1025-00005 · Quorum Insurance Holdings · Engagement

litigation-hold-notice.docx DOCUMENT Litigation

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CALDERWOOD & HARKNESS LLP Attorneys at Law

One Liberty Plaza, 55th Floor New York, New York 10006 Telephone: (212) 506-7000 Facsimile: (212) 506-7001 www.calderwoodharkness.com

March 4, 2026

VIA HAND DELIVERY AND ENCRYPTED EMAIL

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

Re: PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION LITIGATION HOLD NOTICE Pre-Suit Demand by Pinnacle Atlantic Reinsurance Ltd. Regarding Treaty No. PA-QCS-2019-EXL-0044 Calderwood & Harkness Matter No. 1025-00005

Dear Ms. Sondergaard:

I. Purpose and Legal Obligation

Calderwood & Harkness LLP ("C&H") has been retained by Quorum Insurance Holdings Corp. ("QIH") and its wholly owned subsidiary Quorum Casualty & Surety Company ("QC&S," and together with QIH, the "Company") in connection with a pre-suit demand dated February 14, 2026, received from Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"), transmitted through Pinnacle Atlantic's counsel, Hargrove, Fitch & Calloway LLP ("HF&C"). The purpose of this letter is to advise the Company of its immediate and continuing obligation to identify, preserve, and protect all documents, electronically stored information ("ESI"), and tangible things that may be relevant to this dispute, and to set forth the steps that must be taken without delay to satisfy that obligation.

As you are aware, Pinnacle Atlantic disputes the sum of Seventy-Eight Million Four Hundred Thousand Dollars ($78,400,000) in reinsurance recoverables billed by QC&S under the aggregate excess-of-loss reinsurance treaty designated Treaty No. PA-QCS-2019-EXL-0044 (the "Treaty"). In its demand letter, Pinnacle Atlantic seeks the return of the full $78,400,000 in reinsurance recoverables paid to date, together with Twelve Million Six Hundred Thousand Dollars ($12,600,000) in accrued interest, for a total claimed amount of Ninety-One Million Dollars ($91,000,000).

Based on the content and tenor of Pinnacle Atlantic's demand, including HF&C's explicit statement that its client is "prepared to commence formal proceedings without further delay," litigation or formal arbitration proceedings are reasonably anticipated. Such proceedings could be commenced in the Supreme Court of the State of New York, New York County, Commercial Division, or, pursuant to the arbitration clause set forth in Treaty Article 12, before an ARIAS-U.S. arbitration panel constituted in accordance with the ARIAS-U.S. Rules for the Resolution of U.S. Insurance and Reinsurance Disputes. Regardless of the forum in which proceedings may ultimately be commenced, the Company's preservation obligations arise now and are fully effective as of the date of this notice.

QIH and QC&S have an immediate legal obligation to preserve all documents, ESI, and tangible things that may be relevant to this dispute or that may reasonably be expected to be requested or sought in connection with the dispute, whether in discovery, arbitration, or otherwise. This obligation arises under applicable federal and state law, including the common-law duty of preservation triggered when litigation is reasonably anticipated, and is further reinforced by the Federal Rules of Civil Procedure (including, without limitation, Rule 37(e)) and analogous provisions of the New York Civil Practice Law and Rules, to the extent applicable.

Failure to preserve relevant materials can result in severe consequences, including, but not limited to, sanctions, adverse inference instructions, monetary penalties, preclusion of evidence, and other remedial or punitive measures imposed by the court or arbitration panel. Courts have consistently held that the duty to preserve attaches at the point when litigation becomes reasonably foreseeable, and that a party's good-faith obligations require affirmative steps to ensure that relevant evidence is not lost, destroyed, or altered, whether intentionally or through the routine operation of information systems and document retention policies.

This notice supersedes all ordinary document retention and destruction policies, schedules, and procedures with respect to materials within its scope. All routine destruction, deletion, overwriting, recycling, or disposal of materials covered by this hold must cease immediately. No documents or ESI within the scope of this hold may be destroyed, deleted, modified, or discarded under any circumstances, regardless of whether such actions would otherwise be permitted under the Company's standard document retention and information governance policies.

This litigation hold will remain in effect until C&H provides express written notice that it has been modified or released. In the interim, every employee, officer, director, and agent of QIH and QC&S who receives this notice or is notified of its contents bears a personal responsibility to comply fully with its terms.

II. Scope of the Dispute

To assist in identifying the categories of materials that must be preserved, we provide the following summary of the dispute and the principal grounds asserted by Pinnacle Atlantic in its February 14, 2026 demand letter. This summary is provided solely for purposes of delineating the scope of the preservation obligation and does not constitute a concession or acknowledgment regarding the merits of any of Pinnacle Atlantic's claims.

In its demand letter, Pinnacle Atlantic, through HF&C, asserts four principal grounds for its claim that the $78,400,000 in reinsurance recoverables billed by QC&S was improperly invoiced and paid, and that it is entitled to a full refund together with interest:

1. Late Notice Under Treaty Article 7 — Meridian Docks Mass Tort Cluster. Pinnacle Atlantic contends that QC&S failed to provide timely notice under Treaty Article 7 with respect to a cluster of thirty-one (31) related commercial general liability ("CGL") bodily injury claims arising from toxic contamination at the Meridian Docks industrial waterfront redevelopment site in Newark, New Jersey (the "Meridian Docks Claims"). These claims were submitted under QC&S Policy No. CGL-2020-09844, issued to the policyholder Meridian Docks Development LLC. Pinnacle Atlantic alleges that QC&S's notice, which was transmitted on May 22, 2022, was untimely under the Treaty's notice provisions, and that Pinnacle Atlantic was thereby prejudiced and relieved of its reinsurance obligations with respect to these claims.

2. Misallocation of IBNR Reserve Development Under Treaty Article 5. Pinnacle Atlantic alleges that QC&S improperly allocated Twenty-Two Million Three Hundred Thousand Dollars ($22,300,000) in incurred-but-not-reported ("IBNR") reserve development to Treaty Year 2022 (July 1, 2022 – June 30, 2023) rather than to Treaty Year 2021 (July 1, 2021 – June 30, 2022), where such development allegedly should have been reported. Pinnacle Atlantic contends that this misallocation resulted in an inflation of the aggregate net incurred losses ceded to Pinnacle Atlantic under TY 2022 and a corresponding understatement of ceded losses under TY 2021, to Pinnacle Atlantic's detriment.

3. Challenge to Follow-the-Fortunes Doctrine Under Treaty Article 11 — Veridian Financial Services E&O Cluster Settlement. Pinnacle Atlantic challenges the application of the follow-the-fortunes doctrine under Treaty Article 11 with respect to QC&S's settlement of three related professional liability ("errors and omissions") claims against Veridian Financial Services Inc. under QC&S Policy No. PL-2021-15327 (collectively, the "Veridian Claims"). The aggregate settlement amount was Thirty-Four Million Five Hundred Thousand Dollars ($34,500,000), comprising Claim A ($14,200,000), Claim B ($12,800,000), and Claim C ($7,500,000). Pinnacle Atlantic alleges that QC&S's settlement was not the product of a good-faith, reasonable claims-handling process and that the follow-the-fortunes doctrine should not apply to compel Pinnacle Atlantic to indemnify QC&S for the ceded portion of the settlement.

4. Alleged Underreporting of Ceded Earned Premium Under Treaty Article 3. Pinnacle Atlantic alleges that QC&S underreported ceded earned premium by a total of Six Million Eight Hundred Thousand Dollars ($6,800,000) during the relevant treaty years, in violation of the premium reporting obligations set forth in Treaty Article 3. Pinnacle Atlantic contends that QC&S improperly excluded certain premium categories from the ceded earned premium calculation, thereby reducing QC&S's premium obligations under the sliding-scale premium adjustment provisions of the Treaty.

The treaty years at issue are principally TY 2022 (July 1, 2022 – June 30, 2023) and TY 2023 (July 1, 2023 – June 30, 2024). However, because Pinnacle Atlantic's IBNR allocation claim implicates the boundary between accident-year 2021 and accident-year 2022, all related materials from TY 2021 (July 1, 2021 – June 30, 2022) are also within the scope of this hold. Furthermore, to the extent that any materials from periods outside TY 2021 through TY 2023 are relevant to the interpretation or performance of the Treaty, the underlying claims, or the parties' course of dealing, such materials must also be preserved.

III. Categories of Materials to Be Preserved

The following is a detailed, but non-exhaustive, description of the categories of documents, ESI, and tangible things that must be preserved under this hold. If there is any doubt as to whether a particular document or category of information falls within the scope of this hold, the presumption must be in favor of preservation, and the question should be directed to C&H for a determination.

