CALDERWOOD & HARKNESS LLP Attorneys at Law
801 Brickell Avenue, Suite 2800 Miami, Florida 33131
Telephone: (305) 814-7200
Francesca Morano Partner Direct Dial: (305) 814-7238 fmorano@calderwoodharkness.com
April 18, 2023
VIA CERTIFIED MAIL (RETURN RECEIPT REQUESTED) AND EMAIL
Atlantic Omnivrel Insurance Company Claims Department / Notice of Claim Professional Liability Division 275 Asylum Street, Suite 2400 Hartford, CT 06103
Attention: Claims Manager, Professional Liability Division
Re: Notice of Claim and Tender of Defense — Managers' Liability / Wrongful Acts Policy No. AFML-2022-08745 Insured: Pellegrino Capital Group LLC Claim: JAMS Ref. No. 1440032871 — Meridian Shores Hospitality LLC v. Pellegrino Capital Group LLC Valuation Date: December 31, 2022
Dear Claims Manager:
I. Purpose and Introduction
This firm represents Pellegrino Capital Group LLC ("PCG"), a Florida limited liability company (EIN 83-2147605), with its principal place of business at 1900 Bayshore Boulevard, Suite 1400, Tampa, Florida 33606. PCG is the named insured under that certain Managers' Liability / Wrongful Acts Policy issued by Atlantic Omnivrel Insurance Company, bearing Policy No. AFML-2022-08745 (the "Policy"), with per-occurrence limits of Ten Million Dollars ($10,000,000) and aggregate limits of Ten Million Dollars ($10,000,000).
We write to formally notify Atlantic Omnivrel Insurance Company ("Atlantic Fidelity" or the "Insurer") of a claim against PCG and to tender the defense and indemnity of such claim to Atlantic Fidelity under the terms and conditions of the Policy. The claim arises from a Demand for Arbitration filed by Meridian Shores Hospitality LLC ("MSH") against PCG before JAMS, assigned Case No. 1440032871, in connection with a dispute over PCG's exercise of a contractual call option and its management of a joint venture entity. This letter constitutes formal notice of that claim and a request for full coverage, including the payment of all defense costs, as set forth more fully below.
Calderwood & Harkness LLP was engaged by PCG to represent it in the underlying arbitration and related insurance matters pursuant to an engagement letter dated March 22, 2023 (Calderwood & Harkness Matter No. 1027-00003). I serve as the Responsible Partner on this matter, and my partner, Samuel Eklund, serves as the Billing Partner. The nature of the claims at issue, the factual circumstances giving rise to them, and the basis for coverage under the Policy are described in detail in the sections that follow.
II. Description of the Insured and Its Role
PCG is a Florida-based family office that manages and oversees a diversified portfolio of investments with approximately $1.2 billion in assets under management. PCG's investment strategies span the hospitality, multifamily residential, and alternative-asset sectors. Dominic R. Pellegrino serves as Managing Member of PCG and controls one hundred percent (100%) of PCG's membership interests.
Among its portfolio of investments, PCG serves as the sole Manager and sixty-five percent (65%) interest holder of Palmetto Grand Ventures LLC ("PGV"), a Florida limited liability company (EIN 82-5063921; Florida Division of Corporations Filing No. L17000124583). PGV was formed on June 15, 2017, as a joint venture between PCG and MSH for the specific purpose of acquiring, owning, and operating The Palmetto Grand Resort & Spa (the "Hotel"), a 312-room luxury beachfront hotel located at 650 Mandalay Avenue, Clearwater Beach, Florida 33767. The Hotel is operated under a franchise agreement with Aurelian Hotels & Resorts Inc.
The ownership structure of PGV is as follows: PCG holds a sixty-five percent (65%) membership interest, and MSH holds a thirty-five percent (35%) membership interest. Pursuant to the Amended and Restated Operating Agreement of Palmetto Grand Ventures LLC, effective as of June 15, 2017 (the "Operating Agreement" or "OA"), PCG was designated as the sole Manager of PGV, vested with broad discretionary authority over the day-to-day operations of the joint venture, including but not limited to capital expenditure planning, debt management, property maintenance and improvement, asset management, budgeting, and overall strategic direction. In its capacity as Manager, PCG has overseen all significant business decisions for PGV since the joint venture's formation.
