197Ec7A3 328015 Zeeman Letter 2¶

Mi stewart

Marimar Soltero

July 8, 2025

BY EMAIL DELIVERY ONLY

Sarah Zeeman szeeman @ gmail.com

Re:

STGC Claim: S023-328015-21

Policy:

O-9892-140655

Insured:

Sarah Zeeman 2740 Grove Street NE, Atlanta, GA 30319 (the “Property”) Sweatman vs. Zeeman

Property: Lawsuit:

21-CV-9795 (the “Lawsuit’”) Dear Sarah Zeeman: As you know, I have been assigned to administer the claim you presented to Stewart Title Guaranty

Company (“STGC”). Please be reminded that a title policy is a contract of indemnity which provides coverage for certain specified losses and perils, subject to the terms, conditions, exclusions, and exceptions found therein. The Policy generally provides coverage as follows:

This Policy insures You against actual loss, including any costs, attorneys’ fees and expenses provided under this Policy, resulting from the Covered Risks set forth below, if the Land is an improved residential lot on which there is located a one-tofour family residence and each insured named in Schedule A is a Natural Person. Your insurance is effective on the Policy Date. This Policy covers Your actual loss

from any risk described under Covered Risks if the event creating the risk exists on the Policy Date or, to the extent expressly stated, after the Policy Date. Your insurance is limited by all of the following:

e

Conditions on pages 2 and 3.

[Emphasis added.]

In that regard, I direct your attention to the Conditions in the Policy, which provide in pertinent part:

1. Handling A Claim Or Legal Action Stewart Title Guaranty Company 3402 W. Cypress Street, Tampa, Florida 33607 (813) 371-6694 direct

(813) 315-7288 fax

marimar.soltero@stewart.com

Wwww.stewart.com

a. You must cooperate with Us in handling any claim or legal action and give Us all relevant information.

b. If you fail or refuse to cooperate with Us, Your coverage will be reduced or ended, but only to the extent Your failure or refusal affects Our ability to resolve the claim or defend You.

The parties to the Lawsuit have been in the process of executing a settlement agreement (the

“Settlement Agreement’). Retained counsel, Brett Ledermeier, had reached out numerous times and had been waiting to receive your feedback on the draft Settlement Agreement for about 5 months. The parties to the Lawsuit are now waiting for you to provide details on the purported code violations referenced in the call with the city attorney on June 20, 2025. Brett Ledermeier has followed up with you and your private counsels, Jeff Banks and David Stuart, without a response providing the requested information. Please be further advised that any purported code violations concerning water runoff from your

neighbor’s property or related issues are not covered by your Policy. The only matter covered under your Policy is the alleged encroachment of your HVAC onto your neighbor’s land, which issue will be addressed and resolved by virtue of the Settlement Agreement. You have had ample opportunity to review and execute the Settkement Agreement in the past

5 months and are

unreasonably delaying the resolution of this matter. Your failure to execute the Settlement

Agreement prejudices STGC and prevents it from resolving your claim. In accordance with the Policy, we require your cooperation with respect to the Settlement

Agreement and any outstanding steps required to finalize said agreement. Should you fail to provide the requested information by July 11, 2025 or to execute the Settlement Agreement by July 18, 2025, you will have failed to cooperate with STGC and its retained counsel and prevented STGC from resolving your title claim. Should that occur, STGC will withdraw coverage due to your failure to cooperate. Thank you for your attention to this matter,

STEWART TITLE GUARANTY COMPANY

AManwnon \ottiw Marimar Soltero, Esq.

Claims Counsel