A. Treaty Documents

All documents constituting or relating to the Treaty and its formation, execution, performance, and interpretation must be preserved, including but not limited to:

• The fully executed aggregate excess-of-loss reinsurance treaty (Treaty No. PA-QCS-2019-EXL-0044), effective July 1, 2019, between QC&S as cedent and Pinnacle Atlantic as reinsurer.

• All endorsements, amendments, addenda, extension agreements, side letters, and renewal documentation executed or exchanged in connection with the Treaty, including, without limitation, the two successive one-year extension agreements that extended the Treaty through June 30, 2026.

• All cover notes, placement slips, binder documentation, and market placement correspondence prepared by, exchanged through, or maintained by Broadreach Intermediaries Inc. ("Broadreach") in connection with the initial placement of the Treaty and each subsequent renewal or extension.

• Pinnacle Atlantic's formal non-renewal notice dated October 1, 2025, together with any correspondence, emails, or other communications preceding, accompanying, or following that notice.

• All drafts of the Treaty, endorsements, and amendments exchanged during negotiation, including markup versions and internal commentary thereon.

B. Billing, Premium, and Financial Records

All documents and records relating to the financial aspects of the Treaty, including billing, premium reporting, and loss accounting, must be preserved:

• All reinsurance billing statements, invoices, debit notes, credit notes, and payment records for cessions under TY 2021, TY 2022, and TY 2023.

• All seven billing installments transmitted between October 15, 2022 and March 29, 2024, reflecting the $78,400,000 in paid reinsurance recoverables at issue. These installments include, based on the Company's records: the first installment of $15,000,000 on October 15, 2022, and the final installment of $3,200,000 on March 29, 2024, together with all intermediate installments and supporting documentation for each.

• All ceded earned premium calculations, workpapers, spreadsheets, and periodic reporting for TY 2021, TY 2022, and TY 2023. This includes, without limitation, all documentation relating to QC&S's reported ceded earned premium of $38,400,000 for TY 2022.

• All documentation regarding the application and interpretation of the Article 3.4 exclusion of run-off portfolio transfer premiums from the ceded premium base, including any internal analyses, memoranda, or communications regarding the proper scope of that exclusion.

• All sliding-scale premium adjustment calculations, including workpapers and supporting analyses reflecting the provisional rate of forty-two percent (42%), the minimum rate of thirty-five percent (35%), and the maximum rate of fifty-two percent (52%), as applied for each treaty year within scope.

• All premium and loss accounting records maintained by, transmitted through, or received from Broadreach Intermediaries Inc. in its capacity as intermediary under the Treaty, including monthly or quarterly bordereau, account statements, and settlement reports.

C. Claims Files — Meridian Docks Mass Tort Cluster

All documents and records relating to the Meridian Docks Claims must be preserved in their entirety:

• Complete claims files, including all sub-files, for each of the thirty-one (31) related CGL bodily injury claims submitted under Policy No. CGL-2020-09844, issued to Meridian Docks Development LLC.

• All reserve-setting documentation for the Meridian Docks Claims, including initial reserve entries dated on or around March 15, 2021, the factual and analytical bases supporting initial reserve amounts, and all reserve worksheets and reserve authority documentation.

• All subsequent reserve changes, including upward and downward reserve adjustments, reserve committee minutes reflecting review and approval of reserve changes, and all reserve development records through the present date.

• All internal memoranda, emails, instant messages, and other communications regarding the decision to establish reserves for the Meridian Docks Claims and, critically, the timing and manner of reinsurance notice to Pinnacle Atlantic. This category includes all communications among claims personnel, reinsurance personnel, actuarial staff, and management concerning the question of when and how to notify Pinnacle Atlantic of the Meridian Docks Claims.

• All documentation relating to the application of the Treaty Article 7 individual claim reporting threshold of One Million Dollars ($1,000,000) and the aggregate reserve threshold that triggered the Treaty's notice requirement, including any analysis of when those thresholds were reached.

• All correspondence, transmittals, and other communications directed to or received from Pinnacle Atlantic through Broadreach regarding the Meridian Docks Claims, including, without limitation, the formal notice of loss dated May 22, 2022 and all follow-up communications.

• All policyholder correspondence with Meridian Docks Development LLC, including coverage correspondence, reservation-of-rights letters, and claim status communications.

• All correspondence with claimants' counsel, defense counsel, and any other third parties involved in the defense or resolution of the Meridian Docks Claims, including expert reports, mediation materials, and settlement correspondence.

• All net incurred loss records reflecting the aggregate net incurred losses of $41,200,000 across all thirty-one Meridian Docks Claims.

D. Claims Files — Veridian Financial Services E&O Cluster

All documents and records relating to the Veridian Claims must be preserved in their entirety:

• Complete claims files for all three related professional liability claims under Policy No. PL-2021-15327, issued to Veridian Financial Services Inc., including: Claim A (settled for $14,200,000), Claim B (settled for $12,800,000), and Claim C (settled for $7,500,000).

• All settlement evaluation memoranda, settlement authority requests, claims committee minutes, and internal analyses leading to the aggregate settlement of $34,500,000 executed on or about September 8, 2023. This includes all documentation of the claims-handling process, the assessment of liability exposure, the evaluation of damages, and the rationale for the settlement amounts reached.

• All litigation exposure analyses, including any analyses of trial risk, damages modeling, and attorney assessments of probable outcomes, as well as all reserve reports reflecting the evolution of incurred loss estimates for the Veridian Claims.

• All documentation of the QC&S net retained amount of $26,100,000 after the application of other reinsurance recoveries, including documentation of the allocation of the settlement among applicable reinsurance treaties and excess layers.

• All correspondence with policyholder Veridian Financial Services Inc., claimants and their counsel, defense counsel retained by QC&S, and any mediators or arbitrators involved in the resolution of the Veridian Claims.

• All communications with other reinsurers (other than Pinnacle Atlantic) regarding the Veridian Claims, including any other treaties under which portions of the Veridian losses were ceded.

E. Loss Reserve and IBNR Analyses

All actuarial analyses, reserve opinions, and IBNR development records relating to the Treaty must be preserved:

• All actuarial analyses, reports, certificates, letters, and presentations prepared by Velthorn Actuarial Advisors LLC ("Velthorn"), and specifically by Dr. Stephen Tanaka, FCAS, MAAA, Principal Actuary (75 Ashbury Asset Advisors, Suite 1400, Boston, MA 02109), in connection with QC&S's treaty reserves and IBNR development for TY 2021, TY 2022, and TY 2023. This includes all draft and final versions of actuarial reports and all correspondence between QC&S and Velthorn regarding such reports.

• All IBNR reserve development calculations, loss development factor analyses, loss triangle analyses, and actuarial workpapers, whether prepared by Velthorn or internally by QC&S actuarial staff.

• All documents relating to the allocation of the $22,300,000 in IBNR reserve development as between accident-year 2021 and accident-year 2022, including any analyses, memoranda, presentations, spreadsheets, or communications discussing the basis for the allocation and the treaty-year to which the IBNR development was assigned.

• All internal QC&S actuarial analyses, reserve opinions, appointed actuary statements, and reserve committee materials for TY 2021, TY 2022, and TY 2023.

• All aggregate net incurred loss reports for the Treaty reflecting the reported aggregate net incurred losses of $104,600,000 for TY 2021, $189,700,000 for TY 2022, and $128,700,000 for TY 2023, together with all supporting documentation and workpapers.

• QC&S Schedule F filings (Schedule F — Assumed Reinsurance and Schedule F — Ceded Reinsurance, as applicable) and all statutory financial statement extracts showing the $78,400,000 reinsurance recoverable balance as of December 31, 2025, together with all prior years' Schedule F filings reflecting the Treaty.

F. Communications with Pinnacle Atlantic Reinsurance Ltd.

All communications between the Company and Pinnacle Atlantic must be preserved:

• All correspondence, emails, letters, memoranda, facsimile transmissions, and other written or electronic communications between QC&S (or QIH) and Pinnacle Atlantic Reinsurance Ltd. (or its parent, Pinnacle Atlantic Group Holdings Ltd.) from July 1, 2019 through the present date. This includes communications transmitted directly between the parties as well as communications transmitted through Broadreach or any other intermediary.

• Pinnacle Atlantic's reservation-of-rights letter dated December 12, 2025, together with all internal QC&S analyses and communications regarding that letter.