III. Description of the Underlying Claim
A. Background — The Call-Option Exercise
Section 12.4 of the Operating Agreement grants PCG the right, exercisable at any time after the fifth anniversary of the Effective Date of the Operating Agreement (i.e., after June 15, 2022), to purchase all of MSH's thirty-five percent (35%) membership interest in PGV at "Fair Market Value" as determined by an independent MAI-certified appraiser selected by PCG, subject to certain procedural requirements set forth in Section 12.4 and related subsections of the Operating Agreement.
On January 9, 2023, PCG exercised the call option by delivering written notice to MSH in accordance with Section 12.4 of the Operating Agreement. The call-option exercise notice was transmitted to MSH's designated address by both certified mail and electronic mail.
Pursuant to its rights under the Operating Agreement, PCG retained Whitfield Realty Advisors LLC to perform an independent appraisal of PGV's real property and operating assets. The appraisal was conducted by Gerald K. Whitfield, MAI, and was completed on February 10, 2023. The Whitfield appraisal concluded that the Fair Market Value of one hundred percent (100%) of PGV's real property and operating assets was One Hundred Eighteen Million Dollars ($118,000,000) as of December 31, 2022. The appraiser employed a blended methodology consisting of the income capitalization approach (utilizing a 9.5% capitalization rate and a discounted cash flow analysis at a 10.75% discount rate) and the sales comparison approach, weighted at forty percent (40%) and sixty percent (60%), respectively. These methodologies are consistent with prevailing industry standards for full-service luxury resort hotel properties in the Clearwater Beach and Tampa Bay hospitality markets.
Based on the Whitfield appraisal, PCG calculated the buyout price for MSH's interest as follows:
On March 1, 2023, PCG tendered the sum of Forty-One Million Three Hundred Thousand Dollars ($41,300,000) to MSH as the full and complete purchase price for MSH's thirty-five percent (35%) membership interest in PGV, inclusive of all accrued preferred returns.
On March 10, 2023, MSH rejected the tender in its entirety.
B. MSH's Demand for Arbitration
On March 20, 2023, MSH filed a Demand for Arbitration with JAMS at its Jacksonville, Florida Resolution Center (located at 1 Independent Drive, Suite 1600, Jacksonville, FL 32202), which was assigned Case No. 1440032871. The arbitration was initiated pursuant to Section 15.2 of the Operating Agreement, which provides for binding arbitration of all disputes arising out of or relating to the Operating Agreement, to be administered by JAMS under its Comprehensive Arbitration Rules and Procedures.
MSH is represented in the arbitration by the law firm of Hargrove, Dunlap & Castillo LLP, with offices at 1395 Brickell Avenue, Suite 3100, Miami, Florida 33131. MSH's legal team includes Victoria Castillo, Partner, and Ryan Matsuda, Senior Associate.
On April 28, 2023, the Honorable Margaret Liu Chen (Ret.) was appointed as the sole arbitrator to preside over the matter.
C. MSH's Claims Against PCG
In connection with its Demand for Arbitration, MSH retained Beacon Valuation Group Inc. to prepare a competing appraisal of PGV's assets. The Beacon appraisal was conducted by Dr. Priya Ramanathan, CFA, ASA, and completed on April 14, 2023. The Beacon appraisal concluded that the Fair Market Value of one hundred percent (100%) of PGV's assets was One Hundred Fifty-One Million Five Hundred Thousand Dollars ($151,500,000) — a divergence of approximately 28.4% above the Whitfield appraisal's conclusion of $118,000,000. This divergence exceeds the ten percent (10%) threshold set forth in Section 12.4(c) of the Operating Agreement, which provides for the appointment of a neutral third-party appraiser when the parties' respective appraisals differ by more than ten percent (10%).
Based on the Beacon appraisal, MSH demands a total buyout price of Seventy Million Dollars ($70,000,000), calculated as follows:
The resulting gap between PCG's offered buyout price of $41,300,000 and MSH's demand of $70,000,000 is Twenty-Eight Million Seven Hundred Thousand Dollars ($28,700,000).
