1025-00005 · Quorum Insurance Holdings · Correspondence/Opposing Counsel

demand-to-arbitrate-letter.docx DOCUMENT Litigation

18 / 37 ← → ✕

Contract analysis Extract to table

CALDERWOOD & HARKNESS LLP Attorneys at Law

One Liberty Plaza, 55th Floor New York, New York 10006

Telephone: (212) 506-7800 Facsimile: (212) 506-7801 www.calderwoodharkness.com

March 18, 2026

VIA HAND DELIVERY AND EMAIL

Nathaniel R. Calloway III, Esq. Hargrove, Fitch & Calloway LLP 51 West 52nd Street, 40th Floor New York, New York 10019

Re: Formal Demand for Arbitration Pursuant to Article 22 of Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 Between Quorum Casualty & Surety Company and Pinnacle Atlantic Reinsurance Ltd.

Dear Mr. Calloway:

I. Introduction and Identification of Counsel

I write in my capacity as a partner at Calderwood & Harkness LLP ("C&H") on behalf of our clients, Quorum Insurance Holdings Corp. ("QIH"), a Delaware corporation publicly traded on the Nasdaq Global Select Market (ticker symbol: QIHC), with its principal executive offices located at 200 Constitution Plaza, Suite 3400, Hartford, Connecticut 06103, and its principal insurance subsidiary, Quorum Casualty & Surety Company ("QC&S"), a New York-domiciled stock property and casualty insurer, NAIC Company Code No. 24891, with its principal office at 200 Constitution Plaza, Suite 3200, Hartford, Connecticut 06103.

This letter is sent in response to, and should be read in conjunction with, the pre-suit demand letter dated February 14, 2026 (the "HFC Demand Letter"), transmitted by your firm, Hargrove, Fitch & Calloway LLP ("HFC"), on behalf of Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic" or "PARL"), a Bermuda Class 4 insurer registered with the Bermuda Monetary Authority (BMA Registration No. BMA-4R-2008-0331), with its registered office at Clarendon House, 14 Church Street, Hamilton HM 11, Bermuda, and its United States office at 1285 Avenue of the Americas, 28th Floor, New York, New York 10019. Calderwood & Harkness LLP's engagement in connection with this matter is referenced under C&H Matter Number 1025-00005.

This letter constitutes a formal demand for arbitration pursuant to Article 22 of the Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 (as defined more fully below, the "Treaty") and should be read in conjunction with C&H's separate Response Letter to Pinnacle Atlantic's Pre-Suit Demand of even date, which addresses on the merits each of the four grounds raised in the HFC Demand Letter. QC&S's rights, claims, and defenses are more fully set forth therein and are incorporated herein by reference.

II. Identification of the Treaty and the Dispute

The reinsurance arrangement giving rise to this dispute is governed by the following instrument:

Treaty: Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 (the "Treaty")

Cedent: Quorum Casualty & Surety Company, a New York-domiciled stock property and casualty insurer (NAIC No. 24891)

Reinsurer: Pinnacle Atlantic Reinsurance Ltd., a Bermuda Class 4 insurer (BMA Registration No. BMA-4R-2008-0331)

Effective Date: July 1, 2019

Original Term: Five (5) years, commencing July 1, 2019 and expiring June 30, 2024, subject to automatic annual extensions unless either party provides ninety (90) days' written notice of non-renewal prior to the applicable anniversary date. The Treaty has been extended through June 30, 2026 by virtue of two successive one-year automatic extensions. Pinnacle Atlantic provided written notice of non-renewal to QC&S on October 1, 2025; accordingly, the Treaty will lapse by its terms on June 30, 2026.

Intermediary: Broadreach Intermediaries Inc. (designated under Treaty Article 9 as the intermediary broker of record)

Governing Law: The laws of the State of New York govern the Treaty (Treaty Article 16)

Covered Lines: Commercial general liability, excess and umbrella liability, and professional liability policies issued by QC&S within the scope of the Treaty's subject business definition

Retention: $120,000,000 in aggregate net incurred losses per Treaty Year

Cession Limit: $200,000,000 per Treaty Year, applying to aggregate net incurred losses in excess of the $120,000,000 retention, up to a maximum of $320,000,000 per Treaty Year

The dispute between the parties may be summarized as follows. In the HFC Demand Letter, Pinnacle Atlantic asserted four purported grounds for challenging a total of $78,400,000 in reinsurance recoverables that QC&S has billed to Pinnacle Atlantic under the Treaty for Treaty Years 2022 and 2023. Of that amount, $69,700,000 relates to Treaty Year 2022 and $8,700,000 relates to Treaty Year 2023. In addition to demanding the return of the $78,400,000 in recoverables, Pinnacle Atlantic demanded payment of $12,600,000 in claimed interest, for a total demand of $91,000,000.

The four grounds asserted by Pinnacle Atlantic in the HFC Demand Letter are as follows:

(1) Late Notice (Treaty Article 7). Pinnacle Atlantic alleges that QC&S provided untimely notice of the Meridian Docks mass tort claim cluster, comprising thirty-one (31) commercial general liability claims arising under Policy No. CGL-2020-09844, and that the alleged late notice excuses Pinnacle Atlantic's reinsurance obligations with respect to those claims.

(2) Misallocation of IBNR Reserve Development (Treaty Article 5). Pinnacle Atlantic alleges that QC&S misallocated $22,300,000 in incurred-but-not-reported ("IBNR") reserve development to the Treaty in a manner inconsistent with the loss allocation methodology prescribed by Article 5 of the Treaty.

(3) Failure to Follow the Fortunes (Treaty Article 11). Pinnacle Atlantic alleges that QC&S's settlement of the Veridian Financial Services errors and omissions ("E&O") claim cluster, totaling $34,500,000 under Professional Liability Policy No. PL-2021-15327, was not entitled to the benefit of the follow-the-fortunes doctrine codified in Article 11 of the Treaty.

(4) Ceded Earned Premium Underreporting (Treaty Article 3). Pinnacle Atlantic alleges that QC&S underreported ceded earned premiums by $6,800,000 under Article 3 of the Treaty, contending that QC&S reported $38,400,000 in ceded earned premiums whereas Pinnacle Atlantic's own calculation yields a figure of $45,200,000.

