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Stonefield Logistics Group Litigation 12 docs · open →

Document types detected

Analysis / memo4

Other3

Engagement letter2

Correspondence2

Contract / agreement1

Parties across the matter

Client Stonefield Logistics Group IncDISPUTE Stonefield Logistics Group IncHARKNESS LLPHOWE LLPHarkness LLPHowe LLPInvestigator Ridgeline Forensic Consultants LLCLone Star Fire Protection IncM. BestM. Best RatingManagement Stonefield Logistics Group IncOfficer Stonefield Logistics Group IncPermian Wellhead Services LLCRidgeline Forensic Consultants LLC

Chronology

2024-12-31 · engagement-letter-slg.docx

… he effective date of the adjustment. If the engagement extends beyond December 31, 2024, adjusted rates will apply to services performed on or after the effective date of the ra …

2024-08-19 · client-closing-letter.docx

… : (713) 554-8000 Facsimile: (713) 554-8001 www.calderwoodharkness.com August 19, 2024 Via Email and U.S. Mail Marcus D. Stonefield Chief Executive Officer Stonefield Logistics …

2024-08-16 · client-closing-letter.docx

… settlement payment of $4,500,000.00 was received via wire transfer on August 16, 2024. The funds were deposited directly into SLG's operating account at Pinnacle National Bank …

2024-08-12 · client-closing-letter.docx

… gagement. 2. Summary of Matter Resolution 2.1 Settlement Agreement On August 12, 2024, Stonefield Logistics Group Inc. and Meridian Surety & Indemnity Company executed a Settl …

2024-08-12 · settlement-agreement-and-mutual-release.docx

… UTION VERSION SETTLEMENT AGREEMENT AND MUTUAL RELEASE Effective Date: August 12, 2024 This SETTLEMENT AGREEMENT AND MUTUAL RELEASE (this "Agreement") is entered into as of Aug …

2024-07-01 · client-closing-letter.docx

… maining approximately $1.8 million apart at the close of the session. July 1, 2024: C&H sent a pre-suit statutory notice to Meridian pursuant to Texas Insurance Code Sectio …

2024-07-01 · pre-suit-statutory-notice.docx

… : (713) 555-9200 Facsimile: (713) 555-9201 www.calderwoodharkness.com July 1, 2024 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED, AND ELECTRONIC MAIL Patricia Ng, Vice Presi …

2024-07-01 · settlement-agreement-and-mutual-release.docx

… MS Houston, JAMS Case No. 1440-02917-2024, which ended in impasse. On July 1, 2024, SLG served a pre-suit statutory notice upon Meridian pursuant to Texas Insurance Code Se …

2024-06-20 · mediation-strategy-memo.docx

… his memorandum is prepared in anticipation of mediation scheduled for June 20, 2024, before the Honorable Margaret Colquitt (Ret.) at JAMS Houston. It is protected by the at …

2024-06-20 · client-closing-letter.docx

… SLG's management team, the offer was rejected as grossly inadequate. June 20, 2024: The parties participated in a full-day mediation at JAMS Houston before the Honorable Ma …

2024-06-20 · pre-suit-statutory-notice.docx

… d to participate in a mediation. A mediation session was conducted on June 20, 2024, at JAMS Houston before the Honorable Margaret Colquitt (Retired), a former Justice of th …

2024-06-20 · mediation-position-statement.docx

… 917-2024 Date of Submission: June 17, 2024 Date of Mediation Session: June 20, 2024 Prepared by: Howard Bellamy, Responsible Partner Andrew Fitzpatrick, Lead Associate CALDE …

2024-06-20 · settlement-agreement-and-mutual-release.docx

… t, Suite 2800, Houston, Texas 77010. E. Mediation and Negotiation. On June 20, 2024, the Parties participated in a mediation before the Honorable Margaret Colquitt (Ret.) at …

2024-06-17 · mediation-position-statement.docx

… iator JAMS Houston JAMS Case No.: 1440-02917-2024 Date of Submission: June 17, 2024 Date of Mediation Session: June 20, 2024 Prepared by: Howard Bellamy, Responsible Partner …

2024-06-10 · mediation-strategy-memo.docx

… y, Responsible Partner FROM: Andrew Fitzpatrick, Lead Associate DATE: June 10, 2024 RE: Mediation Strategy — Stonefield Logistics Group Inc. v. Meridian Surety & Indemnity C …

2024-05-14 · mediation-strategy-memo.docx

… mediation as a mechanism for resolving the dispute, and KBH agreed on May 14, 2024, leading to the June 20, 2024 mediation session. Based on the analysis set forth below, I …

2024-05-12 · formal-demand-letter-to-meridian.docx

… (30) calendar days of the date of this letter — that is, on or before May 12, 2024. Failure to respond within that period will leave SLG no alternative but to initiate liti …

2024-05-10 · mediation-strategy-memo.docx

… f the net claim and was promptly rejected by Calderwood & Harkness on May 10, 2024 as grossly inadequate. We proposed mediation as a mechanism for resolving the dispute, an …

