in Re Denbury Resources, Inc. and Denbury Onshore, LLC

ACCEPTED
14-15-00991-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/25/2015 5:20:55 PM
CHRISTOPHER PRINE
CLERK

FILED IN
14th COURT OF APPEALS
______________________________________________________________________________
HOUSTON, TEXAS
11/25/2015 5:20:55 PM
IN THE FOURTEENTH COURT OF APPEALS
CHRISTOPHER A. PRINE
______________________________________________________________________________
Clerk

In re: Denbury Resources Inc. and Denbury Onshore, LLC
______________________________________________________________________________

PETITION FOR WRIT OF MANDAMUS
______________________________________________________________________________

On Petition for a Writ of Mandamus from the 157th Judicial District Court
For the County of Harris, Texas
Honorable Randy Wilson, Presiding
Case No. 15-CV-9546

______________________________________________________________________________

Respectfully Submitted by:

CARVER, DARDEN, KORETZKY, TESSIER,
FINN, BLOSSMAN & AREAUX, LLC
Philip D. Nizialek (Texas Bar No. 15045250)
Sarah E. Stogner (Texas Bar No. 24091139)
Jacqueline M. Brettner (pending pro hac vice)
1100 Poydras Street, Ste. 3100
New Orleans, Louisiana 70163
Telephone: (504) 585-3800
Facsimile: (504) 585-3801

Attorneys for Relators, DENBURY RESOURCE INC.
AND DENBURY ONSHORE, LLC

TRIAL COURT RECORD – VOLUME 2
 9/29/20154:02:38 PM
Chris Daniel - District Clerk Harris County
Envelope No. 7152558
By: LISA COOPER
Filed: 9/29/2015 4:02:38 PM

CAUSE NO. 2015 09546 m

DENBURY RESOURCES INC. and IN THE DISTRICT COURT
DENBURY ONSHORE, LLC

Plaintiffs,
HARRIS COUNTY, TEXAS
v.

IRONSHORE SPECIALTY INSURANCE
COMPANY, ALTERRA EXCESS & 157TH JUDICIAL DISTRICT
SURPLUS INSURANCE COMPANY,
AXIS SURPLUS INSURANCE
COMPANY, AND MARSH USA INC.

Defendants

DENBURY'S CONSOLIDATED RESPONSE TO IRONSHORE'S
MOTIONS FOR PROTECTIVE ORDERS

Ironshore requests entry of protective orders. 1 If granted, Denbury will be prevented from

obtaining information relevant to its allegations and Ironshore's defenses in this case. Texas law

prohibits this? Further, Ironshore has the burden of proving its objections and asserted

privileges. Ironshore cites no law, provides no facts, and attaches only self-serving, conclusory

affidavits. 3 Its motions should be denied.

Additionally, and as fully articulated m Denbury's Motion to Compel, Ironshore's

1 Ironshore filed two separate Motions for Protective Order. One for the Ironshore corporate notice and one for the
FARA corporate notice. Denbury files this combined response for purposes of judicial efficiency. FARA is the
third-party claims administrator for lronshore and under lronshore's control for all purposes IDlder applicable Texas
rules.
2 See Tex. R. Civ. P. 192.3(a); see also Ford Motor Co. v. Castillo, 279 S.W.3d 656, 664 (Tex. 2009) ("The phrase
'relevant to the subject matter' is to be 'liberally construed to allow the litigants to obtain the fullest knowledge of
the facts and issues prior to trial."') (internal citations omitted).
3 Denbury had requested Ironshore provided it with a Rille 193.3(b) compliant privilege log for its discovery
responses since, at least, August 5, 2015. Ironshore refused to do so for over 45 days. Now, in response to
Denbury's motion to compel, lronshore has produced the third iteration of its privilege log, an "Amended Privilege
Log," dated September 25,2015, attached hereto as Exhibit T.

1
objections and asserted privileges are unfounded. 4 This is an insurance coverage lawsuit between

Denbury and its excess insurers. The crux of this coverage dispute is whether the parties intended

to cover damages to third-party property that Denbury leases in its oil and gas operations.

Denbury's position is that it does. The Umbrella policy's blended pollution endorsement was

specifically added to provide this coverage. 5 AGUe's $25 million payment suggests Denbury's

interpretation reflects the parties' actual intent when the policies issued. Ironshore's position is

that its follow-form policy excludes this coverage. 6

Relevant to this discovery dispute, Denbury seeks a declaratory judgment that the

Ironshore Policy provides coverage. Denbury requests damages for lronshore's breach of

contract, bad faith, and unfair trade practices. Denbury also alleges that certain terms and

conditions of Denbury's policies are ambiguous and/or provide illusory coverage. Denbury's

deposition notices seek basic information relevant to these allegations. 7 While Denbury's notices

are exhaustive, 8 the number of topics is driven entirely by Ironshore's refusal to provide

4 .
See Tex. R. Civ. P. 192.6(a) and 215.1; see also Pace v. Jordan, 999 S.W.2d 615,622 (Tex. App.-Houston [1st
Dist.] 1999, pet. denied) (if a party moves for protective order, the party seeking the discovery should file a motion
to compel).
5 See Blended Pollution Endorsement, attached as Exhibit 5 to Denbmy's Second Supp. and Am. Pet.
6 See Ironshore letter denying coverage, dated June 16,2015, attached to Denbury's Mot. to Compel, as Exhibit M.
7 See 'l1:li.87-88 (declaratory judgment of coverage), 89-94 (breach of contract), 105-113 (bad faith), Denbmy's 2nd
Supp. Am. Pet., filed of record June 9, 2015. Denbmy also alleges that lronshore's marketing of the policy to oil and
gas operators (and then denial because portions of the damaged property are subject to mineral leases) constitutes an
unfair trade practice. Id. at CJI'lJ.98-1 04. Texas courts have allowed discovery of extrinsic materials in the interpretation
of a breach of contract claim. See, e.g., Ford Motor Co. v. Castillo, 279 S.W.3d at 663 (Tex. 2009) (internal citations
omitted) ("Like any other breach of contract claim, a claim for breach of settlement agreement is subject to
established procedures ofpleading and proof. .. "it cannot be determined without "full resolution of the surrounding
facts and circumstances."); see also id. at 664 (" ... a party is not required to demonstrate the viability of defenses
before it is entitled to conduct discovery."). Here too, the allegations of Denbmy's well-pled claims are sufficient to
trigger the discoverability of materials and testimony responsive to Denbury's tailored requests.
8 See Denbmy's Notice of Corporate Dep. to lronshore, attached hereto as Exhibit P; see also Denbmy's Notice of
Corporate Dep. to FARA, attached hereto as Exhibit Q. Unless otherwise noted, Denbmy's reference or citation to
"Exhibits A-0" herein refer to the exhibits attached to Denbmy' s Mot. to Compel, flled of record on September 22,
2015. Denbury attaches an Appendix detailing all Exhibits to its Motion to Compel and this Response for the
Court's ease of reference. See attached Exhibit V.

2
meaningful responses to discovery.9

Ironshore, as the party resisting discovery, bears the burden of proving Denbury's

requests seek irrelevant information. lO Ironshore must also present facts showing a particular,

specific, and demonstrable injury.l1 Ironshore cannot simply make conc1usory allegations. 12

Some evidence must be produced in support of its requested protective order. l3 If this evidentiary

burden is not satisfied, then the trial court abuses its discretion by entering the protective order to

limit otherwise proper discovery.14 Denbury asks the Court deny Ironshore's motions.

9 See generally Denbury's Mot. to Compel; see also Tex. R. Civ. P. 193.2(e) ("an objection ... that is obscured by
numerous unfounded objections, is waived unless the court excuses the waiver for good cause shown."); Garcia v.
Peeples, 734 S.W.2d 343, 347 (Tex. 1987) (0 rig. proceeding) (" ... th[e] goal of the discovery process is often
fmstrated by the adversarial approach to discovery. The 'mles of the game' encourage parties to hinder opponents
by forcing them to utilize repetitive and expensive methods to find out the facts. The truth about relevant matters is
often kept submerged beneath the surface of glossy denials and formal challenges to requests until an opponent
unknowingly utters some magic phrase to cause the facts to rise. Courts across the nation have commented on the
lack of candor during discovery in complicated litigation .... "). The cost-effective, reasonable sharing of
discoverable information is all Denbury's notices and written requests seek.
10 See In re Waste Management of Texas, Inc., 2011 WL 3855745 at *5, n. 5 (Tex. App.-Corpus Christi, 2011) ("We
note that this Court and others have placed the burden of proof regarding relevance, or lack thereof, on the party
seeking to avoid discovery."). And note Denbury fully addresses Ironshore's unsupported relevance objections in its
separately filed Mot. to Compel.
11 See Garcia v. Peeples, 734 S.W.2d at 345.
12 I d. (requiring affidavits in support of protective order to identify specific documents and information responsive to

requests, and specific facts supporting bases for shielding same from discovery together with specifics relative to
likely harm absent requested protection). Of note, while the Peeples court found the details of the subject affidavits
sufficient, not only are Ironshore's affidavits lacking the factual specificity relied upon by the Court, but the solution
reached there involved production of responsive documents subject to protective order. Denbury has not objection to
such a remedy here and, indeed, has voluntarily offered to execute a confidentiality agreement on numerous
occasions. See Exhibits A and B, Denbury's Mot. to Compel.
13 Id. ("In United States v. Garrett, 571 F.2d 1323 (5th Cir. 1978), the court noted that a movant must show "a
particular and specific demonstration of fact as distinguished from stereotyped cOllclusory statements. Sweeping
predictions of injury and '[b]road allegations of harm, unsubstantiated by specific examples or articulated
reasoning,' do not justify a protective order.") (internal citations omitted). Tex. R. Civ. P. 192.6 is analogous to its
federal counterpart.
14 Id at 345-48.

3
 I. Pertinent Factual. Background

5118/15 • Denbury propounds Interrogatories and First Set of Requests for Production of
Documents to Ironshore.
6114115 I) Ironshore tlxJue~t~ exte.n~.ion to r{:Epc~nd. a.nd~ j.n exchnnge ft)f ~}dditi-ona1 30 d.a'\/s~ agn-:~e~
to hold v. . .ee.k of 8/"j O/"L 5 f{:-r lrnnshorelI-? /\.Ft/, CfHT){}f;Jte d(:no~it~o.ns.
7/17115 • IroH3hore pn)'~/.ide;,; incGrrrpJ.ete respo:n~e:~ tG r)enbury:~ s 5/18/J:> (hSCO~7{:tJ'"
• Iron shore : s n~:s'pnn~.i V{: prc~ducti{HI is .Un1itfd tn copies of l)enbur}'~' s 'pOHi::.~C~ !}B.d.
f.:o:(((~~~Dc~nd.enee cxCh~·;tD.ged b{~t~?,/ee.n COUIU)(:!.
7/20115 • Denbury again requests available deposition dates for corporate Ironshore/FARA
depositions and fact witness depositions of employees identified in discovery
responses.
e Denbury sends email notice of discovery deficiencies.
8/5115 e Denbury notices corporate depositions for 9/29-30/15 because IrotiEhnre reli.wed to

Denbury's cOlTespondence includes additional available dates in September and
October, together vv'ith all offer to "reset" noticed depositions as necessary.
e Denbury send<; formal letter detailing substantive bases of discovery deficiencies in
It'onshore's 7117/15 responses.
• Denbury requests Rule 193.3(b) privilege log for documents withhe1diredacted from
Irollshore's 7il7/I5 responses.
• Denbury propounds Second Request for Production of Documents and First Set of
Requests for Admission.
e Denbury sends proposed confidentiality agreement to address lronshore's
confidential/proprietRry/trade secret objections to producing documents. lron"hore

8/10115 • \V!thOUt an:v ad\rance t1oti(·e to 1)e.nbury~ IfoI1~hGr{: fHe~~ n10tic~D to qU.:1~h corporate
d.e~~30~~iti{}n~ Hoti(tXl for Septl-:.trtbcr 29·~ 30~ 2f~ 1.5,
8113115 e Denbury calls and emails lronshore requesting available dates to resolve Ironshore' s
motion to quash.
8117115 " Ironshc~re n:.-:\ponds d:Htt ~t '·'\na.y ) be abL.~ to r~rGduc.e ~?;/itnes~es in ()c.tobc:r but d.Ges· not
confirn:1 ~rvaih1bi.Ut):.
e Denbury responds with October availability for requested corporate depositions and
reiterates 7i20!l5 request for dates available to depose fact witnesses.
8/20115
8127115
9/2115 CD Ironshore confirnls date ~rnd dLne J~Jr JronEhore representati Vt:, c~~rt!:~jn fact \:\.:itne\~es~
aDd ::~lO be dett~.nD.Ln(:d.·-~ I';i\'l~/-\ I'(~rH'f:~entat~ \}f~,
III Denburv sends revised notices of deposition reflecting October dates.
9/3/15 4» lco.n\hore ~~HJln:1t:.tr.Lty ·objtx:ts to 1)enh\j.ry\.~ /\.re.as of rnqu~f)/ \vithL~nt r~rO\}ifiing ;:tn:y
\t..!Titten re~PGns(-: or b~t$is for as~erted ot~jecti(n·.ts/prtvi1eg(:g in reBpon~;e to "L)enbury' H

e Denbury requests lronshore provide specific, wlitten objections to any disputed
corporate notice Areas of Inquiry so parties can undertake discove!)' conference.
9/4/15 • lronshof(: pIov~d{~s incon\ph:.~t(: n:~Er)OnSes to l)t;:nbury\-:. second Et::t G~f d.~3CO\"'e:ty> and
~-upp1en!.entaL but f'::.t11i In~~ufficier:.t~ rc~~pf.~n~h~~s to ~){:.nblrry\3 ofig.nud requests.
• Denbury again sends proposed confidentiality agreement to address Ironshore's
confidentiaUproprietaryltTade secret objections to producing documents. 1ronsIwre

4
 9/9115 III Denbury send.,; another notice detailing substantive deficiencies present in lronshore's
9/4115 discovery responses and 8/20/15 "privilege log."
• Iron~.borc~~:; ~··~l<'esponsive produclion'.~ !Hclude& hZ:H'lHy redacted ':;(~la~nl .Note t11es'!:" and
'(~1ai tn I}o<.:n.n'h::nt Hje~.:~' \.\?jthout COIT{:st)o:nding nrnr~h..::~~e h){-;.
9110/15
9115115 @ Parties conduct 3 hour discovery in an effort to resolve respective objections to
outstanding discovery requests.
e Iroru~hore oraH): faise~ ne~\,; Gbj(:ct~OI1S to the /\rea~ uf InquLry .not inc:.tuded in. "'dra:n~":
9/10./15 \'vrltten ot~it)ctiGns,
@ The parties fundamentally disagree on scope of discovery.
III Denbury requests Ironshore agree to produce any court-ordered documents within 15
days of hearing on discovery motions to avoid additional discovery delays. Ironi;h{)re

9116115 @ Denbury re·iterates request that Ironshore agree to produce any court··ordered
documents within 15 days of hearing on discovery motions to avoid additional
discovery delays. lr(l)"l"hore rd'u:'{~i;.
9/18/15 @ lro.n~hor(-: ~G~c~s ~"'IOtio.n~ t~)r r~rGtecLb?e C~rder~ t"}(·.eki ng: to aVG~d the }najc~rity .of
1)(~nbDr'y":-s notjced nreas of'inquiry f(if 1rGHShQre ~tnd }~.i\J~l\ (h::sigH((~S. IrGru~hore ·:s
rnot~on inc.1ude~ nrev1ou~lV tru~erved objecHoHs .
9/22/15 @ Dcnbury files a Motion to Compel responses to its written discovery rcquests and
responsive testimony by lronshore' sand FARA.' s designees to an noticed areas of
inquiry.
9/25/15 fAil tron~hore .ii1f3 c.zwh.'.h.l30ry aftldf;:.vit.~': of I ..ee Sheriden and. l~a~tHj~li "rre;;~dH\"'-ay in 3Upp(~rt
of ~ts pending Iv:rGt~on:; for -Protective {)rden").
rroJl3hure:'s affidav1ts rt>ly on Ironshore':s ~'·l-\n:~(:nd.cd Prtv3leg(~ L.og':~ \:vh!<..:h. Iroru:hc~re
fA)

s~ rnu~ t;:U}(~ou~s'~ ':/ ~)e.r\/e3 on l)en hury fZir the I ~;t tif.ne on this d.ate .
• lro.n~hore aguiri ~:supph::Jn\~.nts~:· its 3:f.':spons(:;s to l)enbury ~s f~rEt S(t of n:-:qu(:~}ts ~f.ur
pr·odnction ~);/itb ~:~n.l{:.n(k:~d :s.ubst(~.nti \/(~ rGda(:tinn.s~
9127/15 lID Denbury requcsts Ironshore idcntify list of specific changes within lronshore's
"amended production." Irollshore again ig.llores Denburv's rc;guest.
9/29/15 III Denbury files response to lronshore's Motion to Compel.

10/2/15 • Hearing set on Denbury's Motion to Compel and lronshore's Motions for Protective
Orders.
10117115 @ Proposed deadline forl'..arties to comply with Court's 1012115 discovery order.
10120/15 III Corporate depositions ofIronshore and PARA set in Manhattan at Ironshore's request.

10/22/15

II. Law & Argument

a. Denbury's Deposition Topics are Reasonably Tailored to Include Only
Relevant Matters

The purpose of discovery is to allow the parties to obtain knowledge of the issues and the

facts prior to trial. Texas courts recognize "the ultimate purpose of discovery is to seek the truth

5
so that disputes may be decided by what the facts reveal, not by what is concealed.,,15 Rule

192.3(a) entitles Denbury to seek discovery "regarding any matter that is not privileged and is

relevant to the subject matter of the pending action, whether it relates to the claim or defense of

the party seeking discovery or the claim or defense of any other party." The information sought

need not be admissible in evidence so long as it "appears reasonably calculated to lead to the

discovery of admissible evidence.,,16 These rules regarding the scope of discovery apply

regardless of the discovery method at issue.

Texas law requires discovery requests be reasonably tailored to avoid including tenuous

information, while still obtaining the necessary, pertinent informationY Denbury satisfies this

requirement by seeking 3 basic categories of information:

1. IronshorelFARA's adjustment of Denbury's Claim; 18

2. Denbury's Policies, including the underwriting of the policies at issue;19 and

3. Ironshore/FARA's adjustment of on-lease pollution damages claimed by similarly-

situated oil and gas operators under identical policy forms.z°

15 See Jampole v. Touchy, 673 S.W.2d 569, 573 (Tex. 1984) overruled in part on other grounds Walker v. Packer,
827 S.W.2d 833 (Tex. 1992).
16 See In re Liberty Mut. Ins. Co., 2009 WL 441897 (Tex. App.-Houston [l4th Dist.] Feb. 24, 2009, (0 rig.
proceeding) (mem. op.) (evidence pertaining to the parties' understanding of insurance policy provisions is relevant
to the insurer's defense that it acted reasonably and in good faith).
17 See e.g. In re CSX Corp., 124 S.W.3d 149, 153 (Tex. 2003) ("A request to identify all safety employees who
worked for Relators over a 30-year period, even though [plaintiff] never worked for Relators or for their parent
company for that length of time, qualifies as the kind of 'fishing expedition' this Court has repeatedly struck
down." (emphasis added». Denbury's requests are much narrower in scope and time.
18 For example, See Ironshore Topic Nos. 4, 7, 8-10, 11-15,21-23, 25, 74, 77-78, 85, 96-98, and 101-02, Exhibit P;
see also FARA Topic Nos. 4, 8-11, 13, 15, 17-18,28-30,32-37,39-40,54-59,84, 100-103, 114-15, 131-33, and
135-37, Exhibit Q.
19For example, See Ironshore Topic Nos. 1-3,7,21,24,26-29, and 36, Exhibit P; see also FARA Topic Nos. 1-3,8-
10,28,33,38-40, and 50-51, Exhibit Q.
For example, See Ironshore Topic Nos. 8-13, 34, 39-40, 61, 82, 85-92, and 101, Exhibit P; see also FARA Topic
20
Nos. 8-10,12,14,16-18,28-30,32-35,37,39-40,54-59,84, 100-03, 114-15, 131-33, and 135-37, Exhibit Q.

6
 Based on Denbury's pled claims,21 Ironshore's adjustment and underwriting of

Denbury's policy, as well as its handling of identical claims by similarly-situated policyholders

are all necessary, pertinent information. Denbury properly limits its requests to relevant time

periods and only Ironshore's handling of analogous claims?2, 23

Additionally, Ironshore publicly represents that it has "designed a more efficient system

to address and process claims." 24 lronshore's website states that "Our claims and underwriting

departments work as one unit under the same leadership team. So when timing is critical,

you're not working with an unfamiliar claims representative; you're working with experts who

21See <][<][87-88 (declaratory judgment of coverage), 89-94 (breach of contract), 105-113 (bad faith), Denbury's 2nd
Supp. Am. Pet., filed of record June 9,2015. Denbury also alleges that lronshore's marketing of the policy to oil and
gas operators (and then denial because portions of the damaged property are subject to mineral leases) constitutes an
unfair trade practice. !d. at <][<[98-104.
22 See In re Waste Management of Texas, Inc., 2011 WL 3855745 *9 (Tex. App.-Corpus Christi, 2011) (internal
citations omitted) ("In examining the appropriate breadth of discovery, it is fundamental that each lawsuit concerns a
specific claim arising from a specific set of facts. Those seeking discovery, however, are often interested in learning
about related accidents, products, or claims ... such requests might be appropriate ... depending on the relationship
between the request for production and the claims at issue in the lawsuit."); see also Allen v. Humphreys, 559
S.W.2d 798, 803 (Tex. 1977) overr14led on other grounds, Walker v. Packer, 827 S.W.2d 833 (Tex. 1992)
(approving a request for the production of "all complaints, lawsuits, or inquiries, including all correspondence,
documents, investigative reports, or any paper by which the defendant responded to these complaints, claiming that
persons have contracted cancer as a result of breathing fumes,:' because party could establish pattern of disease and
because that infonnation was "unavailable from any other source").
23 Cf, e.g., In re Allstate County Mut. Ins. Co., 227 S.W.3d at 670 (holding that requests for transcripts of all
testimony ever given by any Allstate agent on the topic of insurance; every court order finding Allstate wrongfully
adjusted the value of a damaged vehicle; personnel mes of every Allstate employee a Texas court has determined
wrongfully assessed the value of a damaged vehicle; and legal instruments documenting Allstate's status as a
corporation and its net worth were overbroad) (emphasis added); In re CSX Corp., 124 S.W.3d at 153 (stating that
request to identify all safety employees who worked for defendant over a thirty-year period qualifies as a
"fishing expedition") (emphasis added); In re Am. Optical Corp., 988 S.W.2d at 713 (stating that request for
production of all documents the defendant had ever produced on any of its products over the course of its fifty
years in business was overbroad and of questionable relevance) (emphasis added); In re Lowe's Cos., 134 S.W.3d
876,880 (Tex.App.-Houston [14th Dist.] 2004, orig. proceeding) (holding that discovery order was overbroad where
it allowed plaintiffs to access computer data without allY limitation as to time, place, or subject matter and print
data concerning falling merchandise accidents for an unlimited period of time preceding the accident in this
case and for an unlimited geographic area) (emphasis added).
24 Ironshore "U.S. Claim Brochure" p. 2, available for download at
httJ:r!lwww.ironshore.com!pdf3igeneralJlrmt~ihoreClaimsCGllatera1.pdf;Seealsowvv\v.ironsbore.com ("Ironshore
distinguishes itself in the industry by closely aligning our claim professionals with members of the underwriting,
actuarial and finance teams. This is our way of ensuring that the people who make the promises, keep the promises
and that our policyholder claims are handled in a professional and expeditious manner.") (emphasis added) (sites last
visited 9/28/15).

7
know your policy.,,25 Now, Ironshore has denied Denbury's claim and refuses to produce

documents or testimony about how its claims and underwriting departments work, or how

lronshore's "experts who know [Denbury's] policy" actually adjusted Denbury's claim.

Denbury is entitled to discover this relevant and potentially admissible information.

b. Ironshore's Unsupported Privilege Assertions

Ironshore maintains it has produced all "responsive, non-privileged" information

regarding Denbury's c1aim?6 However, a review of the "Claim Notes file" and "Claim

Documents file" show that relevant and discoverable information has been improperly
27
redacted. Additionally, Ironshore has withheld approximately 2,600 pages of Denbury's

underwriting file as "irrelevant, confidential, proprietary, trade secrets.,,28 Denbury asks the

Court order Ironshore produce all withheld documents for in camera inspection to (i) confmn the

accuracy of Ironshore's eleventh hour privilege log, and (ii) ensure Denbury is allowed to review

and depose Ironshore regarding all non-privileged and responsive documents.

