy to schedule a call at your convenience to walk through any of this in greater detail.
Thank you very much for your assistance, Diana. I look forward to working with you on this matter.
Best regards,
Jeffrey Park Senior Associate Calderwood & Harkness LLP Direct: (212) 508-4739 Email: jpark@calderwoodharkness.com
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