MSH asserts three principal claims against PCG:
1. Bad-Faith Valuation (OA Section 12.7). MSH alleges that PCG exercised the call option "in bad faith or with the intent to materially understate Fair Market Value" within the meaning of Section 12.7 of the Operating Agreement. Section 12.7 provides that, in the event the Manager is found to have acted in bad faith in connection with the valuation process, the Manager may be required to pay a penalty of up to twenty-five percent (25%) of the determined Fair Market Value of the redeemed interest. Notwithstanding the twenty-five percent (25%) cap articulated in Section 12.7, MSH seeks what it characterizes as a "punitive adjustment" of Sixteen Million Nine Hundred Seventy-Five Thousand Dollars ($16,975,000), which represents approximately thirty-two percent (32%) of the combined equity share and preferred return MSH claims it is owed. MSH contends that PCG deliberately selected an appraiser predisposed to understating value, manipulated the financial records provided to the appraiser, and timed the exercise of the call option to coincide with a period that MSH alleges was an artificially depressed valuation environment for the Hotel.
2. Breach of Capital Expenditure Obligations (OA Section 8.3). MSH further alleges that PCG, in its capacity as sole Manager of PGV, breached its obligations under Section 8.3 of the Operating Agreement by failing to maintain the Hotel property in first-class condition. Section 8.3 requires the Manager to cause PGV to maintain the property "in a condition consistent with a first-class full-service luxury resort hotel in the Tampa Bay market." MSH contends that PCG's failure to undertake necessary capital improvements resulted in approximately Eight Million Two Hundred Thousand Dollars ($8,200,000) in deferred maintenance that MSH's appraiser, Dr. Ramanathan, incorporated as an upward valuation adjustment in the Beacon appraisal — on the theory that the Hotel's value was artificially depressed by the deferred maintenance at the time of the Whitfield appraisal and that the property's true Fair Market Value should reflect the cost to cure such deferred items.
3. Breach of Fiduciary Duty. MSH contends that PCG breached its duties of good faith and fair dealing owed to MSH as a minority member of PGV. Specifically, MSH alleges that PCG's course of conduct — including the alleged undervaluation of the Hotel, the timing of the call-option exercise, and the failure to maintain the property — constituted a pattern of self-dealing and oppression of MSH's minority interest, designed to enable PCG to acquire MSH's interest at a below-market price.
D. PCG's Response
On April 5, 2023, PCG filed its Response and Counterclaim in the JAMS arbitration proceeding. In its Response, PCG denied all of MSH's allegations in their entirety. PCG maintains that the Whitfield appraisal was conducted by a qualified, independent, MAI-certified appraiser employing market-standard methodologies fully consistent with the Uniform Standards of Professional Appraisal Practice (USPAP) and that the call option was exercised in strict compliance with the terms of the Operating Agreement and in complete good faith. In its Counterclaim, PCG seeks declaratory relief establishing that the buyout price of Forty-One Million Three Hundred Thousand Dollars ($41,300,000) constitutes the proper Fair Market Value of MSH's interest under OA Section 12.4, and that PCG is entitled to complete MSH's redemption at such price.
PCG vigorously contests each of MSH's claims. PCG maintains that its capital expenditure decisions were reasonable, well within the Manager's discretionary authority under the Operating Agreement, and consistent with the Hotel's approved annual budgets — each of which was presented to MSH's representative on PGV's advisory committee. PCG further denies that any fiduciary duty was breached, and notes that the Operating Agreement expressly limits the scope of fiduciary obligations among the members consistent with the Florida Revised Uniform Limited Liability Company Act, Fla. Stat. § 605.04091.
IV. Policy Coverage and Basis for Tender
PCG respectfully submits that the claims asserted by MSH in the underlying arbitration fall squarely within the scope of coverage afforded by the Policy, and Atlantic Fidelity is therefore obligated to provide both a defense and indemnity to PCG in connection with this matter.
The claims asserted against PCG arise exclusively from PCG's acts, errors, and omissions in its capacity as Manager of PGV. Specifically, the claims challenge PCG's exercise of the contractual call option under the Operating Agreement, PCG's selection of the appraiser retained to determine Fair Market Value, PCG's capital expenditure decisions with respect to the Hotel property, and PCG's alleged intent regarding the valuation process. Each of these activities constitutes the performance of PCG's managerial functions under the Operating Agreement and within the scope of the insured's business operations.