"Any party who seeks to deny the production of evidence must claim a specific privilege

against such production. The burden is on the party asserting a privilege from discovery to

25 [d.
26 See Exhibit N, Denbmy's Mot. to Compel; see also Exhibit U hereto. Of note, Ironshore has provided Denbury
with "supplemental productions" dated September 4, 2015, September 18, 2015, and September 25, 2015. These
productions are not "supplemental," but a calculated piecemeal production of information and materials Denbmy is
lawfully entitled to discovery under Texas law. This Court should grant Denbury's Motion to Compel and end
Ironshore's improper discovery tactics.
27 See, e.g., F ARA 4058 (Exhibit N) (first sentence of "Recommendations" section not redacted in September 4,
2015 production and then redacted in September 25,2015 "amended" production (Exhibit U). lronshore represents it
has also produced its "Claims Document" file. However, lronshore' s production of these materials excludes large
ranges of entire pages, and its privilege logs do not allow for an accurate assessment of date range, author, recipient,
or any other identifying information necessary to determine application of privilege. Denbury has not included these
records in this filing due to size, where nearly every page produced is a duplicate of pleadings, communications, and
discovery exchanged between parties to this lawsuit.
28 See Description of withheld documents bates labeled, FARA 4084-6608, Item No. 136, lronshore "Amended
Privilege Log" produced September 25,2015, attached hereto as Exhibit T.

8
produce evidence concerning the applicability of a particular privilege.,,29 Ironshore's motions

list privileges and objections without any legal or evidentiary support. On this basis alone,

Ironshore's motions should be denied.

i. Ironsh.ore Cannot Sh.ield Responsive Materials as Work Product

Ironshore asks this Court to prevent Denbury from eliciting testimony on the basis of

"work product" privilege. 3o The disputed topics include the underwriting and interpretation of

the policies at issue, as well as IronshorelF ARA' s adjustment of Denbury' s claim?l In support,

Ironshore filed the conclusory, self-serving affidavit of its attorney Randell Treadaway on

September 25,2015. 32 This self-serving affidavit is insufficient under Texas law. 33

"Work product" is defined as: (1) "materials prepared or mental impressions developed in

anticipation of litigation or for trial by or for a party or a party's representative ... ;" or (2) "a

communication made in anticipation of litigation or for trial between a party and the party's

representatives or among a party's representatives ... ,,34 Work product only protects materials

prepared in anticipation of litigation or trial prepared by an attorney, a party, or a party's agent.