QC&S categorically denies all four grounds. QC&S maintains that the reinsurance recoverables billed for Treaty Years 2022 and 2023 were properly calculated, timely noticed, and validly ceded in full compliance with the terms of the Treaty. The cessions are proper and are fully payable by Pinnacle Atlantic. QC&S's detailed substantive response to each of the four grounds is set forth in C&H's Response Letter of even date, which is being delivered to HFC simultaneously with this demand for arbitration.

III. Invocation of Treaty Article 22 — Mandatory Arbitration

Article 22 of the Treaty provides, in relevant part, that any dispute arising out of or relating to the Treaty, including but not limited to disputes concerning the interpretation, performance, or breach thereof, shall be resolved exclusively by binding arbitration. Article 22 specifies that any such arbitration shall be conducted in accordance with the Rules of the AIDA Reinsurance and Insurance Arbitration Society — U.S. ("ARIAS-U.S."), as in effect at the time the demand for arbitration is made, and shall be heard by a three-member arbitration panel. Article 22 further provides that the seat of arbitration shall be New York, New York.

The disputes set forth in the HFC Demand Letter — concerning QC&S's purported notice obligations under Article 7, the allocation of incurred losses under Article 5, the application of the follow-the-fortunes doctrine under Article 11, and the calculation of ceded earned premiums under Article 3 — each and every one arise out of and relate directly to the Treaty. These disputes concern the interpretation and performance of specific Treaty provisions and fall squarely and unambiguously within the scope of the arbitration clause contained in Article 22.

Accordingly, QC&S hereby formally invokes Article 22 of the Treaty and demands that all disputes between QC&S and Pinnacle Atlantic arising under or relating to Treaty No. PA-QCS-2019-EXL-0044, including but not limited to the claims, allegations, and demands set forth in HFC's February 14, 2026 letter, be submitted to binding arbitration in accordance with the ARIAS-U.S. Rules and the terms and conditions of Article 22 of the Treaty. This demand is made on behalf of QC&S and, to the extent applicable, on behalf of QIH as the corporate parent of QC&S and a party in interest under the Treaty's dispute resolution framework.

IV. Response to HFC's Assertion that the Arbitration Clause Is Inapplicable

QC&S notes that the HFC Demand Letter contained the assertion — unsupported by any textual analysis or legal authority — that the arbitration clause set forth in Article 22 of the Treaty is "inapplicable" to the specific claims raised by Pinnacle Atlantic. QC&S categorically rejects this assertion, which is without merit in fact or law.

The arbitration clause in Article 22 is broadly worded. It encompasses "any dispute arising out of or relating to" the Treaty. As a matter of well-established precedent, both in the courts of the State of New York and in the federal courts, this formulation — "arising out of or relating to" — is recognized as the most expansive arbitration clause language available, and is routinely enforced to capture all disputes that have any connection to the underlying agreement. See, e.g., Claire Pryor, 58 F.3d 16, 20 (2d Cir. 1995); Oldroyd v. Elmira Sav. Bank, 134 F.3d 72, 76 (2d Cir. 1998).

Under New York law, as codified in Article 75 of the New York Civil Practice Law and Rules ("NY CPLR"), and under the Federal Arbitration Act, 9 U.S.C. §§ 1–16, there is a strong and well-recognized presumption in favor of arbitrability. This presumption is particularly robust in the reinsurance context, where sophisticated commercial parties operating in a specialized market have voluntarily agreed to submit disputes to arbitration before a panel of industry professionals. Courts in New York and throughout the United States have repeatedly emphasized that the policy favoring arbitration in the reinsurance industry is "exceptionally strong," and that doubts concerning the scope of an arbitration clause should be resolved in favor of arbitration. See, e.g., Gregory Greaves, 215 A.D.2d 299, 300 (1st Dep't 1995); Crestline Corporation, 246 F.3d 219, 226 (2d Cir. 2001).

Each of Pinnacle Atlantic's four claimed grounds directly and indisputably concerns the interpretation, application, and performance of specific Treaty articles — namely, Article 3 (premium reporting), Article 5 (loss allocation), Article 7 (notice), and Article 11 (follow the fortunes). These claims are paradigmatic disputes "arising out of or relating to" the Treaty. There is no plausible construction of Article 22 under which claims that turn entirely on the interpretation of Treaty provisions could be deemed outside the scope of an arbitration clause that by its terms covers "any dispute arising out of or relating to" the Treaty.

HFC has identified no textual basis in Article 22, nor in any other provision of the Treaty, for carving out any category of Treaty dispute from the arbitration obligation. No exclusion, limitation, or exception to the arbitration clause exists in the Treaty's text. The arbitration clause is unqualified and applies to all disputes between the parties arising out of or relating to the Treaty.

Any attempt by Pinnacle Atlantic to litigate these claims in the Supreme Court of the State of New York, in any federal court, or in any other judicial forum would be in direct derogation of the parties' bargained-for agreement to arbitrate and would contravene both the letter and the spirit of the Treaty. QC&S will vigorously oppose any such attempt.

V. Appointment of Party-Appointed Arbitrators

Pursuant to Article 22 of the Treaty and the ARIAS-U.S. Rules, each party to the arbitration is entitled to appoint one party-appointed arbitrator. The two party-appointed arbitrators shall thereafter select a neutral umpire to serve as the third member and chair of the arbitration panel.

QC&S hereby notifies Pinnacle Atlantic that QC&S intends to appoint its party-appointed arbitrator and will communicate the identity of that arbitrator to Pinnacle Atlantic and to HFC upon confirmation of the appointee's acceptance. QC&S anticipates completing this appointment within the time period prescribed by the Treaty and the ARIAS-U.S. Rules.

QC&S demands that Pinnacle Atlantic appoint its party-appointed arbitrator within the time period prescribed by Article 22 of the Treaty and the ARIAS-U.S. Rules following Pinnacle Atlantic's receipt of this demand for arbitration. In the event that Pinnacle Atlantic fails or refuses to appoint its party-appointed arbitrator within the prescribed time period, QC&S will exercise all available remedies under the ARIAS-U.S. Rules and applicable law, including the right to seek a court order directing the appointment of an arbitrator on Pinnacle Atlantic's behalf.

Upon the appointment of both party-appointed arbitrators, the two arbitrators shall select the neutral umpire in accordance with the procedures set forth in Article 22 of the Treaty and the ARIAS-U.S. Rules. In the event the two party-appointed arbitrators are unable to agree upon the selection of an umpire within the time period prescribed by the ARIAS-U.S. Rules, the umpire shall be selected through the procedures established by ARIAS-U.S., including, if necessary, the ARIAS-U.S. umpire selection process.