These acts and omissions constitute "Wrongful Acts" as that term is defined in the Policy, which provides coverage for claims arising from the management, administration, and operation of entities managed by the named insured, including claims alleging errors, misstatements, misleading statements, acts, omissions, neglect, breach of duty, and any matter claimed against the insured solely by reason of the insured's status as a manager, officer, or director of a managed entity.
With respect to the specific claims asserted:
Bad-Faith Valuation (OA Section 12.7). The bad-faith allegation directly implicates PCG's managerial conduct and judgment in exercising the contractual call option and in selecting and overseeing the appraisal process. This claim squarely targets PCG's discretionary decision-making in its capacity as Manager and, accordingly, constitutes a claim for a "Wrongful Act" within the Policy's coverage grant.
Breach of Fiduciary Duty. The breach of fiduciary duty claim is directed at PCG's conduct as Manager of PGV and the alleged failure to discharge duties owed to MSH in connection with the management of the joint venture. Claims for breach of fiduciary duty arising from the insured's managerial role are among the core risks insured under the Policy.
Breach of Capital Expenditure Obligations (OA Section 8.3). The deferred-maintenance claim relates directly to PCG's managerial obligation under the Operating Agreement to maintain the Hotel property. The alleged failure to undertake capital improvements constitutes an alleged act or omission in PCG's capacity as Manager, falling within the definition of a "Wrongful Act" covered under the Policy.
PCG's total potential exposure in the underlying arbitration amounts to up to Seventy Million Dollars ($70,000,000), representing MSH's full demand, although PCG firmly believes the claims lack merit and that the realistic exposure, if any, is substantially lower. Nevertheless, the defense of the arbitration will require significant expenditures for legal fees, expert appraisal fees, arbitration administration costs, and related expenses.
The Policy provides per-occurrence limits of Ten Million Dollars ($10,000,000) and aggregate limits of Ten Million Dollars ($10,000,000).
Based on the foregoing, PCG hereby tenders the claim arising from JAMS Case No. 1440032871 to Atlantic Fidelity and respectfully requests the following:
1. That Atlantic Fidelity provide full coverage for all defense costs incurred and to be incurred by PCG in connection with the arbitration proceeding styled Meridian Shores Hospitality LLC v. Pellegrino Capital Group LLC, JAMS Ref. No. 1440032871, including all attorneys' fees, expert fees, arbitration fees, and related litigation expenses;
2. That Atlantic Fidelity provide coverage for any settlement or arbitration award entered against PCG, up to the applicable Policy limits; and
3. That Atlantic Fidelity promptly acknowledge receipt of this tender, assign a claim number, and designate a claims adjuster to handle this matter.
V. Defense Counsel and Anticipated Costs
PCG has retained this firm, Calderwood & Harkness LLP, with offices in Miami, Florida and Tampa, Florida, as its defense counsel in the underlying arbitration. The legal team assigned to this matter consists of the following attorneys:
PCG respectfully requests that Atlantic Fidelity consent to the retention of Calderwood & Harkness LLP as defense counsel in this matter and agree to fund all defense costs incurred in connection with the arbitration, including but not limited to the following anticipated categories of expense:
• Attorneys' fees for Calderwood & Harkness LLP in connection with the defense of the arbitration, including all pre-hearing proceedings, discovery, motion practice, hearing preparation, and the arbitration hearing itself;
• Expert appraisal fees, including fees for Whitfield Realty Advisors LLC (Gerald K. Whitfield, MAI), PCG's retained appraiser, and PCG's pro rata share of the fees for any neutral third-party appraiser appointed pursuant to the dispute resolution mechanism set forth in Section 12.4(c) of the Operating Agreement;
• JAMS filing fees, case administration fees, and arbitrator compensation;
• Mediator fees, to the extent the parties agree to or are ordered to participate in mediation prior to the arbitration hearing;
• Deposition costs, including court reporter fees, videographer fees, and transcript costs; and
• Travel expenses incurred in connection with depositions, hearings, and other proceedings conducted at the JAMS Jacksonville Resolution Center or other locations.
PCG further reserves the right to seek reimbursement from Atlantic Fidelity for all defense costs already incurred since the commencement of Calderwood & Harkness LLP's engagement on March 22, 2023, to the extent such costs are covered under the Policy. A detailed accounting of fees and costs incurred to date will be provided upon request and in connection with the initial coverage determination.
