Re Request For Update Stgc 328015 Zeeman 4¶

Marimar,

I received the redlined agreement, but it included new language with a monetary penalty for any code reports made by the insured this obviously wont be agreed to. Lisa and I spoke (several times) about some of the other redlines and they included the penalty due to the failure to disclose the alleged code violations. I am trying to talk sense into Lisa the recourse would be to file a motion to enforce which makes the language unnecessary. I have asked that Lisa/her client reach out to the City to see if there are any open reports/allegations against Plaintiff/his property. Im going to follow up with the insured again on the alleged violations and see if we can get any traction with her. If we cant provide the alleged list, then the settlement will sit in limbo. Plaintiff is, as you know, quite difficult and insists that the penalty language remain in the settlement agreement unless we provide the list; its really just another way to be difficult.

Ill touch base with Lisa again tomorrow and see if we can put this to rest so that we can circulate a clean copy of the agreement. Once I hear back from her, I will let you know.

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, August 18, 2025 11:23 AM To: Brett Ledermeier bledermeier@mmatllaw.com; Tania Tuttle ttuttle@mmatllaw.com Subject: RE: Request for Update - STGC: 328015 Zeeman

Hi Brett,

Is there an update? Have Lisa or Tim provided the agreement in light of the language in the agreement that would render acquiring the list of code violations moot?

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: Tuesday, August 12, 2025 5:30 PM To: Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com >; Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Subject: [External] RE: Request for Update - STGC: 328015 Zeeman

Marimar,

I just spoke with Tim Mitchell, insurance counsel for Plaintiff, and have been back and forth with Lisa for weeks now trying to get a clean copy for review; she keeps saying I will have it tomorrow and I havent gotten it. I just called her as well and she and Plaintiff are having a meeting tomorrow to finalize it and insurance counsel said he will be on the call and make sure we have the clean copy for final review by tomorrow.

I will stay on top of this and let you know when I receive it.

As for the alleged code violations, the insured is still refusing to provide the same. I am taking the position that it is a non-issue because the effective date of the settlement, which contains language about not making harassing claims to the City, is the date of execution.

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 addition, unless you are in the To: or CC