• Pinnacle Atlantic's pre-suit demand letter dated February 14, 2026, transmitted by Hargrove, Fitch & Calloway LLP through its partner Nathaniel R. Calloway III, together with all enclosures, exhibits, and attachments thereto.

• All meeting notes, call notes, telephone logs, memoranda-to-file, and other records of oral communications with Pinnacle Atlantic personnel, including but not limited to Sir Edmund Haverford (Chief Executive Officer, Pinnacle Atlantic Group Holdings Ltd.), Lorraine Metcalf (Chief Claims Officer, Pinnacle Atlantic Reinsurance Ltd.), and Conrad Hesse (Senior Vice President, Treaty Disputes & Recoveries, Pinnacle Atlantic Reinsurance Ltd.).

• All internal QC&S and QIH communications discussing, analyzing, or responding to communications from Pinnacle Atlantic.

G. Communications with Broadreach Intermediaries Inc.

All communications with the Treaty's intermediary must be preserved:

• All correspondence, emails, transmittals, memoranda, and other written or electronic communications between QC&S (or QIH) and Broadreach Intermediaries Inc. (100 Wall Street, 18th Floor, New York, NY 10005), including communications directed to or received from the account executive, James "Jamie" Castellano, and any other Broadreach personnel, from July 1, 2019 through the present date.

• All intermediary transmittals, broker market reports, market updates, and placement correspondence relating to the Treaty's original placement, renewals, and extensions.

• All documents, data, and communications transmitted between QC&S and Pinnacle Atlantic through Broadreach in its capacity as intermediary under Treaty Article 9, including all claim notifications, billing transmittals, premium reports, and account statements.

• All records of meetings, telephone calls, and other oral communications with Broadreach personnel regarding the Treaty, the disputed cessions, or the Pinnacle Atlantic dispute.

H. Internal Analyses and Decision-Making Records

All internal Company records relating to the Treaty and the dispute must be preserved:

• All internal QIH and QC&S memoranda, analyses, presentations, discussion papers, and decision memoranda relating to the Treaty, the disputed cessions, the Meridian Docks Claims, the Veridian Claims, the IBNR allocation, ceded premium reporting, or the Pinnacle Atlantic dispute generally.

• All board of directors materials, board committee materials, and committee minutes reflecting discussion of the Treaty, the disputed cessions, or the Pinnacle Atlantic dispute, including but not limited to materials prepared for and minutes of the QIH Board Audit Committee meeting held on February 24, 2026, at which the retention of outside litigation counsel was authorized.

• All communications with Harmon & Whitfield LLP (contact partner: Elaine Whitfield-Ross, Esq.; 185 Asylum Street, Suite 2600, Hartford, CT 06103) regarding the Treaty's compliance with New York Insurance Law credit-for-reinsurance requirements, including any opinions, memoranda, or advice received from Harmon & Whitfield regarding the enforceability of the Treaty or the collectibility of the reinsurance recoverable.

• All communications with Meridian Whitcomb & Co. LLP (contact: Patricia Hernandez, CPA, Audit Partner; 300 Park Avenue, 22nd Floor, New York, NY 10022) regarding the audit treatment of the $78,400,000 reinsurance recoverable on QIH's consolidated GAAP financial statements, including any analyses of collectibility, any impairment assessments, and any correspondence or workpapers relating to the financial statement presentation of the recoverable.

I. Financial and Regulatory Records

All financial and regulatory filings and records relating to the Treaty and the disputed amounts must be preserved:

• QC&S statutory financial statements, including annual statements filed with the Connecticut Insurance Department and the NAIC, for calendar years 2021 through 2025, inclusive, together with all supporting schedules, exhibits, and notes.

• QIH consolidated GAAP financial statements for fiscal years 2021 through 2025, inclusive, together with all supporting workpapers, schedules, and notes.

• All documents relating to the $78,400,000 reinsurance recoverable balance and its treatment under both GAAP and statutory accounting principles, including any collectibility analyses, credit assessments, or impairment evaluations.

• All documents relating to QIH's $750,000,000 senior secured revolving credit facility with Cartwright National Bank, N.A., as administrative agent (contact: Andrew Bao, Relationship Manager; 383 Madison Avenue, New York, NY 10179), to the extent that such documents reference, discuss, or implicate: (a) QC&S statutory surplus requirements, including the minimum statutory surplus covenant of $1,100,000,000; (b) material litigation reporting obligations, including any notice provisions requiring disclosure of threatened or pending litigation exceeding specified thresholds; or (c) the Pinnacle Atlantic dispute or the disputed reinsurance recoverable.

• Any filings with the U.S. Securities and Exchange Commission, including Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, and Current Reports on Form 8-K, that reference, discuss, or disclose the Pinnacle Atlantic dispute, the Treaty, or the $78,400,000 reinsurance recoverable, together with all drafts, comment letters, and supporting documentation.

J. Electronic Data and Systems

All ESI residing in the Company's information systems and on personal devices used for business purposes must be preserved:

• All ESI in email systems, including Hollowell Systems, Strathmore Data Systems, and any cloud-based email platforms, encompassing active mailboxes, archived messages, sent items, drafts, calendar entries, and deleted items (including items in deleted-items folders and items recoverable from server-side retention), for all identified custodians.

• All ESI in document management systems (including Tidewater Systems, Aldermere Systems, or any other system in use), claims management systems (including Severin Solutions or any successor system), actuarial databases and modeling platforms, reinsurance accounting systems, and shared network drives, to the extent such ESI falls within the scope of this hold.

• All data residing on personal devices, including Company-issued and personally owned laptops, desktop computers, mobile phones, tablets, and external storage devices (USB drives, external hard drives), used by identified custodians for business purposes relating to the Treaty or the dispute.

• All voicemail recordings, instant messages (including messages on Northgate Data Systems, Meridian Solutions, or any other collaboration platform in use), text messages (SMS and Westmark Software), and communications on any other messaging or collaboration platform used by identified custodians in connection with business relating to the Treaty or the dispute.

• All backup tapes, disaster recovery archives, system snapshots, and cloud storage repositories (including cloud backups maintained through services such as Crestline Systems, Ridgeway Industries, or similar providers) that contain or may contain materials within the scope of this hold.

IV. Identified Custodians

The following individuals are identified as custodians whose files, email accounts, personal devices, and system data must be preserved in accordance with this notice. Each custodian will receive a copy of this notice and must execute the accompanying Litigation Hold Acknowledgment Form and return it to Calderwood & Harkness LLP within five (5) business days of receipt.

QIH / QC&S Custodians

1. Martin Galbraith — Chief Executive Officer, Quorum Insurance Holdings Corp.

2. Rachel Sondergaard — General Counsel, Quorum Insurance Holdings Corp.

3. Tobias Engström — Senior Vice President, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp.

4. Diana Kessler-Hoff — Vice President, Claims & Reinsurance Recoveries, Quorum Casualty & Surety Company.

5. All QC&S claims adjusters and claims managers who handled, supervised, or had material involvement in the Meridian Docks mass tort cluster claims or the Veridian Financial Services E&O cluster claims. Diana Kessler-Hoff is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.

6. All QC&S actuarial staff members who participated in reserve setting, IBNR development analyses, or loss development factor analyses for TY 2021, TY 2022, or TY 2023 in connection with the Treaty or the underlying claims at issue. Tobias Engström is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.

7. All QC&S reinsurance accounting personnel who prepared, reviewed, approved, or transmitted treaty billings, ceded earned premium calculations, sliding-scale premium adjustment calculations, or reinsurance recoverable balance computations in connection with the Treaty for TY 2021, TY 2022, or TY 2023. Tobias Engström is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.

8. All members of the QIH Board Audit Committee who received materials relating to the Pinnacle Atlantic dispute, including but not limited to materials distributed in connection with the February 24, 2026 Board Audit Committee meeting. Rachel Sondergaard is requested to identify these individuals and provide the list to C&H within five (5) business days of the date of this notice.

Third-Party Custodians (Notification Recommended)

In addition to the internal custodians identified above, C&H recommends that QC&S promptly take the following steps with respect to third parties who are likely to possess relevant documents and ESI:

• James "Jamie" Castellano, Account Executive, Broadreach Intermediaries Inc. (100 Wall Street, 18th Floor, New York, NY 10005). C&H recommends that QC&S, through Rachel Sondergaard or her designee, promptly notify Broadreach of its obligation to preserve all records, correspondence, transmittals, and other documents relating to Treaty No. PA-QCS-2019-EXL-0044. As the intermediary through which substantially all communications and financial transmittals between QC&S and Pinnacle Atlantic were channeled, Broadreach's records are of critical importance to the Company's defense. C&H stands ready to prepare and transmit a formal preservation notice to Broadreach upon the Company's authorization.