In accordance with the ARIAS-U.S. Rules and the longstanding custom and practice in reinsurance arbitrations, all three arbitrators — the two party-appointed arbitrators and the neutral umpire — must be current or former officers of insurance or reinsurance companies. QC&S expects Pinnacle Atlantic to comply with this requirement and will object to any proposed arbitrator who does not meet this qualification.

VI. Scope of Arbitration

QC&S demands that the arbitration encompass all claims, counterclaims, defenses, and disputes arising under or relating to Treaty No. PA-QCS-2019-EXL-0044, including without limitation:

(a) Pinnacle Atlantic's challenge to the $78,400,000 in reinsurance recoverables billed by QC&S under the Treaty for Treaty Year 2022 ($69,700,000) and Treaty Year 2023 ($8,700,000), and QC&S's defense and affirmation of those billings;

(b) Pinnacle Atlantic's demand for the return of $78,400,000 already paid, together with $12,600,000 in claimed interest thereon, totaling $91,000,000, and QC&S's defense against such demand;

(c) Pinnacle Atlantic's allegation of late notice under Treaty Article 7 with respect to the Meridian Docks mass tort claim cluster, comprising thirty-one (31) claims under Commercial General Liability Policy No. CGL-2020-09844, with aggregate net incurred losses of $41,200,000, and QC&S's defense that notice was timely and in full compliance with the Treaty;

(d) Pinnacle Atlantic's allegation of misallocation of $22,300,000 in incurred-but-not-reported reserve development under Treaty Article 5, and QC&S's defense that all reserve allocations were made in accordance with the methodology prescribed by Article 5 and consistent with sound actuarial principles;

(e) Pinnacle Atlantic's challenge under Treaty Article 11 to the Veridian Financial Services E&O cluster settlement, totaling $34,500,000 under Professional Liability Policy No. PL-2021-15327, consisting of Claim A ($14,200,000), Claim B ($12,800,000), and Claim C ($7,500,000), and QC&S's defense that the settlement was made in good faith, within the cedent's business judgment, and is entitled to the benefit of the follow-the-fortunes doctrine as codified in Article 11;

(f) Pinnacle Atlantic's allegation of ceded earned premium underreporting of $6,800,000 under Treaty Article 3, based on Pinnacle Atlantic's contention that QC&S reported ceded earned premiums of $38,400,000 whereas Pinnacle Atlantic's own calculation yields a figure of $45,200,000, and QC&S's defense that the premium reports were accurate and in compliance with Article 3;

(g) QC&S's counterclaims against Pinnacle Atlantic, including but not limited to (i) a counterclaim for declaratory judgment confirming the validity of all cessions under the Treaty for Treaty Years 2022 and 2023 and declaring that Pinnacle Atlantic is obligated to pay the full amount of the reinsurance recoverables billed by QC&S, and (ii) a counterclaim for breach of the Treaty arising from Pinnacle Atlantic's wrongful demand for disgorgement of properly ceded reinsurance recoverables and its threat of litigation in derogation of the arbitration clause; and

(h) Any and all other disputes, claims, counterclaims, or issues between the parties arising out of or relating to Treaty No. PA-QCS-2019-EXL-0044, whether now existing or hereafter arising during the pendency of the arbitration proceedings.

QC&S reserves the right to amend, supplement, or refine the scope of its claims and counterclaims as the arbitration proceedings progress and as discovery is completed, in accordance with the ARIAS-U.S. Rules and any procedural orders issued by the arbitration panel.

VII. Notice Regarding Judicial Proceedings

QC&S places Pinnacle Atlantic and HFC on notice that, should Pinnacle Atlantic or HFC file any action, complaint, petition, or other proceeding in the Supreme Court of the State of New York, New York County, Commercial Division, or in any other state or federal court of competent jurisdiction, seeking to litigate any of the disputes covered by the arbitration clause in Article 22, QC&S will promptly move to compel arbitration pursuant to NY CPLR § 7503 and/or Section 4 of the Federal Arbitration Act, 9 U.S.C. § 4, and will seek a stay of all judicial proceedings pending the completion of arbitration pursuant to NY CPLR § 7503(a) and/or Section 3 of the Federal Arbitration Act, 9 U.S.C. § 3.

QC&S is confident that any court presented with the broad, unambiguous, and enforceable arbitration clause contained in Article 22 of the Treaty will enforce the parties' agreement to arbitrate and will stay any judicial proceedings that Pinnacle Atlantic may attempt to initiate. The Treaty was negotiated and executed by sophisticated commercial parties operating in the reinsurance market, both of which were represented by experienced counsel and brokers, and the arbitration clause reflects a considered, bargained-for allocation of dispute resolution rights.

Pinnacle Atlantic should not incur, and QC&S should not be required to bear, the unnecessary costs, burden, and delay attendant to litigating the threshold question of arbitrability when the Treaty contains an unambiguous and fully enforceable agreement to arbitrate all disputes arising out of or relating to the Treaty. The resources of both parties and of the courts would be far better directed toward the substantive resolution of the underlying disputes in the arbitral forum that the parties selected when they entered into the Treaty.

QC&S expressly reserves all rights to seek recovery of attorneys' fees, costs, and expenses incurred in connection with any motion to compel arbitration that may be necessitated by Pinnacle Atlantic's refusal or failure to honor the arbitration clause contained in Article 22, to the extent such fees and costs are recoverable under applicable law, the ARIAS-U.S. Rules, or the terms of the Treaty.

VIII. Reservation of Rights

QC&S's invocation of Article 22 of the Treaty and this formal demand for arbitration are made expressly without waiver of any rights, claims, counterclaims, defenses, privileges, immunities, or remedies available to QC&S or QIH under the Treaty, at law, in equity, or otherwise, all of which are hereby expressly reserved.

QC&S reserves all rights to assert additional claims, counterclaims, defenses, and affirmative defenses in the arbitration proceedings as may be warranted by the facts and applicable law, including claims and defenses that may become apparent during the course of discovery and the exchange of information in the arbitration.

Nothing in this letter, nor in C&H's Response Letter of even date, shall be construed as an admission of any fact, allegation, liability, or obligation, or as a concession of any issue of fact or law. QC&S continues to deny, and hereby expressly denies, all allegations, claims, and grounds set forth in HFC's February 14, 2026 demand letter.