VI. Key Individuals and Entities Referenced
For the convenience of the claims department, the following is a summary of the principal individuals and entities referenced in this notice of claim:
Named Insured:
Pellegrino Capital Group LLC 1900 Bayshore Boulevard, Suite 1400 Tampa, FL 33606 EIN: 83-2147605
Key Personnel of PCG:
• Dominic R. Pellegrino, Managing Member
• Adriana Pellegrino-Voss, Senior Vice President of Investments
• Marcus Thiel, Chief Financial Officer
Claimant:
Meridian Shores Hospitality LLC 220 Royal Palm Way, Suite 300 Palm Beach, FL 33480 Principals: Nathaniel "Nate" Cordero, Managing Member; Elena Cordero, Member
Joint Venture Entity:
Palmetto Grand Ventures LLC 1900 Bayshore Boulevard, Suite 1400 Tampa, FL 33606 EIN: 82-5063921 Florida Division of Corporations Filing No. L17000124583
Hotel Property:
The Palmetto Grand Resort & Spa 650 Mandalay Avenue Clearwater Beach, FL 33767 (312-room luxury beachfront resort, managed under franchise agreement with Aurelian Hotels & Resorts Inc.)
JV Lender:
Gulf Atlantic National Bank 201 East Pine Street Orlando, FL 32801 (Loan No. CRE-2017-06284; outstanding balance of $48,600,000 as of December 31, 2022)
PCG's Accountants:
Grantham, Pryce & Associates CPAs Tampa, FL Contact: Howard Grantham, CPA
Arbitration Forum:
JAMS, Jacksonville Resolution Center 1 Independent Drive, Suite 1600 Jacksonville, FL 32202 JAMS Case No. 1440032871 Arbitrator: Hon. Margaret Liu Chen (Ret.)
VII. Enclosed Documents
The following documents are enclosed herewith for Atlantic Fidelity's review in connection with its evaluation of this claim:
1. Copy of Meridian Shores Hospitality LLC's Demand for Arbitration, dated March 20, 2023;
2. Copy of Pellegrino Capital Group LLC's Response and Counterclaim, dated April 5, 2023;
3. Copy of the Amended and Restated Operating Agreement of Palmetto Grand Ventures LLC, effective June 15, 2017, together with relevant excerpts of the following sections: Section 8.3 (Capital Expenditure Obligations), Section 12.4 (Call-Option Exercise), Section 12.5 (Valuation Procedures), Section 12.7 (Bad-Faith Penalty), and Section 15.2 (Dispute Resolution / Arbitration);
4. Copy of PCG's call-option exercise notice to MSH, dated January 9, 2023;
5. Executive summary of the appraisal prepared by Whitfield Realty Advisors LLC (Gerald K. Whitfield, MAI), concluding a Fair Market Value of $118,000,000 as of December 31, 2022, dated February 10, 2023;
6. Copy of the Calderwood & Harkness LLP engagement letter with Pellegrino Capital Group LLC, dated March 22, 2023; and
7. Copy of the Policy (No. AFML-2022-08745) declarations page, to the extent available from PCG's files.
We note that certain of these documents, including the full Whitfield appraisal report and the complete Operating Agreement, are voluminous. We have enclosed the most relevant portions and summaries. Should Atlantic Fidelity require the full, unredacted versions of any of these documents, or any additional materials, we will promptly provide them upon request.
VIII. Reservation of Rights and Cooperation
PCG acknowledges and accepts its obligation under the Policy to cooperate fully with Atlantic Fidelity in the investigation, evaluation, and defense of this claim. PCG will make its officers, employees, and agents available for interviews and depositions as reasonably requested by the Insurer, and will provide access to relevant documents and records in a timely manner.
PCG respectfully requests that Atlantic Fidelity provide prompt written acknowledgment of its receipt of this tender of claim and defense, and that Atlantic Fidelity issue its coverage determination as expeditiously as possible. Given the pendency of the arbitration proceeding and the arbitrator's scheduling order, which requires disclosure of expert reports and completion of fact discovery within the coming months, the timely engagement of the Insurer in the defense is essential.
PCG hereby reserves all of its rights under the Policy, including but not limited to:
• The right to seek reimbursement for all covered defense costs, including attorneys' fees, expert fees, and arbitration expenses, incurred from and after March 22, 2023;
• The right to coverage for any settlement payment or arbitration award entered against PCG, up to the applicable Policy limits;
• The right to challenge any denial or limitation of coverage, whether in whole or in part, and whether expressed through a reservation of rights letter or otherwise; and
• All other rights, claims, and remedies available to PCG under the Policy, at law, or in equity.
