Re External Re Topography Report Stgc 328015 Zeeman¶

Is Eric available as well? Does noon tomorrow work for both of you? If so, I will give you a call then.

Brett Michael-Schiff Ledermeier Senior Associate, Real Estate Litigation

Mailing: 850 Windy Hill Road | Unit 1762 | Smyrna, GA 30081

11625 Rainwater Drive | Ste 125 | Alpharetta, Ga 30009 Direct: 404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com bledermeier@mmatllaw.com

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From: Marimar Soltero Marimar.Soltero@stewart.com Sent: Thursday, January 30, 2025 4:09 PM To: Brett Ledermeier bledermeier@mmatllaw.com Cc: Tania Tuttle ttuttle@mmatllaw.com Subject: RE: [External] Re: Topography report - STGC: 328015 Zeeman

Hi Brett,

I am available any time tomorrow after 9 am and Monday from 8-5 pm. Let me know what works best for you.

I hope you have a great day,

Marimar Soltero

Claims Counsel

Stewart Title Guaranty Company

3402 W. Cypress St.

Tampa, FL 33607

O (813) 371-6694 | F (813) 315-7288

stewart.com http://www.stewart.com/ | marimar.soltero@stewart.com marimar.soltero@stewart.com |

STEWART INFORMATION SERVICES CORPORATION (NYSE: STC)

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From: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com > Sent: Wednesday, January 29, 2025 5:03 PM To: Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com > Cc: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Subject: RE: [External] Re: Topography report

Marimar,

I hope all is well. The indemnification language is on the first page of the new plat and it covers both properties. It is a legal requirement for any new plat and essentially an acknowledgment that the sewer lines are not the cities responsibility (which, legally, they are not) and that the property owners wont take actions that would harm the city, natural resources, etc.

For a general case update, I spoke with the insured last week (several days there were anywhere from 6-8 calls and upwards of 5-10 emails) regarding the settlement, the survey, the transcript, and the impervious surface issue that can be resolved through either a court order or a variance process. I have also asked that the insured and opposing counsel both highlight and note the survey for any questions or concerns; I have yet to receive a copy from either of them. I have been trying to set up a meeting with Gaddy as the Judge only gave us until Monday, February 3rd for opposing counsel and I to meet with the surveyor, finalize the survey, and address next steps for the impervious surface concerns. I am waiting on availability from the insured and have requested the same on two occasions this week. I also spoke in length with opposing counsel and they had one minor issue noted with the survey; the property line, per the agreement, is the fence post, but a pin could not be placed in that exact location as there are 10 inches of concrete around the post. That is an easy fix by the surveyor. With respect to the impervious surface next steps, opposing counsel acknowledges the efficiencies of going the court order route, but her client has not made a decision yet; he is waiting on the meeting with the surveyor. Addressing the impervious surface concern is a prerequisite to even drafting the settlement as it materially alters it; opposing counsel is hopeful to have the decision by end of week at which time we can have the settlement prepared for execution.

The new property line was not staked, by agreement between both sides, and we cancelled the same. The only outstanding issues are the impervious surface next steps and the transcript, which does have some rather blatant errors or misses entire conversations; this is a concern for the insured as she doesnt believe the settlement terms are accurate. I have assured her, several times, that all material terms to the settlement are accurate and supported by our t