IX. Document Preservation

QC&S hereby demands that Pinnacle Atlantic immediately implement and enforce a comprehensive litigation hold and preserve all documents, electronically stored information ("ESI"), and communications of any kind relating to Treaty No. PA-QCS-2019-EXL-0044, including without limitation:

• All underwriting files, submissions, binders, and correspondence relating to the Treaty or to any policy ceded thereunder;

• All claims files, loss reports, reserving worksheets, and claims correspondence relating to the Meridian Docks mass tort cluster, the Veridian Financial Services E&O cluster, and any other claims ceded or potentially ceded under the Treaty;

• All actuarial analyses, reserve studies, loss development projections, IBNR calculations, and related working papers;

• All internal correspondence, memoranda, emails, instant messages, and other communications among Pinnacle Atlantic's officers, employees, and agents concerning the Treaty, the disputes described herein, or the decision to issue the HFC Demand Letter;

• All communications with Broadreach Intermediaries Inc., including but not limited to communications with Account Executive James Castellano, concerning the Treaty, the cessions at issue, premium reporting, loss notifications, and the disputes described herein;

• All billing, accounting, and financial records relating to the Treaty, including premium bordereaux, loss bordereaux, statements of account, and payment records; and

• All analyses, memoranda, presentations, board materials, and other documents prepared by or on behalf of Pinnacle Atlantic in connection with the disputes described herein or the decision to challenge the reinsurance recoverables billed by QC&S.

Pinnacle Atlantic's preservation obligations extend to all documents and ESI in the possession, custody, or control of Pinnacle Atlantic, its corporate parent Pinnacle Atlantic Group Holdings Ltd., and its officers, directors, and employees, including but not limited to Sir Edmund Haverford (Chief Executive Officer), Lorraine Metcalf (Chief Claims Officer), and Conrad Hesse (Senior Vice President, Treaty Disputes & Recoveries). QC&S expects that Pinnacle Atlantic will take immediate and effective steps to ensure that no relevant documents or ESI are destroyed, deleted, altered, or allowed to be overwritten, including the suspension of any automatic document destruction or ESI retention policies that might otherwise result in the loss of relevant materials.

Failure to comply with these preservation obligations may result in QC&S seeking appropriate relief from the arbitration panel or, if necessary, from a court of competent jurisdiction, including adverse inference instructions and sanctions for spoliation of evidence.

X. Request for Response

QC&S requests that HFC confirm on behalf of Pinnacle Atlantic, in writing, within ten (10) business days of Pinnacle Atlantic's receipt of this letter, each of the following:

(a) That Pinnacle Atlantic agrees to proceed to binding arbitration of all disputes between the parties arising under or relating to Treaty No. PA-QCS-2019-EXL-0044 in accordance with Article 22 of the Treaty and the ARIAS-U.S. Rules;

(b) The identity of Pinnacle Atlantic's party-appointed arbitrator, or, in the alternative, a firm timeline for such appointment that is consistent with the time periods prescribed by the Treaty and the ARIAS-U.S. Rules; and

(c) That Pinnacle Atlantic has implemented a comprehensive litigation hold and will preserve all documents, ESI, and communications relevant to the disputes described herein, as demanded in Section IX above.

In the event that QC&S does not receive a timely and affirmative response to each of the foregoing requests, or if Pinnacle Atlantic refuses to honor the arbitration clause contained in Article 22, QC&S will proceed to exercise all remedies available to it under the Treaty, the ARIAS-U.S. Rules, and applicable law, including without limitation the filing of a petition to compel arbitration in the Supreme Court of the State of New York, New York County, or in the United States District Court for the Southern District of New York, as appropriate.

XI. Confidentiality

This letter, together with the arbitration proceedings demanded herein, is confidential as between the parties in accordance with the confidentiality provisions of the ARIAS-U.S. Rules and the applicable provisions of the Treaty. QC&S expects that Pinnacle Atlantic and HFC will treat this letter and its contents as confidential and will not disclose the same to any third party except as may be required by law, regulation, or court order, or as may be necessary for the administration of the arbitration.

QC&S notes, however, that QIH is a publicly traded company whose securities are listed on the Nasdaq Global Select Market and that QIH may have disclosure obligations under the Securities Act of 1933, the Securities Exchange Act of 1934, and the rules and regulations of the U.S. Securities and Exchange Commission. QC&S and QIH expressly reserve the right to make such disclosures regarding this dispute and the arbitration proceedings as may be required by applicable securities laws, regulations, and listing standards, and nothing in the Treaty, the ARIAS-U.S. Rules, or this letter shall be construed to prohibit or limit such required disclosures.

XII. Contact Information and Communications

All communications regarding this matter should be directed to:

Douglas Carmichael, Esq. Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, New York 10006 Telephone: (212) 506-7814 Facsimile: (212) 506-7801

Email: dcarmichael@calderwoodharkness.com

With a copy to:

Jeffrey Park, Esq. Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, New York 10006 Telephone: (212) 506-7839 Facsimile: (212) 506-7801

Email: jpark@calderwoodharkness.com

Copies of this letter are being sent simultaneously to the individuals identified in the cc block below.

We trust that Pinnacle Atlantic will honor the bargained-for arbitration clause in the Treaty and will cooperate in the prompt constitution of the arbitration panel so that the parties' disputes may be resolved efficiently and in accordance with the terms of their agreement. We look forward to receiving HFC's response within the time frame specified above.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Douglas Carmichael Partner

Direct Dial: (212) 506-7814

Email: dcarmichael@calderwoodharkness.com

Enclosures: Response Letter to Pinnacle Atlantic's Pre-Suit Demand (dated March 18, 2026)

cc:

Rachel Sondergaard, Esq., General Counsel, Quorum Insurance Holdings Corp., 200 Constitution Plaza, Suite 3400, Hartford, CT 06103

Tobias Engström, SVP, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp., 200 Constitution Plaza, Suite 3400, Hartford, CT 06103

Francesca Morano, Esq., Calderwood & Harkness LLP

Jeffrey Park, Esq., Calderwood & Harkness LLP

CONFIDENTIAL — This letter and its contents are intended solely for the use of the addressee and the individuals identified herein. This letter may contain information that is privileged, confidential, or otherwise protected from disclosure. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this letter in error, please contact the sender immediately.