2024-05-10 · email-meridian-counterproposal.eml

… ia Kessler Cc: Andrew Fitzpatrick ; Samuel Okonkwo Date: Friday, May 10, 2024 11:18 AM CDT Subject: RE: Stonefield Logistics Group Inc. — Settlement Discussion / Polic …

2024-05-06 · mediation-strategy-memo.docx

… andt & Howe LLP ("KBH"), extended a settlement offer of $1,750,000 on May 6, 2024. This offer represents approximately 38.6% of the net claim and was promptly rejected by …

2024-05-06 · client-closing-letter.docx

… Meridian's initial settlement offer of $1,750,000.00 (communicated on May 6, 2024) would have represented only approximately 38.6% of the net claim, a discount of more tha …

2024-05-06 · email-meridian-counterproposal.eml

… rd Bellamy Cc: Andrew Fitzpatrick ; Samuel Okonkwo Date: Monday, May 6, 2024 2:15 PM CDT Subject: Stonefield Logistics Group Inc. — Settlement Discussion / Policy No. …

2024-05-06 · pre-suit-statutory-notice.docx

… the claim and that Meridian's denial was without reasonable basis. On May 6, 2024, Meridian responded to the Demand Letter by offering a payment of only $1,750,000 as a pu …

2024-05-06 · mediation-position-statement.docx

… h statutory penalties and remedies under the Texas Insurance Code. On May 6, 2024, Meridian, through its coverage counsel at Kessler, Brandt & Howe LLP, responded with a " …

2024-04-29 · coverage-opinion-memo.docx

… ne, we estimate that penalty interest will begin accruing on or about April 29, 2024, and will continue to accumulate until Meridian tenders payment in full. Fourth, Meridian …

2024-04-29 · client-closing-letter.docx

… per annum on the unpaid claim. As of the approximate date of accrual (April 29, 2024, i.e., sixty days after SLG's February 1, 2024 proof of loss and ninety days from the dat …

2024-04-29 · email-meridian-counterproposal.eml

… 24. The 61st business day following that submission was approximately April 29, 2024. Accordingly, 18% per annum statutory interest has been accruing on the $4,530,000 net cl …

2024-04-12 · mediation-strategy-memo.docx

… tands scrutiny under the facts or applicable Texas law. Following our April 12, 2024 formal demand letter, Meridian, through its outside counsel at Kessler, Brandt & Howe LLP …

2024-04-12 · client-closing-letter.docx

… the evidentiary record established by the Ridgeline forensic report. April 12, 2024: C&H sent a formal demand letter to Meridian, addressed to Patricia Ng, Vice President of …

2024-04-12 · email-meridian-counterproposal.eml

… ian's obligations under the policy. As we set forth in detail in our April 12, 2024 demand letter, SLG's coverage position under Policy No. IML-TX-0039821-2023 is compelling …

2024-04-12 · formal-demand-letter-to-meridian.docx

… (713) 654-8200 | Facsimile: (713) 654-8201 www.calderwoodharkness.com April 12, 2024 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED, AND ELECTRONIC MAIL Ms. Patricia Ng Vice Pr …

2024-04-12 · pre-suit-statutory-notice.docx

… r the Texas Insurance Code. C. Prior Demand and Settlement Efforts On April 12, 2024, Calderwood & Harkness sent a formal written demand letter to Meridian on behalf of SLG ( …

2024-04-12 · mediation-position-statement.docx

… meaning the $10,000,000 annual aggregate limit is not implicated. On April 12, 2024, SLG, through undersigned counsel, submitted a formal demand letter to Meridian demanding …

2024-03-31 · coverage-opinion-memo.docx

… ility Policy No. IML-TX-0039821-2023, effective April 1, 2023 through March 31, 2024, including all endorsements, schedules, declarations pages, and any amendments thereto (c …

2024-03-31 · mediation-strategy-memo.docx

… ed by Meridian to SLG for the policy period of April 1, 2023, through March 31, 2024. The Policy contains a broad coverage grant that insures against "all risks of direct phy …

2024-03-31 · preliminary-coverage-assessment-memo.docx

… nd, because no prior claims have been made during the April 1, 2023 – March 31, 2024 policy period, the $10,000,000 annual aggregate limit is entirely unimpaired. It should b …

2024-03-31 · client-closing-letter.docx

… ility Policy No. IML-TX-0039821-2023 (effective April 1, 2023 through March 31, 2024), including all endorsements, schedules, and declarations; 4. The Ridgeline Forensic Con …

2024-03-31 · pre-suit-statutory-notice.docx

… 9821-2023, with a policy period effective from April 1, 2023, through March 31, 2024 (the "Policy"). The Policy provides the following material coverage parameters: • Per-Oc …

2024-03-31 · mediation-position-statement.docx

… cy is $174,600, and the policy period runs from April 1, 2023 through March 31, 2024. The loss at issue falls squarely within the policy period. Despite the clarity of covera …

2024-03-31 · engagement-letter-slg.docx

… . IML-TX-0039821-2023 (the "Policy"), effective April 1, 2023 through March 31, 2024, in connection with the cargo loss sustained at SLG's transload facility located at 4501 …