• Dr. Stephen Tanaka, FCAS, MAAA, Principal Actuary, Velthorn Actuarial Advisors LLC (75 Ashbury Asset Advisors, Suite 1400, Boston, MA 02109). C&H recommends that QC&S notify Velthorn of the need to preserve all actuarial workpapers, reports, certificates, correspondence, data files, and communications relating to QC&S treaty reserves and IBNR development for TY 2021, TY 2022, and TY 2023. Given the centrality of the IBNR allocation issue to Pinnacle Atlantic's claims, Velthorn's files are likely to contain materials of substantial evidentiary significance. C&H will prepare and transmit separate preservation notices to Velthorn upon QC&S's authorization.

C&H will send separate, formal preservation notices to Broadreach and Velthorn promptly upon receipt of QC&S's written authorization to do so. We request that such authorization be provided at the earliest practicable date.

V. Preservation Instructions

A. Immediate Actions Required

The following steps must be taken immediately, and in no event later than two (2) business days from the date of this notice:

1. Suspend Routine Destruction. Suspend all routine document destruction, recycling, shredding, or overwriting schedules, whether applied to paper documents or ESI, as applied to all materials within the scope of this hold. This includes the suspension of any records retention or disposition schedules that would otherwise authorize the destruction of materials falling within the categories described in Section III above.

2. Notify the IT Department. Direct the Company's Information Technology department to immediately suspend all auto-deletion policies, mailbox size limitations that trigger automatic archiving or purging, and any other automated processes that could result in the deletion or alteration of email, files, or data on the accounts, devices, and systems of all identified custodians. The IT department should confirm in writing to Rachel Sondergaard that these measures have been implemented.

3. Preserve Backup Tapes and Archives. Direct the IT department to identify and preserve all backup tapes, disaster recovery archives, system snapshots, and cloud storage backups that contain or may contain data of identified custodians or materials within the scope of this hold. All scheduled tape rotation, overwriting, or degaussing must be halted until further notice from C&H.

4. Instruct All Custodians. Distribute a copy of this notice to each identified custodian and instruct them, clearly and unequivocally, that they must not delete, discard, alter, modify, conceal, or remove any documents, files, ESI, or other materials within the scope of this hold. Custodians must be informed that this obligation extends to materials on personal devices used for business purposes, including personal email accounts, text messages, and messaging applications through which business-related communications may have been conducted.

5. Collect and Segregate Physical Files. Identify and collect all physical files, paper documents, and tangible materials related to the Treaty, the Meridian Docks Claims, the Veridian Claims, the IBNR analyses, premium reporting, and the Pinnacle Atlantic dispute. These materials should be segregated in a secure, designated location with restricted access, and an inventory of the collected materials should be prepared and provided to C&H.

B. Ongoing Obligations

The litigation hold established by this notice is a continuing obligation. In addition to the immediate actions described above, the Company and all identified custodians must observe the following ongoing requirements:

• Duration. This hold remains in effect until C&H provides express written notice that the hold has been modified, narrowed, or released. No individual may unilaterally determine that the hold no longer applies to any category of materials or to his or her own files or systems.

• Newly Created Materials. Documents and ESI created after the date of this notice that fall within the scope described in Section III above must also be preserved. The preservation obligation is not limited to materials existing as of the date of this notice; it extends to all materials generated in the ordinary course of business that relate to the Treaty, the underlying claims, or the Pinnacle Atlantic dispute.

• Newly Identified Sources. If any custodian or other Company employee becomes aware of additional sources of relevant information not previously identified — including additional file repositories, personal email accounts, external storage devices, or paper files — they must promptly notify Rachel Sondergaard and C&H so that appropriate preservation measures can be implemented.

• Departing Employees. If any identified custodian departs the Company for any reason, including resignation, retirement, termination, or transfer to a position outside the scope of this hold, the Company must ensure that all of the departing custodian's files, email archives, and devices are preserved and retained prior to the custodian's departure. The Company should not permit any departing custodian to remove, delete, or destroy any materials within the scope of this hold. Rachel Sondergaard should promptly notify C&H of any anticipated or actual departure of an identified custodian.

C. Reporting to Counsel

To ensure that the litigation hold has been effectively implemented and that all preservation measures are in place, C&H requests the following:

• Rachel Sondergaard or her designee should confirm to Douglas Carmichael at C&H, in writing, within five (5) business days of the date of this letter, that: (a) the litigation hold has been implemented in accordance with this notice; (b) all identified custodians have been notified and have received copies of this notice; (c) IT preservation measures, including the suspension of auto-deletion policies and the preservation of backup tapes and archives, are in place and confirmed; and (d) physical files have been collected and segregated as described above.

• Provide to C&H a complete list of the additional custodians identified pursuant to Section IV above (i.e., the claims adjusters, claims managers, actuarial staff, reinsurance accounting personnel, and Board Audit Committee members), including each individual's full name, title, department, office location, and email address.

• Report any difficulties in implementation, preservation gaps, instances of potential non-compliance, or other issues that may affect the Company's ability to fulfill its preservation obligations. Any such issues should be reported immediately to C&H so that appropriate remedial measures can be taken without delay.

VI. Consequences of Non-Compliance

We wish to emphasize in the strongest possible terms the seriousness of the preservation obligation and the consequences that may follow from a failure to comply.

Courts and arbitration panels impose severe sanctions for the spoliation of evidence, whether the destruction or alteration of relevant materials occurs intentionally or through negligence. Such sanctions may include, without limitation:

• Adverse inference instructions directing the finder of fact to presume that destroyed or lost evidence was unfavorable to the party that failed to preserve it;

• Monetary sanctions, including awards of attorneys' fees, costs, and expenses incurred by the opposing party as a result of the spoliation;

• Preclusion orders preventing the spoliating party from introducing evidence or pursuing claims or defenses related to the destroyed materials;

• In extreme cases, dismissal of claims or entry of default judgment against the spoliating party.

The duty of preservation is not merely an institutional obligation of the Company. Each individual custodian bears a personal responsibility to comply with this hold within his or her area of control. Failure to preserve materials, whether through active destruction or passive neglect, may expose the Company to sanctions and may subject individuals to disciplinary action.

Any questions regarding whether specific materials, documents, or categories of information fall within the scope of this hold should be resolved in favor of preservation and directed to the following attorneys at C&H for a prompt determination:

• Jeffrey Park, Senior Associate — (212) 506-7244 / jpark@calderwoodharkness.com

• Yuki Nakamura, Associate — (212) 506-7312 / ynakamura@calderwoodharkness.com

Do not destroy, delete, or discard any materials about which there is any question without first obtaining guidance from C&H.

VII. Contact Information

Questions regarding this notice, including questions about its scope, the identification of custodians, the implementation of preservation measures, or any other aspect of the litigation hold, should be directed to the following members of the C&H litigation team:

Douglas Carmichael, Partner Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7150

Email: dcarmichael@calderwoodharkness.com

Jeffrey Park, Senior Associate Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7244

Email: jpark@calderwoodharkness.com

Yuki Nakamura, Associate Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7312

Email: ynakamura@calderwoodharkness.com

We appreciate the Company's prompt attention to this critical matter and stand ready to assist in any way necessary to ensure that the litigation hold is implemented fully and effectively.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Douglas Carmichael Partner

Enclosure: Litigation Hold Acknowledgment Form (template for custodian signatures)

cc: (via encrypted email)

Martin Galbraith, Chief Executive Officer, Quorum Insurance Holdings Corp. Tobias Engström, Senior Vice President, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp. Diana Kessler-Hoff, Vice President, Claims & Reinsurance Recoveries, Quorum Casualty & Surety Company Francesca Morano, Partner, Calderwood & Harkness LLP Jeffrey Park, Senior Associate, Calderwood & Harkness LLP Yuki Nakamura, Associate, Calderwood & Harkness LLP

CONFIDENTIAL — This document constitutes a privileged and confidential attorney-client communication prepared by Calderwood & Harkness LLP for the exclusive use of its clients Quorum Insurance Holdings Corp. and Quorum Casualty & Surety Company. This communication is protected by the attorney-client privilege, the work product doctrine, and all other applicable privileges and protections. Any unauthorized review, use, disclosure, or distribution is strictly prohibited. If you have received this document in error, please notify the sender immediately and destroy all copies.

