Re External Re Reimbursement Of Outstanding Fees 2740 Grove Street Ne Stgc 328015 Zeeman¶

I can confirm that the transcripts were ordered by private counsel. I did not have any prior agreement for payment of the transcripts. I recall the insured and private counsel asking about reimbursement, but I said that is coverage and needs to be directed to you.

Happy to answer any other questions! Hope youre doing well and your day is off to a great start.

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: Tuesday, February 11, 2025 11:57 AM To: Brett Ledermeier bledermeier@mmatllaw.com Subject: FW: [External] Re: Reimbursement of outstanding fees - 2740 Grove Street Ne - STGC: 328015 Zeeman Importance: High

Good Morning Brett,

Can you confirm the invoice for the transcripts, https://prnt.sc/mIiP8os8Y4fW, for $2,853.20 was ordered by the insureds private counsel? Did you have any prior agreement with Ms. Zeemans private counsel to tender any amount or all of the amount before the transcripts were ordered?

I hope you have a wonderful 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 |

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From: Sarah Zeeman <szeeman@gmail.com szeeman@gmail.com > Sent: Tuesday, February 11, 2025 11:52 AM To: Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com > Cc: Eric Zeni <eric.zeni@stewart.com eric.zeni@stewart.com >; Justin Davis <Justin.Davis@stewart.com Justin.Davis@stewart.com > Subject: Re: [External] Re: Reimbursement of outstanding fees - 2740 Grove Street Ne - STGC: 328015 Zeeman

Marimar

As you are aware the deposition was a subpoena was filed by the opposing party. It was a requirement.

There was zero communication by you or Brett on how the fees would be handled. As my representation, you have a fiduciary responsibility to represent in all parts of this legal manner.

If you recall this is during the time of your suggestion for creative use of Bretts escrow account to pay the opposing party 12,000.

On Tue, Feb 11, 2025 at 11:30AM Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com > wrote:

Hi Sarah,

It is my understanding that your private counsel requested the depositions and transcripts. As your private counsel requested these items, the invoices were directed to them. I cannot speak to any conversations that you had with your private counsel with respect to any notice they provided you as I was not a part of those conversations.

As previously noted, pursuant to the Policy, the Company is not required to reimburse you for settlement costs, attorneys' fees or expenses the Company did not approve in advance. In this case, the Company did not previously approve of the deposition or transcript expenses you are seeking reimbursement for. However, as a courtesy to you, the Company has elected to reimburse you for the $1,426.60.

I am including a copy of the Conditions in the Policy for your reference (this is located on Page 3 of your Policy):

Marimar Soltero

Claims Counsel

Stewart Title Guaranty Company

3402 W. Cypress St. <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.google.com_maps_search_3402-2BW.-2BCypress-2BSt.-250D-250A-2B-250D-250A-2BTampa-2C-2BFL-2B33607-3Fentry-3Dgmail-26source-3Dg&d=DwMFaQ&c=A2I0cd0yeEKQCn3mv-g-KzOAX7YMnpExrKRXrh8neX0&r=B74EBWiikQ67Mz8ZYuIOnD-U