29See Peeples v. Honorable Fourth Supreme ludicial Dist., 701 S.W.2d 635, 637 (Tex. 1985) (internal citations
omitted) (emphasis added).
30See Ironshore Topic Nos. 21, 22,23,24, and 25, attached as Exhibit P; see also FARA Topic Nos. 28, 29, 30, 31,
32, 33, 34, 35, 36, 37, and 84 attached as Exhibit Q.
31See Ironshore Topic Nos. 1-3,7, 21, 24,26-29, and 36, Exhibit P; see also FARA Topic Nos. 1-3, 8-10, 28, 33,
38-40, and 50-51, Exhibit Q (underwriting); see also Ironshore Topic Nos. 4,7,8-10,11-15,21-23,25,74,77-78,
85,96-98, and 101-02, Exhibit P; see also FARA Topic Nos. 4, 8-11, 13, 15, 17-18,28-30,32-37,39-40,54-59,84,
100-103,114-15,131-33, and 135-37, Exhibit Q (Denbury's Claim).
32 See .cu . ,;.'-. .t·.GO' Five Houston Center Spring, Texas 77379
Houston, Texas 77027 1401 IVIcKirmey Street, Suite 1700 rnarc@wojolaw.com
~~~;:Js:mfI~~'.12my.{.n:~L-n~~:.g~,~!p', Houston, TX 77010
jjohnson@brownsilTls.com mriseden@craincaton.com
hK~,~HmQ:;'Tg~~~~T?j,!!,g!Ah?E!:g~g}

via U.S. Mail and/or electronic service on September 2, 2015 at or before 5:00 p.m., and the

electronic transmission was reported as complete.

00
PHILIP D. NIZIALEK

Page 3 of 18
 EXHIBIT "A"

I. Instructions

1. You are requested to produce all documents electronically. Pursuant to Rule

196.4, You are requested to produce electronic data responsive to these Requests in

tiff or pdf searchable format, including e-mail.

2. Answer each request for documents separately by listing the documents and

including in each response information that identifies the document and its bates

number.

3. For a document that no longer exists or cannot be located, identify the document,

state how and when it passed out of existence or could no longer be located, and the

reasons for the disappearance. Also, identify each person having knowledge about the

disposition or loss of the document, and identify any other document evidencing the

lost document's existence or any facts about the lost document.

a. When identifying the document, you must state the following:

i. The nature of the document (e.g. letter, handwritten note).

11. The title or heading that appears on the document.

iii. The date of the document and the date of each addendum,

00
supplement, or other addition or change.
'+-<
0
7
iv. The identities of the author, signer of the document, and person on
(l)

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whose behalf or at whose request or direction the document was
00
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prepared or delivered.
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b. When identifying the Person, you must state the following:
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1. The full name.
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 ii. The present or last known residential address and telephone

number.

111. The present or last known office address and telephone number.

IV. The present occupation, job title, employer, and employer's

address.

4. If You claim all or part of any responsive document or communication is

privileged, then You are requested to provide the appropriate information regarding

such assertion of privilege, as set forth in Tex. R. Civ. P. § 193.3.

II. Definitions

a. "Ironshore," "You" and "Your", as used herein, shall refer to Ironshore Specialty

Insurance Company and shall include, without limitation, any and all of its parents, subsidiaries,

employees, Underwriters, Adjusters, agents and attorneys.

b. "Marsh" shall refer to Marsh USA, Inc. and shall include, without limitation, any

and all of its parents, subsidiaries, employees, agents, broker, and attorneys.

c. "Zurich" shall refer to Zurich American Insurance Company and shall include,

without limitation, any and all of its parents, subsidiaries, employees, Underwriters, Adjusters,

agents and attorneys.

00
d. "AGLIC" shall refer to American Guarantee & Liability Insurance Company and

shall include, without limitation, any and all of its parents, subsidiaries, employees,

Underwriters, Adjusters, agents and attorneys.

e. "Alterra" shall refer to Alterra Excess & Surplus Insurance Company and shall

include, without limitation, any and all of its parents, subsidiaries, employees, Underwriters,

Adjusters, agents and attorneys.

Page 5 of 18
 f. "Axis" shall refer to Axis Surplus Insurance Company and shall include, without

limitation, any and all of its parents, subsidiaries, employees, Underwriters, Adjusters, agents and

attorneys.

g. "Denbury" shall refer to Denbury Resources Inc. and Denbury Onshore, LLC, or

any other Denbury entity for which Marsh procured insurance.

h. "F ARA" shall refer to FARA Insurance Services, and shall include, without

limitation, any and all of its parents, subsidiaries, employees, Underwriters, Adjusters, agents and

attorneys.

1. "CGL Policy" shall refer to the commercial general liability policy number

9242578-00, issued to Denbury by Zurich American Insurance Company, with the effective dates

of April I, 2013 to April 1, 2014.

J. "Umbrella Policy" shall refer to policy number AUC 924673-00, issued to

Denbury by AGLIe, with effective dates of April 1, 2013 to April 1,2014.

k. "Ironshore Policy" shall refer to policy number 000988602, issued to Denbury by

Ironshore, with the effective dates of April 1, 2013 to April 1, 2014.

1. "Alterra Policy" shall refer to policy number MAX6XL0000443, issued to

Denbury Alterra, with the effective dates of April I, 2013 to April 1, 2014.

00
m. "Axis Policy" shall refer to policy number EAU766369101/2013, issued to

Denbury by Axis, with the effective dates of April 1, 2013 to April 1, 2014.

n. "Policies" shall collectively refer to the CGL Policy, the Umbrella Policy, the

Ironshore Policy, the Alterra Policy and the Axis Policy, as defined above, and shall include any

and all policy registers, policy logs, schedules, forms, and endorsements.

Page 60f18
 o. "Other Insurance" shall mean any other insurance policy issued to Denbury other

than the Policies.

p. "Litigation" shall mean Denbury Resources Inc. et al v. lronshore Specialty Ins.

Co., et al. Case No. 2015-09546 currently pending in the 157th Judicial District Court in Harris

County, Texas.

q. "Delhi Incident" shall mean the control of well and pollution incident

commencing on or about June 13,2013 in the Delhi Field Unit located in the state of Louisiana.

r. "Denbury's Claim" shall mean all insurance claims, notices, demands for defense,

indemnity, or any other claim for insurance coverage related to the Delhi Incident.

s. "Blended Pollution Endorsement" shall refer to endorsements bearing the form

number U-UMB-200-A CW (7/99) and/or form number U-EXS-200-A-CW (4/99) that were

included in and made a part of the Umbrella Policy.

t. "Insurers" shall collectively refer to Zurich American Insurance Company,

American Guarantee & Liability Insurance Company, Ironshore Specialty Insurance Company,

Alterra Excess & Surplus Insurance Company, and Axis Surplus Insurance Company.

u. "Underwriting" or "Underwrites" shall mean the process of determining the

acceptability of a particular submission for insurance through evaluation and analysis of the

00
nature and extent of the risk presented, and of determining the amount, price, and conditions

under which the submission is acceptable. Underwriting and Underwrites shall further mean the

process of drafting an insurance policy to cover the accepted submission.

v. "Submission" shall mean a proposal for insurance, including but not limited to an

application, submitted for Underwriting.

Page 70flS
 w. "Adjusting" or "Adjust" or "Adjustment" shall mean administration, handling,

evaluation, analysis, investigation, review, quantification, interpretation, verification, expert

consultation, negotiation, or assessment of coverage, damages, quantum, exclusions, warranties,

or conditions related to any Claim by any Person, including but not limited to third party

administrators.

x. "On-Lease" shall refer to any surface location covered by a mineral lease where an

Energy Market policyholder is a lessee.

y. "Claim" shall mean demand to recover, under a policy of insurance, for loss that

may come within the coverage provided by that policy, including but not limited to demands for

defense, demands for indemnity, or any other request for insurance coverage under any insurance

policy. "Claim" shall also refer tothe meaning of "c1aim" contemplated by Texas Insurance Code

§ 542.051.

z. "Claims Adjuster" shall mean any Person who performs Adjusting of a Claim,

and includes Your employees and the employees of any third parties performing Adjusting of a

Claim for You.

aa. "Reserve" shall mean an estimate of the value of a Claim or group of Claims not

yet paid, including but not limited to an estimate of the amount for which a particular Claim will

00
ultimately be settled or adjudicated.

bb. "Reinsurance" shall mean a transaction in which one party, the "reinsurer," in

consideration of a premium paid to it, agrees to indemnify another party, the "reinsured," for part

or all of the liability assumed by the reinsured under a policy of insurance that it has issued.

cc. "Energy Market" shall mean Your policyholders or potential policyholders

engaged in oil, gas, and petroleum exploration and production operations.

Page 8 of 18
 dd. "Good Faith and Fair Dealing" shall mean the duties imposed by Texas Insurance

Code Chapters 541 and 542.

ee. "Original Proof of Loss" shall refer to Denbury's October 14, 2014

correspondence addressed to Ironshore's attorney, Randell E. Treadaway, and all accompanying

attachments thereto including Denbury's Sworn Proof of Loss to AGLIC executed September 29,

2014, Zurich's October 6,2014 correspondence to Denbury tendering payment of its $25 million

policy limits, and Denbury's Sworn Proof of Loss to Ironshore executed October 14, 2014.

ff. "Roberts Litigation" shall refer to the lawsuit captioned Sunflower Cemetery, Inc.,

et al. v. Denbury Onshore, LLC, et al., identified with Civil Action No. 43629A, pending in the

5th Judicial District Court for the Parish of Franklin, Louisiana.

gg. "Voluntary Payment Clause" shall refer to the provision in Ironshore's Policy that

states "The Insured shall not, except at its own expense, settle any claim or suit or incur any

defense costs for any an amount to which this Policy applies without the Insurer's written

consent."

hh. "Updated Proof of Loss" shall refer to Denbury's February 27, 2015

correspondence addressed to Ironshore's attorney, Randell E. Treadaway, and all accompanying

attachments thereto including Denbury's updated Sworn Proof of Loss to Ironshore executed

00
February 27,2015.

ii. "Owned, Rented, or Occupied Exclusion" shall refer to the provision within the

Blended Pollution Endorsement of the Umbrella Policy stating "Clean up, removal, containment,

treatment, detoxification or neutralization of "pollutants" existing at, or under or within the

boundaries of any premises, site or location owned, rented or occupied by any insured."

Page 9 of 18
 jj. "ANR" shall refer to ANR Pipeline Company, and shall include, without

limitation, any and all of its parents, subsidiaries, employees, agents and attorneys.

kk. "ANR Initial Costs Settlement" shall refer to the Agreement between ANR and

Denbury dated December 11,2013 and identified as DRI-SD-5525-5534.

11. "ANR Cut and Cap Settlement" shall refer to the Agreement between ANR and

Denbury dated September 25,2013 and identified as DRI-SD-5535-5545.

mm. "ANR Tariff Settlement" shall refer to shall refer to the Agreement between ANR

and Denbury dated February 9,2015 and identified as DRI-SD-5717-5726.

nn. "Loutre Land Settlement" shall refer to the Agreement between Loutre Land and

Timber Company and Denbury dated June 3, 2014 and identified as DRI-SD-5593-5612.

00. "Impacted Areas" shall refer to any premises, site or location with any discharge,

dispersal, seepage, migration, release or escape of any man-made or naturally occurring solid,

liquid, gaseous or thermal irritant or contaminant, including but not limited to: smoke; vapor;

soot; fumes; acids; alkalis; chemicals; and waste.

pp. "Communications" shall mean the transmission, sending, and/or receipt of

information of any kind by and/or through any means, whether face-to-face or otherwise,

including, but not limited to, speech, writings, language (machine, foreign, or otherwise), or

00 recording.

qq. "Document" means all written, typed, or printed matter and all electronic,

magnetic, digital, or other records or documentation of any kind or description in your actual

possession, custody, or control, including those in the possession, custody, or control of any and

all present or former directors, officers, employees, consultants, accountants, attorneys, or other

agents, whether or not prepared by you. "Document" includes, but is not limited to, the

Page 10 of 18
following: Communications, policies, schedules, calendars, spreadsheets, letters, reports, charts,

diagrams, correspondence, memoranda, notes, records, minutes, contracts, agreements, records or

notations of telephone or personal conversations or conferences, interoffice communications,

intraoffice communications, e-mail, voicemail, microfilm, bulletins, circulars, pamphlets,

photographs, faxes, invoices, recordings, computer printouts, drafts, resumes, logs, and

worksheets.

rr. "Electronic" or "magnetic" data means electronic or digital information that is

stored in a medium from which it can be retrieved and examined. The term refers to the original

(or identical duplicate when the original is not available) and any other copies of the data that

may have attached comments, notes, marks, or highlighting of any kind. Electronic or magnetic

data includes, but is not limited to, the following: computer programs; operating systems;

computer activity logs; programming notes or instructions; e-mail receipts, messages, or

transmissions; output resulting from the use of any software program, including word-processing

documents, spreadsheets, database files, charts, graphs, and outlines; metadata; PIP and PDP

files; batch files; deleted files; temporary files; Intemet- or web-browser-generated information

stored in textual, graphical, or audio format, including _history files, caches, and cookies; and any

miscellaneous files or file fragments. Electronic or magnetic data includes any items stored on

magnetic, optical, digital, or other electronic-storage media, such as hard drives, floppy disks,

CD-ROMs, DVDs, tapes, smart cards, integrated-circuit cards (e.g., SIM cards), removable

media (e.g., Zip drives, thumb drive), microfiche, or punched cards. Electronic or magnetic data

also includes the file, folder, tabs, containers, and labels attached to or associated with any

physical storage device with each original or copy.

Page 11 of 18
 ss. "E-mail" or "Electronic Mail" shall mean any method of electronic messaging,

including any text message and instant-messaging method or service.

it. The term "each" includes the word "every" and "every" includes the word "each."

uu. The term "and" includes the word "or" and "or" includes the word "and."

vv. The term "including" shall be construed as broadly as possible and shall mean

"without limitation."

ww. "Person" shall mean any natural person, corporation, firm, association,

partnership, joint venture, proprietorship, governmental body, governmental agency, or any other

organization, business, or legal entity, and all predecessors or successors in interest.

xx. The phrase "related to or discussing," as used herein, shall mean all information

and all facts andlor Documents that directly, indirectly or in any other way support, negate, bear

upon, touch upon, incorporate, affect, include, pertain to, andlor are otherwise connected with the

subject matter about which a request is being made.

DOCUMENTS

1. A copy of deponent's current resume or curriculum vitae;

2. A copy of deponent's current driver's license or government-issued photo identification;

3. A copy of each and every document reviewed in preparation for Your testimony at the
scheduled deposition; and
00

4. All Documents responsive to Denbury's First and Second Sets of Requests for Production
served on May 18,2015 and August 5,2015; and

5. All Documents responsive to the Examination Topics listed below.

EXAMINATION TOPICS

1. Denbury.

2. Denbury's operations.

Page 12 of 18
 3. The risks presented by Denbury's operations.

4. The Delhi Incident.

5. The Policies.

6. Reserves under the Policies.

7. The Blended Pollution Endorsement.

8. The case Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960 (5th Cir. 2010).

9. The case Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL 3557541 (W.D. La.
2013).

10. The case Pioneer Exploration, L.L.c. v. Steadfast Ins. Co., 767 F.3d 503 (5th Cir. 2014).

11. Ironshore's application of the Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx.
960 (5th Cir. 2010) decision to its liability policies.

12. Ironshore's application of the Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL
3557541 (W.D. La. 2013) decision to its liability policies.

13. Ironshore's application of the Pioneer Exploration, L.L.c. v. Steadfast Ins. Co., 767 F.3d
503 (5th Cir. 2014) decision to its liability policies.

14. Ironshore's relationship with Denbury's Insurers.

15. Ironshore's Communications with Denbury's Insurers.

16. Ironshore's review of any Adjustment ofDenbury's Claim.

17. Ironshore's relationship with Marsh.

00 18. Ironshore's Communications with Marsh.
"""'0
M 19. Ironshore's relationship with Denbury.

i-:
~S

In accordance with Texas Govel:nment Code 406JH3 efiecttonicaDy transmitted authenticated
doc!tlments are valid. If there is a question regarding the validity of this document and or seal
please ~man support@hcdistrictde:rk.com
 r"""T5~~I:~'t)l~j';~~?s"§7~~'8Tr5"f:~~;S'~}()'~ls~;"to"'f~~~{~'l~;8'st~~(rF)I:'(}E~(3j:T\;~~~"{5;~a8;~s'1
~ ~
t. . . . . . . . . . ". .,. . . ,',. . ". . . . . . .,. .". . . . . . . . . . . . . . . . . . . . . . . . . . ,.,.,.,. ",. . . :.,. . .,.;. . . . . . . . . . . . . .,. . . . .:. . . .,. . . . ,.:. . ,. . .,.,.,.:. . . ,'. .;. . . .,. . . . .,. . . . .,.". '.:. " ,. .,.:.:.,.,. . ,.,. . . . . . . .,;. . . .,. . . . '" . .,. . .,.:. . .:.:. .". . :.,.,.,.,.,.,. .,.,.,. . . ,;. . . . . .:. .,. . . . . . . . :.,. , '. ". .,. ,',.,. ,',.,.J

CAUSE NO. 2015-09546

DENBURY RESOURCES INC. and IN THE DISTRICT COURT
DENBURY ONSHORE, LLC

Plaintiffs,
HARRIS COUNTY, TEXAS
v.

IRONSHORE SPECIALTY INSURANCE
COMPANY, ALTERRA EXCESS & 157th JUDICIAL DISTRICT
SURPLUS INSURANCE COMPANY,
AXIS SURPLUS INSURANCE
COMPANY, AND MARSH USA INC.

Defendants

NOTICE OF ORAL AND VIDEOTAPED DEPOSITION AND REQUEST FOR
DOCUMENTS OF THE DESIGNATED CORPORATE REPRESENTATIVE(S) OF
F.A. RICHARD & ASSOCIATES, INC. ("FARA")

TO: F.A. Richard & Associates, Inc.
through its attorneys of record,
Mark C. Clemer
James D. Johnson
Brown Sims, P.C.
1177 West Loop South
Tenth Floor
Houston, Texas 77027
-And-
o
N
Randell E. Treadaway
'-I-;
o Brad D. Ferrand
Michelle O'Daniels
Zaunbrecher Treadaway, LLC
406 N. Florida Street, Suite 2
Covington, Louisiana 70443

I.
PLEASE TAKE NOTICE that, pursuant to Texas Rule of Civil Procedure 199.2(b)(1) and

199.2(b)(5), Denbury Resources Inc. and Denbury Onshore, LLC, will take the oral and videotaped
deposition of the designated Corporate Representative of EA. Richard & Associates, Inc.

("FARA"), on October 21, 2015, commencing at 1:00 p.m. at the law offices of Pillsbury

Winthrop Shaw Pittman, LLP, 1540 Broadway Avenue, New York, New York 10036, by

agreement ofthe parties.

II.
FARA's designee(s) is further directed to produce responsive documents to the requests

listed in Exhibit "A" within thirty (30) days of service of this notice.

1II.
The deposition will continue from day to day until completed.

N.
The deposition will be recorded stenographically and on videotape. The stenographic and

video recordings will be conducted by Kay E. Donelly & Associates.

Respectfully submitted,

. /.;::~~:;£~f~i~~;?~:~:~l··;i(·;:::~:;~:~~::=·:::::'::::,;> x~,,;
PIDLIP Ib:"NIZIALEK::T~jt"(#i5045250r
SARAH E. STOGNER (#24091139)
JACQUELINE M. BRETTNER (pro hac vice)
Carver, Darden, Koretzky, Tessier, Finn,
Blossman, & Areaux, L.L.c.
1100 Poydras Street, Suite 3100
New Orleans, Louisiana 70163
Telephone: (504) 585-3800
Facsimile: (504) 585-3801
Email: nizlalek@carverdarden.com
stogner@carverdarden.com
brettner@' carverdarden .com
Counsel for Plaintiffs

Page 2 of 20
 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the Denbury's Notice of Oral and Videotaped

Deposition of Corporate Representative(s) of F.A. Richard & Associates, Inc. has been served on

the following:

Mr. Randell E. Treadaway Mr. Christopher C. Frost Mr. Michael Knippen
Ms. Michelle O'Daniels Mr. Michael Mulvaney Mr. David Rock
NfL Brad D. Ferrand 1.'1/1r. Joshua It Baker Mr. James M. Eastham
Zaunhrecher Treadaway, LLC Maynard, Cooper, Gale Traub LiehelTfwn Straus &
406 N. l'lorida Street, Suite 2 1901 Sixth Avenue, Suite 2400 ShrcYvsbeny, lLP
Covington, LA 70433 Binnil1ghaIn, AL 35203 303 West Madison St., Ste. 1200
mn,Qy.qR.?;tl:~hn¥.:.~~n-g ~:fl:mlt~i;'i.l;Q!AY.D.?1:!!.9g~~b~~I&QXn Chicago, IL 60606
lXlodle!:YaI@ grmliL corn rmnulvanev@mavndardcoopeLcom rnknippen@traublieberman.com
bI?~;t~¥:z:t\!!,\r~,\y':q;:!r: jJ??,!sf;I~~.Q}!!y.mmt~~,~!mf;r.:9~?m jg!!,slnwmqR.p.:!mNtf;b~nnfm.,9gXn
arock@traubliebennau.com

Mr. Mark C. Clemer IVIs. Mindy Riseden lVil". Marc J. Wojci.ecbowski
Mr. James Johnson Mr. Henry KoUenberg Vlojciechowski & Associates, PC
fJrovm Sims Crain. Caton & James 17447 Kuykendalll Rd. Ste. 200
1177 West Loop South, 10tt; Floor Five Houston Center Spring, Texas 77379
Houston, Texas 77027 1401 :McKinney Street, Suite 1700 marc@vv'oiolaw.com
m~:t~m~IP;J.l~!:Qy.{.m;.L1]}~:g;:m Houston, TX 77010
ijohnson (robrownsiuls.com mriseden@craincaton.com
N~~,~U~c11b.~1:g§;~~~n~j,!!S:!Argn:.~~,~m

via U.S. Mail and/or electronic service on September 3, 2015 at or before 5:00 p.m., and the

electronic transmission was reported as complete.

PHILIP D. NIZIALEK

Page 3 of 20
 EXHIBIT "A"

I. Instructions

1. You are requested to produce all documents electronically. Pursuant to Rule

196.4, You are requested to produce electronic data responsive to these Requests in

tiff or pdf searchable format, including e-mail.

2. Answer each request for documents separately by listing the documents and

including in each response information that identifies the document and its bates

number.

3. For a document that no longer exists or cannot be located, identify the document,

state how and when it passed out of existence or could no longer be located, and the

reasons for the disappearance. Also, identify each person having knowledge about the

disposition or loss of the document, and identify any other document evidencing the

lost document's existence or any facts about the lost document.

a. When identifying the document, you must state the following:

i. The nature of the document (e.g. letter, handwritten note).

ii. The title or heading that appears on the document.

iii. The date of the document and the date of each addendum,

0
supplement, or other addition or change.
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 11. The present or last known residential address and telephone

number.

111. The present or last known office address and telephone number.

IV. The present occupation, job title, employer, and employer's

address.

4. If You claim all or part of any responsive document or communication is

privileged, then You are requested to provide the appropriate information regarding

such assertion of privilege, as set forth in Tex. R. Civ. P. § 193.3.

II. Definitions

a. "FARA, " "You" and "Your", as used herein, shall refer to F.A. Richard &

Associates, Inc. and shall include, without limitation, any and all of its parents, subsidiaries,

employees, Underwriters, Adjusters, agents and attorneys.

b. "Marsh" shall refer to Marsh USA, Inc. and shall include, without limitation, any

and all of its parents, subsidiaries, employees, agents, broker, and attorneys.

c. "Zurich" shall refer to Zurich American Insurance Company and shall include,

without limitation, any and all of its parents, subsidiaries, employees, Underwriters, Adjusters,

agents and attorneys.

d. "AGLIC" shall refer to American Guarantee & Liability Insurance Company and

shall include, without limitation, any and all of its parents, subsidiaries, employees,

Underwriters, Adjusters, agents and attorneys.

e. "Alterra" shall refer to Alterra Excess & Surplus Insurance Company and shall

include, without limitation, any and all of its parents, subsidiaries, employees, Underwriters,

Adjusters, agents and attorneys.

Page 50f20
 f. "Axis" shall refer to Axis Surplus Insurance Company and shall include, without

limitation, any and all of its parents, subsidiaries, employees, Underwriters, Adjusters, agents and

attorneys.

g. "Denbury" shall refer to Denbury Resources Inc. and Denbury Onshore, LLC, or

any other Denbury entity for which Marsh procured insurance.

h. "Iron shore" shall refer to Ironshore Specialty Insurance Company, and shall

include, without limitation, any and all of its parents, subsidiaries, employees, Underwriters,

Adjusters, agents and attorneys.

1. "CGL Policy" shall refer to the commercial general liability policy number

9242578-00, issued to Denbury by Zurich American Insurance Company, with the effective dates

of Aprill, 2013 to April!, 2014.

j. "Umbrella Policy" shall refer to policy number AUC 924673-00, issued to

Denbury by AGLIC, with effective dates of Aprill, 2013 to Aprill, 2014.

k. "Ironshore Policy" shall refer to policy number 000988602, issued to Denbury by

Ironshore, with the effective dates of April 1, 2013 to Aprill, 2014.

1. "Alterra Policy" shall refer to policy number MAX6XL0000443, issued to

Denbury Alterra, with the effective dates of April 1, 2013 to Aprill, 2014.

m. "Axis Policy" shall refer to policy number EAU766369/0 1120 13, issued to

Denbury by Axis, with the effective dates of Aprill, 2013 to April 1, 2014.