CALDERWOOD & HARKNESS LLP Attorneys at Law
One Liberty Plaza, 55th Floor New York, New York 10006 Telephone: (212) 506-7000 Facsimile: (212) 506-7001 www.calderwoodharkness.com
March 4, 2026
VIA HAND DELIVERY AND ENCRYPTED EMAIL
Rachel Sondergaard, Esq. General Counsel Quorum Insurance Holdings Corp. 200 Constitution Plaza, Suite 3400 Hartford, CT 06103
Re: PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION LITIGATION HOLD NOTICE Pre-Suit Demand by Pinnacle Atlantic Reinsurance Ltd. Regarding Treaty No. PA-QCS-2019-EXL-0044 Calderwood & Harkness Matter No. 1025-00005
Dear Ms. Sondergaard:
I. Purpose and Legal Obligation
Calderwood & Harkness LLP ("C&H") has been retained by Quorum Insurance Holdings Corp. ("QIH") and its wholly owned subsidiary Quorum Casualty & Surety Company ("QC&S," and together with QIH, the "Company") in connection with a pre-suit demand dated February 14, 2026, received from Pinnacle Atlantic Reinsurance Ltd. ("Pinnacle Atlantic"), transmitted through Pinnacle Atlantic's counsel, Hargrove, Fitch & Calloway LLP ("HF&C"). The purpose of this letter is to advise the Company of its immediate and continuing obligation to identify, preserve, and protect all documents, electronically stored information ("ESI"), and tangible things that may be relevant to this dispute, and to set forth the steps that must be taken without delay to satisfy that obligation.
As you are aware, Pinnacle Atlantic disputes the sum of Seventy-Eight Million Four Hundred Thousand Dollars ($78,400,000) in reinsurance recoverables billed by QC&S under the aggregate excess-of-loss reinsurance treaty designated Treaty No. PA-QCS-2019-EXL-0044 (the "Treaty"). In its demand letter, Pinnacle Atlantic seeks the return of the full $78,400,000 in reinsurance recoverables paid to date, together with Twelve Million Six Hundred Thousand Dollars ($12,600,000) in accrued interest, for a total claimed amount of Ninety-One Million Dollars ($91,000,000).
Based on the content and tenor of Pinnacle Atlantic's demand, including HF&C's explicit statement that its client is "prepared to commence formal proceedings without further delay," litigation or formal arbitration proceedings are reasonably anticipated. Such proceedings could be commenced in the Supreme Court of the State of New York, New York County, Commercial Division, or, pursuant to the arbitration clause set forth in Treaty Article 12, before an ARIAS-U.S. arbitration panel constituted in accordance with the ARIAS-U.S. Rules for the Resolution of U.S. Insurance and Reinsurance Disputes. Regardless of the forum in which proceedings may ultimately be commenced, the Company's preservation obligations arise now and are fully effective as of the date of this notice.
QIH and QC&S have an immediate legal obligation to preserve all documents, ESI, and tangible things that may be relevant to this dispute or that may reasonably be expected to be requested or sought in connection with the dispute, whether in discovery, arbitration, or otherwise. This obligation arises under applicable federal and state law, including the common-law duty of preservation triggered when litigation is reasonably anticipated, and is further reinforced by the Federal Rules of Civil Procedure (including, without limitation, Rule 37(e)) and analogous provisions of the New York Civil Practice Law and Rules, to the extent applicable.
Failure to preserve relevant materials can result in severe consequences, including, but not limited to, sanctions, adverse inference instructions, monetary penalties, preclusion of evidence, and other remedial or punitive measures imposed by the court or arbitration panel. Courts have consistently held that the duty to preserve attaches at the point when litigation becomes reasonably foreseeable, and that a party's good-faith obligations require affirmative steps to ensure that relevant evidence is not lost, destroyed, or altered, whether intentionally or through the routine operation of information systems and document retention policies.
This notice supersedes all ordinary document retention and destruction policies, schedules, and procedures with respect to materials within its scope. All routine destruction, deletion, overwriting, recycling, or disposal of materials covered by this hold must cease immediately. No documents or ESI within the scope of this hold may be destroyed, deleted, modified, or discarded under any circumstances, regardless of whether such actions would otherwise be permitted under the Company's standard document retention and information governance policies.
This litigation hold will remain in effect until C&H provides express written notice that it has been modified or released. In the interim, every employee, officer, director, and agent of QIH and QC&S who receives this notice or is notified of its contents bears a personal responsibility to comply fully with its terms.
II. Scope of the Dispute
To assist in identifying the categories of materials that must be preserved, we provide the following summary of the dispute and the principal grounds asserted by Pinnacle Atlantic in its February 14, 2026 demand letter. This summary is provided solely for purposes of delineating the scope of the preservation obligation and does not constitute a concession or acknowledgment regarding the merits of any of Pinnacle Atlantic's claims.
In its demand letter, Pinnacle Atlantic, through HF&C, asserts four principal grounds for its claim that the $78,400,000 in reinsurance recoverables billed by QC&S was improperly invoiced and paid, and that it is entitled to a full refund together with interest:
1. Late Notice Under Treaty Article 7 — Meridian Docks Mass Tort Cluster. Pinnacle Atlantic contends that QC&S failed to provide timely notice under Treaty Article 7 with respect to a cluster of thirty-one (31) related commercial general liability ("CGL") bodily injury claims arising from toxic contamination at the Meridian Docks industrial waterfront redevelopment site in Newark, New Jersey (the "Meridian Docks Claims"). These claims were submitted under QC&S Policy No. CGL-2020-09844, issued to the policyholder Meridian Docks Development LLC. Pinnacle Atlantic alleges that QC&S's notice, which was transmitted on May 22, 2022, was untimely under the Treaty's notice provisions, and that Pinnacle Atlantic was thereby prejudiced and relieved of its reinsurance obligations with respect to these claims.
2. Misallocation of IBNR Reserve Development Under Treaty Article 5. Pinnacle Atlantic alleges that QC&S improperly allocated Twenty-Two Million Three Hundred Thousand Dollars ($22,300,000) in incurred-but-not-reported ("IBNR") reserve development to Treaty Year 2022 (July 1, 2022 – June 30, 2023) rather than to Treaty Year 2021 (July 1, 2021 – June 30, 2022), where such development allegedly should have been reported. Pinnacle Atlantic contends that this misallocation resulted in an inflation of the aggregate net incurred losses ceded to Pinnacle Atlantic under TY 2022 and a corresponding understatement of ceded losses under TY 2021, to Pinnacle Atlantic's detriment.
3. Challenge to Follow-the-Fortunes Doctrine Under Treaty Article 11 — Veridian Financial Services E&O Cluster Settlement. Pinnacle Atlantic challenges the application of the follow-the-fortunes doctrine under Treaty Article 11 with respect to QC&S's settlement of three related professional liability ("errors and omissions") claims against Veridian Financial Services Inc. under QC&S Policy No. PL-2021-15327 (collectively, the "Veridian Claims"). The aggregate settlement amount was Thirty-Four Million Five Hundred Thousand Dollars ($34,500,000), comprising Claim A ($14,200,000), Claim B ($12,800,000), and Claim C ($7,500,000). Pinnacle Atlantic alleges that QC&S's settlement was not the product of a good-faith, reasonable claims-handling process and that the follow-the-fortunes doctrine should not apply to compel Pinnacle Atlantic to indemnify QC&S for the ceded portion of the settlement.
4. Alleged Underreporting of Ceded Earned Premium Under Treaty Article 3. Pinnacle Atlantic alleges that QC&S underreported ceded earned premium by a total of Six Million Eight Hundred Thousand Dollars ($6,800,000) during the relevant treaty years, in violation of the premium reporting obligations set forth in Treaty Article 3. Pinnacle Atlantic contends that QC&S improperly excluded certain premium categories from the ceded earned premium calculation, thereby reducing QC&S's premium obligations under the sliding-scale premium adjustment provisions of the Treaty.
The treaty years at issue are principally TY 2022 (July 1, 2022 – June 30, 2023) and TY 2023 (July 1, 2023 – June 30, 2024). However, because Pinnacle Atlantic's IBNR allocation claim implicates the boundary between accident-year 2021 and accident-year 2022, all related materials from TY 2021 (July 1, 2021 – June 30, 2022) are also within the scope of this hold. Furthermore, to the extent that any materials from periods outside TY 2021 through TY 2023 are relevant to the interpretation or performance of the Treaty, the underlying claims, or the parties' course of dealing, such materials must also be preserved.
III. Categories of Materials to Be Preserved
The following is a detailed, but non-exhaustive, description of the categories of documents, ESI, and tangible things that must be preserved under this hold. If there is any doubt as to whether a particular document or category of information falls within the scope of this hold, the presumption must be in favor of preservation, and the question should be directed to C&H for a determination.
A. Treaty Documents
All documents constituting or relating to the Treaty and its formation, execution, performance, and interpretation must be preserved, including but not limited to:
• The fully executed aggregate excess-of-loss reinsurance treaty (Treaty No. PA-QCS-2019-EXL-0044), effective July 1, 2019, between QC&S as cedent and Pinnacle Atlantic as reinsurer.
• All endorsements, amendments, addenda, extension agreements, side letters, and renewal documentation executed or exchanged in connection with the Treaty, including, without limitation, the two successive one-year extension agreements that extended the Treaty through June 30, 2026.