To the extent that Atlantic Fidelity issues a reservation of rights in connection with this claim, PCG expressly reserves the right to dispute any such reservation and to assert that the Insurer is estopped from denying or limiting coverage by virtue of its conduct or any untimely or insufficient response to this tender.
Nothing contained in this letter shall be construed as a waiver of any right or defense available to PCG under the Policy, under applicable Florida law, or otherwise.
IX. Contact Information
All correspondence, coverage determinations, and other communications regarding this claim should be directed to:
Francesca Morano, Partner Calderwood & Harkness LLP 801 Brickell Avenue, Suite 2800 Miami, FL 33131 Telephone: (305) 814-7238 Facsimile: (305) 814-7201
Email: fmorano@calderwoodharkness.com
Reference: Calderwood & Harkness Matter No. 1027-00003 JAMS Ref. No. 1440032871
With a copy to:
Marcus Thiel, Chief Financial Officer Pellegrino Capital Group LLC 1900 Bayshore Boulevard, Suite 1400 Tampa, FL 33606 Telephone: (813) 725-4400
Email: mthiel@pellegrinocapital.com
We respectfully request that Atlantic Fidelity acknowledge this tender of claim and defense in writing within fifteen (15) business days of receipt of this letter. In the event we do not receive a timely response, PCG will consider all available options to protect its rights under the Policy.
We appreciate Atlantic Fidelity's prompt attention to this matter and look forward to a collaborative and efficient resolution of the coverage issues presented herein. Should you require any additional information or documentation in connection with your evaluation of this claim, please do not hesitate to contact me directly at the number listed above.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Francesca Morano Partner
801 Brickell Avenue, Suite 2800 Miami, Florida 33131
cc: Dominic R. Pellegrino, Managing Member, Pellegrino Capital Group LLC cc: Adriana Pellegrino-Voss, SVP of Investments, Pellegrino Capital Group LLC cc: Marcus Thiel, CFO, Pellegrino Capital Group LLC cc: Samuel Eklund, Partner, Calderwood & Harkness LLP
Enclosures (7):
1. Demand for Arbitration (March 20, 2023)
2. PCG's Response and Counterclaim (April 5, 2023)
3. Operating Agreement of Palmetto Grand Ventures LLC (June 15, 2017) — Relevant Excerpts (Sections 8.3, 12.4, 12.5, 12.7, and 15.2)
4. Call-Option Exercise Notice (January 9, 2023)
5. Whitfield Realty Advisors LLC Appraisal Summary ($118.0M; February 10, 2023)
6. Calderwood & Harkness LLP Engagement Letter (March 22, 2023)
7. Policy Declarations Page — Policy No. AFML-2022-08745
| Component | Amount | |
| Gross Asset Value (100% of PGV) | $118,000,000 | |
| Less: Outstanding Debt (Gulf Atlantic National Bank, Loan No. CRE-2017-06284) | ($48,600,000) | |
| JV Net Equity | $69,400,000 | |
| MSH's 35% Share of Net Equity | $24,290,000 | |
| Plus: MSH's Accrued Preferred Return (8% cumulative compounding on $18,505,000 total capital contributions) | $17,010,000 | |
| Total Offered Buyout Price | $41,300,000 | |
| Component | Amount | |
| Gross Asset Value per Beacon Appraisal (100% of PGV) | $151,500,000 | |
| Less: Outstanding Debt | ($48,600,000) | |
| Net Equity per Beacon Appraisal | $102,900,000 | |
| MSH's 35% Share of Net Equity | $36,015,000 | |
| Plus: MSH's Accrued Preferred Return | $17,010,000 | |
| Plus: Claimed Bad-Faith Penalty | $16,975,000 | |
| MSH's Total Demand | $70,000,000 | |
| Attorney | Role | Practice Group |
| Francesca Morano | Responsible Partner | Litigation (General) |
| Samuel Eklund | Billing Partner | Litigation (General) |
| Simone Laroche | Lead Associate | Litigation (General) |
| Jeffrey Park | Working Associate | Litigation (General) |