Extract to table

Quorum continues to reserve all rights and remedies available to it under the MSA, at law, and in equity, and nothing in this letter shall be construed as a waiver or limitation of any such right or remedy

2 of the MSA provides that Palomar shall indemnify and hold harmless Quorum from and against all "losses arising from Palomar's breach of its data security obligations

Palomar's July 7 letter does not meaningfully address this separate breach, and any resolution of this matter must account for both the underlying data security failure and the notification failure

Any settlement or resolution of this matter must be grounded in an acknowledgment of Palomar's contractual liability, not in a characterization that suggests Palomar is making a voluntary concession of grace

Palomar must provide full and adequate financial indemnification for the incident response costs incurred by Quorum, as set forth in this letter and the Demand Letter

This letter is written and transmitted entirely without prejudice to any claim, position, or argument that Quorum may assert in any forum, and nothing herein shall be construed as an admission of any fact, liability, or defense