• All cover notes, placement slips, binder documentation, and market placement correspondence prepared by, exchanged through, or maintained by Broadreach Intermediaries Inc. ("Broadreach") in connection with the initial placement of the Treaty and each subsequent renewal or extension.
• Pinnacle Atlantic's formal non-renewal notice dated October 1, 2025, together with any correspondence, emails, or other communications preceding, accompanying, or following that notice.
• All drafts of the Treaty, endorsements, and amendments exchanged during negotiation, including markup versions and internal commentary thereon.
B. Billing, Premium, and Financial Records
All documents and records relating to the financial aspects of the Treaty, including billing, premium reporting, and loss accounting, must be preserved:
• All reinsurance billing statements, invoices, debit notes, credit notes, and payment records for cessions under TY 2021, TY 2022, and TY 2023.
• All seven billing installments transmitted between October 15, 2022 and March 29, 2024, reflecting the $78,400,000 in paid reinsurance recoverables at issue. These installments include, based on the Company's records: the first installment of $15,000,000 on October 15, 2022, and the final installment of $3,200,000 on March 29, 2024, together with all intermediate installments and supporting documentation for each.
• All ceded earned premium calculations, workpapers, spreadsheets, and periodic reporting for TY 2021, TY 2022, and TY 2023. This includes, without limitation, all documentation relating to QC&S's reported ceded earned premium of $38,400,000 for TY 2022.
• All documentation regarding the application and interpretation of the Article 3.4 exclusion of run-off portfolio transfer premiums from the ceded premium base, including any internal analyses, memoranda, or communications regarding the proper scope of that exclusion.
• All sliding-scale premium adjustment calculations, including workpapers and supporting analyses reflecting the provisional rate of forty-two percent (42%), the minimum rate of thirty-five percent (35%), and the maximum rate of fifty-two percent (52%), as applied for each treaty year within scope.
• All premium and loss accounting records maintained by, transmitted through, or received from Broadreach Intermediaries Inc. in its capacity as intermediary under the Treaty, including monthly or quarterly bordereau, account statements, and settlement reports.
C. Claims Files — Meridian Docks Mass Tort Cluster
All documents and records relating to the Meridian Docks Claims must be preserved in their entirety:
• Complete claims files, including all sub-files, for each of the thirty-one (31) related CGL bodily injury claims submitted under Policy No. CGL-2020-09844, issued to Meridian Docks Development LLC.
• All reserve-setting documentation for the Meridian Docks Claims, including initial reserve entries dated on or around March 15, 2021, the factual and analytical bases supporting initial reserve amounts, and all reserve worksheets and reserve authority documentation.
• All subsequent reserve changes, including upward and downward reserve adjustments, reserve committee minutes reflecting review and approval of reserve changes, and all reserve development records through the present date.
• All internal memoranda, emails, instant messages, and other communications regarding the decision to establish reserves for the Meridian Docks Claims and, critically, the timing and manner of reinsurance notice to Pinnacle Atlantic. This category includes all communications among claims personnel, reinsurance personnel, actuarial staff, and management concerning the question of when and how to notify Pinnacle Atlantic of the Meridian Docks Claims.
• All documentation relating to the application of the Treaty Article 7 individual claim reporting threshold of One Million Dollars ($1,000,000) and the aggregate reserve threshold that triggered the Treaty's notice requirement, including any analysis of when those thresholds were reached.
• All correspondence, transmittals, and other communications directed to or received from Pinnacle Atlantic through Broadreach regarding the Meridian Docks Claims, including, without limitation, the formal notice of loss dated May 22, 2022 and all follow-up communications.
• All policyholder correspondence with Meridian Docks Development LLC, including coverage correspondence, reservation-of-rights letters, and claim status communications.
• All correspondence with claimants' counsel, defense counsel, and any other third parties involved in the defense or resolution of the Meridian Docks Claims, including expert reports, mediation materials, and settlement correspondence.
• All net incurred loss records reflecting the aggregate net incurred losses of $41,200,000 across all thirty-one Meridian Docks Claims.
D. Claims Files — Veridian Financial Services E&O Cluster
All documents and records relating to the Veridian Claims must be preserved in their entirety:
• Complete claims files for all three related professional liability claims under Policy No. PL-2021-15327, issued to Veridian Financial Services Inc., including: Claim A (settled for $14,200,000), Claim B (settled for $12,800,000), and Claim C (settled for $7,500,000).
• All settlement evaluation memoranda, settlement authority requests, claims committee minutes, and internal analyses leading to the aggregate settlement of $34,500,000 executed on or about September 8, 2023. This includes all documentation of the claims-handling process, the assessment of liability exposure, the evaluation of damages, and the rationale for the settlement amounts reached.
• All litigation exposure analyses, including any analyses of trial risk, damages modeling, and attorney assessments of probable outcomes, as well as all reserve reports reflecting the evolution of incurred loss estimates for the Veridian Claims.
• All documentation of the QC&S net retained amount of $26,100,000 after the application of other reinsurance recoveries, including documentation of the allocation of the settlement among applicable reinsurance treaties and excess layers.
• All correspondence with policyholder Veridian Financial Services Inc., claimants and their counsel, defense counsel retained by QC&S, and any mediators or arbitrators involved in the resolution of the Veridian Claims.
• All communications with other reinsurers (other than Pinnacle Atlantic) regarding the Veridian Claims, including any other treaties under which portions of the Veridian losses were ceded.
E. Loss Reserve and IBNR Analyses
All actuarial analyses, reserve opinions, and IBNR development records relating to the Treaty must be preserved:
• All actuarial analyses, reports, certificates, letters, and presentations prepared by Velthorn Actuarial Advisors LLC ("Velthorn"), and specifically by Dr. Stephen Tanaka, FCAS, MAAA, Principal Actuary (75 Ashbury Asset Advisors, Suite 1400, Boston, MA 02109), in connection with QC&S's treaty reserves and IBNR development for TY 2021, TY 2022, and TY 2023. This includes all draft and final versions of actuarial reports and all correspondence between QC&S and Velthorn regarding such reports.
• All IBNR reserve development calculations, loss development factor analyses, loss triangle analyses, and actuarial workpapers, whether prepared by Velthorn or internally by QC&S actuarial staff.
• All documents relating to the allocation of the $22,300,000 in IBNR reserve development as between accident-year 2021 and accident-year 2022, including any analyses, memoranda, presentations, spreadsheets, or communications discussing the basis for the allocation and the treaty-year to which the IBNR development was assigned.
• All internal QC&S actuarial analyses, reserve opinions, appointed actuary statements, and reserve committee materials for TY 2021, TY 2022, and TY 2023.
• All aggregate net incurred loss reports for the Treaty reflecting the reported aggregate net incurred losses of $104,600,000 for TY 2021, $189,700,000 for TY 2022, and $128,700,000 for TY 2023, together with all supporting documentation and workpapers.
• QC&S Schedule F filings (Schedule F — Assumed Reinsurance and Schedule F — Ceded Reinsurance, as applicable) and all statutory financial statement extracts showing the $78,400,000 reinsurance recoverable balance as of December 31, 2025, together with all prior years' Schedule F filings reflecting the Treaty.
F. Communications with Pinnacle Atlantic Reinsurance Ltd.
All communications between the Company and Pinnacle Atlantic must be preserved:
• All correspondence, emails, letters, memoranda, facsimile transmissions, and other written or electronic communications between QC&S (or QIH) and Pinnacle Atlantic Reinsurance Ltd. (or its parent, Pinnacle Atlantic Group Holdings Ltd.) from July 1, 2019 through the present date. This includes communications transmitted directly between the parties as well as communications transmitted through Broadreach or any other intermediary.
• Pinnacle Atlantic's reservation-of-rights letter dated December 12, 2025, together with all internal QC&S analyses and communications regarding that letter.
• Pinnacle Atlantic's pre-suit demand letter dated February 14, 2026, transmitted by Hargrove, Fitch & Calloway LLP through its partner Nathaniel R. Calloway III, together with all enclosures, exhibits, and attachments thereto.
• All meeting notes, call notes, telephone logs, memoranda-to-file, and other records of oral communications with Pinnacle Atlantic personnel, including but not limited to Sir Edmund Haverford (Chief Executive Officer, Pinnacle Atlantic Group Holdings Ltd.), Lorraine Metcalf (Chief Claims Officer, Pinnacle Atlantic Reinsurance Ltd.), and Conrad Hesse (Senior Vice President, Treaty Disputes & Recoveries, Pinnacle Atlantic Reinsurance Ltd.).
• All internal QC&S and QIH communications discussing, analyzing, or responding to communications from Pinnacle Atlantic.
G. Communications with Broadreach Intermediaries Inc.