n. "Policies" shall collectively refer to the CGL Policy, the Umbrella Policy, the

Ironshore Policy, the Alterra Policy and the Axis Policy, as defined above, and shall include any

and all policy registers, policy logs, schedules, forms, and endorsements.

Page 60f20
 o. "Other Insurance" shall mean any other insurance policy issued to Denbury other

than the Policies.

p. "Litigation" shall mean Denbury Resources Inc. et al v. Ironshore Specialty Ins.

Co., et al. Case No. 2015-09546 currently pending in the 157th Judicial District Court in Harris

County, Texas.

q. "Delhi Incident" shall mean the control of well and pollution incident

commencing on or about June 13,2013 in the Delhi Field Unit located in the state of Louisiana.

r. "Denbury's Claim" shall mean all insurance claims, notices, demands for defense,

indemnity, or any other claim for insurance coverage related to the Delhi Incident.

s. "Blended Pollution Endorsement" shall refer to endorsements bearing the form

number U-UMB-200-A CW (7/99) and/or form number U-EXS-200-A-CW (4/99) that were

included in and made a part of the Umbrella Policy.

t. "Insurers" shall collectively refer to Zurich American Insurance Company,

American Guarantee & Liability Insurance Company, Ironshore Specialty Insurance Company,

Alterra Excess & Surplus Insurance Company, and Axis Surplus Insurance Company.

u. "Underwriting" or "Underwrites" shall mean the process of determining the

acceptability of a particular submission for insurance through evaluation and analysis of the

nature and extent of the risk presented, and of determining the amount, price, and conditions

under which the submission is acceptable. Underwriting and Underwrites shall further mean the

process of drafting an insurance policy to cover the accepted submission.

v. "Submission" shall mean a proposal for insurance, including but not limited to an

application, submitted for Underwriting.

Page 70f20
 w. "Adjusting" or "Adjust" or "Adjustment" shall mean administration, handling,

evaluation, analysis, investigation, review, quantification, interpretation, verification, expert

consultation, negotiation, or assessment of coverage, damages, quantum, exclusions, warranties,

or conditions related to any Claim by any Person, including but not limited to third party

administrators.

x. "On-Lease" shall refer to any surface location covered by a mineral lease where an

Energy Market policyholder is a lessee.

y. "Claim" shall mean demand to recover, under a policy of insurance, for loss that

may come within the coverage provided by that policy, including but not limited to demands for

defense, demands for indemnity, or any other request for insurance coverage under any insurance

policy. "Claim" shall also refer tothe meaning of "claim" contemplated by Texas Insurance Code

§ 542.051.

z. "Claims Adjuster" shall mean any Person who performs Adjusting of a Claim,

and includes Your employees and the employees of any third parties performing Adjusting of a

Claim for You.

aa. "Reserve" shall mean an estimate of the value of a Claim or group of Claims not

yet paid, including but not limited to an estimate of the amount for which a particular Claim will

ultimately be settled or adjudicated.

bb. "Reinsurance" shall mean a transaction in which one party, the "reinsurer," in

consideration of a premium paid to it, agrees to indemnify another party, the "reinsured," for part

or all of the liability assumed by the reinsured under a policy of insurance that it has issued.

cc. "Energy Market" shall mean Your policyholders or potential policyholders

engaged in oil, gas, and petroleum exploration and production operations.

Page 8 of 20
 dd. "Good Faith and Fair Dealing" shall mean the duties imposed by Texas fusurance

Code Chapters 541 and 542.

ee. "Original Proof of Loss" shall refer to Denbury's October 14, 2014

correspondence addressed to Ironshore's attorney, Randell E. Treadaway, and all accompanying

attachments thereto including Denbury's Sworn Proof of Loss to AGLIC executed September 29,

2014, Zurich's October 6,2014 correspondence to Denbury tendering payment of its $25 million

policy limits, and Denbury's Sworn Proof of Loss to Ironshore executed October 14,2014.

ff. "Roberts Litigation" shall refer to the lawsuit captioned Sunflower Cemetery, Inc.,

et al. v. Denbury Onshore, LLC, et al., identified with Civil Action No. 43629A, pending in the

5th Judicial District Court for the Parish of Franklin, Louisiana.

gg. "Voluntary Payment Clause" shall refer to the provision in Ironshore's Policy that

states "The fusured shall not, except at its own expense, settle any claim or suit or incur any

defense costs for any an amount to which this Policy applies without the fusurer's written

consent."

hh. "Updated Proof of Loss" shall refer to Denbury's February 27, 2015

correspondence addressed to Ironshore's attorney, Randell E. Treadaway, and all accompanying

attachments thereto including Denbury's updated Sworn Proof of Loss to Ironshore executed

Febmary 27,2015.

ii. "Owned, Rented, or Occupied Exclusion" shall refer to the provision within the

Blended Pollution Endorsement of the Umbrella Policy stating "Clean up, removal, containment,

treatment, detoxification or neutralization of "pollutants" existing at, or under or within the

boundaries of any premises, site or location owned, rented or occupied by any insured."

Page 90f20
 jj. "ANR" shall refer to ANR Pipeline Company, and shall include, without

limitation, any and all of its parents, subsidiaries, employees, agents and attorneys.

kk. "ANR fuitial Costs Settlement" shall refer to the Agreement between ANR and

Denbury dated December 11,2013 and identified as DRI-SD-5525-5534.

11. "ANR Cut and Cap Settlement" shall refer to the Agreement between ANR and

Denbury dated September 25, 2013 and identified as DRI-SD-5535-5545.

mm. "ANR Tariff Settlement" shall refer to shall refer to the Agreement between ANR

and Denbury dated February 9, 2015 and identified as DRI-SD-57 17-5726.

nn. "Loutre Land Settlement" shall refer to the Agreement between Loutre Land and

Timber Company and Denbury dated June 3, 2014 and identified as DRI-SD-5593-5612.

00. "Impacted Areas" shall refer to any premises, site or location with any discharge,

dispersal, seepage, migration, release or escape of any man-made or naturally occurring solid,

liquid, gaseous or thermal irritant or contaminant, including but not limited to: smoke; vapor;

soot; fumes; acids; alkalis; chemicals; and waste.

pp. "Communications" shall mean the transmission, sending, and/or receipt of

information of any kind by and/or through any means, whether face-to-face or otherwise,

including, but not limited to, speech, writings, language (machine, foreign, or otherwise), or

o
N
recording.
'+-;
o
o qq. "Document" means all written, typed, or printed matter and all electronic,

magnetic, digital, or other records or documentation of any kind or description in your actual

possession, custody, or control, including those in the possession, custody, or control of any and

all present or former directors, officers, employees, consultants, accountants, attorneys, or other

agents, whether or not prepared by you. "Document" includes, but is not limited to, the

Page 10 of 20
following: Communications, policies, schedules, calendars, spreadsheets, letters, reports, charts,

diagrams, conespondence, memoranda, notes, records, minutes, contracts, agreements, records or

notations of telephone or personal conversations or conferences, interoffice communications,

intraoffice communications, e-mail, voicemail, microfilm, bulletins, circulars, pamphlets,

photographs, faxes, invoices, recordings, computer printouts, drafts, resumes, logs, and

worksheets.

IT. "Electronic" or "magnetic" data means electronic or digital information that is

stored in a medium from which it can be retrieved and examined. The term refers to the original

(or identical duplicate when the original is not available) and any other copies of the data that

may have attached comments, notes, marks, or highlighting of any kind. Electronic or magnetic

data includes, but is not limited to, the following: computer programs; operating systems;

computer activity logs; programming notes or instructions; e-mail receipts, messages, or

transmissions; output resulting from the use of any software program, including word-processing

documents, spreadsheets, database files, charts, graphs, and outlines; metadata; PIP and PDP

files; batch files; deleted files; temporary files; Internet- or web-browser-generated information

stored in textual, graphical, or audio format, including history files, caches, and cookies; and any

miscellaneous files or file fragments. Electronic or magnetic data includes any items stored on

magnetic, optical, digital, or other electronic-storage media, such as hard drives, floppy disks,

CD-ROMs, DVDs, tapes, smart cards, integrated-circuit cards (e.g., SIM cards), removable

media (e.g., Zip drives, thumb drive), microfiche, or punched cards. Electronic or magnetic data

also includes the file, folder, tabs, containers, and labels attached to or associated with any

physical storage device with each original or copy.

Page 11 of 20
 ss. "E-mail" or "Electronic Mail" shall mean any method of electronic messaging,

including any text message and instant-messaging method or service.

tt. The term "each" includes the word "every" and "every" includes the word "each."

uu. The term "and" includes the word "or" and "or" includes the word "and."

vv. The term "including" shall be construed as broadly as possible and shall mean

"without limitation."

ww. "Person" shall mean any natural person, corporation, firm, association,

partnership, joint venture, proprietorship, governmental body, governmental agency, or any other

organization, business, or legal entity, and all predecessors or successors in interest.

xx. The phrase "related to or discussing," as used herein, shall mean all information

and all facts and/or Documents that directly, indirectly or in any other way support, negate, bear

upon, touch upon, incorporate, affect, include, pertain to, and/or are otherwise connected with the

subject matter about which a request is being made.

DOCUMENTS

1. A copy of deponent's current resume or curriculum vitae;

2. A copy of deponent's current driver's license or government-issued photo identification;

3. A copy of each and every document reviewed in preparation for Your testimony at the
scheduled deposition;

4. All Documents responsive to Denbury' s First and Second Sets of Requests for Production
served on May 18, 2015 and August 5, 2015; and

5. All Documents related to or discussing the Examination Topics listed below.

EXAMINATION TOPICS

1. Denbury.

2. Denbury's operations.

Page 12 of 20
 3. The risks presented by Denbury's operations.

4. The Delhi Incident.

5. The Policies.

6. Reserves under the Policies.

7. The Blended Pollution Endorsement.

8. The case Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960 (5th Cir. 2010).

9. The case Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL 3557541 (W.D. La.
2013).

10. The case Pioneer Exploration, L.L.c. v. Steadfast Ins. Co., 767 F.3d 503 (5th Cir. 2014).

11. FARA's application of the Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960
(5th Cir. 2010) decision to the Ironshore Policy.

12. FARA's application of the Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960
(5th Cir. 2010) decision to Other Liability Policies.

13. FARA's application of the Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL
3557541 (W.D. La. 2013) decision to the Ironshore Policy.

14. FARA's application of the Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL
3557541 (W.D. La. 2013) decision to Other Liability Policies.

15. FARA's application of the Pioneer Exploration, L.L.C. v. Steadfast Ins. Co., 767 F.3d
503 (5th Cir. 2014) decision to the Ironshore Policy.

16. FARA's application of the Pioneer Exploration, L.L.c. v. Steadfast Ins. Co., 767 F.3d
503 (5th Cir. 2014) decision to the Other Liability Policies.
0
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17. F ARA' s relationship with Denbury' s Insurers.
M

;::l
]! Plincipal at Clark County
Senior Litigation Adjuster School Oistlict
Specially Claims Management
August 2001 - April 2014 (12 years 9 months) I Saddle Brook/Secauctls,New Jersey
Brian Davis
FirefighterlParamedlc
I handled liligated and non-litigated claims througoollt the United States for NaUooal Accounts, Primary
and Excess Insurance Companies, Risk Retention Groups, and Self-Insured clients. The types of claims I
have handled include prernisBsliability. environmental claims, excess umbrella claims, construction Kent Swartzlander
defect, as well as somB New York State labor law li\i..qation. Duties included account management, Baltalion Chief al Chester Fire Dept
analyzing coverage issues, drafting coverage position letters, monitoring UUgation, and preparing Large
Loss Advisories. The position also entailed performing legal billing reviews for self insur~ clients.
Attendance at trials and mediations is sometimes required. I am licensed in New York, Texas, and Pr[scllla Tom
Sr. CRenl Representative at Marsh
Florida
Risk & Insurance Servi<:oo

Claims Officer/litigation Examiner Kevin Williams
Unit Manager, Auto liability Major
Chubb insurance
Cas<> !II Travelers
March 1009 - August 2001 (12 years (> months) I New Prnliidence/F[orham Park! Warren New Jersey

I handled and monitored litigated and non-litigated claims throughout the New Jersey/New York Jaffrey Petway
Metropolitan region. The types of claims I hanQled included general liability , excess! umbrella, as well as Claims Representalive al The Besi
Insurance RecruiUng Specialist - Stat"
Borne errors and omissKlOs litigation. Tho position involved evaluating complex coverage issues, {jraftiflg Farm
coverage position lelters. coordinating file invesligations, evaluating !iability and, negotiatlng setllementa.
Bob Galluwi
My dulies also included preparing cases for lrial as wei! as attendance at settlement conferences,
Senior Consultant at Lombard
mediations, and Irials. Consulting

Kirkland McKenzie
Suit Examiner Senior CD Specialist at QBE
General Accident Insurance Company Insurance
March 1985 - March 1989 (4 years 1 monlh) I New York. New York

1 Handled litigated generalliabili\y and labor law claims in New York, Bronx, Kings, Queens and Paul Eilers
Assistant Vice Pre$ideol at RLl
Richmond Counties. Duties included coordinaling file invesligajions; evaluating liability, and preparing
Insuraru:e Company
cases for trial. In addition to f!egotiating settlements. the position entailed attending settlement
conferences and monitoring ongoing trials.

II Certifications

I possess an adjuster's license in New York, Texa~, and Florida

https:llwww.linkedin.com/profile/preview?locale=e~US&trk=prof-O-sb-preview-primary-., , 9/1412015
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Tom also knows about._.

Commercial Lines Coverage Environmental Mediation

Product liability Trials Litigation Public LiaMily

Worke.s Compensation Insurance law Property Damage

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1/1 Education

West Virginia Wesleyan College
Bachelor's degree, Political Science and Government
Ac1ivities and SOCieties: DebateTeam

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• Advice for Contacting Tom
please e-mail meatdevine8@optonllne.net

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'}.

:Defertdants §

AFF'l:oAV):r Of~LF;El'.Sa:EldI)AN

S'fAl'EOF NEr.irYORK §
§
GPUl\jTY QFN:EW 'YORK §

BEFQREME, the 'undersigned authority, on this day persqnaily (ippeaped

:L rvrx.name i~ .L~e'T,$heri(i~t1-.J }~rllA$$i~tant Vi~G-Pre8id¢nt pfSl)edalty' Casualty
Cli,lirns . ;'1i IrOil$hore $pt;cia!ty 111~:Up:l.m:;eGotnpany ('i.Jronsh{)re~)" r a~!l()yer.twcnty~
oue{(1) years of age, of soundmiml,an4(itllet\:vi~~cPJl1pet(;)nt tP111a'Ke thi$(j:fJ:ldavit,
I hAVe p¢rsoPt)L k!1('!\vledge ofthet1tctS stated inthis affidavit; and tll~y ot dis¢~s$ihg pollution ck.an'-up
OJ)
«j Undm'Nriting tor tlw.l:SllergyMarket;Vn~k~rwritil1gfQr th¢ ht1i.1shore.Pdicy at issu(~ill
~
thisJitig?tJon;1)HderwritillgofanY rn:msh(fr~r()liGy.pt(l\'1siol1 that. eX!Jludes. coverage
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for Dehbuty's daim; any S:tJbmissioJ:l f{,)rin~uImw.e. 1cU1,d¢tth~ -fo.uci~;aocttl11~nt$
related t(i QX (nsc~:lSshig JrortshoreTsreInsw:ance; .and . al1doCUll1Cnts related tq or
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di~cnssing how Irm;i$hoteunqenvtites EtlergYMarketin~ul'.a:nCG J{)l" th¢ last 5 years,
;..;
H,TbJ,)~e 111at~daIs my official hand al1d seal of office
this October 22. 2015

Ce:rt:iJied Document Number: 67238731

Chris D;nllel, DISTRICT CLERK
HARRIS COUNTY, TL'L\S

In accordance with Texas Government Code 406.013 eledronically transmitted authenticated
docu.ments are valid. If there is a question regarding the validity of this. document and or seal
please e-:mail.support@.hcdistrictderk.com
 CAUSE NO. 2015-09546

DENBURY RESOURCES INC. and § IN THE DISTRICT COURT
DENBURY ONSHORE, LLC §
§
Plaintiffs §
VS. § 157 th JUDICIAL DISTRICT
§
IRONSHORE SPECIALTY INSURANCE §
COMPANY, ALTERRA EXCESS & §
SURPLUS INSURANCE COMPANY, §
AXIS SURPLUS INSURANCE § HARRIS COUNTY, TEXAS
COMPANY, and MARSH USA INC. §
§
Defendants §

IRONSHORE SPECIALTY INSURANCE COMPANY'S
AMENDED PRIVILEGE LOG

COMES NOW, Defendant Ironshore Specialty Insurance Company (hereinafter

"Iron shore" or "Defendant"), pursuant to Rule 193.3 of the Texas Rules of Civil Procedure, and

submits the following Amended Privilege Log describing information and/or material withheld

from production; the date and a description of the material; and the privilege or privileges asserted:

Item FARA BATES DATE Description of Document Privilege

0001 08/04115 F ARA Invoice to Ironshore Irrelevant
Atty. Client

2 0002 - 0018 06/30/15 Correspondence from Defense Counsel to F ARA Work Product
Re: Invoices Atty. Client
Irrelevant

3 0019 07/06/15, Correspondence between F ARA & Ironshore Work Product
07/14115 Re: Invoices Atty. Client
Irrelevant

4 0020 - 0024 06/24/15, Corresp. between Defense Counsel, FAR A & lronshore Work Product
07/06/15, Re: F ARA file; Defense Counsel Memorandum Atty. Client
07114/15

5 0047 - 0048 06/24/15 Defense Counsel Litigation Budget to F ARA & Ironshore Work Product
Atty. Client
Irrelevant

1
rn"~'1~~x'fl'II1~t";;~r~;;''''''''''1
~
~ ,~
~,.............,.....................,......., ...." ........................................................................~
 6 0049 - 0050 06/24115, Corresp. between Defense Counsel, F ARA & Ironshore Work Product
07114115 Re: Litigation Budget Atty. Client
Irrelevant

7 0051 - 0069 06/24115 Legal Memorandum to FARA and Ironshore Work Product
Atty. Client

8 0076 - 0184 Undated Legal Memorandum prepared by Defense Counsel Work Product

9 0241 - 0242 06/24115, Corresp. between Defense Counsel, FARA & Ironshore Work Product
07114115 Re: File Materials; Legal Memorandum Atty. Client

10 0243 - 0249 06116115, Corresp. between Defense Counsel, FARA & Ironshore Work Product
07/14/15 Re: Legal Memorandum Atty. Client

11 0255 - 0259 06/16115 Legal Memorandum prepared by Defense Counsel Work Product

12 0260 - 0262 06/16115 Corresp. from Defense Counsel to FARA & Ironshore Work Product
Re: Legal Memorandum Atty. Client

13 0267 - 0285 06/24115 Legal Memorandum prepared by Defense Counsel Work Product
Atty. Client

14 0308 - 0309 06/24115 Defense Counsel Litigation Budget Work Product
Atty. Client
IITelevant

15 0310 06/24115 Corresp. from Defense Counsel to F ARA & Ironshore Work Product
Re: Exhibits attached to Legal Memorandum Atty. Client

16 0311-0329 06/24115 Legal Memorandum prepared by Defense Counsel Work Product
Atty. Client

17 0336-0444 Undated Legal Memorandum prepared by Defense Counsel Work Product

18 0501- 0505 06/16115, Corresp. from Defense Counsel to FARA & lronshore Work Product
06/24115 Re: Legal Memorandum Atty. Client

19 0511- 0515 06116/15 Legal Memorandum prepared by Defense Counsel Work Product
('I
20 0516 06/09115 F ARA Invoice to Ironshore Irrelevant
'+-<
0
Atty. Client
('I
Q)
01) 21 0517 - 0520 05/04115- Corresp. between Defense Counsel, FARA & Ironshore Work Product
CI:l
0... 05/06115 Re: Litigation update Atty. Client
M
M
t- 22 0521 - 0523 05/08115 Legal Memorandum draft prepared by Defense Counsel Work Product
oo
M
('I
t-
\0
23 0601 - 0621 05111115 Defense Counsel Invoice to F ARA Work Product
;..; Atty. Client
Q)
,..c Irrelevant
§
Z 24 0622 - 0623 05/27115 F ARA Invoice to Ironshore Irrelevant
"ElQ) Atty. Client
§
u
0
0 2
"0
Q)
1.1::
'-2
Q)
u
 25 0624 - 0660 03/09/15, Defense Counsel Invoices to FARA Work Product
04/06/15 Atty. Client
Irrelevant

26 0661 OS/27/15 F ARA Invoice to Ironshore Irrelevant
Atty. Client

27 0662 OS/22/15 Proposed Reserves Irrelevant

28 0663 - 0665 04/02115 Corresp. between Defense Counsel, FARA & Ironshore Work Product
Re: Draft Pleadings Atty. Client

29 0683 - 0684 03/27/15 Correspondence from Board of Law Examiners, TX Irrelevant
Re: Non-resident acknowledgement letter

30 0685 - 0686 04/01115 Correspondence between Defense Counsel Work Product
Re: Case Strategy; Draft Pleadings

31 0694 - 0696 04/01115 Correspondence between Defense Counsel and Ironshore Work Product
Re: Case Strategy; Draft Pleadings Atty. Client

32 0704 - 0706 04/01/15 Correspondence between Defense Counsel and Ironshore Work Product
Re: Case Strategy; Draft Pleadings Atty. Client

33 0707 - 0714 Undated Draft Pleadings prepared by Defense Counsel Work Product

34 0741 - 0742 04/02/15 Corresp. from Defense Counsel to FARA & lronshore Work Product
Re: Draft Pleadings Atty. Client

35 0751 - 0752 04/06/15 Corresp. from Defense Counsel to FARA & Ironshore Wark Product
Re: Draft Pleadings; Defense Investigation Atty. Client

36 0753 - 0755 04/06/15 Corresp. between Defense Counsel, FARA & Ironshore Wark Product
Re: Draft Pleadings Atty. Client

37 0756 - 0768 Undated Draft Pleadings prepared by Defense Counsel Work Product

38 0769 - 0771 05/04/15 Corresp. from Defense Counsel to FARA & Ironshare Work Product
Re: Legal Memorandum Atty. Client

39 0773 - 0775 03/16/15 Corresp. from Defense Counsel to FARA & Ironshore Work Product
N
Re: Legal Memorandum Atty. Client
'+-<
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M 40 0844 - 0847 10/21/14, Corresp. between Defense Counsel, F ARA & Ironshore Wark Product
=:

;..;
(\)
,J:J
E1
;::l 108 1781- 1782 12/12/13 Reserves Irrelevant
Z
.....,
.:::
(\)

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(\)
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u
 109 1783 12/11/13 F ARA Invoice to Ironshore Irrelevant

110 2868 - 2869 08/08/13 F ARA Invoice to Ironshore Irrelevant

111 3623 07/08113 F ARA Invoice to Ironshore Irrelevant

112 3638 07/08/13 Reserves Irrelevant

113 3943 - 3948 06/16/15- Corresp. between Defense Counsel, F ARA & Ironshore Work Product
07123/15 Re: Draft Pleadings; Legal Memorandum; Budget Atty. Client

114 3949 - 3950 06/22/15 Corresp. between Defense Counsel, FARA & Ironshore Work Product
Re: Invoices Atty. Client
Irrelevant

115 3951 - 3952 06/16/15 Corresp. between Defense Counsel, FARA & Ironshore Work Product
Re: Legal Memorandum Atty. Client

116 3952 - 3959 OS/22/15- Corresp. between Defense Counsel, F ARA & Ironshore Work Product
06/22/15 Re: Invoices; Reserves Atty. Client
Irrelevant

117 3954 - 3976 02111/15- Corresp. between Defense Counsel, FARA & Ironshore Work Product
OS/29/15 Re: Legal Memorandum; Draft Pleadings and Corresp. Atty. Client

118 3967 - 3968 03/16/15 Correspondence from Defense Counsel to F ARA Work Product
Re: Invoices Atty. Client
Irrelevant

119 3971 - 3972 02111/15- Corresp. between Defense Counsel, FARA & Ironshore Work Product
03/06/15 Re: Invoices Atty. Client
Irrelevant

120 3976 - 3979 02/27/15 Correspondence between F ARA and Ironshore Irrelevant
Re: Reserves

121 3979 - 4037 02/27115- Corresp. between Defense Counsel, FARA & Ironshore Work Product
02/24115 Re: Legal Memo; information request; draft corresp. Atty. Client
-
N

' +-;
0
122 3990 - 3991 01/29115 Correspondence between F ARA and Ironshore Irrelevant
00 Re: Reserves
Cl)
OJ)

'"
A.. 123 3988 - 3991 01/29/15- Corresp. between Defense Counsel, F ARA & Ironshore Work Product
M 02112/15 Re: Invoices Atty. Client
M
r- Irrelevant
oo
M
N
r- 124 4012 - 4013 10/16/14 Corresp. between Defense Counsel, F ARA & Ironshore Work Product
'CI
;..; Re: Reserves; Invoices Atty. Client
Cl)
,.0 Irrelevant
S
:::s
Z
..... 125 4018 09/05/14 Corresp. from Defense Counsel to FARA & Ironshore Work Product
~
Cl) Atty. Client
S
:::s
u
0
0 8
"0
Cl)
<;::::
.€
Cl)
u
 Joint Defense
Irrelevant

126 4026 - 4027 08112114 Corresp. between Defense Counsel, F ARA & Ironshore Work Product
Atty. Client
Irrelevant

127 4033 - 4034 07114114 FARA Note Re: Reserves Irrelevant

128 4038 - 4039 06118/14 FARA Note Re: Reserves Irrelevant

129 4040 06/05/14 Corresp. from F ARA to Defense Counsel & Ironshore Work Product
Atty. Client

130 4042 - 4043 04/24114 Corresp. between Defense Counsel, FARA & Ironshore Work Product
Atty. Client

131 4044 02111114 FARA Note Re: Reserves Irrelevant

132 4049 - 4050 12112113 Correspondence between F ARA and Ironshore Irrelevant
Re: Reserves

133 4053 11114/13 FARA Note Re: Reserves Irrelevant

134 4058 08/06113 FARA Note Re: Reserves Irrelevant

135 4077 07/08113 FARA Note Re: Reserves Irrelevant

136 4080 07/08113 F ARA Note Re: Reserves Irrelevant

137 4084-6608 lronshore Underwriting File Irrelevant
Confidential,
Proprietary,
Trade Secrets

Item JDA Description of Document Privilege

138 001-011 Joint Defense Agreement Work Product
Joint Defense
Irrelevant

[SIGNATURE BLOCK ON FOLLOWING PAGE]

9
 Respectfully submitted,

BROWN SIMS, P.C.

By: slRandell E. Treadaway
Mark C. Clemer
Texas Bar No. 04372300
James D. "J.D." Johnson
Texas Bar No. 24085918
Michelle Richard
Texas Bar No. 24093037
Tenth Floor
1177 West Loop South
Houston, Texas 77027-9007
Telephone: (713) 629-1580
Facsimile: (713) 629-5027
mc1emer@brownsims.com
jjohnson @brownsims.com
mrichard@brownsims.com

and