CALDERWOOD & HARKNESS LLP Attorneys at Law
One Liberty Plaza, 55th Floor New York, New York 10006
Telephone: (212) 506-7800 Facsimile: (212) 506-7801 www.calderwoodharkness.com
March 18, 2026
VIA HAND DELIVERY AND EMAIL
Nathaniel R. Calloway III, Esq. Hargrove, Fitch & Calloway LLP 51 West 52nd Street, 40th Floor New York, New York 10019
Re: Formal Demand for Arbitration Pursuant to Article 22 of Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 Between Quorum Casualty & Surety Company and Pinnacle Atlantic Reinsurance Ltd.
Dear Mr. Calloway:
I. Introduction and Identification of Counsel
I write in my capacity as a partner at Calderwood & Harkness LLP ("C&H") on behalf of our clients, Quorum Insurance Holdings Corp. ("QIH"), a Delaware corporation publicly traded on the Nasdaq Global Select Market (ticker symbol: QIHC), with its principal executive offices located at 200 Constitution Plaza, Suite 3400, Hartford, Connecticut 06103, and its principal insurance subsidiary, Quorum Casualty & Surety Company ("QC&S"), a New York-domiciled stock property and casualty insurer, NAIC Company Code No. 24891, with its principal office at 200 Constitution Plaza, Suite 3200, Hartford, Connecticut 06103.
This letter is sent in response to, and should be read in conjunction with, the pre-suit demand letter dated February 14, 2026 (the "HFC Demand Letter"), transmitted by your firm, Hargrove, Fitch & Calloway LLP ("HFC"), on behalf of Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic" or "PARL"), a Bermuda Class 4 insurer registered with the Bermuda Monetary Authority (BMA Registration No. BMA-4R-2008-0331), with its registered office at Clarendon House, 14 Church Street, Hamilton HM 11, Bermuda, and its United States office at 1285 Avenue of the Americas, 28th Floor, New York, New York 10019. Calderwood & Harkness LLP's engagement in connection with this matter is referenced under C&H Matter Number 1025-00005.
This letter constitutes a formal demand for arbitration pursuant to Article 22 of the Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 (as defined more fully below, the "Treaty") and should be read in conjunction with C&H's separate Response Letter to Pinnacle Atlantic's Pre-Suit Demand of even date, which addresses on the merits each of the four grounds raised in the HFC Demand Letter. QC&S's rights, claims, and defenses are more fully set forth therein and are incorporated herein by reference.
II. Identification of the Treaty and the Dispute
The reinsurance arrangement giving rise to this dispute is governed by the following instrument:
Treaty: Aggregate Excess-of-Loss Reinsurance Treaty No. PA-QCS-2019-EXL-0044 (the "Treaty")
Cedent: Quorum Casualty & Surety Company, a New York-domiciled stock property and casualty insurer (NAIC No. 24891)
Reinsurer: Pinnacle Atlantic Reinsurance Ltd., a Bermuda Class 4 insurer (BMA Registration No. BMA-4R-2008-0331)
Effective Date: July 1, 2019
Original Term: Five (5) years, commencing July 1, 2019 and expiring June 30, 2024, subject to automatic annual extensions unless either party provides ninety (90) days' written notice of non-renewal prior to the applicable anniversary date. The Treaty has been extended through June 30, 2026 by virtue of two successive one-year automatic extensions. Pinnacle Atlantic provided written notice of non-renewal to QC&S on October 1, 2025; accordingly, the Treaty will lapse by its terms on June 30, 2026.
Intermediary: Broadreach Intermediaries Inc. (designated under Treaty Article 9 as the intermediary broker of record)
Governing Law: The laws of the State of New York govern the Treaty (Treaty Article 16)
Covered Lines: Commercial general liability, excess and umbrella liability, and professional liability policies issued by QC&S within the scope of the Treaty's subject business definition
Retention: $120,000,000 in aggregate net incurred losses per Treaty Year
Cession Limit: $200,000,000 per Treaty Year, applying to aggregate net incurred losses in excess of the $120,000,000 retention, up to a maximum of $320,000,000 per Treaty Year
The dispute between the parties may be summarized as follows. In the HFC Demand Letter, Pinnacle Atlantic asserted four purported grounds for challenging a total of $78,400,000 in reinsurance recoverables that QC&S has billed to Pinnacle Atlantic under the Treaty for Treaty Years 2022 and 2023. Of that amount, $69,700,000 relates to Treaty Year 2022 and $8,700,000 relates to Treaty Year 2023. In addition to demanding the return of the $78,400,000 in recoverables, Pinnacle Atlantic demanded payment of $12,600,000 in claimed interest, for a total demand of $91,000,000.
The four grounds asserted by Pinnacle Atlantic in the HFC Demand Letter are as follows:
(1) Late Notice (Treaty Article 7). Pinnacle Atlantic alleges that QC&S provided untimely notice of the Meridian Docks mass tort claim cluster, comprising thirty-one (31) commercial general liability claims arising under Policy No. CGL-2020-09844, and that the alleged late notice excuses Pinnacle Atlantic's reinsurance obligations with respect to those claims.
(2) Misallocation of IBNR Reserve Development (Treaty Article 5). Pinnacle Atlantic alleges that QC&S misallocated $22,300,000 in incurred-but-not-reported ("IBNR") reserve development to the Treaty in a manner inconsistent with the loss allocation methodology prescribed by Article 5 of the Treaty.
(3) Failure to Follow the Fortunes (Treaty Article 11). Pinnacle Atlantic alleges that QC&S's settlement of the Veridian Financial Services errors and omissions ("E&O") claim cluster, totaling $34,500,000 under Professional Liability Policy No. PL-2021-15327, was not entitled to the benefit of the follow-the-fortunes doctrine codified in Article 11 of the Treaty.
(4) Ceded Earned Premium Underreporting (Treaty Article 3). Pinnacle Atlantic alleges that QC&S underreported ceded earned premiums by $6,800,000 under Article 3 of the Treaty, contending that QC&S reported $38,400,000 in ceded earned premiums whereas Pinnacle Atlantic's own calculation yields a figure of $45,200,000.
QC&S categorically denies all four grounds. QC&S maintains that the reinsurance recoverables billed for Treaty Years 2022 and 2023 were properly calculated, timely noticed, and validly ceded in full compliance with the terms of the Treaty. The cessions are proper and are fully payable by Pinnacle Atlantic. QC&S's detailed substantive response to each of the four grounds is set forth in C&H's Response Letter of even date, which is being delivered to HFC simultaneously with this demand for arbitration.
III. Invocation of Treaty Article 22 — Mandatory Arbitration