All communications with the Treaty's intermediary must be preserved:
• All correspondence, emails, transmittals, memoranda, and other written or electronic communications between QC&S (or QIH) and Broadreach Intermediaries Inc. (100 Wall Street, 18th Floor, New York, NY 10005), including communications directed to or received from the account executive, James "Jamie" Castellano, and any other Broadreach personnel, from July 1, 2019 through the present date.
• All intermediary transmittals, broker market reports, market updates, and placement correspondence relating to the Treaty's original placement, renewals, and extensions.
• All documents, data, and communications transmitted between QC&S and Pinnacle Atlantic through Broadreach in its capacity as intermediary under Treaty Article 9, including all claim notifications, billing transmittals, premium reports, and account statements.
• All records of meetings, telephone calls, and other oral communications with Broadreach personnel regarding the Treaty, the disputed cessions, or the Pinnacle Atlantic dispute.
H. Internal Analyses and Decision-Making Records
All internal Company records relating to the Treaty and the dispute must be preserved:
• All internal QIH and QC&S memoranda, analyses, presentations, discussion papers, and decision memoranda relating to the Treaty, the disputed cessions, the Meridian Docks Claims, the Veridian Claims, the IBNR allocation, ceded premium reporting, or the Pinnacle Atlantic dispute generally.
• All board of directors materials, board committee materials, and committee minutes reflecting discussion of the Treaty, the disputed cessions, or the Pinnacle Atlantic dispute, including but not limited to materials prepared for and minutes of the QIH Board Audit Committee meeting held on February 24, 2026, at which the retention of outside litigation counsel was authorized.
• All communications with Harmon & Whitfield LLP (contact partner: Elaine Whitfield-Ross, Esq.; 185 Asylum Street, Suite 2600, Hartford, CT 06103) regarding the Treaty's compliance with New York Insurance Law credit-for-reinsurance requirements, including any opinions, memoranda, or advice received from Harmon & Whitfield regarding the enforceability of the Treaty or the collectibility of the reinsurance recoverable.
• All communications with Meridian Whitcomb & Co. LLP (contact: Patricia Hernandez, CPA, Audit Partner; 300 Park Avenue, 22nd Floor, New York, NY 10022) regarding the audit treatment of the $78,400,000 reinsurance recoverable on QIH's consolidated GAAP financial statements, including any analyses of collectibility, any impairment assessments, and any correspondence or workpapers relating to the financial statement presentation of the recoverable.
I. Financial and Regulatory Records
All financial and regulatory filings and records relating to the Treaty and the disputed amounts must be preserved:
• QC&S statutory financial statements, including annual statements filed with the Connecticut Insurance Department and the NAIC, for calendar years 2021 through 2025, inclusive, together with all supporting schedules, exhibits, and notes.
• QIH consolidated GAAP financial statements for fiscal years 2021 through 2025, inclusive, together with all supporting workpapers, schedules, and notes.
• All documents relating to the $78,400,000 reinsurance recoverable balance and its treatment under both GAAP and statutory accounting principles, including any collectibility analyses, credit assessments, or impairment evaluations.
• All documents relating to QIH's $750,000,000 senior secured revolving credit facility with Cartwright National Bank, N.A., as administrative agent (contact: Andrew Bao, Relationship Manager; 383 Madison Avenue, New York, NY 10179), to the extent that such documents reference, discuss, or implicate: (a) QC&S statutory surplus requirements, including the minimum statutory surplus covenant of $1,100,000,000; (b) material litigation reporting obligations, including any notice provisions requiring disclosure of threatened or pending litigation exceeding specified thresholds; or (c) the Pinnacle Atlantic dispute or the disputed reinsurance recoverable.
• Any filings with the U.S. Securities and Exchange Commission, including Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, and Current Reports on Form 8-K, that reference, discuss, or disclose the Pinnacle Atlantic dispute, the Treaty, or the $78,400,000 reinsurance recoverable, together with all drafts, comment letters, and supporting documentation.
J. Electronic Data and Systems
All ESI residing in the Company's information systems and on personal devices used for business purposes must be preserved:
• All ESI in email systems, including Hollowell Systems, Strathmore Data Systems, and any cloud-based email platforms, encompassing active mailboxes, archived messages, sent items, drafts, calendar entries, and deleted items (including items in deleted-items folders and items recoverable from server-side retention), for all identified custodians.
• All ESI in document management systems (including Tidewater Systems, Aldermere Systems, or any other system in use), claims management systems (including Severin Solutions or any successor system), actuarial databases and modeling platforms, reinsurance accounting systems, and shared network drives, to the extent such ESI falls within the scope of this hold.
• All data residing on personal devices, including Company-issued and personally owned laptops, desktop computers, mobile phones, tablets, and external storage devices (USB drives, external hard drives), used by identified custodians for business purposes relating to the Treaty or the dispute.
• All voicemail recordings, instant messages (including messages on Northgate Data Systems, Meridian Solutions, or any other collaboration platform in use), text messages (SMS and Westmark Software), and communications on any other messaging or collaboration platform used by identified custodians in connection with business relating to the Treaty or the dispute.
• All backup tapes, disaster recovery archives, system snapshots, and cloud storage repositories (including cloud backups maintained through services such as Crestline Systems, Ridgeway Industries, or similar providers) that contain or may contain materials within the scope of this hold.
IV. Identified Custodians
The following individuals are identified as custodians whose files, email accounts, personal devices, and system data must be preserved in accordance with this notice. Each custodian will receive a copy of this notice and must execute the accompanying Litigation Hold Acknowledgment Form and return it to Calderwood & Harkness LLP within five (5) business days of receipt.
QIH / QC&S Custodians
1. Martin Galbraith — Chief Executive Officer, Quorum Insurance Holdings Corp.
2. Rachel Sondergaard — General Counsel, Quorum Insurance Holdings Corp.
3. Tobias Engström — Senior Vice President, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp.
4. Diana Kessler-Hoff — Vice President, Claims & Reinsurance Recoveries, Quorum Casualty & Surety Company.
5. All QC&S claims adjusters and claims managers who handled, supervised, or had material involvement in the Meridian Docks mass tort cluster claims or the Veridian Financial Services E&O cluster claims. Diana Kessler-Hoff is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.
6. All QC&S actuarial staff members who participated in reserve setting, IBNR development analyses, or loss development factor analyses for TY 2021, TY 2022, or TY 2023 in connection with the Treaty or the underlying claims at issue. Tobias Engström is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.
7. All QC&S reinsurance accounting personnel who prepared, reviewed, approved, or transmitted treaty billings, ceded earned premium calculations, sliding-scale premium adjustment calculations, or reinsurance recoverable balance computations in connection with the Treaty for TY 2021, TY 2022, or TY 2023. Tobias Engström is requested to identify these individuals by name, title, and department and provide the list to Rachel Sondergaard and C&H within three (3) business days of the date of this notice.
8. All members of the QIH Board Audit Committee who received materials relating to the Pinnacle Atlantic dispute, including but not limited to materials distributed in connection with the February 24, 2026 Board Audit Committee meeting. Rachel Sondergaard is requested to identify these individuals and provide the list to C&H within five (5) business days of the date of this notice.
Third-Party Custodians (Notification Recommended)
In addition to the internal custodians identified above, C&H recommends that QC&S promptly take the following steps with respect to third parties who are likely to possess relevant documents and ESI:
• James "Jamie" Castellano, Account Executive, Broadreach Intermediaries Inc. (100 Wall Street, 18th Floor, New York, NY 10005). C&H recommends that QC&S, through Rachel Sondergaard or her designee, promptly notify Broadreach of its obligation to preserve all records, correspondence, transmittals, and other documents relating to Treaty No. PA-QCS-2019-EXL-0044. As the intermediary through which substantially all communications and financial transmittals between QC&S and Pinnacle Atlantic were channeled, Broadreach's records are of critical importance to the Company's defense. C&H stands ready to prepare and transmit a formal preservation notice to Broadreach upon the Company's authorization.
• Dr. Stephen Tanaka, FCAS, MAAA, Principal Actuary, Velthorn Actuarial Advisors LLC (75 Ashbury Asset Advisors, Suite 1400, Boston, MA 02109). C&H recommends that QC&S notify Velthorn of the need to preserve all actuarial workpapers, reports, certificates, correspondence, data files, and communications relating to QC&S treaty reserves and IBNR development for TY 2021, TY 2022, and TY 2023. Given the centrality of the IBNR allocation issue to Pinnacle Atlantic's claims, Velthorn's files are likely to contain materials of substantial evidentiary significance. C&H will prepare and transmit separate preservation notices to Velthorn upon QC&S's authorization.