Randell E. Treadaway (admitted pro hac vice)
LA Bar No. 01624
Brad D. Ferrand (admitted pro hac vice)
LA Bar No. 29860
ZAUNBRECHER TREADAWAY, L.L.C.
406 N. Florida Street, Suite 2
Covington, Louisiana 70433-2907
Telephone: (985) 871-8787
Te1efax: (985) 871-8788
randy@ztlalaw.com
brad@ztlalaw.com

-
N

'-+-;
o
COUNSEL FOR DEFENDANT
SPECIALTY INSURANCE COMPANY
IRONSHORE
o

10
 CERTIFICATE OF SERVICE

This will certify that a true and correct copy of the foregoing pleading has been sent to all
counsel of record via e-mail on this the 25 th day of September, 2015:

Phillip D. Nizialek, T.A.
Sarah E. Stogner
Jacqueline M. Brettner
CARVER, DARDEN, KORETZKY, TESSIER, FINN, BLOSSMAN & AREAUX, LLC
1100 Poydras St., Ste. 3100
New Orleans, LA 70163
Phone: (504) 585-3800
Fax: (504) 585-3801
nizialek (Wcarvcrdardcn.com
stogner@carverdm·den.com
hI~Hn!;T.@.f.fir.Y.~~~Itfir.4~~X!.,~.Qrg
Counsel for Plaintiffs

Michael S. Knippen
Kimberly H. Petrina
David Rock
James M. Eastham
TRAUB, LIEBERMAN, STRAUS & SHREWSBERRY, LLP
303 W. Madison, Suite 1200
Chicago, illinois 60606
Phone: (312) 332-3900
Fax: (312) 332-3908
mknippen@trauhliebermal1.com
kpetrina@ traublieberman. com
dmck@traublicbcrmml.com
ieastham @trauhEeherman,com
Counsel for Defendant Axis Surplus Insurance Company
C. Henry Kollenberg
Melinda M. Riseden
CRAIN, CATON & JAMES, P.c.
'+-<
1401 McKinney Street
o
17th Floor, Five Houston Center
Houston, Texas 77010
Phone: (713) 658-2323
Fax: (713) 658-1921
hko llenberg (cD cralncaton .com
mr1 seden ({:Ii craincaton .com
Counsel for Defendant Marsh USA, Inc.

11
 Marc J. Wojciechowski
W OJClECHOWSKI & ASSOCIATES, P.C.
1747 Kuykendahl Road, Suite 200
Spring, Texas 77379
Phone: (281) 999-7774
Fax: (281) 999-1953
marc@\voiolaw.com
and
Michael D. Mulvaney
Christopher C. Frost
Josh B. Baker
MAYNARD, COOPER & GALE, P.C.
2400 Regions/Harbert Plaza
1901 Sixth Avenue North
Birmingham, AL 35203
Fax: (205) 254-1999
mmul yaney (W mavnardcooper.com
cfrost@rnaynardcooper.com
ibaker(g!maynardcooper.colH
Counsel for Defendant Alterra Excess & Surplus Insurance Company

slRandell E. Treadaway

('.l

4...;
0
('.l
.-

r:::

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, July 23, 2015 4:52 PM
To: Alan Zaunbrecher; Brett Bollinger; Michelle O'Daniels; Brad Ferrand; Jeff
McDonald; Peter Englande
Cc: Bonni;e.clhla.miP.aigne; Patricia Musso; Devine) Tom
Subject: II iii

All,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
4136 N. Florida Street, Suite 2
Covington, LA 713433
Telephone: (985) 871-8787

Date 08/03/21315 Type: General
By Tom Devine
Subject: EM FROM CLIENT TO COVERAGE COUNSEL

From: Lee T. Sheridan [mailto:Lee.Sheridan@ironshore.com]
Sent: Thursday, July 23, 21315 3:413 PM
To: Randy Treadaway
Cc: Mark C. Clemer (mclemer@brownsims.com); James D. Johnson; Michelle O'Daniels;
Brad Ferrand; Stephanie Cochran; Devine J Tom
Subject: RE: 137-23-15 Sheridan re Claim #3927045 South Delhi Field/Denbury
Resources

LEE SHERIDAN
Assistant Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL I NEW YORK, NY 11313134
Office: 646.826.6638 I Cell: 646.599.7122

--
" i"

Date 08/133/21315 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, July 23, 21315 3:38 PM
To: Lee T. Sheridan
Cc: Mark C. Clemer (mclemer@brownsims.com); James D. Johnson; Michelle O'Daniels;
Brad Ferrand; Stephanie Cochran; Devine, Tom
Subject: 111
01i71-i2i31-i1.5.S.hielrjiidja.n.r.e.C.lja.i.m.#j31912.7i13j4j5.Slo.u.tlh.Dle.l.hli.F.iiell.dl/.D.e.nib.ulr.y• • • • •
Resources-iii

Hi Lee. Hope all is well.

FARA003943
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treada"ay, L.l. Co
4136 N,. Florida street, Suite 2
Covington, LA 79433
Telephone: (985) 871-8787

Date 1)8/133/21315 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztl"law.com)
Sent: Friday, July 17, 2615 113:32 AM
To: lee T. Sheridan
Cc: Mark c~ Clemer (mclemer@brownsims.com); James D. Johnson; Oe'line..l Tom;
1-lichelle O'Daniels; Stephanie Cochran
Subject: 67-17-15 Sheriidan re Claim #3927645 South Delhi
Resourc:e

Good morning again Lee.

Best Regards,

Rande·ll E. Treadaway, Esq.
Zaunb·recher Treada,.,,}', L. L. C.
4136 N. Florida Street, Suite 2
Cevington, LA 79433
Telephone: (985) 871-8787
Direct Dial: (985) 273-

Date 1)7/14/2a15 Type: Gener"l
By Tom Devine
Subject: EM TO CLIENT RE: 11111111111111111
<"mp>

From: Devine~ Tom
sent: Tuesday, July 14, 2015 12:12 PM
To: 'le~ T. Sheridan'
Cc: 'OSCeast@yorkrsg_com'
Subject: FW: 06-24-15 0jSjtie.rl-iDje.viiinielirjeIiDieinib.uir.YilRieiSjo.ulrlcie.sl'liejtliajl.';iv, Ironshore, et
al.-FARA Claim #3927645 l

lee:

Date 67/14/2615 Type: General
By Tom Devine
Subject: EM TO CLIENT

From: Devine, Tom
Sent: Tuesday, July 14, 2015 11:01 AM
To: 'Lee T. Sheridan'
subject: RE: 06-24-15 Oster-Devine re Djeinlib.u.rYIiRI.eiisoiuiircieiiSi'leitil"iili,.vii'IIronsnore, et
al.-FARA Claim #3927045-Interim Report I

FARA003944
Lee:

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT

From: Lee T. Sheridan [mailto:Lee.Sheridan@ironshore,com]
Sent: Monday, July 06, 2015 4:26 PM
To: Devine, Tom
Subject: RE: 06-24-15 Oster-Devine re DJe.n.biuilrYiliRellso.uilrcjellsl'lejtjllaili'lviil' Ironshore, et
al,-FARA Claim #3927045-Interim Report i
Importance: High

LEE SHERIDAN
Assistant Vice president
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL I NEW YORK, NY 10004
Office: 646,826,6638

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM TO CLIENT

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT

From: Lee T, Sheridan [mailto:Lee,Sheridan@ironshore,com]
Sent: Monday, July 06, 2015 3:25 PM
To: Devine, Tom
Subject: FW: 06-24-15 Oster-Devine re JDie.n.b.u.r.YIIR.els.ojulr.c.eisl'ile.tila.l.'ilvi'IIronshore, et
al,-FARA Claim #3927045-Interim Report I I

Tom,

LEE SHERIDAN
Assistant Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL I NEW YORK, NY 10004
Office: 646.826,6638

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM C/C

From: Randy Treadaway [mailto:randy@ztlalaw,com]
Sent: Wednesday, June 24, 2015 12:21 PM
To: Sanford Oster (Sanford,Oster@Ironshore,com); Devine, Tom
Cc: Mark C, Clemer (mclemer@brownsims,com); James D, Johnson; Michelle O'Daniels;
Stephanie Cochran
Subject: 06-24-15 oster-l-Die.vili'niejllrejlDiieinibiuiriYIiRieisioiuiricje.sl'lieitliaili'ilvi'IiIironshore, et
al,-FARA Claim #3927045

FARA003945
 Sandy/Tom,

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT RE: l1li11111111l1li

From: Sanford Oster [mailto:Sanford.Oster@ironshore.comj
Sent: Wednesday, June 24, 2015 12:52 PM
To: Lee T. Sheridan
Cc: John Reusch; Randy Treadaway; Mark C. Clemer; Devine, Tom
Subject: FW: 06-24-15 Oster-Devine re D3e.n.b.u.r.YIIR.elslolu.rlcielsl'lIe.tlia.11i'lviil' Ironshore, et
al.-FARA Claim #3927045-Interim Report i I

Sandy

SANFORD OSTER
Vice President

Date 07/14/2015 Type: General
By Tom Oevine
Subject: EM FROM COVERAGE COUNSEL RE: STATUS REPORT

From: Randy Treadaway [mailto:randy@ztlalaw.comj
Sent: Wednesday, June 24, 2015 12:20 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; James D. Johnson;
Stephanie Cochran
Subject: 06-24-15 Oster-Devine re DenbuJir.Y. .
Rieisioiuiricieisl'liejtliaili'livj'lilirio.nshore, et

--
al.-FARA Claim #3927045-Interim Report I I

Good afternoon Sandy and Tom. Hope all is well.
""'"

Best Regards,

Randell E. Treadaway, Esq.
zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

FARA003946
Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL 111111111111111111111111

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, June 16, 2015 2:59 PM
To: Sanford Oster; Devine, Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; Stephanie Cochran;
Johnson
RE: 06-16-15 Oster-Devine re Resources Inc.

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT RE:

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tuesday, June 16, 2015 2:58 PM
To: Randy Treadaway; Devine, Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; Stephanie Cochran;
Johnson
RE: 06-16-15 Oster-Devine re FARA Claim 3927045- Resources Inc.

Date 07/14/2015 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, June 16, 2015 2:16 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; Stephanie Cochran;
James D. Johnson
Subject: 06-16-15 Oster-Devine re FARA Claim 3927045- Resources Inc. vs

Good afternoon Sandy and Tom. Hope all is well.

FARA003947
Best Regards,

Randell E. TreadaNay> Esq.
Zaunbrecher Treadaway, l.l.C.
466 N. Florida street, Suite l
Covington~ LA 73433
Telephone: (98S) 871-8787
Direct Dial: (985) 273-3122
Mobile: (594) 583-3999
Telefax: (985) 871-8788
Email: r.andy@ztlalaw.com
l>Jeosite: "'''''".ztlalaw.com

CONFIDENTIALITY NOTICE:

FARA003948
Date 06/22/2015 Type: General
By Ronnie Ronzello
Subject: EM to and from client re111111111111111111
From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Monday, June 22, 2015 4:26 PM
To: Ronzello, Ronald; Devine, Tom; Bill Gleason; Sanford Oster
Subject: RE: Claim 3927045

JOHN REUSCH
Senior Vice President a' Chief Claims Officer - Property & Casualty
IRONSHORE CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 06089
Office: 860.408.78281 Mobile: 860.218.06981 VCARD

From: Ronzello, Ronald [mailto:ronald.ronzello@FARA.com]
Sent: Monday, June 22, 2015 5:25 PM
To: John Reusch; Devine, Tom; Bill Gleason; Sanford Oster
Subject: RE: Claim 3927045

Ronald L. Ronzello J.D.
Unit Manager - Claim Operations
Branch Claims
985.674.4680 office
800.259.8388 ext. 4680 toll free
985.624.8684 fax
ronald.ronzello@fara.com email
FARA, A York Risk Services Company
P.O. Box 183188
Columbus, OH 43218-3188

From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Monday, June 22, 2015 4:21 PM
To: Devine, Tom; Bill Gleason; Sanford Oster
Cc: Ronzello, Ronald
Subject: RE: 1111111111111111111111 Claim 3927045

JOHN REUSCH
Senior Vice President a' Chief Claims Officer - Property & Casualty
IRONSHORE CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 06089
Office: 860.408.78281 Mobile: 860.218.06981 VCARD

From: Devine, Tom [mailto:Tom.Devine@FARA.com]
Sent: Monday, June 22, 2015 5:06 PM
To: John Reusch; Bill Gleason; Sanford Oster
Cc: Ronzello, Ronald
Subject: FW: ~jliiillllllllllllll Claim 3927045
Importance: High

John:

FARA003949
 Thanks.

Alissa Noore
Client Treasury Associate
985.674.4766 office
clienttl"easuryopsmandevil.l.e@yorkrsg.com
FARA, A York Risk Services Company
1625 West Causeway Approach
~l"ndevill",LA 7e471

The information in this e-mail and in any attachments is confidential and may be
privil~ged. If you are not th~ intended recipient, please destroy this
communication and notify the sender iromeciia"tely. You should not retain, copy or
USe this e-mail for any purpose, nor disclose all or any part of its contents to
any ather person or persons.

The information in this a-mail and in any attachments is confidential and may be
privileged. If you are not the intended recipient. please destroy this
communication and notify the sender immediately. Vou should not retain, copy or
use this e-mail for any purpose, nor disclose all or any part of its c

Da"te 66/22/2e1S Type, General
By Tom Devin"
Subject: EM TO CLIENT RE:

From! Devine~ Tom
Sent: Nonday, June 22, 2015 5:96 PM
To: 'John Reu5ch'; 'bill.gleason@ironshore.com'; San.ford oster
Cc: Ran2ello~ Ronald
Subject: FW: '111111111111111111111
Claim 3927645
Importance: H~gh

-
'

Oat.. 06/22/2015 Type: General
By Tom Devine
subject: EM FROM COVERAGE COUNSEL

Subject: 06-16-15
vs Irons-hare Insurance

Good afternoon Sand)' and Tom. Hope all is well.

--
~

FARA003951
 Best Regard",

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
486 N. Florida Street, Suite 2
Covington, LA 78433
Telephone: (985) 871-8787
<;..., Direct Dial: (985) 273-3122
o
o
Mobile: (594)
583-3999
Telefax: (985) 871-8788
Email: I.andy@ztlalaw.com
Website: www.ztlalaw.c~~

CONFIDENTIALITY NOTICE:

Date 06/22/2015 Type; General
By Tom Devine
Subject: EM TO CLIENT RE:

From: Oevifle~ Tom
Sent: Nednesday, June 17, 2015 2:11 PM
To: . bill. gleason@ironshore.comt
Cc: . ..com~

FILE #392794511111111111111

FARA003952
 Mr. Reusch:

Date 06/22/2015 Type: General
By Tom
Subject: em from-IIIIIIIIIIII

From: Winstead~ Lori
Sent: Tuesday, June 09, 2015 5:28 PM
To: Devine, Tom
Cc: Los
Subject Holdings, Inc., 1581, South Delhi Field, LA
Spill,

Tom,

Thanks,

Lori Winstead
Client Treasury Associate
985.674.4716 office
ClientTreasuryOPSMandeville@yorkrsg.com email
FARA, A York Risk Services Company
1625 W. Causeway Approach
Mandeville, LA 70471

From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Tuesday, June 09, 2015 4:23 PM
To: Winstead, Lori
Cc: Sanford
Subject: RE: Ironshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,

John

JOHN REUSCH
Senior Vice President ,,2 Chief Claims Officer - Property & Casualty
IRONSHORE CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 06089
Office: 860.408.78281 Mobile: 860.218.06981 VCARD

"-'
o
From: Winstead, Lori [mailto:Lori.Winstead@FARA.com]
Sent: Tuesday, June 09, 2015 4:47 PM
To: Bill Gleason; John Reusch; IronshoremgatpaUS
Cc: LossFunalwrar'Q
Subject: Iranshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,
Importance:

Thanks,

Lori Winstead
Client Treasury Associate
985.674.4716 office
ClientTreasuryOPSMandeville@yorkrsg.com email
FARA, A York Risk Services Company
1625 W. Causeway Approach
Mandeville, LA 70471

FARA003953
From: Winstead, Lori [mailto:Lori.Winstead@FARA.com]
Sent: Wednesday, June 03, 2015 2:09 PM
To: Bill.Gleason@ironshore.com; John.Reusch@ironshore.com;
IronshoremgatpaUS@ironshore.com
Cc: Los
Subject Ironshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,
Importance:

Thanks,

Lori Winstead
Client Treasury Associate
985.674.4716 office
ClientTreasuryOPSMandeville@yorkrsg.com email
FARA, A York Risk Services Company
1625 W. Causeway Approach
Mandeville, LA 70471

From: info@iclaimsexpert.com [mailto:info@iclaimsexpert.com]

Date OS/29/2015 Type: General
By Tom Devine
Subject: MAY 8TH E-MAIL FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, May 08, 2015 1:55 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom
Cc: Michelle O'Daniels; Mark C. Clemer (mclemer@brownsims.com); James D. Johnson;
Brad Ferrand; Stephanie Cochran
Subject: 05-08-15 Oster-Devine . vs
Ironshore

Good afternoon Sandy and Tom. Hope all is well.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.

Date OS/29/2015 Type: General
By Tom Devine
Subject: EM TO COVERAGE COUNSEL

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, May 29, 2015 11:34 AM
To: Devine., Tom
Cc: John Reusch; Ronzello, Ronal~dllllllllllllllllllllllill
Subject: RE: 05-27-15 Devine re •

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS

Date OS/29/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT RE:

FARA003954
 From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, May 29, 2815 11:34 AM
To: Devine" Torn
Cc: John Reusch; Ronzello,
Subject: RE: 85-27-15 Devine r:;e;-iilllllllllllllllllllllill

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS

Date 85/29/2815 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, May 86, 2815 5:85 PM
To: Devine) Tom; Sanford Oster
Cc: mclemer@brownsims.com; Michelle O'Daniels; James D. Johnson; Brad Ferrand;
Stephanie Cochran
Subject: RE: 85-86-15 Oster-Devine
Insurance

Best

Randell E. Treadaway, Esq.

Date 85/29/2815 Type: General
By Tom Devine
Subject: EM TO COVERAGE COUNSEL

From: Devine, Tom [mailto:Tom.Devine@FARA.com]
Sent: Wednesday, May 86, 2815 4:85 PM
To: Randy Treadaway; Sanford Oster
Cc: mclemer@brownsims.com; Michelle O'Daniels; James D. Johnson; Brad Ferrand;
Stephanie Cochran
Subject: RE: 85-86-15 Resources Inc.
vs Ironshore

--
"1"
Date
By
OS/29/2815
Tom Devine
Type: General

Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, May 06, 2815 4:41 PM
To: Sanford Oster; Devine" Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; James D. Johnson;
Brad Ferrand; Stephanie Cochran
Subject: 05-86-15 Oster-Devine re FARA Claim 3927045-
Ironshore

Good afternoon Sandy and Tom. Hope all is well.

Best Regards,

FARA003955
 Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date OS/29/2015 Type: General
By Tom Devine
Subject: EM FROM DENBURY

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error~ please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Devine, Tom [mailto:Tom.Devine@FARA.com]
Sent: Tuesday, May 05, 2015 1:45 PM
To: Randy Treadaway
Cc: Sanford
Subject: FW: 0ms.t;eirllllllllllllil
ill

Randy:

Tom Devine
From: Jack Strother mailto:jack.strother@denbury.com]
Sent: Tuesday, May 05, 2015 2:43 PM
To: Devine" Tom
Cc: randy@ztlalaw.com
Subject: Delhi excess claim

Tom"

--
"1"
Please see the attached response and accompanying documentation to your March 16,
2015 correspondence. Please let me know if you have any questions. Thank you.

Jack Strother
Chief Corporate Counsel -
Litigation & Risk Management
Office: 972.673.2617
Fax: 972-673-2460

5320 Legacy Drive
Plano, TX 75024

Date OS/29/2015 Type: General
By Tom Devine
Subject: EM TO CLIENT RE:

From: Devine" Tom
Sent: Friday, May 29, 2015 11:09 AM

FARA003956
 To: Sanford Oster
Ce: 'Jonn.Reusch@ironshore.com'; Ronzello, Ronald
Subject: FW: 05-27-15 Devine re 3927045

Sanely:

Date OS/28/2615 Type: General
By Tom Devine
Subject: EM TO COVERAGE COUNSEL

From; Devine; Tam
Sent: Thursday, May 28, 2015 8:09 AM
To: 'Randy Treacla\~ay'
Cc: Bonnie Champagne
Subject: RE: e5-27-15 Devine 111111111111111111111

Date 05/27/2015 Type: General
By Shirley A Fritch
Subject:

Date 05/27/2015 Type: General
By Ronnie Ronzello
Subject; E~l to Kelly re • • • 11
Fr~n: Ronzello, Ronald
Sent: Wednesda}', Hay 27, 2915 7:44 A~j
To: Stewart, Kelly (Kelly.Stewarb~FARA.com)
Cc: Devine" Tom
Subject: 392704511111111111111111111111111111

From: Sanford Oster [mailto:sanford.oster@ironshore.comJ
sent: friday, ~\ay 22, 2015 1:09 PI-l
To: Devine, Tom
Ce: Ronzello, Ronald

--""'" Subject: Re: Denbury 3927045

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
Ne-. York, NY 16004
646 826-4944-Office
347 7S9-1976-Cell
SanTord.oste~ironshore.com

From: Devine, Tom [mailto:Tom.Devine@FARA.comJ
Sent: F.-iday, May 22, 2015 91:67 P~l
To, Sanford Oster
Ce: Ronzell0, Ronald
Subject: FW: Denbury 3927045

Sandy:

FARA003957
 Oster [mailto:Sanford.Oster@ironshore.com]
Tuesday, May 19, 2015 9:21 AM
To: Devine" Tom
Cc: John Reusch; Ronzello, Ronald
Subject: FW: Denbury 3927045

Tom,)

Ronald L. Ronzello J.D.
Unit Manager - Claim Operations
Branch Claims
985.674.4680 office
800.259.8388 ext. 4680 toll free
985.624.8684 fax
ronald.ronzello@fara.com email
FARA, A York Risk Services Company
P.O. Box 183188
Columbus, OH 43218-3188

Date OS/27/2015 Type: General
By Tom Devine
Subject: em from client re: 111111111111111

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, May 22, 2015 1:09 PM
To: Devine" Tom
Cc: Ronzello, Ronald
Subject: Re: Denbury 3927045

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Devine, Tom [mailto:Tom.Devine@FARA.com]
Sent: Friday, May 22, 2015 01:07 PM
To: Sanford Oster
Cc: Ronzello, Ronald
Subject: FW: Denbury 3927045

Sandy:

rom: San or Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tuesday, May 19, 2015 9:21 AM
To: Devine" Tom
Cc: John Reusch; Ronzello, Ronald
Subject: FW: Denbury 3927045

Tom,

Date OS/22/2015 Type: General
By Tom Devine
Subject:

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

FARA003958
Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved: 1111111111111111111111
Status:

l1li

l1li

Date 05/05/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT TO C/C

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tuesday, May 05, 2015 9:16 AM
To: Randy Treadaway; Devine, Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; James D. Johnson;
Brad Ferrand; Stephanie Cochran
Subject: RE: 05-04-15 Oster-Devine Resources Inc.
vs Ironshore Insurance

FARA003959
 Sandy

SANFORD OSTER
Vice President

Date 05/05/2015 Type: General
By Tom Devine
Subject: EM FROM e/e RE: MEETING

Good afternoon Sandy and Tom. Hope all is well.

'-+-<
o
00

FARA003960
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com

Date 05/05/2015 Type: General
By Tom Devine
Subject: EM FROM C/C

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, April 27, 2015 12:29 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom
Cc: Michelle O'Daniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran
Subject: 04-27-15 Oster-Devine re FARA.~lclllalilmIl31912171041151-IIDlelnlblulrIYIIRlelslolu.rces Inc. vs
Ironshore Specialty Insurance CompanYl

Good afternoon Sandy and Tom. Hope all is well.

Date 05/05/2015 Type: General
By Tom Devine
Subject: EM FROM CLIENT TO D/C

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, April 02, 2015 4:23 PM
To: Sanford Oster; Devine, Tom
Cc: 'mclemer@brownsims.com'; 'modlegal@gmail.com'; 'jjohnson@brownsims.com'
Subject: RE: 04-02-15 Oster-Devine re FARjAilc.llailj·mil3.9.2.7.014.5.-IIDle.n.biujlrYIiR.e.s.o.u.r.cjeisIllInc.
vs Ironshore Specialty Insurance CompanYl

FARA003961
Many thanks Sandy.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2

Date 05/05/2015 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, April 02, 2015 3:41 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom
Cc: Mark C. Clemer (mclemer@brownsims.com); Michelle O'Daniels; James D. Johnson
Subject: 04-02-15 Oster-Devine re FARA~cllialll'mIl31912171014151-IIDlelnlblulrIYIiRlelslolu.r.cieisilIilnc. vs
Ironshore Specialty Insurance Company I

Good afternoon Sandy and Tom. Hope all is well.

We await your instructions.

Best Regards,

Randell E. Treadaway, Esq.

Date 05/05/2015 Type: General
By Tom Devine
Subject: em from coverage counsel

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, April 01, 2015 5:39 PM
To: Mark C. Clemer
Cc: Michelle O'Daniels; Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom;
Stephanie Cochran
: RE: 04-01-15 Clemer re Denbu

Many thanks Mark.

Best

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Flordia Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:

Date 05/05/2015 Type: General
By Tom Devine
Subject: EM FROM D/C

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Wednesday, April 01, 2015 4:08 PM
To: Randy Treadaway

FARA003962
Cc: Michelle O'Daniels; Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom;
Stephanie Cochran
. 04-01-15 Clemer re

Thanks Randy,

Best regards,

Mark

Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, April 01, 2015 10:50 AM
To: Mark C. Clemer
Cc: Michelle O'Daniels; Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom;
Stephanie Cochran
ect: 04-01-15 ClemjeirlirjeliDie.nibiuilliiliiililiiilliiliii

Date 05/05/2015 Type: General
By Tom Devine
Subject: em from coverage counsel

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, April 01, 2015 11:50 AM
To: Mark C. Clemer (mclemer@brownsims.com)
Cc: Michelle O'Daniels; Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom;
Stephanie Cochran

-
Good morning Mark.

FARA003963
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788

Date 04/07/2015 Type: General
By Kylie Miller
Subject: **OUTGOING MAIL CONFIRMATION**

91 7199 9991 7035 6088 0777

**SENT AS DIRECTED**

From: Devine~ Tom
Posted At: Tuesday, April 07, 2015 9:34 AM
Posted To: OSC EAST
Conversation: 3927045
Subject: FW: 3927045

Please attach theu Denbury original reservationu to the first attachment dated
March 16, 2015 and mail certified return receipt requested. Tom Devine

From: Devine~ Tom
Sent: Monday, March 16, 2015 2:15 PM
To: 'OSCEASTRECOVERED@yorkrsg.com'
Cc: 'randy@ztlalaw.com'
Subject: 3927045

Please attach theu Denbury original reservationu to the first attachment dated
March 16, 2015 and mail certified return receipt requested. Tom Devine
Thomas Devine
Senior Environmental Adjuster
FARA
973.404.1119 office
tom.devine@FARA.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 04/07/2015 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, March 20, 2015 11:19 AM
To: Devine, Tom
Cc: Sanford Oster (Sanford.Oster@Ironshore.com)
Subject: FW: 03-20-15 Oster-Devine re FAR'IAilc.llaill·mIi319.2i7i0.4i5i-IiDie.n.biuiriYIiRleisi0iuirlcieisillilnc.
vs Ironshore Specialty Insurance CompanYl

FARA003964
Good morning Tom.

Please give us a call if you have any questions. In the meantime, have a great
weekend.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2

Date 04/07/2015 Type: General
By Tom Devine
Subject: EM FROM COVERAGE COUNSEL

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, March 16, 2015 3:29 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Devine, Tom
Cc: Michelle O'Daniels; Brad Ferrand; Stephanie Cochran; Mark C. Clemer
(mclemer@brownsims.com)
Subject· Oster-Devine re

FARA003965
 Best Regards,

Rand,,·ll E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
4@6 N.. Florida street, Suite 2
covington~ LA 73433
Telephone: (985) 872-8787
Direct Dial: (985) 273-3122

--
"<:t

Date 04/e7/2815 Type: General
By Tom Devine
Subject: E~l fROM COVERAGE COUNSEL

From: Randy Treadaway [lllailto;randy@Ztlalaw.com]
Sent: ;'londay, t·larch 16, 21i'!1S 2;e1 PM
To: Springmann, Michael; Sanford Oster
Cc: Michelle O)Oaniels; mclemer~~rO\~nsims.cQm; Brad Ferrand; Stephanie Cochran;
Devine J Tom

Good afternoon Mike and thanks for your email.

Best Regards,

FARA003966
Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122

Date 04/07/2015 Type: General
By Tom Devine
Subject: EM FROM CIC

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, March 16, 2015 2:01 PM
To: Springmann, Michael; Sanford Oster
Cc: Michelle O'Daniels; mclemer@brownsims.com; Brad Ferrand; Stephanie Cochran;
Tom

Good afternoon Mike and thanks for your email.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2

Date 03/17/2015 Type: General
By Ryan Roads
Subject: "Outgoing Mail Confirmation"

*'SENT AS DIRECTED*'

91 7199 9991 7035 6099 0872

From: Devine) Tom
Posted At: Monday, March 16, 2015 2:15 PM
Posted To: OSC EAST
Conversation: 3927045
Subject: 3927045

Please attach theu Denbury original reservationu to the first attachment dated
March 16, 2015 and mail certified return receipt requested. Tom Devine
Thomas Devine
Senior Environmental Adjuster
FARA
973.404.1119 office
tom.devine@FARA.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 03/16/2015 Type: General
By Michael springmamninilllllllllllllill
Subject: EM to Tom w/ CC I

From: Springmann, Michael
Sent: Monday, March 16, 2015 11:57 AM
To: Devine, Tom
Cc: claimattachments@fara.com
Subject: FW: 3927045 Denbury Resources