Article 22 of the Treaty provides, in relevant part, that any dispute arising out of or relating to the Treaty, including but not limited to disputes concerning the interpretation, performance, or breach thereof, shall be resolved exclusively by binding arbitration. Article 22 specifies that any such arbitration shall be conducted in accordance with the Rules of the AIDA Reinsurance and Insurance Arbitration Society — U.S. ("ARIAS-U.S."), as in effect at the time the demand for arbitration is made, and shall be heard by a three-member arbitration panel. Article 22 further provides that the seat of arbitration shall be New York, New York.
The disputes set forth in the HFC Demand Letter — concerning QC&S's purported notice obligations under Article 7, the allocation of incurred losses under Article 5, the application of the follow-the-fortunes doctrine under Article 11, and the calculation of ceded earned premiums under Article 3 — each and every one arise out of and relate directly to the Treaty. These disputes concern the interpretation and performance of specific Treaty provisions and fall squarely and unambiguously within the scope of the arbitration clause contained in Article 22.
Accordingly, QC&S hereby formally invokes Article 22 of the Treaty and demands that all disputes between QC&S and Pinnacle Atlantic arising under or relating to Treaty No. PA-QCS-2019-EXL-0044, including but not limited to the claims, allegations, and demands set forth in HFC's February 14, 2026 letter, be submitted to binding arbitration in accordance with the ARIAS-U.S. Rules and the terms and conditions of Article 22 of the Treaty. This demand is made on behalf of QC&S and, to the extent applicable, on behalf of QIH as the corporate parent of QC&S and a party in interest under the Treaty's dispute resolution framework.
IV. Response to HFC's Assertion that the Arbitration Clause Is Inapplicable
QC&S notes that the HFC Demand Letter contained the assertion — unsupported by any textual analysis or legal authority — that the arbitration clause set forth in Article 22 of the Treaty is "inapplicable" to the specific claims raised by Pinnacle Atlantic. QC&S categorically rejects this assertion, which is without merit in fact or law.
The arbitration clause in Article 22 is broadly worded. It encompasses "any dispute arising out of or relating to" the Treaty. As a matter of well-established precedent, both in the courts of the State of New York and in the federal courts, this formulation — "arising out of or relating to" — is recognized as the most expansive arbitration clause language available, and is routinely enforced to capture all disputes that have any connection to the underlying agreement. See, e.g., Claire Pryor, 58 F.3d 16, 20 (2d Cir. 1995); Oldroyd v. Elmira Sav. Bank, 134 F.3d 72, 76 (2d Cir. 1998).
Under New York law, as codified in Article 75 of the New York Civil Practice Law and Rules ("NY CPLR"), and under the Federal Arbitration Act, 9 U.S.C. §§ 1–16, there is a strong and well-recognized presumption in favor of arbitrability. This presumption is particularly robust in the reinsurance context, where sophisticated commercial parties operating in a specialized market have voluntarily agreed to submit disputes to arbitration before a panel of industry professionals. Courts in New York and throughout the United States have repeatedly emphasized that the policy favoring arbitration in the reinsurance industry is "exceptionally strong," and that doubts concerning the scope of an arbitration clause should be resolved in favor of arbitration. See, e.g., Gregory Greaves, 215 A.D.2d 299, 300 (1st Dep't 1995); Crestline Corporation, 246 F.3d 219, 226 (2d Cir. 2001).
Each of Pinnacle Atlantic's four claimed grounds directly and indisputably concerns the interpretation, application, and performance of specific Treaty articles — namely, Article 3 (premium reporting), Article 5 (loss allocation), Article 7 (notice), and Article 11 (follow the fortunes). These claims are paradigmatic disputes "arising out of or relating to" the Treaty. There is no plausible construction of Article 22 under which claims that turn entirely on the interpretation of Treaty provisions could be deemed outside the scope of an arbitration clause that by its terms covers "any dispute arising out of or relating to" the Treaty.
HFC has identified no textual basis in Article 22, nor in any other provision of the Treaty, for carving out any category of Treaty dispute from the arbitration obligation. No exclusion, limitation, or exception to the arbitration clause exists in the Treaty's text. The arbitration clause is unqualified and applies to all disputes between the parties arising out of or relating to the Treaty.
Any attempt by Pinnacle Atlantic to litigate these claims in the Supreme Court of the State of New York, in any federal court, or in any other judicial forum would be in direct derogation of the parties' bargained-for agreement to arbitrate and would contravene both the letter and the spirit of the Treaty. QC&S will vigorously oppose any such attempt.
V. Appointment of Party-Appointed Arbitrators
Pursuant to Article 22 of the Treaty and the ARIAS-U.S. Rules, each party to the arbitration is entitled to appoint one party-appointed arbitrator. The two party-appointed arbitrators shall thereafter select a neutral umpire to serve as the third member and chair of the arbitration panel.
QC&S hereby notifies Pinnacle Atlantic that QC&S intends to appoint its party-appointed arbitrator and will communicate the identity of that arbitrator to Pinnacle Atlantic and to HFC upon confirmation of the appointee's acceptance. QC&S anticipates completing this appointment within the time period prescribed by the Treaty and the ARIAS-U.S. Rules.
QC&S demands that Pinnacle Atlantic appoint its party-appointed arbitrator within the time period prescribed by Article 22 of the Treaty and the ARIAS-U.S. Rules following Pinnacle Atlantic's receipt of this demand for arbitration. In the event that Pinnacle Atlantic fails or refuses to appoint its party-appointed arbitrator within the prescribed time period, QC&S will exercise all available remedies under the ARIAS-U.S. Rules and applicable law, including the right to seek a court order directing the appointment of an arbitrator on Pinnacle Atlantic's behalf.
Upon the appointment of both party-appointed arbitrators, the two arbitrators shall select the neutral umpire in accordance with the procedures set forth in Article 22 of the Treaty and the ARIAS-U.S. Rules. In the event the two party-appointed arbitrators are unable to agree upon the selection of an umpire within the time period prescribed by the ARIAS-U.S. Rules, the umpire shall be selected through the procedures established by ARIAS-U.S., including, if necessary, the ARIAS-U.S. umpire selection process.
In accordance with the ARIAS-U.S. Rules and the longstanding custom and practice in reinsurance arbitrations, all three arbitrators — the two party-appointed arbitrators and the neutral umpire — must be current or former officers of insurance or reinsurance companies. QC&S expects Pinnacle Atlantic to comply with this requirement and will object to any proposed arbitrator who does not meet this qualification.
