Re Settlement Agreement Revision Stgc 328015 Zeeman¶

Marimar,

I just tried calling to discuss this matter. If you have availability before EOD, please feel free to call me at 7705305669.

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: Brett Ledermeier Sent: Thursday, June 19, 2025 1:49 PM To: Marimar Soltero Marimar.Soltero@stewart.com Cc: Celeste Watwood cwatwood@mmatllaw.com Subject: RE: Settlement Agreement Revision - STGC: 328015 Zeeman

I hope all is well! I have spoken with private counsel at length several times last week and the week prior. We have not received any redlines and the insured directed private counsel to not send revisions. It is putting us in a very difficult position. I requested the settlement again today and have answered a plethora of questions/demands sent via email by the insured to try to explain the process and address concerns. The last redlined version is attached. It has not been updated since April 4th. We will make sure any defined terms are addressed, and any grammatical errors, but the material terms need to be reviewed/approved in order to finalize this. We also need the plat to be approved before it would be deemed "final" which is the trigger point for the fence removal.

As for the plat, the City of Brookhaven Attorney claims they are not bound by the Court Order (which we anticipated could happen). He has scheduled a virtual meeting with all counsel and parties to the litigation tomorrow at 9:30AM. Would you also like to be on the call?

Also, please feel free to give me a call today on this matter if you have availability. My phone forwarding is being weird, so my cell is best: 7705305669.

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: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately.

From: Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com > Sent: Wednesday, June 18, 2025 9:35 AM To: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com > Subject: RE: Settlement Agreement Revision - STGC: 328015 Zeeman

Good Morning Brett,

I wanted to follow up on whether Zeeman and Banks provided their revisions to the agreement. I would also like a copy of the latest draft settlement agreement.

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: Marimar Soltero Sent: Thursday, June 12, 2025 11:59 AM To: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com > Subject: Settlement Agreement Revision -