From: Bonnie Champagne [mailto:bonnie@ztlalaw.com]
Sent: Monday, March 09, 2015 2:41 PM
To: Springmann, Michael
Subject: Denbury Resources

FARA003967
Regards.
Bonnie Champagne

Bonnie Champagne
legal. Administrator
Zaunbreeher Tread",.ay, LLC
496 N. Florida street, Suite 2
Covington, LA 79433
Direct Dial: 985-273-3129
Phone: 985-871.-8787
Fax: 985-871-8788

Date 93/16/2915 Type: General
By Hichael Springmann
Subject: EH to CC, DC and client re file transfer to Tom

From: Sanford Oster [mailto:Sanford.Oster@iranshore.com]
Sent: }ronday, Haren 16, 2015 12:13 PM
To: Springmann, Michael; 'randy@Ztlalaw.com'
CC; 'modlegal@gmail.com%; '!!lclemer@brownsims .. c:om~;, (brad@ztlala.w~com';
'stephanie@ztlalaw.com'; Devine Tom
Subject: Re: 93-19-15 Resources FARA

Tom .. 1'1ike.,.
Thanks for the follow-up

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY leaB4
546 8Z6-4944-0ffice
347 759-1976-Cell
Sanfard.oster@ironshore.com

From: Springmann, 14ichael
Sent: Nonday, ~larch 16, 2e15 11;52 AN
To: •Randy Treadaway'; Sanford Oster
Cc: Michelle O'Oaniels; Mark C. Clemer (mcl~n€r@brownsims.com); Brad Ferrand;
Stephanie Cochran; Devin@,) Tom
Subject: RE: 93-19-15 Resources FARA
392

All, this file has been transferred to FARAtis Tom Devine (973) 464-1200;
tom.devine@fara.com. Tom ,.ill process the supplemental ROR letter today under his
signatuFe. Thanks.

Date 93/16/2815 Type: General
By Michael Springmann
Subject: EM from client 11111111111111111111111111
From: springmann, Nichael
Sent: ,'ronday, ~larch 16, 2e15 11:49 AM
To: Devine, Tom
Subject· FARA Claim

Tom..!" this is now yours.

From: Randy Traadaway [mailto:randy@:ztlalaw.com]
Sent: Tuesday, March 10, 2915 2:16 PM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Oaniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran
Subject:
3927945

1-lany thanks Sandy.

FARA003968
S"st Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
486 N:. Florida street, Suite 2
Covington, LA 7a433
Telephone! (985) 87~-8787
Direct Dial: {98S) 273-3122
~lobil.e; (Sa4) 583-3999
Telef·ax; (985) 871-8788
Email: randy@ztlalaw.eom
Websi.te: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFOR~4TION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) N~\ED ABOVE This message is sent by or on behalf of a Is,,'yar
at the law firm of Zaunbrecher Treadaway, lol.Co and is intended onl~i for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attaehments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employ"e or agent responsible for delivering this ",essage
to the intended recipient, please do nat read, copy, use or disclose this
communi·cation to others_ IT you have received this communication in error . . please
notify us immediately by reply e-mail or by telephone (call us collect at
S64-B33-73ee) and immediately delete this message and all of its attachments.
Thank )'ou.

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tuesday, ~larch le, 2elS 2:a4 PM
To: Randy Treada\oJay; Springmaon,. Hichael
Cc: Michelle O'Oaniels; Mark C. Clemer (mclemer@brownsims.com); Brad ferrand;
Stephanie Cochran
Subject: HE! FARA Claim

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLA~IS
ONE STATE STREET PLAZA I 8TH fL ! NEW YORK, NY 1eee4
Office: 646.8z6.4~441 Mabile: 347.7S9.1~761 VCARD

From: Randy Treadaway [mailt<>:randy@ztlalaw.com]
Sent: Tuesday, March le, leiS 18:56 ~1
To! Sanford Oster; Springmann~ Michael
Cc: f-'Hchelle OtOaniels; Mark C. Clemer (mclaner@brawnsims .. com); Brad Ferrand;
Stephanie Cochran
: 93-16-15 Claim 3~27e45

Good morning Sandy and Mike. Hope all is well.

Date 93/16[2915 Type: General
By
Subject: Michael spr;ilfllglm.a.n.nllllllllllil
EM from DC m

From: Springmann, Michael
Sent: Nonday, Haren 16, 2e~5 11:49 AM
To: Devine~ Tom
Cc: claimattachments§fara.com
Subject: FW: 03-19-15 Oster-s9liiijiiililiiiiililRieisioiUirjciejSIiFiAiRAilcil.aii.mlll
3927a45 I

From: Randy Treadaway [mailto:randy@Ztlalaw.com]
Sent: Tuesday, March ~6, 2elS 9:56 AM
To: Sanford Oster (Sanford.Oster@IronshOl'e.com); Springmann, ~liehael
Cc: Hichelle O'Oaniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran
Sub'ect: 03-18-15 Oster-S ...i ureas FARA Claim 3927e45

FARA003969
 Best Regards,

Randell E. Treadaway. Esq.
Zaunbre~her Treadaway, L.L.C.
406 ~. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 872-8787
Direct Dial: (985) 273-3122
Mobile: (S04) 583·3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: WM"J.ztlalaw.com

Date 03/12/2015 Type: General
By Tom Devine
Subject: EM TO DiC

--
7

From: Oevine~ Tom
Sent: Thursday, March 12, 2815 4:34 PM
To: . al.an@ztlalaw. corn >
Subject: OUR CLAm #3927045 South Delhi Spill v. Denbury

Randy:

The above captioned file has been transferred to me from Mike Springman.
Please forward any future correspondence to my attention. Thanks. Tom Devine

Thomas Devine
Senior Environmental Adjuster
FAllA
973.484.1119 office
tom.devine@FARA_com email
FARA, A York Risk Services Company

Date 03/18/2015 Type: Supervisory Claim Review
By Ronnie Rooze110
subject: Supervisory Review

FARA003970
Tom,
Reassigning to you. Let DC know you are handling.

Email was sent to tom.devine@fara.com regarding these instructions.

Date 03/06/2015 Type: General
By Michael
Subject: F/U to

From: Springmann, Michael
Sent: Friday, March 06, 2015 1:51 PM
To: John Reusch (John.Reusch@ironshore.com)
Cc: Sanford Oster (Sanford.Oster@ironshore.com); Ronzello, Ronald
Subject: 3927045 South Delhi/Denbury

From: Springmann, Michael
Sent: Thursday, February 12, 2015 7:49 AM
To: John Reusch John.Reusch@ironshore.com); LossFund@Fara.com; Ronzello, Ronald
Subject: FW: Ironshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,

From: Sanford Oster [mailto:Sanford.Oster@ironshore.comj
Sent: Wednesday, February 11, 2015 11:41 AM
To: Springmann, Michael
Subject: RE: 3927045 Denbury Resources

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Springmann, Michael
Sent: Wednesday, February 11, 2015 11:32 AM
To: Sanford Oster (Sanford.Oster@ironshore.com)
Subject: FW: 3927045 Denbury Resources

From: Bonnie Champagne [mailto:bonnie@ztlalaw.comj
Sent: Wednesday, February 11, 2015 10:54 AM
To: Springmann, Michael
Subject: Denbury Resources

Many thanks,
Bonnie Champagne

Bonnie Champagne
Legal Administrator
Zaunbrecher Treadaway, LLC
406 N. Florida Street, Suite 2
Covington, LA 70433
Direct Dial: 985-273-3129
Phone: 985-871-8787
Fax: 985-871-8788

From: John Reusch [mailto:John.Reusch@ironshore.comj
Sent: Wednesday, February 11, 2015 9:27 PM
To: Loss Ronzello, Ronald; 'michael.springman@fara.com'
Subject: Ironshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,

John
John Reusch
Senior Vice President
Chief Claims Officer - P & C Claims
175 Powder Forest Drive, 1st Floor
Weatogue, CT 06089
D: (860) 408-7828

FARA003971
C: (860) 218-0698
F: (860) 408-7801
E: john.reusch@ironshore.com

From: info@iclaimsexpert.com [mailto:info@iclaimsexpert.com]
Sent: Wednesday, February 11, 2015 01:28 PM
To: Bill Gleason; John Reusch; IronshoremgatpaUS; lossfund@fara.com

Ironshore Holdings, Inc., 1581, South Delhi Field, LA Spill,

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 03/06/2015 Type: General
By Michael Springmann
Subject: EM from client: local counsel Brown Sims

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, February 27, 2015 4:47 PM
To: Ronzello, Ronald; John Reusch; 'randy@ztlalaw.com'; Springmann, Michael
Subject: Re: Denbury Suit

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Ronzello, Ronald [mailto:ronald.ronzello@FARA.com]
Sent: Friday, February 27, 2015 05:24 PM
To: John Reusch; Sanford Oster
Subject: Denbury Suit

Date 03/06/2015 Type: General
By
Subject: EM from spri~nlgimlalnlnllllllllllllllllllllllill
Michael CC: U

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, March 03, 2015 8:49 AM

FARA003972
To: Sanford Oster; Ronzello, Ronald
Cc: Springmann, Michael; John Reusch
Subject: 83-83-15 Oster-Ronzello RE: Denbury Suit - 1111111111111111
Sandy/Ron,

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
486 N. Florida Street, Suite 2
Covington, LA 78433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (584) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 03/06/2015 Type: General
By Michael Springmann
Subject: EM exch CC and Superv re sched conf call

From: Ronzello, Ronald
Sent: Saturday, February 28, 2015 11:19 AM
To: Randy Treadaway; Sanford oster; John Reusch; Springmann, Michael
Cc: Michelle O'Daniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran
Subject: RE: 02-28-15 Oster re Denbury v. Ironshore, et

Ronald L. Ronzello J.D.
Unit Manager - Claim Operations
Branch Claims
985.674.4688 office
808.259.8388 ext. 4688 toll free
985.624.8684 fax
ronald.ronzello@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 78471

Date 83/86/2815 Type: General
By
Subject: Michael
EM from sprji.n.g.mja.ninillllllllllllllll
CC m

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Saturday, February 28, 2015 7:22 AM
To: Sanford Oster; Ronzello, Ronald; John Reusch; Springmann, Michael
Cc: Michelle O'Daniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran
Subject: 02-28-15 Oster re Denbury v. Ironshore, et al1l1l1l1l1l1l1l1l1l1l1l1l1

FARA003973
 Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 03/06/2015 Type: General
By Michael Springmann
Subject: EM from client liliiii
From: Sanford oster [mailto:Sanford.oster@ironshore.com]
Sent: Friday, March 06, 2015 10:51 AM
To:

Mike,

Thank you.

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: John Reusch
Sent: Friday, March 06, 2015 11:48 AM
To: ECS Corporate; Tim McAuliffe; Ben Beauvais; Jordan Gantz; Leonidas Nguyen
Cc: Kelly Salmon; Monika Geranio; Tiffany Soyack; Bill Gleason; Inpoint; Sanford
Oster;
Subject:Gl.aliinliHjeinldlrdilclklslilllllllllllllllllllllllllll
III

-
'7 John

JOHN REUSCH
Senior Vice President a' Chief Claims Officer - Property & Casualty
IRONSHORE CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 06089
Office: 860.408.78281 Mobile: 860.218.06981 VCARD

Date 02/28/2015 Type: General
By Ronnie Ronzello
Subject: EM from and to DC

From: Ronzello, Ronald
Sent: Saturday, February 28, 2015 11:19 AM
To: 'Randy Treadaway'; Sanford Oster; John Reusch; Springmann, Michael
Cc: Michelle O'Daniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran

FARA003974
Subject: RE: 02-28-15 Oster re Denbury v. Ironshore, et

Ronald L. Ronzello J.D.
Unit Manager - Claim Operations
Branch Claims
985.674.4680 office
800.259.8388 ext. 4680 toll free
985.624.8684 fax
ronald.ronzello@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Saturday, February 28, 2015 7:22 AM
To: Sanford Oster; Ronzello, Ronald; John Reusch; Springmann, Michael
Cc: Michelle O'Daniels; Mark C. Clemer (mclemer@brownsims.com); Brad Ferrand;
Stephanie Cochran
Subject: 02-28-15 oster re Denbury v. Ironshore, et

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error~ please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, February 27, 2015 4:47 PM
To: 'ronald.ronzello@FARA.com'; John Reusch; Randy Treadaway;
'Michael.Springmann@fara.com'
Subject: Re: Denbury Suit

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice

FARA003975
 347 759-1976-Cell
Sanford.oster@ironshore.com

From: Ronzello, Ronald [mailto:ronald.ronzello@FARA.com]
Sent: Friday, February 27, 2015 05:24 PM
To: John Reusch; Sanford Oster
Subject: Denbury Suit

Ronald L. Ronzello J.D.
Unit Manager - Claim Operations
Branch Claims
985.674.4680 office
800.259.8388 ext. 4680 toll free
985.624.8684 fax
ronald.ronzello@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

The information in this e-mail and in any attachments is confidential and may be
privileged. If you are not the intended recipient, please destroy this
communication and notify the sender immediately. You should not retain, copy or
use this e-mail for any purpose, nor disclose all or any part of its conten

Date 02/27/2015 Type: General

Subject:
By ~iiiillliliiiilllllllllllllllllill
ill
From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Friday, February 27, 2015 1:51 PM
To: Springmann, Michael; Sanford Oster; Ronzello, Ronald; Freyre, Carlos
Subject: Re: 3927045 Denbury

Thanks everyone. Enjoy the weekend.
John Reusch
Senior Vice President
Chief Claims Officer - P & C Claims
175 Powder Forest Drive, 1st Floor
Weatogue, CT 06089
D: (860) 408-7828
C: (860) 218-0698
F: (860) 408-7801
E: john.reusch@ironshore.com

From: Springmann, Michael
Sent: Friday, February 27, 2015 1:48 PM
To: 'John Reusch'; Sanford Oster; Ronzello, Ronald; Freyre, Carlos
Subject: RE: 3927045 Denbury

.....
,....
'1"

-----Original Message-----
From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Friday, February 27, 2015 10:34 AM
To: Sanford Oster; Springmann, Michael; Ronzello, Ronald; Freyre, Carlos
Subject: Re: Denbury

John
John Reusch
Senior Vice President
Chief Claims Officer - P & C Claims
175 Powder Forest Drive, 1st Floor
Weatogue, CT 06089
D: (860) 408-7828
C: (860) 218-0698
F: (860) 408-7801
E: john.reusch@ironshore.com

FARA003976

Date 02/27/2015 Type: General
By Michael Springmann
Subject: EM from Shirley Fritch 11111111111111111111
From: Fritch, Shirley
Sent: Friday, February 27, 2015 1:43 PM
To: Springmann, Michael
Cc: Ronzello, Ronald; Freyre, Carlos
Subject: RE: RUSH FW: Denbury 3927045

Shirley Fritch
Regional Vice President
225.448.0355 office
877.570.3272 toll free
225.448.0026 fax
985.773.3034 cell
shirley.fritch@fara.com email
FARA, A York Risk Services Company
4041 Essen Lane, Suite 200
Baton Rouge, LA 70809

Date 02/27/2015 Type: General
By Shirley A Fritch
Subject:

Date 02/27/2015 Type: General
By Michael Springmann
Subject: EM to Shirley Fritch 111111111111111111111
From: Springmann, Michael
Sent: Friday, February 27, 2015 10:46 AM
To: Fritch, Shirley
Cc: Ronzello, Ronald; Freyre, Carlos (Carlos.Freyre@yorkrsg.com)
Subject: RUSH FW: Denbury 3927045
Importance: High

-----Original Message-----
From: Sanford oster [mailto:Sanford.Oster@ironshore.comj
Sent: Friday, February 27, 2015 10:30 AM
To: Springmann, Michael; Ronzello, Ronald; Freyre, Carlos; John Reusch
Subject: Fw: Denbury

Thanks,
Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

Original Message
From: John Reusch
Sent: Friday, February 27, 2015 10:58 AM
To: Sanford Oster; James Gannon; Tadzi Jones
Subject: Q1

FARA003977
 John
Thanks.
John Reusch
Senior Vice President
Chief Claims Officer - P & C Claims
175 Powder Forest Drive, 1st Floor
Weatogue, CT 06089
D: (860) 408-7828
C: (860) 218-0698
F: (860) 408-7801
E: john.reusch@ironshore.com
«xmp>

Date 02(27(2015 Type: General
By
Subject:

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06(14(2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved: 111111111111111111111
Status:

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FARA003978
u

Date 02/27/2015 Type: General
By Michael 5pringmann
Subject: EM (2) from client 1111111111111111111
From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Friday, February 27, 2015 10:34 AM
To: Sanford Oster; Springmann, Michael; Ronzello, Ronald; Freyre, Carlos
Subject: Re: Denbury

John
John Reusch
Senior Vice President
Chief Claims Officer - P & C Claims
175 Powder Forest Drive, 1st Floor
Weatogue, CT 06089
D: (860) 408-7828
C: (860) 218-0698
F: (860) 408-7801
E: john.reusch@ironshore.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, February 27, 2015 10:30 AM
To: Springmann, Michael; Ronzello, Ronald; Freyre, Carlos; John Reusch
Subject: Fw: Denbury

Thanks,
Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

Date 02/24/2015 Type: General
By
Subject: Michael sprinig.m.alnlnllllllllllllllllllllllllllllill
EM to client ~

From: Springmann, Michael
Sent: Tuesday, February 24, 2015 12:02 PM
To: 'John Reusch'; Sanford Oster
Cc: Ronzello, Ronald; Freyre, Carlos
Subject: RE: 3927045 South Delhi Field/Denbury Resources

Thanks.

Date 02/24/2015 Type: General
By Michael Springmann
Subject: EM from client 1111111111111111
From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Tuesday, February 24, 2015 11:20 AM
To: Springmann, Michael; Sanford Oster
Cc: Ronzello, Ronald; Freyre, Carlos
Subject: RE: 3927045 South Delhi Field/Denbury Resources

Hi Mike,

FA~003979
JOHN REUSCH
Senior Vice President a' Chief Claims Officer - Property & Casualty
IRONSHORE CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 136089
Office: 860.408.78281 Mobile: 8613.218.06981 VCARD

Date 132/24/2015 Type: General
By Michael sprinjg.mlalnlnllllill
Subject: EM to client ~

From: Freyre, Carlos [mailto:Carlos.Freyre@yorkrsg.com]
Sent: Tuesday, February 24, 21315 11:139 AM
To: Springmann, Michael
Subject: RE: 39271345 South Delhi Field/Denbury Resources

Mike-thank you

Carlos Freyre
AVP- Product Management, Casualty Practice Leader
973.404.1125 office
973.404.91352 fax
732.236.6143 cell
carlos.freyre@yorkrsg.com email
York Risk Services Group
99 Cherry Hill Rd
Suite 2313
Parsippany NJ 137054

From: Springmann, Michael
Sent: Tuesday, February 24, 2015 11:132 AM
To: John Reusch (John.Reusch@ironshore.com); Sanford Oster
(Sanford.Oster@ironshore.com)
Cc: Ronzello, Ronald; Freyre, Carlos (Carlos.Freyre@yorkrsg.com)
Subject: 3927045 South Delhi Field/Denbury Resources

Sandy and John, Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 713471

Date 132/24/21315 Type: General
By Michael Springmann
Subject: EM from CC to LA to sched call 111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, February 23, 21315 9:213 AM
To: Mark C. Clemer
Cc: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael; Michelle
O'Daniels
Subject: RE: 132-23-15 Clemer FW: 132-213-15 Springmann-Oster re Denbury Resources
Holt Bryant Pollution Claim-FARA Claim 39271345-Interim Report

Best

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
4136 N. Florida Street, Suite 2
Covington, LA 713433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122

FARA003980
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Monday, February 23, 2015 9:17 AM
To: Randy Treadaway
Cc: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael; Michelle
O'Daniels
Subject: RE: 02-23-15 Clemer FW: 02-20-15 Springmann-Oster re Denbury Resources
Holt Bryant Pollution Claim-FARA Claim 3927045-Interim Report

Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, February 23, 2015 8:49 AM
To: Mark C. Clemer
Cc: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael; Michelle
O'Daniels
Subject: 02-23-15 Clemer FW: 02-20-15 Springmann-Oster re Denbury Resources Holt
Bryant Pollution Claim-FARA Claim 3927045-Interim Report

Good morning Mark.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Saturday, February 21, 2015 11:14 AM
To: Randy Treadaway
Cc: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael; Michelle
0' Daniels
Subject: RE: 02-21-15 Clemer FW: 02-20-15 Springmann-Oster re Denbury Resources
Holt Bryant Pollution Claim-FARA Claim 3927045-Interim Report

Thanks Randy,

Mark

Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

Sent: Saturday, February 21, 2015 6:48 AM
To: Mark C. Clemer - Brown Sims (mclemer@brownsims.com)
Cc: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael; Michelle
0' Daniels
Subject: 02-21-15 Clemer FW: 02-20-15 Springmann-Oster re Denbury Resources Holt
Bryant Pollution Claim-FARA Claim 3927045-Interim Report

Good morning Mark. Hope all is well.

FARA003981
 Have a great weekend.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbre·cher Treads\."ay" L .. L~C#
4e6 U. Flordia street, Suite 2
Covington, LA 79433
Telephone: (98S) 871-8787
Telefax: (985) 871-8788
Cell: (5e4) 583-3999
Email: Randy@ztlalaw.eom
Webs.ite: ' '

Date 92/24/2915 Type: General
By Michael Springmann
Subject: CC Status Report

February 2a~ 2915

VIA E~1AIl ONLY
Michael K. Springmann~ J.D.
Senior Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
~lande\lille, LA 78471

RE: Denbury Resources, Inc. Holt-Bryant Pollution Claim
Insured: Deobury Resources~ Inc~
D/A: June 4, 2013
Ironshore Policy No. 0ee98S602
FARA Claim No.: 3927645
Our file: 14-114/RET

Dear i'like:

--
<:t

FARA003982
--
4-

FARA003983
 Very truly yaurs~

Randell E. Treadaway

Randell E. Treadaway

RET/se (w!enels.)

--
"From: Randy Treadaway [mailto:randy@ztlalaw.com}
Sent: Friday, February 26, 231S 3:97 PM
To: springmann, 11ichael; Sanford Oster (Sanford.Oster@Ironshore.com)
Cc: John Reusch; Michelle O'Daniels; Brad Ferrand; Stephanie Cochran
Subject: 92-20-15 Springmann-Oste" re Denbury Resources Holt Bryant Pollution
Ciaim-FARA Claim 3927e4S-Interim Report

FARA003984
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 02/23/2015 Type: General
By Michael Springmann
Subject: EM from J. Reusch re

From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Friday, February 20, 2015 5:41 PM
To: Springmann, Michael; Sanford Oster; Ronzello, Ronald
Cc: Sanford Oster
Subject: RE: 392704511111111111111111

JOHN REUSCH
Senior Vice President a' Chief Claims Officer - Property & Casualty IRONSHORE
CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 06089
Office: 860.408.78281 Mobile: 860.218.06981 VCARD

Date 02/20/2015 Type: General
By Michael Springmann
Subject: EM from/to John Reusch re III
From: Springmann, Michael
Sent: Friday, February 20, 2015 4:56 PM
To: 'John Reusch'; Sanford Oster; Ronzello, Ronald
Cc: Sanford Oster
Subject: RE: 3927045111111111111111111

Thanks.

-----Original Message-----
From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Friday, February 20, 2015 12:44 PM
To: Springmann, Michael; Sanford Oster; Ronzello, Ronald
Cc: Sanford Oster
Subject: RE: 3927045 11111111111111111

FARA003985
John

JOHN REUSCH
Senior Vice President a' Chief Claims Officer - Property & Casualty IRONSHORE
CLAIMS
175 POWDER FOREST DRIVE 1 2ND FL 1 WEATOGUE, CT 06089
Office: 860.408.78281 Mobile: 860.218.06981 VCARD

E-mail regarding unrelated case

Date 02/19/2015 Type: General
By Michael Springmann
Subject: EM from client/to CC and DC 1111111111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, February 20, 2015 7:36 AM
To: Sanford Oster
Cc: Springmann, Michael; Ronzello, Ronald; JOhnIiR.elu.slc.h.;IiFirieiYlriel'licarlos
Subject: 02-20-15 Oster-Springmann Re: 3927045 I

Good morning Sandy and Mike and thanks for your emails.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 273-3122
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

From: Springmann, Michael
Sent: Thursday, February 19, 2015 4:33 PM
To: 'Sanford Oster'; 'randy@ztlalaw.com'; 'mclemer@brownsims.com'
Subject: RE: 3927045 Denbury Claim

-----Original Message-----
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, February 11, 2015 5:24 AM
To: 'randy@ztlalaw.com'; 'mclemer@brownsims.com'
Cc: Springmann, Michael

FARA003986
 Subject: Denbury Claim

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

Date 02/19/2015 Type: General
By Michael Springmann
Subject: EM from/to client 1111111111111111
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, February 19, 2015 5:05 PM
To: Springmann, Michael; Ronzello, Ronald
Cc: John Reusch; 'randy@ztlalaw.com'; Freyre, Carlos
Subject: Re: 3927045

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Springmann, Michael
Sent: Thursday, February 19, 2015 4:26 PM
To: 'Sanford Oster'; Ronzello, Ronald
Cc: John Reusch; ·ranjdIYd@.z.t.l.a.l.a.wl.•c.olml'lIl
Subject: RE: 3927045 I

--
~

-----Original Message-----
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, February 19, 2015 4:18 PM
To: Springmann, Michael; Ronzello, Ronald
Cc: John Reusch; 'randy@ztlalaw.com'
Subject:

FARA003987
 Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

Date 02/12/2015 Type: General
By Michael
Subject: EM from/to

From: Springmann, Michael
Sent: Thursday, February 12, 2015 7:49 AM
To: John Reusch John.Reusch@ironshore.com); LossFund@Fara.com; Ronzello, Ronald
Subject: FW: Ironshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, February 11, 2015 11:41 AM
To: Springmann, Michael
Subject: RE: 3927045 Denbury Resources

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Springmann, Michael
Sent: Wednesday, February 11, 2015 11:32 AM
To: Sanford Oster (Sanford.Oster@ironshore.com)
Subject: FW: 3927045 Denbury Resources

From: Bonnie Champagne [mailto:bonnie@ztlalaw.com]
Sent: Wednesday, February 11, 2015 10:54 AM
To: Springmann, Michael
Subject: Denbury Resources

Many thanks,
Bonnie Champagne

Bonnie Champagne

--
" i"
Legal Administrator
Zaunbrecher Treadaway, LLC
406 N. Florida Street, Suite 2
Covington, LA 70433
Direct Dial: 985-273-3129
Phone: 985-871-8787
Fax: 985-871-8788

From: John Reusch [mailto:John.Reusch@ironshore.com]
Sent: Wednesday, February 11, 2015 9:27 PM
To: Los Ronzello, Ronald; 'michael.springman@fara.com'
Subj Ironshore Holdings, Inc., 1581, South Delhi Field, LA
Spill,

John
John Reusch
Senior Vice President
Chief Claims Officer - P & C Claims
175 Powder Forest Drive, 1st Floor
Weatogue, CT 06089
D: (860) 408-7828
C: (860) 218-0698

FARA003988
F: (860) 408-7801
E: john.reusch@ironshore.com

From: info@iclaimsexpert.com [mailto:info@iclaimsexpert.com]
Sent: Wednesday, February 11, 2015 01:28 PM
To: Bill Gleason; John Reusch; IronshoremgatpaUS; lossfund@fara.com

Ironshore Holdings, Inc., 1581, South Delhi Field, LA Spill,

Date 02/11/2015 Type: General
By
Subject: Michael ~~'·~'~~:~~~;'IIIIIIIIIIIIIIIIIIIIIIII
EM to/from

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: t~ednesday, February 11, 2015 11:41 AM
To: Springmann, Michael
Subject: RE: 3927045 Denbury Resources

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Springmann, Michael
Sent: Wednesday, February 11, 2015 11:32 AM
To: Sanford Oster (Sanford.Oster@ironshore.com)
Subject: FW: 3927045 Denbury Resources

From: Bonnie Champagne [mailto:bonnie@ztlalaw.com]
Sent: Wednesday, February 11, 2015 10:54 AM
To: Springmann, Michael
Subject: Denbury Resources

Many thanks,
Bonnie Champagne

Bonnie Champagne
Legal Administrator
Zaunbrecher Treadaway, LLC
406 N. Florida Street, Suite 2
Covington, LA 70433
Direct Dial: 985-273-3129
Phone: 985-871-8787
Fax: 985-871-8788

Date 02/11/2015 Type: General
By
Subject: Michael
TC w/ CC;SPirjilnlg.mialn;nilllllllllllllllllllllllllllll
E

FARA003989
Date 01/29/2015 Type: General
By Michael Springmann
Subject: Reserves as of 01/29/15

Reserves as of 01/29/2015

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved: 01/29/2015 10:00:20:AM

Status:

--
--
-

Date 01/29/2015 Type: General
By Michael Springmann
Subject: EM to/from client 1111111111111111111111111