VI. Scope of Arbitration
QC&S demands that the arbitration encompass all claims, counterclaims, defenses, and disputes arising under or relating to Treaty No. PA-QCS-2019-EXL-0044, including without limitation:
(a) Pinnacle Atlantic's challenge to the $78,400,000 in reinsurance recoverables billed by QC&S under the Treaty for Treaty Year 2022 ($69,700,000) and Treaty Year 2023 ($8,700,000), and QC&S's defense and affirmation of those billings;
(b) Pinnacle Atlantic's demand for the return of $78,400,000 already paid, together with $12,600,000 in claimed interest thereon, totaling $91,000,000, and QC&S's defense against such demand;
(c) Pinnacle Atlantic's allegation of late notice under Treaty Article 7 with respect to the Meridian Docks mass tort claim cluster, comprising thirty-one (31) claims under Commercial General Liability Policy No. CGL-2020-09844, with aggregate net incurred losses of $41,200,000, and QC&S's defense that notice was timely and in full compliance with the Treaty;
(d) Pinnacle Atlantic's allegation of misallocation of $22,300,000 in incurred-but-not-reported reserve development under Treaty Article 5, and QC&S's defense that all reserve allocations were made in accordance with the methodology prescribed by Article 5 and consistent with sound actuarial principles;
(e) Pinnacle Atlantic's challenge under Treaty Article 11 to the Veridian Financial Services E&O cluster settlement, totaling $34,500,000 under Professional Liability Policy No. PL-2021-15327, consisting of Claim A ($14,200,000), Claim B ($12,800,000), and Claim C ($7,500,000), and QC&S's defense that the settlement was made in good faith, within the cedent's business judgment, and is entitled to the benefit of the follow-the-fortunes doctrine as codified in Article 11;
(f) Pinnacle Atlantic's allegation of ceded earned premium underreporting of $6,800,000 under Treaty Article 3, based on Pinnacle Atlantic's contention that QC&S reported ceded earned premiums of $38,400,000 whereas Pinnacle Atlantic's own calculation yields a figure of $45,200,000, and QC&S's defense that the premium reports were accurate and in compliance with Article 3;
(g) QC&S's counterclaims against Pinnacle Atlantic, including but not limited to (i) a counterclaim for declaratory judgment confirming the validity of all cessions under the Treaty for Treaty Years 2022 and 2023 and declaring that Pinnacle Atlantic is obligated to pay the full amount of the reinsurance recoverables billed by QC&S, and (ii) a counterclaim for breach of the Treaty arising from Pinnacle Atlantic's wrongful demand for disgorgement of properly ceded reinsurance recoverables and its threat of litigation in derogation of the arbitration clause; and
(h) Any and all other disputes, claims, counterclaims, or issues between the parties arising out of or relating to Treaty No. PA-QCS-2019-EXL-0044, whether now existing or hereafter arising during the pendency of the arbitration proceedings.
QC&S reserves the right to amend, supplement, or refine the scope of its claims and counterclaims as the arbitration proceedings progress and as discovery is completed, in accordance with the ARIAS-U.S. Rules and any procedural orders issued by the arbitration panel.
VII. Notice Regarding Judicial Proceedings
QC&S places Pinnacle Atlantic and HFC on notice that, should Pinnacle Atlantic or HFC file any action, complaint, petition, or other proceeding in the Supreme Court of the State of New York, New York County, Commercial Division, or in any other state or federal court of competent jurisdiction, seeking to litigate any of the disputes covered by the arbitration clause in Article 22, QC&S will promptly move to compel arbitration pursuant to NY CPLR § 7503 and/or Section 4 of the Federal Arbitration Act, 9 U.S.C. § 4, and will seek a stay of all judicial proceedings pending the completion of arbitration pursuant to NY CPLR § 7503(a) and/or Section 3 of the Federal Arbitration Act, 9 U.S.C. § 3.
QC&S is confident that any court presented with the broad, unambiguous, and enforceable arbitration clause contained in Article 22 of the Treaty will enforce the parties' agreement to arbitrate and will stay any judicial proceedings that Pinnacle Atlantic may attempt to initiate. The Treaty was negotiated and executed by sophisticated commercial parties operating in the reinsurance market, both of which were represented by experienced counsel and brokers, and the arbitration clause reflects a considered, bargained-for allocation of dispute resolution rights.
Pinnacle Atlantic should not incur, and QC&S should not be required to bear, the unnecessary costs, burden, and delay attendant to litigating the threshold question of arbitrability when the Treaty contains an unambiguous and fully enforceable agreement to arbitrate all disputes arising out of or relating to the Treaty. The resources of both parties and of the courts would be far better directed toward the substantive resolution of the underlying disputes in the arbitral forum that the parties selected when they entered into the Treaty.
QC&S expressly reserves all rights to seek recovery of attorneys' fees, costs, and expenses incurred in connection with any motion to compel arbitration that may be necessitated by Pinnacle Atlantic's refusal or failure to honor the arbitration clause contained in Article 22, to the extent such fees and costs are recoverable under applicable law, the ARIAS-U.S. Rules, or the terms of the Treaty.
VIII. Reservation of Rights
QC&S's invocation of Article 22 of the Treaty and this formal demand for arbitration are made expressly without waiver of any rights, claims, counterclaims, defenses, privileges, immunities, or remedies available to QC&S or QIH under the Treaty, at law, in equity, or otherwise, all of which are hereby expressly reserved.
QC&S reserves all rights to assert additional claims, counterclaims, defenses, and affirmative defenses in the arbitration proceedings as may be warranted by the facts and applicable law, including claims and defenses that may become apparent during the course of discovery and the exchange of information in the arbitration.
Nothing in this letter, nor in C&H's Response Letter of even date, shall be construed as an admission of any fact, allegation, liability, or obligation, or as a concession of any issue of fact or law. QC&S continues to deny, and hereby expressly denies, all allegations, claims, and grounds set forth in HFC's February 14, 2026 demand letter.
IX. Document Preservation
QC&S hereby demands that Pinnacle Atlantic immediately implement and enforce a comprehensive litigation hold and preserve all documents, electronically stored information ("ESI"), and communications of any kind relating to Treaty No. PA-QCS-2019-EXL-0044, including without limitation:
• All underwriting files, submissions, binders, and correspondence relating to the Treaty or to any policy ceded thereunder;