C&H will send separate, formal preservation notices to Broadreach and Velthorn promptly upon receipt of QC&S's written authorization to do so. We request that such authorization be provided at the earliest practicable date.
V. Preservation Instructions
A. Immediate Actions Required
The following steps must be taken immediately, and in no event later than two (2) business days from the date of this notice:
1. Suspend Routine Destruction. Suspend all routine document destruction, recycling, shredding, or overwriting schedules, whether applied to paper documents or ESI, as applied to all materials within the scope of this hold. This includes the suspension of any records retention or disposition schedules that would otherwise authorize the destruction of materials falling within the categories described in Section III above.
2. Notify the IT Department. Direct the Company's Information Technology department to immediately suspend all auto-deletion policies, mailbox size limitations that trigger automatic archiving or purging, and any other automated processes that could result in the deletion or alteration of email, files, or data on the accounts, devices, and systems of all identified custodians. The IT department should confirm in writing to Rachel Sondergaard that these measures have been implemented.
3. Preserve Backup Tapes and Archives. Direct the IT department to identify and preserve all backup tapes, disaster recovery archives, system snapshots, and cloud storage backups that contain or may contain data of identified custodians or materials within the scope of this hold. All scheduled tape rotation, overwriting, or degaussing must be halted until further notice from C&H.
4. Instruct All Custodians. Distribute a copy of this notice to each identified custodian and instruct them, clearly and unequivocally, that they must not delete, discard, alter, modify, conceal, or remove any documents, files, ESI, or other materials within the scope of this hold. Custodians must be informed that this obligation extends to materials on personal devices used for business purposes, including personal email accounts, text messages, and messaging applications through which business-related communications may have been conducted.
5. Collect and Segregate Physical Files. Identify and collect all physical files, paper documents, and tangible materials related to the Treaty, the Meridian Docks Claims, the Veridian Claims, the IBNR analyses, premium reporting, and the Pinnacle Atlantic dispute. These materials should be segregated in a secure, designated location with restricted access, and an inventory of the collected materials should be prepared and provided to C&H.
B. Ongoing Obligations
The litigation hold established by this notice is a continuing obligation. In addition to the immediate actions described above, the Company and all identified custodians must observe the following ongoing requirements:
• Duration. This hold remains in effect until C&H provides express written notice that the hold has been modified, narrowed, or released. No individual may unilaterally determine that the hold no longer applies to any category of materials or to his or her own files or systems.
• Newly Created Materials. Documents and ESI created after the date of this notice that fall within the scope described in Section III above must also be preserved. The preservation obligation is not limited to materials existing as of the date of this notice; it extends to all materials generated in the ordinary course of business that relate to the Treaty, the underlying claims, or the Pinnacle Atlantic dispute.
• Newly Identified Sources. If any custodian or other Company employee becomes aware of additional sources of relevant information not previously identified — including additional file repositories, personal email accounts, external storage devices, or paper files — they must promptly notify Rachel Sondergaard and C&H so that appropriate preservation measures can be implemented.
• Departing Employees. If any identified custodian departs the Company for any reason, including resignation, retirement, termination, or transfer to a position outside the scope of this hold, the Company must ensure that all of the departing custodian's files, email archives, and devices are preserved and retained prior to the custodian's departure. The Company should not permit any departing custodian to remove, delete, or destroy any materials within the scope of this hold. Rachel Sondergaard should promptly notify C&H of any anticipated or actual departure of an identified custodian.
C. Reporting to Counsel
To ensure that the litigation hold has been effectively implemented and that all preservation measures are in place, C&H requests the following:
• Rachel Sondergaard or her designee should confirm to Douglas Carmichael at C&H, in writing, within five (5) business days of the date of this letter, that: (a) the litigation hold has been implemented in accordance with this notice; (b) all identified custodians have been notified and have received copies of this notice; (c) IT preservation measures, including the suspension of auto-deletion policies and the preservation of backup tapes and archives, are in place and confirmed; and (d) physical files have been collected and segregated as described above.
• Provide to C&H a complete list of the additional custodians identified pursuant to Section IV above (i.e., the claims adjusters, claims managers, actuarial staff, reinsurance accounting personnel, and Board Audit Committee members), including each individual's full name, title, department, office location, and email address.
• Report any difficulties in implementation, preservation gaps, instances of potential non-compliance, or other issues that may affect the Company's ability to fulfill its preservation obligations. Any such issues should be reported immediately to C&H so that appropriate remedial measures can be taken without delay.
VI. Consequences of Non-Compliance
We wish to emphasize in the strongest possible terms the seriousness of the preservation obligation and the consequences that may follow from a failure to comply.
Courts and arbitration panels impose severe sanctions for the spoliation of evidence, whether the destruction or alteration of relevant materials occurs intentionally or through negligence. Such sanctions may include, without limitation:
• Adverse inference instructions directing the finder of fact to presume that destroyed or lost evidence was unfavorable to the party that failed to preserve it;
• Monetary sanctions, including awards of attorneys' fees, costs, and expenses incurred by the opposing party as a result of the spoliation;
• Preclusion orders preventing the spoliating party from introducing evidence or pursuing claims or defenses related to the destroyed materials;
• In extreme cases, dismissal of claims or entry of default judgment against the spoliating party.
The duty of preservation is not merely an institutional obligation of the Company. Each individual custodian bears a personal responsibility to comply with this hold within his or her area of control. Failure to preserve materials, whether through active destruction or passive neglect, may expose the Company to sanctions and may subject individuals to disciplinary action.
Any questions regarding whether specific materials, documents, or categories of information fall within the scope of this hold should be resolved in favor of preservation and directed to the following attorneys at C&H for a prompt determination:
• Jeffrey Park, Senior Associate — (212) 506-7244 / jpark@calderwoodharkness.com
• Yuki Nakamura, Associate — (212) 506-7312 / ynakamura@calderwoodharkness.com
Do not destroy, delete, or discard any materials about which there is any question without first obtaining guidance from C&H.
VII. Contact Information
Questions regarding this notice, including questions about its scope, the identification of custodians, the implementation of preservation measures, or any other aspect of the litigation hold, should be directed to the following members of the C&H litigation team:
Douglas Carmichael, Partner Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7150
Email: dcarmichael@calderwoodharkness.com
Jeffrey Park, Senior Associate Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7244
Email: jpark@calderwoodharkness.com
Yuki Nakamura, Associate Calderwood & Harkness LLP One Liberty Plaza, 55th Floor New York, NY 10006 Telephone: (212) 506-7312
Email: ynakamura@calderwoodharkness.com
We appreciate the Company's prompt attention to this critical matter and stand ready to assist in any way necessary to ensure that the litigation hold is implemented fully and effectively.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Douglas Carmichael Partner
Enclosure: Litigation Hold Acknowledgment Form (template for custodian signatures)
cc: (via encrypted email)
Martin Galbraith, Chief Executive Officer, Quorum Insurance Holdings Corp. Tobias Engström, Senior Vice President, Reinsurance & Capital Markets, Quorum Insurance Holdings Corp. Diana Kessler-Hoff, Vice President, Claims & Reinsurance Recoveries, Quorum Casualty & Surety Company Francesca Morano, Partner, Calderwood & Harkness LLP Jeffrey Park, Senior Associate, Calderwood & Harkness LLP Yuki Nakamura, Associate, Calderwood & Harkness LLP
CONFIDENTIAL — This document constitutes a privileged and confidential attorney-client communication prepared by Calderwood & Harkness LLP for the exclusive use of its clients Quorum Insurance Holdings Corp. and Quorum Casualty & Surety Company. This communication is protected by the attorney-client privilege, the work product doctrine, and all other applicable privileges and protections. Any unauthorized review, use, disclosure, or distribution is strictly prohibited. If you have received this document in error, please notify the sender immediately and destroy all copies.

CALDERWOOD & HARKNESS LLP Attorneys at Law

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