FARA003990
From: Springmann, Michael
Sent: Thursday, January 29, 2015 9:49 AM
To: Sanford Oster (Sanford.Oster@ironshore.com)
Subject: 3927045 Denbury

Michael K. Springmann, J.D.
Senio·r Environmental Adjuster
Please send arr attachments to: claimattachments@fara.com
985.674.4892 office
985.624.8684 fax
michael.springman~~ara.com email
FARA, A York Risk Services Company
1625 \,est Causeway Approach
Mandeville, LA 70471

From: Springmann, Michael
Sent: Thursday, January 29, 2015 9:49 AM
To: Sanford Oster (Sanford.Oster@ironsnore.com)
Subject: 3927045 Denbury

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara~com
985.674.4802 office
, 985.624.8684 fax
michael.springmann@Tara.com email
FARA, A York Risk services Company
1625 \';est Causeway Approach
Mandeville, LA 70471

Date 81/29/2815 Type: General
By Michael Springmann
Subject: Conf call wj CC

Participants:
IS: Sandy Oster
CC: Randy Treadaway and Michelle O'Oaniels
TX Local Atty: ~jark Clemer
F.J\RA: Hike Springmann

FARA003991
Date 01/29/2015 Type: General
By Michael Springmann
5 ub j ect: EM e xc h w/ CC re 111111111111111111111111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com)
Sent: Tuesday, January 27, 2015 1:56 PM
To: Sanford Oster; Springmann, Michael; 'mclemer@brownsims.com'
Cc: Michelle O'Daniels; Brad Ferrand; Stephanie Cochran
Subject: 01-27-15 osterj-SIlPirli.n.gmljan. n.. r.e
. ..FA
. RAllclIliaiilml#1I3i9.27i0.4i15IisollutllhIDlelll.hlillllllllllllllll
.
Field/Denbury Resources I

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Randy Treadaway [mailto:randy@ztlalaw.com)
Sent: Monday, January 26, 2015 11:52 AM
To: Sanford Oster; Springmann, Michael; 'mclemer@brownsims.com'
Cc: 'modlegal@gmail.com'; Brad Ferrand; Stephanie Cochran
Subject: RE: 01-26-15
Field/Denbury Resources0Jstlleirl-.siPirlilnlg.mlalnin
I
. .rle. .FIAiRIAllcll.alimm1i#.3i9i2i7i0i4i5IiSjo.utllhIiDlelllhiillllllllll
1

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com)
Sent: Monday, January 26, 2015 11:52 AM
To: 'randy@ztlalaw.com'; Springmann, Michael; 'mclemer@brownsims.com'
Cc: 'modlegal@gmail.com'; 'brad@ztlalaw.com'; 'stephanie@ztlalaw.com'
Subject: Re: 01-26-15
Field/Denbury 0Jstiieirl-isiP.riilnagimialninlirieIiFIA.RiAliciliaiiimli#i3i9i2.7i0i4i5IiSioiutilhIiDieil.hiillllllllll
Resourcesl

Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

FARA003992
 From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: ~IDnday, January 26, 2015 11:44 AM
To: Sanford Oster (Sanford.Ost@r@Ironshore.com); Springmann, Michael; Mark C.
Cl@mer (mclemer(iijbrownsims.com)
Cc: Michelle o'oaniels; Brad Ferrand; Stephanie Cochran
Subject: 61-26-15
Field/D8nbury osterJ-.siPirii.nlg.m.agninlirj8IiFIA.RIAlicilia.i.m
Resources I
. #i3.9.2i7.04ii5iiSioiuitjhiiDj8illhiilllllllllll
.

B@st Regards,

Rande-II E. Treadaway, Esq.
Zaunbrecher Tr@adaway, L.L.C.
486 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: {98S} 273-3122
Mobile: (504) 583-3999
T@lefax: (985) 871-8788
Email: randy@ztlalaw.co.1l
Website: M>Jw.ztlalaw . . ~om

Fram: Sanford Oster [mailto:Sanfora.Oster@irons.hore.com]
Sent: Tuesday, December 23, 2014 1:S8 PM
To: • mClemer@bt"'ownsims ~ comf; • randy@ztlalaw . .com',; $pringmano,l- ~~ichael
Cc: s modlegal@gmail .. com'; f stephanie@ztlalat1.com'J;; jmalik@bro~.m:sims ~ com
1 t

Suhject: Re: 11-20-14 Oster-$ FARA Claim #3927045 South Delhi
Field/Denbut"'y R~sotJrces

.-<
~
.-<

Sandy

SanTc-rd Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 1ee04
546 826-4944-Office
347 759-1976-Ce11
Sanford.oster@ironshore.com

From: Nark C. clemer [mailto:mclemer@bro,.nsims.com]
sent: Tuesday, December 23, 2014 1:54 PM
To: Sanford Oster; Randy Treadaway; Springmann, Michael
Cc: Michelle O'Oaniels; Stephanie Cochran; 3ennifer l. Malik
Subject:
Field/Denbury ResourcesOS~ltleirl-lsIPirlilnlgmllalnlnlirleIiFIAIRIA
RE: 11-20-14 !
. .clllalilmli#13.9.2.7.0i415IjSloiu.tihIiDjejl.hjilllllllll

FARA003993
Nark

Ma~k c. Clemer~ Shareholder
mclemer@brownsims.com
Brown sims
1177 West loop South, Tenth Floor
Houston, Texas 771027
o 713.629.158e F 713.629.5927
v~~v.brownsims.com

Date 91/29/2015 Type: General
By
Subject: Michael
EM from ;~r~~iiiiillllllllllllill
~ re

from: Sanford Oster [mailto:Sanford.Oster@ironshore.comJ
Sent: Thursday, November 29, 2614 19:23 ~~
To! R.,andy Treadaway; Springmann~ Michael
Cc: Mark C. Clemer (mclemer@brownsims.com); ~lichelle O'Daniels; Stephanie Cochran
Subject: ResourcesOs~tieiril-i5IPlriinligmiianllnlirieIiFAIlRAlliciliaiimll#ii39ii2'i,ei4ii5IiSOiiU+j-ihIDieiil.hiilllllllll
RE: 11-29-14
Field/Danbury I

SANFORD OSTER
Vice: President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE ST.4TE STREET PlAZA ! 8TH FL ! NEI4 YORK, NY 133e4
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.ccm]
Sent; Thursday, November 26, 2314 16; 12 Al-l
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: Nark C. Cleme,. ( rownsims.com); ~lichelle O'Daniels; Stephanie Cochran
Subject: 11-2a-14
Field/Denbury O~~::~liiliiiiiiliiliiiilllililiiiliiiiliililililillllllllllllil
Resources

Good morning Sandy and Nike.

FARA003994
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 11/18/2014 Type: General
By Michael Springmann
Subject: EM to CC req status 11111111111111111111111111
From: Springmann, Michael
Sent: Tuesday, November 18, 2314 9:22 AM
To: 'Randy Treadaway'
Subject: 3927045 South Delhi Field/Denbury

Randy,

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 11/34/2014 Type: General
By Michael Springmann
Subject: VMM for/EM to cc1111111111111111111111111
From: Springmann, Michael
Sent: Tuesday, November 04, 2314 1:05 PM
To: 'Randy Treadaway'
Cc: Sanford Oster; mclemer@brownsims.com; modlegal@gmail.com

FARA003995
Subj ect: RIiiE.:.1i0.-j2.41-j1.4.C.ljejm.elr.RjEI:.FiA.R.A.C.I.ajilm.#j3j9j2i7.0.4j5IiSjOlult.hIiDjejl.hjiIiFjijelild/Denbury
Resources-I!

Date 11/04/2014 Type: General
By Michael Springmann
Subject: EM from CC re 10/31 conf call

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, October 30, 2014 1:49 PM
To: Springmann, Michael
Cc: Sanford Oster; mclemer@brownsims.com; modlegal@gmail.com
Subject: Rijie.:.1.0.-2.41-.1.4.C.I.eimle.r.RIEi:.FAiR.A.C.lia.iim.#.3.9j2.7i014.5Is.o.ultjh.D.emlihji.Fjiieild/DenbUry
Resources-II

Good afternoon All,

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 273-3122
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, October 29, 2014 4:52 PM
To: Sanford Oster; 'mclemer@brownsims.com'; Springmann, Michael
Cc: 'modlegal@gmail.com'
Subject: jR.Ei:1lIi1.01-12411-.114Il1icII.elm.eirIlRIEi:IIF.A.RgAIlIiCjl.a.i.mllli#j3j9.2.71014m5Il1iSioiult.hIlliD.e.llh.i.Fji.e.ld/Denbury
Resources I

Dear All,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error, please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Sanford oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, October 29, 2014 4:51 PM
To: Randy Treadaway; 'mclemer@brownsims.com'; 'Michael.Springmann@fara.com'
Cc: 'modlegal@gmail.com'
Subject: .Riiei:.1i0.-i24i1-ili4Il1icilie.mieir.RiEi:.FiA.RiAljciliaiiimllli#i3i9i2.7j0i4i5.Sio.ultmhIiDjejlghjiIiFiijeild/Denbury
Resourcesl

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004

FARA003996
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, October 29, 2014 05:37 PM
To: Sanford Oster; 'mclemer@brownsims.com' ;
'Michael.Springmann@fara.com'
Cc: Michelle O'Daniels
Subject: RiEi:1i10i-.2i4i-.1i4Iicilje.mjeir. .
Resources-II
RiEi:.FIAiR.Aiic.l.aji.m. .
#i3i9i2i70.4.5iiSio.u.tihljDjejl.hiiIiFiieiild/DenbUry

Sandy/Mark,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error, please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, October 29, 2014 4:36 PM
To: 'mclemer@brownsims.com'; 'Michael.Springmann@fara.com'; Randy Treadaway;
'modlegal@gmail.com'
Subj ect: Rjiel:1I1.01-12141-.114I11c.llelmgelr.RIEi:.FIAIRIAllcilla.i.m.#.3.9.217IO.4.5.Sloiuit.h.D.ell.hli.Fii.e.ld/Denbury
Resources- m

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Wednesday, October 29, 2014 05:30 PM
To: Springmann, Michael ; Sanford Oster;
randy@ztlalaw.com ; modlegal@gmail.com
Subj ect: RjEI:1I1.0.-12.41-.1.4.Cjllelm.elr.R.E.:.FIAIR.A.C.I.a.iimjl#.3.9.2i7i014i5.Sio.ultlhjlD.e.l.h.i.Fii.e.ld/Denbury
Resources-II

Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
a 713.629.1580 F 713.629.5027
www.brownsims.com

From: Springmann, Michael [mailto:Michael.Springmann@fara.com]
Sent: Monday, October 27, 2014 8:35 AM
To: Sanford Oster; randy@ztlalaw.com; Mark C. Clemer; modlegal@gmail.com
Subj ect: RjiEi:.1i01-i2141-ilI4.Cjlieimjelr.RjEi:.FiA.R.A.C.I.a.i.m.#i3i9i2.7.0.415.S.0.U.t.h.Dlell.hii.F.i.eiild/Denbury
Resources-I!

FARA003997
Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, October 23, 2014 1:17 PM
To: Mark C. Clemer
D. Williams;
South Delhi

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA ! 8TH FL ! NEW YORK, NY 10004
Office: 646.826.4944! Mobile: 347.759.1976! VCARD

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, october 24, 2014 12:57 PM
To: 'randy@ztlalaw.com'; 'mclemer@brownsims.com'; 'modlegal@gmail.com'
Cc: Springmann, Michael
Subj ect: Rjel:.lj01-12.4m-.114.cil.elmlelr.RjEI:.FiA.RIA.cI1.a.i.m.#13.9i2i7i0.4.5.S.olu.t.h.D.e.lih.iiiFliie.ld/Denbury
Resources -II

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, October 24, 2014 12:58 PM
To: Mark C. Clemer ; Michelle Odaniels-email

Cc: Springmann, Michael ; Sanford Oster
Subject: IJ0.-.2.411-1.4I1c.l.eim.e.rIlR. E.:.FA.R.Aliciiliaii.ml#1i319i2i7.0i4.5IiSlo.u.t.hIiD.eil.h.i.Fiiieilid./iDienbUry
Resources ~
.

Mark.,

Michael K. Springmann, J.D.
Senior Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471
Telephone: 985.674.4802
Telefax: 985.624.8684
michael.springmann@fara.com email

Best Regards,

FARA003998
Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error~ please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Friday, October 24, 2014 11:53 AM
To: Randy Treadaway; Michelle Odaniels-email
Subject: FARA Claim #3927045 South Delhi Field/Denbury

Randy and Michelle,

Mark

Mark C. Clemer, Shareholder
mclemer@brownsirns.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

Date 11/04/2014 Type: General
By Michael Springmann
Subject: EM from CC to IS Mitrovich-Walsh re 11111111111111
From: Richard Walsh [mailto:Richard.Walsh@ironshore.com]
Sent: Wednesday, October 29, 2014 10:38 AM
To: 'randy@ztlalaw.com'; Mike Mitrovic
Cc: Sanford Oster; John Reusch; Springmann, Michael; 'modlegal@gmail.com';
'stephanie@ztlalaw.com'
Subject: Re: 10-29-14

Randy:

Best}

RTW

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, October 29, 2014 11:24 AM Eastern Standard Time
To: Mike Mitrovic; Richard Walsh
Cc: Sanford Oster; John Reusch; Springmann, Michael ;
Michelle O'Daniels ; Stephanie Cochran

FARA003999
 Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 11/04/2014 Type: General
By Michael
Subject: EM from

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Wednesday, October 29, 2014 4:51 PM
To: Sanford Oster; 'randy@ztlalaw.com'; Springmann, Michael
Cc: 'modlegal@gmail.com'
Sub j ect: RIE.:.1101-.2.4.-1114.cI1.e.m.elr.RiE.:.FiA.RiA.C.1.aiiim.#.3.9.217i0.415.Slo.u.t.h.Dle.llhli.Fii.elld/Denbury
Resources-I!!!l

Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, October 29, 2014 4:51 PM
To: 'randy@ztlalaw.com'; 'mclemer@brownsims.com'; Springmann, Michael
Cc: 'modlegal@gmail.com'
Subject: R'ieii:11i0i1-2i4
Resources 1
.. -1i4i1ciileimieiir. RiEi:IiFAilRAiliciliaiilmli#i3i9i2.7.0i4i5.SiOiUjtahIiDieilihiiIiFiiieild/DenbUry
.

Sanford Oster, VP
Casualty Claims

--
"1-
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, October 29, 2014 05:37 PM
To: Sanford Oster; 'mclemer@brownsims.com' ;
'Michael.Springmann@fara.com'
Cc: Michelle O'Daniels
Subj
i 1-
ect: RjE.:.1 0 2.4.-1.4.cil.e.m.elr.RIEi:.FA.RA.C.lia.iim.#.3m9.2.7.014j5ISlo.u.tlh.D.e.lih.i.Flijeild/Denbu ry
Resources-a

Sandy/Mark,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787

FARA004000
 Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/29/2014 Type: General
By Michael Springmann
Subject: EM exch w/ LA, CC and client re 11111111111111
From: Springmann, Michael
Sent: Wednesday, October 29, 2014 4:39 PM
To: 'Randy Treadaway'; Sanford Oster; 'mclemer@brownsims.com'
Cc: Michelle O'Daniels
Subj ect: RiiiE.:.1i0.-.2.4.-j1.4I1Cjljelmie.r.RiE.:.FiAiRiA.C.liaji.m.#j3.912.7i014j5.Siolu.t.h.D.ejlmhji.Fjideild/Denbury
Resources-II

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, October 29, 2014 4:37 PM
To: Sanford oster; 'mclemer@brownsims.com'; Springmann~ Michael
Cc: Michelle O'Daniels
Subject: RiiiE.:1i1i01-2i4i1-1i4iic.l.elmie.rilRiEi:. .
FAIR.Ailc.ljajiimiI#j3.9.2.7i0i4i5ISlo.u.tihilDje.l.hji. .Fiieiild/DenbUry
Resources-I

Sandy/Mark,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error, please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, October 29, 2014 4:36 PM
To: 'mclemer@brownsims.com'; 'Michael.Springmann@fara.com'; Randy Treadaway;

--
'<:t
'modlegal@gmail.com'
Subject: Rjeii:11i0.-.2i411-1i4i1cilieim.eirIiRIiEi:ilFA
Resources-.
. RAliciiliaiimli#1i39ii27i0i41i5.SioiiutjlhIDiieillhiiilFiieiild/DenbUry
.

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Mark C. clemer [mailto:mclemer@brownsims.com]
Sent: Wednesday, October 29, 2014 05:30 PM
To: Springmann, Michael ; Sanford Oster;
randy@ztlalaw.com ; modlegal@gmail.com
Subject:
ResDurces jR.Ei:.1.0.-.214.-.1.4. .C.I.e.m.e.rIR.EiI:.FIA.R.AiicII.a.i.m. #g39.2j7IO.4.5I1s.o.U.t.hIiDlejllhgiIF.11·eljld/Denbury
.
1
Thanks

FARA004001
Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

From: Springmann, Michael [mailto:Michael.Springmann@fara.com]
Sent: Monday, October 27, 2014 8:35 AM
To: Sanford Oster; randy@ztlalaw.com; Mark C. Clemer; modlegal@gmail.com
Subject: ,RiiEi:1i10i1-i24i1-i14i1icilie.mieir. .
Resources,
RiEi:IiFAilRAiliciliaiijml#ii3i9i2g7i0i4i5IiSioiutjlhIiDieil.hiiIiFiiieild/DenbUry

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, October 23, 2014 1:17 PM
To: Mark C. Clemer
Cc: Randy Treadaway; Michael D. Williams; Springmann, Michael
Subject: RE: 10-22-14 Oster Claim #3927045 South Delhi
F

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, October 24, 2014 12:57 PM
To: 'randy@ztlalaw.com'; 'mclemer@brownsims.com'; 'modlegal@gmail.com'
Cc: Springmann, Michael
Subject: R-me.:.1.0i-i2i41-i1j4Iicllme.mie.r.RiEI:.FjAiRiAilcil.a.iimll#j3.912.7.0.4j5.Slo.ult.hilD.e.l.h.iIiF.i.eiild/Denbury
Resources-II

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, October 24, 2014 12:58 PM
To: Mark C. Clemer ; Michelle Odaniels-email

Cc: Springmann, Michael ; Sanford Oster
Subject: 1,0i1-2i4i1-1i4i1cilieim.e.rIlRjiEi:IiFAiRIAilciiliaiimll#ii39ii27.0i4ii5ISiiouitihIlDieiil.hiiIiFiieiilid./iDienbUry
Resources,

Mark,

FARA004002
Michael K. Springmann, J.D.
Senior Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471
Telephone: 985.674.4802
Telefax: 985.624.8684
michael.springmann@fara.com email

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/27/2014 Type: General
By Michael Springmann
Subject: EM to LA Clemer re 1111111111111111111111111
From: Springmann, Michael
Sent: Monday, October 27, 2014 8:35 AM
To: 'Sanford Oster'; 'randy@ztlalaw.com'; 'mclemer@brownsims.com';
'modlegal@gmail.com'
Subject: RjEi:1i10.-.2141-g1.4. .cillelm.elrIlRiE.:;F.AiR.Allc.l.a.i.mll#i3i9i2i70i4i5IiSjOiu.tihIjD.e.llhii;iFiieiild/DenbUry
Resources-ill

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, October 23, 2014 1:17 PM
To: Mark C. Clemer
Williams; Springmann, Michael
South Delhi

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, October 24, 2014 12:57 PM
To: 'randy@ztlalaw.com'; 'mclemer@brownsims.com'; 'modlegal@gmail.com'
Cc: Springmann, Michael
Subject: jRle.:1I10i1-i2411-11411Ic.lle.m.elrIlR.Ei:. .F.A.R.Alic.lia.i.m;i#i3j91217d0.415I1SjOjUlt.hIlD.eil.hii. .Fii.eild/Denbury
Resources-I

FARA004003
Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, october 24, 2014 12:58 PM
To: Mark C. Clemer ; Michelle Odaniels-email

Cc: Springmann, Michael ; Sanford Oster
Subj ect: 1j0.-.24.-1.4.cillelmlelr.R.EI:.FAIR;A.cI1.alilm.#.3.9i2i7.0.4i5I11so.u.tlh.DielllhiiiiFlileilid/.D.enbUry
Resources~1lfI!

Mark,

Michael K. Springmann, J.D.
Senior Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471
Telephone: 985.674.4802
Telefax: 985.624.8684
michael.springmann@fara.com email

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/27/2014 Type: General
By Michael Springmann
Subject: EM exch CC and local atty Clemer

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, October 24, 2014 12:57 PM
To: 'randy@ztlalaw.com·; 'mclemer@brownsims.com'; 'modlegal@gmail.com'
Cc: Springmann, Michael
Subj ect: Riiie.:.1j01-j2.41-j1.4.Cjlle.m.elr.RjEI:.FiA.RIAiljcI1.aiilm.#i319.2i7i014.5.S.0.U.t.hiljD.e.l.hji.Flilejld/Denbury
Resources-iii

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, october 24, 2014 11:58 AM
To: Mark C. Clemer; Michelle Odaniels-email
Cc: Springmann, Michael; Sanford Oster (Sanford.Oster@Ironshore.com)
Subj ect: 1-lii0.-i2i41-ilI4.C.l.elmie.rIiRiE.:IiFjAiRiAiljCjlla.ilm.#.3.9.2.7.0i4j5IiSioiuitlhIiDjeil.h.iiiF.iie.l.d./.Dienbury
Resources-ii

FARA004004
Mark.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471
Telephone: 985.674.4802
Telefax: 985.624.8684
michael.springmann@fara.com email

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error~ please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Mark C. Clemer [mailto:mclemer@brownsims.com]
Sent: Friday, October 24, 2014 11:53 AM
To: Randy Treadaway; Michelle Odaniels-email
Subject: FARA Claim #3927045 South Delhi Field/Denbury Resources1l1l1l1l1l1l1l111

Randy and Michelle,

Best regards,

Mark

Mark C. Clemer, Shareholder
mclemer@brownsims.com
Brown Sims
1177 West Loop South, Tenth Floor
Houston, Texas 77027
o 713.629.1580 F 713.629.5027
www.brownsims.com

Date 10/27/2014 Type: General
By
Subject: Michael
EM from sprii.ndg.mja.nlnilllllllllllllllllllllllill
CC I

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, October 23, 2014 3:33 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: Michelle O'Daniels; Stephanie Cochran
Subject: 10-23-14 Oster- hi
Field/Denbury Resources

FARA004005
Good afternoon again Sandy and Mike.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
4E!6 N;. Florida street, Suite 2
Covington, LA 7E!433
Telephone: (98S) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/27/ZE!14 Type: General
5y Michael Springmann
Subject: E~l from client lilllllllllllllllllll.
From: Randy Treadaway [mailto:randy@ztlalaw.com}
Sent: Thursday, October 23, 2014 2:33 PM
To: Sanford Oster; Springmann~ Michael

-
Cc: Michelle O'Daniels; Stephanie Cochran
Subject: RE: 13-23-14
Field/Denbury Resources0Jsitieirl-isiPirii.n.gmlia.ninlirieIiFiA.RiAIiCiliajilmli#i3j9i2i7i0i4i5IiSioi"it.hIiDieillhiillllllll
I

Randell E. Treada\From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, October 23, 2014 2:25 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael

-
Cc: Michelle O'Daniels; Stephanie Cochran
Subject: 10-23-14
Field/Denbury

Good afternoon Sandy and Mike.

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/27/2014 Type: General
By Michael Springmann
Subject: EM from client to Mark Clemer 11111111111111111111
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, October 23, 2014 1:17 PM
To: Mark C. Clemer
D. Williams; Springmann, Michael

--
""'"
SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

Date 10/27/2014 Type: General
By
Subject: Michael
EM from spriilnlg.mjalnlnllllllllllllllll
CC I I

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, October 22, 2014 10:18 AM
To: Sanford Oster
Cc: John Reusch; Michelle Michael
Subject: 10-22-14 Oster-S South

Good morning Sandy.

FARA004007
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/27/2014 Type: General
By Michael Springmann
Subject: EM from client to CC:

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, October 21, 2014 10:36 AM
To: Sanford Oster; Springmann, Michael
Cc: John Reusch; Tadzi Jones; 'modlegal@gmail.com'; Stephanie
Subject: RE: 10-21-14 Oster Claim #39
F

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tuesday, October 21, 2014 10:28 AM
To: 'randy@ztlalaw.com'; Springmann, Michael
Cc: John Reusch; Tadzi Jones; 'modlegal@gmail.com'; 'stephanie@ztlalaw.com'
Subject: Re: 10-21-14 Oster-Springmann re FARA Claim #3927045
Resources-Draft for Information to

Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice

FARA004008
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, October 21, 2B14 1B:21 AM
To: Sanford Oster; Springmann, Michael
Cc: John Reusch; Tadzi Jones; Michelle O'Daniels ; Stephanie
Cochran
Subject: 1B-21-14 Oster-Springmann re FARA Claim #3927B45 South Delhi
for to

Good morning Sandy and Mike. I hope Sandy and John

Date 1B/27/2B14 Type: General
By Michael springjm.aininillllllllllli
Subject: EM from CC re ~

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, October 21, 2B14 1B:22 AM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: John Reusch; Tadzi Jones; Michelle O'Daniels; Stephanie Cochran
Subject: 1B-21-14 Oster-Springmann re FARA Claim #3927B45 South Delhi
Resources-Draft

FARA004009
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/16/2014 Type: General
By Michael
Subject: EM from

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, October 14, 2014 6:49 PM
To: Sanford Oster
Cc: Springmann, Michael; modlegal@gmail.com; John Reusch; Tadzi Jones
Subject: Re: 10-14-14 Oster re Denbury Resources-Claim #392704511111111111111111

Sandy,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 273-3122
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/16/2014 Type: General
By Michael Springmann
Subject: EM from client to CC: POA re 11111111111111111
Sent: Tuesday, October 14, 2014 6:41 PM
To: 'randy@ztlalaw.com'
Cc: Springmann, Michael; 'modlegal@gmail.com';John Reusch; Tadz~li'IJloinleisilllllllll
Subject: Re: 10-14-14 Oster re Denbury Resources-Claim #3927045 1

FARA004010
 Enjoy the evening.
Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

Date 10/16/2014 Type: General

By
Subject: EM from ~~~Iiliiiillllllllllllllllllllllllil
Michael CC:

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, October 14, 2014 3:35 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com)
Cc: Springmann, Michael; Michelle O'Daniels
Subject: 10-14-14 Oster re Denbury Resources-Claim #392704511111111111111111

Good afternoon Sandy and Mike. Hope all is well.

--"""

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999

FARA004011
 Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 10/16/2014 Type: General
By Michael Springmann
Subject: Reserves as of 10/16/14

Reserves as of 10/16/2014

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved: .11111111111
Status:

III

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FARA004012
u
Date 10/16/2014 Type: General
By Michael Springmann
Subject: EM to/from client 1111111111111111111111111
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, October 16, 2014 3:45 PM
To: Springmann, Michael
Subject: Riei:1i1j0.-jlI61-jlI4IisiPlrji.nlgmann re 3927045 South Delhi Field/Denbury
Resources-m

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Springmann, Michael
Sent: Thursday, October 16, 2014 3:44 PM
To: 'Sanford Oster'
Subject: JRiEi:1i1i0.-ili6.-i14i1isiPirii.n.gmann re 3927045 South Delhi Field/Denbury
Resources l

s.

Date 10/16/2014 Type: General
By Michael Springmann
Subject: EM exchange CC and client re 11111111111111111111
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, October 16, 2014 3:41 PM
To: 'randy@ztlalaw.com'; Springmann, Michael
Cc: 'bonnie@ztlalaw.com'
Subject: Rje. :.l.0
. . -1.6
. ..
-1i4I1sIPlir.ilng.mann re 3927045 South Delhi Field/Denbury
Resources. I

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, October 16, 2014 04:35 PM
To: Springmann, Michael
Cc: Sanford Oster; Bonnie Champagne
Subject: 10-16-14 Springmann re 3927045 South Delhi Field/Denbury Resources1llll

Hi Mike. Hope all is well.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

FARA004013

Date 09/29/2014 Type: General
By Michael Springmann
Subject: EM from CC to Zurich atty req DVDs

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, September 29, 2014 10:11 AM
To: Philip D. Nizialek
Cc: Natalie Limber; Kevin Lahm; Mike Knippen; Springmann, Michael; Laborde,
Gibson; Michael Golding (Michael.Golding@starrcompanies.com); Michelle O'Daniels
Subject: 09-29-14 Niialek re Denbury Resources-Request for Video-DVS's of Surface
Damage Caused By Well Failure

Good morning Phil.

Please advise as to the status of Ironshoreus requests for copies of the DVDs
depicting surface damage caused by the well failure, which Ironshore needs to
facilitate its analysis of Denburyus claim.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 09/29/2014 Type: General
By Michael Springmann
Subject: EM from CC to client 11111111111111111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, September 29, 2014 10:04 AM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels
Subject: RE: 09-26-14 Oster-Springmann re FARA Claim #3927045 South Delhi
Field/Denbury Resources1lll!lllllllllillillllllllllillilililillllillillilllllllllil
Sandy,

Best

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 09/26/2014 Type: General
By Michael Springmann
Subject: EM exchange CC and client re 111111111111111111111
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, September 26, 2014 4:26 PM
To: 'randy@ztlalaw.com'; Springmann, Michael
Cc: 'michelle@ztlalaw.com'
Subject: Re: 09-26-14
Field/Denbury Resources0Jstieiirl-isiP.rii.nlgmlia.n.nlirieIiFIA.RAlliciliaiilmli#i3i9i2i7i0i4i5liSiOiUjtlhliDieilihiillllllili
I

Sanford Oster, VP
Casualty Claims

FARA004014
 Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, September 26, 2014 3:43 PM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels
Subject: 09-26-14
Field/Denbury osterJ-siiP.riilngamlialnlnlirieIiFAIiRAiliciliaiilm.#1i3i9i2i7i0i4i5IiSioiuit.hIiDieil.hiilllllllllllll
Resources i

Hi Sandy,

Best

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, September 26, 2014 3:40 PM
To: Randy Treadaway; 'Michael.Springmann@fara.com'
Cc: Michelle O'Daniels
Subj ect: Rllie.:.0.91-12161-1114I1siPlrliln.glmialn.nllrle.FIAIRIAIIc.lla.i.m.#.31912i7IO.4i5.S.o.ultlh.D.ellihmiilF ield/Denbury
Resources-I

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, September 26, 2014 04:35 PM
To: Springmann, Michael
Cc: Sanford Oster; Michelle O'Daniels