• All claims files, loss reports, reserving worksheets, and claims correspondence relating to the Meridian Docks mass tort cluster, the Veridian Financial Services E&O cluster, and any other claims ceded or potentially ceded under the Treaty;
• All actuarial analyses, reserve studies, loss development projections, IBNR calculations, and related working papers;
• All internal correspondence, memoranda, emails, instant messages, and other communications among Pinnacle Atlantic's officers, employees, and agents concerning the Treaty, the disputes described herein, or the decision to issue the HFC Demand Letter;
• All communications with Broadreach Intermediaries Inc., including but not limited to communications with Account Executive James Castellano, concerning the Treaty, the cessions at issue, premium reporting, loss notifications, and the disputes described herein;
• All billing, accounting, and financial records relating to the Treaty, including premium bordereaux, loss bordereaux, statements of account, and payment records; and
• All analyses, memoranda, presentations, board materials, and other documents prepared by or on behalf of Pinnacle Atlantic in connection with the disputes described herein or the decision to challenge the reinsurance recoverables billed by QC&S.
Pinnacle Atlantic's preservation obligations extend to all documents and ESI in the possession, custody, or control of Pinnacle Atlantic, its corporate parent Pinnacle Atlantic Group Holdings Ltd., and its officers, directors, and employees, including but not limited to Sir Edmund Haverford (Chief Executive Officer), Lorraine Metcalf (Chief Claims Officer), and Conrad Hesse (Senior Vice President, Treaty Disputes & Recoveries). QC&S expects that Pinnacle Atlantic will take immediate and effective steps to ensure that no relevant documents or ESI are destroyed, deleted, altered, or allowed to be overwritten, including the suspension of any automatic document destruction or ESI retention policies that might otherwise result in the loss of relevant materials.
Failure to comply with these preservation obligations may result in QC&S seeking appropriate relief from the arbitration panel or, if necessary, from a court of competent jurisdiction, including adverse inference instructions and sanctions for spoliation of evidence.
X. Request for Response
QC&S requests that HFC confirm on behalf of Pinnacle Atlantic, in writing, within ten (10) business days of Pinnacle Atlantic's receipt of this letter, each of the following:
(a) That Pinnacle Atlantic agrees to proceed to binding arbitration of all disputes between the parties arising under or relating to Treaty No. PA-QCS-2019-EXL-0044 in accordance with Article 22 of the Treaty and the ARIAS-U.S. Rules;
(b) The identity of Pinnacle Atlantic's party-appointed arbitrator, or, in the alternative, a firm timeline for such appointment that is consistent with the time periods prescribed by the Treaty and the ARIAS-U.S. Rules; and
(c) That Pinnacle Atlantic has implemented a comprehensive litigation hold and will preserve all documents, ESI, and communications relevant to the disputes described herein, as demanded in Section IX above.
In the event that QC&S does not receive a timely and affirmative response to each of the foregoing requests, or if Pinnacle Atlantic refuses to honor the arbitration clause contained in Article 22, QC&S will proceed to exercise all remedies available to it under the Treaty, the ARIAS-U.S. Rules, and applicable law, including without limitation the filing of a petition to compel arbitration in the Supreme Court of the State of New York, New York County, or in the United States District Court for the Southern District of New York, as appropriate.
XI. Confidentiality
This letter, together with the arbitration proceedings demanded herein, is confidential as between the parties in accordance with the confidentiality provisions of the ARIAS-U.S. Rules and the applicable provisions of the Treaty. QC&S expects that Pinnacle Atlantic and HFC will treat this letter and its contents as confidential and will not disclose the same to any third party except as may be required by law, regulation, or court order, or as may be necessary for the administration of the arbitration.
QC&S notes, however, that QIH is a publicly traded company whose securities are listed on the Nasdaq Global Select Market and that QIH may have disclosure obligations under the Securities Act of 1933, the Securities Exchange Act of 1934, and the rules and regulations of the U.S. Securities and Exchange Commission. QC&S and QIH expressly reserve the right to make such disclosures regarding this dispute and the arbitration proceedings as may be required by applicable securities laws, regulations, and listing standards, and nothing in the Treaty, the ARIAS-U.S. Rules, or this letter shall be construed to prohibit or limit such required disclosures.
XII. Contact Information and Communications
All communications regarding this matter should be directed to:
Douglas Carmichael, Esq. Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, New York 10006 Telephone: (212) 506-7814 Facsimile: (212) 506-7801
Email: dcarmichael@calderwoodharkness.com
With a copy to:
Jeffrey Park, Esq. Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, New York 10006 Telephone: (212) 506-7839 Facsimile: (212) 506-7801
Email: jpark@calderwoodharkness.com
Copies of this letter are being sent simultaneously to the individuals identified in the cc block below.
We trust that Pinnacle Atlantic will honor the bargained-for arbitration clause in the Treaty and will cooperate in the prompt constitution of the arbitration panel so that the parties' disputes may be resolved efficiently and in accordance with the terms of their agreement. We look forward to receiving HFC's response within the time frame specified above.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Douglas Carmichael Partner
Direct Dial: (212) 506-7814
Email: dcarmichael@calderwoodharkness.com
Enclosures: Response Letter to Pinnacle Atlantic's Pre-Suit Demand (dated March 18, 2026)
cc:
Rachel Sondergaard, Esq., General Counsel, Quorum Insurance Holdings Corp., 200 Constitution Plaza, Suite 3400, Hartford, CT 06103
Tobias Engström, SVP, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp., 200 Constitution Plaza, Suite 3400, Hartford, CT 06103
Francesca Morano, Esq., Calderwood & Harkness LLP
Jeffrey Park, Esq., Calderwood & Harkness LLP
CONFIDENTIAL — This letter and its contents are intended solely for the use of the addressee and the individuals identified herein. This letter may contain information that is privileged, confidential, or otherwise protected from disclosure. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this letter in error, please contact the sender immediately.

CALDERWOOD & HARKNESS LLP Attorneys at Law

VIA HAND DELIVERY AND EMAIL

CALDERWOOD & HARKNESS LLP

Record

Parties

Dates

Amounts