Re Zeeman Conference Update 3¶

She has not given us any indication as to why she is refusing to provide the requested information. I wish I could give more detail on that, but I truly do not know why she is refusing to provide it.

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: Monday, July 21, 2025 1:58 PM To: Brett Ledermeier bledermeier@mmatllaw.com; Eric Zeni Eric.Zeni@stewart.com Cc: Tania Tuttle ttuttle@mmatllaw.com Subject: RE: Zeeman - Conference/Update

Has the insured provided any insight as to why she is refusing to provide the code enforcement information?

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: Monday, July 21, 2025 1:52 PM To: Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com >; Eric Zeni <Eric.Zeni@stewart.com Eric.Zeni@stewart.com > Cc: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Subject: [External] RE: Zeeman - Conference/Update

Eric/Marimar,

I hope you had a great weekend! I was finally able to get the signed topography and have sent it to the insured. Gaddy was non-responsive and yes, you are correct, all versions were already provided to the insured; she wanted the topography page from the final plat reconfiguration signed by Gaddy despite the actual plat already having been executed. With regard to the settlement, we did receive redlines from the insured and we are waiting to hear back from opposing counsel on her client's review so that we can finalize it for execution. As for the alleged code violations, the insured has not provided the same. Opposing counsel will undoubtedly want this information prior to executing any settlement agreement, but we can at least move forward with finalizing it; I hope to have the final revisions/comments this week so that we can circulate a clean copy - I will provide the clean copy to you both once I have it.

With respect to me "leaving off" her other counsel, there was only one communication up until last week and we responded to an email the City Attorney sent to opposing counsel, Lisa Rose, and I. I have already informed the insured that leaving her private counsel off was inadvertent and he was included in our email to the Court with the City Attorney. The only email the insured could be referencing is an email asking about the Court's preference for an amended consent order adding the City as a named party versus the City signing an "acknowledged and consented to by:". Ultimately, the Court informed us that the Judge prefers the acknowledgment rather than adding the City as a named party. That will be sufficient to bind the City and push the plat forward for approval.

Please let me know if you have any questions or would like clarification on any of the aforementioned.

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

CONFIDENTIALITY NOTICE No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In additio