Subj ect: 01ii91-j2j6.-i1.4.SjPlriilndg.mja.nln.r.e.FiA.R.A.C.l.a.iim.#d3.9.2.7i0.4.5IiS.o.ult.h.Die.l.h.i.Flije.ld/Denbury
Resources-I

-
"'T
.-<
Mike"

Best Regards and a great weekend to all.

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

FARA004015
 Date 09/26/2014 Type: General
By
Subject:

Date 09/23/2014 Type: General

By
Subject: Michael ~~r~:~'iiilllllllllllllllllllllllllllllil
EM from CC re

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, September 22, 2014 8:28 PM
To: Sanford Oster
Cc: Springmann, Michael; Michelle O'Daniels
Subject: Re: 9-22-14 Oster RE: Denbury Resources-File

Best
Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 273-3122
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

On Sep 22, 2014, at 8:24 PM, "Sanford Oster" wrote:

Regards,
Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice

--
' ; Michelle O'Daniels

Subject: 9-22-14 Oster RE: Denbury Resources-File 392704511111111111111111111111

Good evening Sandy.

FARA004016
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Flordia street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

Date 09/12/2014 Type: General
By Michael Springmann
Subject: EM exch client and CC req detailed status report

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, September 12, 2014 9:58 AM
To: Randy Treadaway
Cc: Springmann, Michael; Michelle O'Daniels
Subject: RE: 09-12-14 Oster RE: Denbury Resources-File 3927045-Status of Claim

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, September 12, 2014 10:46 AM
To: Sanford Oster
Cc: Michael K. Springmann (michael.springmann@fara.com); Michelle O'Daniels
Subject: 09-12-14 Oster RE: Denbury Resources-File 3927045-Status of Claim

Good morning Sandy and thanks for your email.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended
recipient or is not the employee or agent responsible for delivering this message
to the intended reCipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error~ please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

FARA004017
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Friday, September 12, 2014 8:29 AM
To: Randy Treadaway
Cc: Michael K. Springmann (michael.springmann@fara.com)
Subject: Denbury Resources-File 3927045

Sandy

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

Date 09/05/2014 Type: General
By Michael
Subject: EM from

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, August 14, 2014 1:03 PM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels
Subject: 08-14-14 Oster-Springmann RE: 3927045 South Delhi/Denburyilllllllllllil

Good afternoon Sandy and Mike.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 08/20/2014 Type: General
By Michael Springmann
Subject: conf call w/ CC and client re 8/15 meet w/ Id

Present: CC Randy Treadaway and Michelle O'Daniels
Client: Sandy Oster
FARA: MKS

FARA004018
 Date 08/20/2014 Type: General
By Michael Springmann
Subject: EM exch w/ CC and client re sched conf call

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, August 19, 2014 4:26 PM
To: Springmann, Michael; Sanford Oster
Cc: Michelle O'Daniels
Subject: RE: 08-19-14 0Jstieiir.-siiP.rii.ng.mlia.n.nlirieIiFAIIR.Aliciliaii.ml#ji3i9i2i7i0i4i5liSiOiUjtihliDelhi
Field/Denbury Resources I I

--
""1" Sandy/Mike,

Best

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Flordia Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

From: Springmann, Michael
Sent: Tuesday, August 19, 2014 4:04 PM
To: 'Sanford Oster'; 'randy@ztlalaw.com'
Cc: 'michelle@ztlalaw.com'
Subject: RE: 08-19-14 0Jstieiirl-siiP.riiln.glmialn;nlirieIiFAIlRAlliciliaiilml#ji3i9i2i7i0i4i5liSiOiuitlhliDelhi
Field/Denbury Resources~l

FARA004019
 From: Sanford oster [mailto:sanford.Oster@ironshore.com]
Sent: Tuesday, August 19, 2014 4:02 PM
To: 'randy@ztlalaw.com'; Springmann, Michael
Cc: 'michelle@ztlalaw.com'
Subject: Re: 08-19-14 os~tlelrl-lsIPlrlll·nlglmlalnlnllrleIlFIAIRIAlicillalli·m1I#.3g912i7i0i4i15ISioiuitihIliDelhi
Field/Denbury Resources i

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-office
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Tuesday, August 19, 2014 04:48 PM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels
Subject: 08-19-14 Oster-Js.p.r.li·n.glmlainlnlllrieIiFAIiRAllciiliaii.ml#ii3i9i27i0i4i15IiSiOiUjt.hIiDieil.hii
Field/Denbury Resources I

Good afternoon Sandy and Mike. Hope all is well.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 08/14/2014 Type: General
By Ryan Roads
Subject: "Outgoing Mail Confirmation"

**SENT AS DIRECTED**

--
'<1"
91 7199 9991 7034 1620 1657

From: Springmann, Michael
Posted At: Thursday, August 14, 2014 10:44 AM
Posted To: OSC EAST
Conversation: iCE 3927045 South Delhi Field, LA Spill/Denbury Resources Inc. - ROR
Letter
Subject: iCE 3927045 South Delhi Field, LA Spill/Denbury Resources Inc. - ROR
Letter

Please send by Certified Mail, Return Receipt Requested and Regular Mail to:

Jack Strother
Denbury Resources, Inc.
5320 Legacy Drive
Plano, TX 75024

Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax

FARA004020
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 08/14/2014 Type: General
By Michael Springmann
Subject: ROR Letter

Attached to file

From: Springmann, Michael
Sent: Thursday, August 14, 2014 9:44 AM
To: ·OSCEast@yorkrsg.com'
Subject: iCE 3927045 South Delhi Field, LA Spill/Denbury Resources Inc. - ROR
Letter

Please send by Certified Mail, Return Receipt Requested and Regular Mail to:

Jack Strother
Denbury Resources, Inc.
5320 Legacy Drive
Plano, TX 75024

Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 08/14/2014 Type: General
By Michael Springmann
Subject: EM to client and CC 1111111111111

....
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, August 14, 2014 9:58 AM
To: Randy Treadaway; Springmann, Michael
Subject: RE: 08-14-14 Springmann RE: 3927045 South Delhi/Denbury1l1l1l1l1l1l11

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, August 14, 2014 9:46 AM
To: Springmann, Michael; Sanford.Oster@Ironshore.com
Subject: 08-14-14 Springmann RE: 3927045 South Delhi/Denbury1l1l1l1l1l1l1l1l1l1ll

Many thanks Mike.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com

FARA004021
Website: www.ztlalaw.com

From: Springmann, Michael
Sent: Thursday, August 14, 2014 9:39 AM
To: 'Randy Treadaway'; Sanford Oster (Sanford.Oster@Ironshore.com)
Subject: 3927045 South DelhijDenbury

Randy and Sandy, Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 08/14/2014 Type: General
By Michael Springmann
Subject: EM to Id & Agent w/ ROR letter

From: Springmann, Michael
Sent: Thursday, August 14, 2014 9:42 AM
To: 'jack.strother@denbury.com'
Cc: 'Mary.C.Paulson@march.com'
Subject: 3927045 South Delhi Field, LA Spill/Denbury Resources Inc.

Mr. Strother, please see the attached coverage letter. Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 08/14/2014 Type: General
By Michael Springmann
Subject: EM exch w/ CC and Client: 1111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, August 13, 2014 8:36 AM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels
Subject: 08-13-14 Oster-Springmann re FARA ciaim #3927045 South Delhi
Field/Denbury Resources1l1.lIlIllIlIlIlIillllllllllllllillllllli
Good morning Sandy and thanks for your email.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

CONFIDENTIALITY NOTICE:
INFORMATION IN THIS MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE
OF THE RECIPIENT(S) NAMED ABOVE This message is sent by or on behalf of a lawyer
at the law firm of Zaunbrecher Treadaway, L.L.C. and is intended only for the use
of the individual or entity to whom it is addressed. This message contains
information and/or attachments that are privileged, confidential and exempt from
disclosure under applicable law. If the reader of this message is not the intended

FARA004022
recipient or is not the employee or agent responsible for delivering this message
to the intended recipient, please do not read, copy, use or disclose this
communication to others. If you have received this communication in error, please
notify us immediately by reply e-mail or by telephone (call us collect at
504-833-7300) and immediately delete this message and all of its attachments.
Thank you.

From: Sanford Oster [mailto:Sanford.Oster@ironshore.comj
Sent: Wednesday, August 13, 2014 8:27 AM
To: Randy Treadaway; Springmann, Michael
Cc: Michelle O'Daniels
Subject: RE: 08-12-14 0Jstlejirl-SjP.rliin.glmlialninlireilIFAilRA
. .ciiliaiilm.#1i39ii27 0 4 5.south Delhi
Field/Denbury Resources I i i ii

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA [ 8TH FL [ NEW YORK, NY 10004
Office: 646.826.4944[ Mobile: 347.759.1976[ VCARD

From: Sanford Oster [mailto:Sanford.Oster@ironshore.comj
Sent: Wednesday, August 13, 2014 8:27 AM
To: Randy Treadaway; Springmann, Michael
Cc: Michelle O'Daniels
Subject: RE: 08-12-14 0Jstiie.r.-isiPiriilnlglmia.n.nlirieIiF.A.RIAliciliaii.mli#i3i9i2i7i0i4i5.south Delhi
Field/Denbury Resources I I

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA [ 8TH FL [ NEW YORK, NY 10004
Office: 646.826.4944[ Mobile: 347.759.1976[ VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.comj
Sent: Tuesday, August 12, 2014 3:22 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: Michelle O'Daniels
Subject: 08-12-14 Oster-Springmann re FARA Claim #3927045 South Delhi
Field/Denbury Resourcesilllllllllililliiillliliiliiliiliililil
Good afternoon Sandy and Mike.

"
Q

~
f
r
,
u· .' •
~ §

~
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 08/14/2014 Type: General
By Michael Springmann
Subject: EM exch CC and Client re 111111111111111111111
From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, August 13, 2014 8:40 AM
To: Randy Treadaway; Springmann, Michael
Cc: Michelle O'Daniels
Subject: RE: 08-12-14 Oster-Springmann re FARA Claim #3927045 South Delhi
Field/Denbury Resources~jilillllllllllilllllillilliliiiiiliil

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS

FARA004023
ONE STATE STREET PLAZA 18TH Fl I NEW YORK, NY 18884
Office: 646. 826. 4944 ! Mabile: 347.759.19761 VCARD

From: Randy Treadat"ay [mailto:randY@Ztlal..w.enm]
Sent: Wednesday, August 13, 2814 8:37 A}1
To: Sanford Oster; Springmann, Michael
Ce: Michelle D'Oaniels
subject: RE: 88-12-14 oster-Springmann re FARA Claim #3927045 South Delhi
Field/Denbury Resourees1l1l1l1l1i1l1i1l1l1l1l1l1l1l1l1l1lilill
Sandy,

Randell E. Treadaway, Esq.
Zaunbrecher Treada\!Jay, L.L.C.
486 N •.Florida Stre"t, Suit" 2
Covington~ LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (584) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.co!l\
\~ebsite: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshora.com]
Sent: Wednesday, August 13, 2814 8:82 AM
To: Randy Treadaway; Springmann, Michael
Cc: fliichelle O'Daniels
Subject: ResourcesO~liiiliililiiiiliiliiiillliiilii~liiiiliiililliliillllll
RE: 88-12-14
Field/Denbury

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
mJE STATE STREET PLAZA ! 8TH FL ! NE\~ YORK, NY 18804
Office: 646. 826. 4944! Mobile: 347.759.19761 VCARD

From: Randy Treadaway ["",il.to:randy@Ztlalaw.cnm]
Sent: Tuesday, August 12, 2El14 11:e2 AM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: }lichelle 0' Daniels
Subject: 08'12-14 Oster- re FARA Claim #3927El45 South Delhi
Field/Denbury Resources-

Good morning Sandy and Mike. Hope all is well.

Best Regards.

Randell E. Treadaway. Esq.
Zaunbrecher Treadat.ay. L.l. C.
436 N. Florida Street, Suite 2
covington. LA 78433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (Se4) 583-3999
Telefax: (985) 871·8788
Email: randy@ztlalaw.co!l\
Website: 'Ww~'lI .. ztlalaw~com

Date 88/14/2314 Type: General
By Michael Springmann
Subject: EM from CC to client 1111111111111111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.comj
Sent: Nonday. August 11, 2814 le:11 AM
To: Sanford Oster
Cc: Springmann, Michael; Michelle O'Daniels
subject: RE: 88-11'1.4 Oster-springmann re FARA Claim #3927045 South Delhi
Field(Denbury Resources=illllillilllllllllilllllllllllllllilliillllliilllilllllllli

FARA004024
 ..-
From: Sanford Oster [mailto:Sanford.Oster@ironshore.comj

..
Sent: Monday, August 11, 2014 10:10 AM
To: Randy Treadaway
Cc: Springmann, Michael; Michelle O'Daniels
Subject: RE: 08-11-14 0Jstjieirl-isiP.rii.nglmlia.n.nlirieIiFAIiRAliiciliaii.mg#1i39ii27i0i4ii5iisoiiutjlhiiDieil.hiilllllllll
Field/Denbury Resources I I I

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.comj

..
Sent: Monday, August 11, 2014 10:04 AM
To: Sanford Oster
Cc: Springmann, Michael; Michelle O'Daniels
Subject: 08-11-14
Field/Denbury oster-jSiP.r.li·n.gmlialn.nllr.eilFIAiRjAilCiliaili·mil#.31912i7i0i4i5I1s.oiuit.hIlDiellihili·1I1I1I1I1I1I1
Resources~

Good morning Sandy. Hope you had an enjoyable weekend.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 08/13/2014 Type: Supervisory Claim Review
By Ronnie Ronzello

--""" Subject: Supervisory Review

Claim being handled by coverage atty. Determining if damages will reach
Ironshore's layer.

Date 08/13/2014 Type: General
By Michael Springmann
Subject: EM from Markel adjuister

From: Nokomis Lemons [mailto:Nokomis.Lemons@markelcorp.comj
sent: Tuesday, June 10, 2014 9:56 AM
To: Matthiessen, MaryAnn
Cc: Springmann, Michael
Subject: RE: South Delhi Field Incident - Your File #: FARA3927045 - Alterra File
#: MXUL25756

Nokomis F. Lemons
Sr. Claims Examiner

Markel Corporation

FARA004025
 4521 Highwoods parkway, Glen Allen, VA 23060
Direct: (804) 287-6979
Toll Free: (888) 629-8848 ext. 6979
Fax: (804) 287-6933
nokomis.lemons@markelcorp.com
www.markelcorp.com
From: Matthiessen, MaryAnn [mailto:MaryAnn.Matthiessen@FARA.com]
Sent: Monday, June 09, 2014 11:17 AM
To: Nokomis Lemons
Cc: Springmann, Michael
Subject: RE: South Delhi Field Incident - Your File #: FARA3927045 - Alterra File
#: MXUL25756

Date 08/12/2014 Type: General
By Michael Springmann
Subject: Reserves as of 08/12/14

Reserves as of 08/12/2014

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved:

Status:

-
- - -
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FARA004026
u

Date 08/12/2014 Type: General
By
Subject:

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tuesday, August 12, 2014 4:24 PM
To: Springmann, Michael
Subject: Re: 3927045 South Delhi Field/Denbury

Sanford Oster, VP
Casualty Claims
Ironshore
One state Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Springmann, Michael
Sent: Tuesday, August 12, 2014 2:50 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com)
Subject: 3927045 South Delhi Field/Denbury

Date 08/08/2014 Type: General
By Michael Springmann
Subject: Conf call w/ CC and client

Attendees:

CC: Randy Treadaway
Client: Sandy Oster
FARA: MKS

Date 08/08/2014 Type: General
By Michael Springmann
Subject: EM exch CC and client re schedl conf call today

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, August 08, 2014 12:08 PM
To: Sanford Oster

Randell E. Treadaway, Esq.

FARA004027
 Zaunbrecher Treadaway, LLC
406 N. Florida street, Suite 2
Covington, LA 70433
Office: (985) 871-8787
Direct: (985) 273-3122
Fax: (985) 871-8788
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com
Sent from my I-Phone
(504) 583-3999

On Aug 8, 2014, at 12:07 PM, "Sanford Oster" wrote:

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Springmann, Michael [mailto:Michael.Springmann@fara.com]
Sent: Friday, August 08, 2014 12:59 PM
To: Randy Treadaway; Sanford Oster
Cc: Michelle O'Daniels
Subject:
Resources

Randy,

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, August 08, 2014 11:54 AM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: Michelle O'Daniels
Subject:
Resources
08-08-14 reB3.9.2j7.0.4i5IjSlo.ult.hIiDieilhili·1I1I1I1I1I1I1I1I1I1I1
II

Sandy/Mike,

8est Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com

--
-.:t
Website: www.ztlalaw.com

Date 08/04/2014 Type: General
By Michael Springmann
Subject: EM from CC: Id 111111111111111111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, August 04, 2014 1:38 PM
To: Springmann, Michael; Sanford.Oster@Ironshore.com
Cc: Michelle O'Daniels
Subject: R'IiiEI:.0.8.-.0141-.1.4.0.slt.elrl-iSIPgrlijn.glmja.nlnilr.e.319.217.0.4i5.S.0jU.tlhilDie.llh.iIiFiileil.d./IDieinlb.ulrlYillllll
ResourceS-I
BIll

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999

FARA004028
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Springmann, Michael

..
Sent: Monday, August 04, 2014 1:37 PM
To: 'Randy Treadaway'; Sanford Oster (Sanford.Oster@Ironshore.com)
Cc: Michelle O'Daniels
Subj ect: R.iiE.:.0i8.-i014.-ilI4.ols.t.eirl-ls.p.rdi;nlglmlaln.n.rie.319.217i014.5.Slolu.tlh.D.e.llhii.Fii.e.l.d./iDle.n.blu.rIYIIIIIII
Resources -. 11

From: Randy Treadaway [mailto:randy@ztlalaw.com]

..
Sent: Monday, August 04, 2014 8:59 AM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: Michelle O'Daniels
Subject:
Resources-, =11I1I1i1l1l1l1l1l1
Good morning Sandy and Mike. Hope all is well.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 07/24/2014 Type: General
By Michael Springmann
Subject: Conference call w/ Sandy and CC

FARA004029

Date 07/24/2014 Type: General
By Michael Springmann
Subject: EM from CC req teleconf w/ client

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, July 24, 2014 2:05 PM
To: Springmann, Michael; Sanford Oster
Cc: Michelle O'Daniels; James Gannon; John Reusch
Subject: R~Eii:1017i-12i4i1-1i4i10iistieiirl-siPiriiinlglmlianlnlllreili39 27 0 45 South Delhi Field/Denbury
Resources-. iiii
Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, July 24, 2014 2:04 PM
To: Randy Treadaway; Springmann, Michael
Cc: Michelle O'Daniels; James Gannon; John Reusch
Subj ect: R'IiiEI:.0.71-i214.-11i4.olsltle.rl-.sIPlrii.njg.mja.n.n.r.e.3 9.2.7 045 South De lhi Fie ld/Denbury
Resources-I 1 1i

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Springmann, Michael [mailto:Michael.Springmann@fara.com]
Sent: Thursday, July 24, 2014 2:02 PM
To: Randy Treadaway; Sanford Oster
Cc: Michelle O'Daniels; James Gannon; John Reusch
South Delhi Field/Denbury
Resources Killiliiiililliiiiiiiiiiliiiiliillilli4~
Subject: -I

FARA004030
 From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, July 24, 2014 2:00 PM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels; James Gannon; John Reusch
Subject:
Resourcesl
'1iilliillillliliiliili re 3927045 South Delhi Field/Denbury

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, July 24, 2014 1:59 PM
To: Randy Treadaway; 5pringmann, Michael
Cc: Michelle O'Daniels; James Gannon; John Reusch
Subject: 'jilill-i2141-i1.4Iiiliiliiiilli South Delhi Field/Denbury
Resources -I

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA / 8TH FL / NEW YORK, NY 10004
Office: 646.826.4944/ Mobile: 347.759.1976/ VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, July 24, 2014 2:54 PM
To: Sanford Oster; Springmann, Michael
Cc: Michelle O'Daniels
Subject: 0J7i1-i24i1-i14i1ioistiieirl-isiPiriiinag.miain.nlirieIi3i9i270.4 5 south Delhi Field/Denbury
Resourcesl ii ili
Good afternoon Sandy and Mike. Hope all is well.

--
'1"

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 07/17/2014 Type: General
By Michael Springmann
Subject: EM exch client and CC re 11111111111111111111
From: Randy Treadaway [mailto:randy@ztlalaw.com]

FARA004031
 Sent: Wednesday, July 09, 2014 10:36 AM
To: Sanford oster; Springmann, Michael
Subject: R~EI:. .0171-10191-1114. .olsltlelrl-isIPlriilnlglmlalnln r e 3927045 South Delhi Field/Denbury
Resources -I i il
I il

Best

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Wednesday, July 09, 2014 10:17 AM
To: Randy Treadaway; Springmann, Michael
Subject: R.Ei:. .0171-.0.9.-ilI4. .ols.tle.rl-isIP;riiin.g.m.aln.nilr e.3927045 South Delhi Field/Denbury
Resources-I i

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Wednesday, July 09, 2014 11:11 AM
To: Springmann, Michael; Sanford Oster
Subject: 0~71-10191-1114110lsltlelrl-lsIPlrlilnlglmlalnlnllrlell3 9 2.7045 South Delhi Field/Denbury
Resources m I 11
Good morning Mike and Sandy. Hope all is well.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
,.... Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
,....
'T
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 07/17/2014 Type: General
By
Subject: Michael
EM from springimja.n.nllllllllllllllllllllill
CC re m

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Monday, June 30, 2014 4:27 PM
To: Sanford Oster (Sanford.Oster@Ironshore.com); Springmann, Michael
Cc: Michelle O'Daniels (modlegal@gmail.com)
Subject: 06-30-14 Oster-

Good afternoon Sandy and Mike,

FARA004032
Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 07/17/2014 Type: General
By Michael Springmann
Subject: Reserves as of 07/17/14

Reserves as of 07/17/2014

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved: 111111111
Status:

•

FARA004033
 -- -

Date 06/19/2014 Type: General
By Michael Springmann
Subject: EM to cc w/ Zurich policies; req info on pollution

From: Springmann, Michael
Sent: Thursday, June 19, 2014 9:30 AM
To: 'Randy Treadaway'
Subject: FW: 3927045 South Deli Field, LA/Denbury Resources Inc.; Zurich claim No.
9120121113

From: Dixon, Karen [mailto:karen.dixon@mbtlaw.com]
Sent: Thursday, June 19, 2014 9:22 AM
To: Springmann, Michael
Subject: RE: 3927045 South Deli Field, LA/Denbury Resources Inc.; Zurich claim NO.
9120121113

Dear Michael.,

--
-<:t Please see the attached Zurich policies that you requested.

Karen

Karen M. Dixon
(312) 474-7913
karen.dixon@mbtlaw.com

123 N. Wacker Dr. I Suite 1800 I Chicago, IL 60606
(312) 474-7900 I Fax (312) 474-7898
www.mbtlaw.com

Date 06/19/2014 Type: General
By Michael Springmann
Subject: EM from Zurich w/ policies

From: Dixon, Karen [mailto:karen.dixon@mbtlaw.com]
Sent: Thursday, June 19, 2014 9:22 AM
To: Springmann, Michael
Subject: RE: 3927045 South Deli Field, LA/Denbury Resources Inc.; Zurich claim No.

FARA004034
 9120121113

Dear Michael,

Please see the attached Zurich policies that you requested.

Karen

Karen M. Dixon
(312) 474-7913
karen.dixon@mbtlaw.com

123 N. Wacker Dr. t Suite 1800 t Chicago, IL 60606
(312) 474-7900 t Fax (312) 474-7898
www.mbtlaw.com

Date 06/18/2014 Type: General
By Michael Springmann
Subject: EM to CC to include FARA claim no.

From: Springmann, Michael
Sent: Wednesday, June 18, 2014 12:00 PM
To: 'Randy Treadaway'
Subject: RE: 3927045 Insured: Denbury Resources, Inc. - Matter: South Delhi Field,
LA Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

Randy, please include my claim no. 3927045 on all future correspondence. Thanks.

Date 06/18/2014 Type: General
By Michael Springmann
Subject: EM to Zurich counsel req policies

From: Springmann, Michael
Sent: Wednesday, June 18, 2014 11:58 AM
To: 'karen.dixon@mbtlaw.com'
Subject: 3927045 South Deli Field, LA/Denbury Resources Inc.; Zurich claim No.
9120121113

Karen, FARA Insurance Services is a third party administrator for certain matters
involving Ironshore Specialty Insurance Company (Ironshore). Ironshore provides
excess coverage to our mutual insured Denbury Resources Inc~

I am in receipt of a copy of your 4/22/14 coverage letter to Philip D. Nizialek.

Please favor me with copies of the following:
1. The primary CGL policies Zurich issued to the insured that were in effect from
April 1, 2012 to April 1, 2014;
2. The 2012-2013 Umbrella policy Zurich issued to the insured;
3. Any pollution policies in effect from April 1, 2012 to April 1, 2013

Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster

--
~
Please send -all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 06/18/2014 Type: General
By Michael Springmann
Subject: EM to cc wi additional info

From: Springmann, Michael
Sent: Wednesday, June 18, 2014 11:45 AM
To: 'Randy Treadaway'
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

FARA004035
 Date 06/18/2014 Type: General
By Michael Springmann
Subject: EM (2) from CC req additional info

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, June 05, 2014 9:58 AM
To: Sanford Oster
Cc: Matthiessen, MaryAnn; Ronzello, Ronald; Springmann, Michael; Michelle
O'Daniels
Subject: Re: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

Sandy,

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 273-3122
Telefax: (985) 871-8788
Cell: (504) 583-3999
Email: Randy@ztlalaw.com
Website: www.ztlalaw.com

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Friday, April 25, 2014 8:56 AM
To: Springmann, Michael
Cc: sanford.oster@ironshore.com; Michelle O'Daniels (modlegal@gmail.com)
Subject: 04-25-14 Springmann re 3927045 South Delhi Field/Denbury
Resources-Request for Additional Policies

Good morning Mike,

--
"1- Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
Mobile: (504) 583-3999
Telefax: (985) 871-8788
Email: randy@ztlalaw.com
Website: www.ztlalaw.com

Date 06/18/2014 Type: General
By Michael Springmann
Subject: EM from client: Zurich wid its denial

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thursday, June 05, 2014 8:02 AM
To: Sanford Oster; Matthiessen, MaryAnn; Springmann, Michael
Cc: Ronzello, Ronald; Randy Treadaway
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA

FARA004036
 Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Sanford Oster
Sent: Thursday, June 05, 2014 9:00 AM
To: 'Matthiessen, MaryAnn'
Cc: Ronzello, Ronald; 'Randy Treadaway'
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

SANFORD OSTER
Vice President
IRONSHORE SPECIALTY CASUALTY CLAIMS
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004
Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Matthiessen, MaryAnn [mailto:MaryAnn.Matthiessen@FARA.comj
Sent: Thursday, June 05, 2014 8:28 AM
To: Sanford Oster
Cc: Ronzello, Ronald
Subject: FW: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

Hi Sandy,
This is the old Denbury case, apparently Zurich sits below Ironshore and has
reviewed and changed their coverage opinion, (as well as their policy?)
At this time, I think we need to discuss to see which counsel needs to handle and
evaluate this matter on behalf of Ironshore.
Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster
609.610.4497 office

--
"1"
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Higgins, Jeff [mailto:JHiggins@lockton.comj
Sent: Tue 6/3/2014 4:25 PM
To: Matthiessen, MaryAnn; 'Regina.Francis@markelcorp.com';
'pamela.mitchell@axiscapital.com'; 'brandy.henderson@libertymutual.com';
'nokomis.lemons@alterra-us.com'; 'PStefanou@archinsurance.com'
Cc: 'Martha Balogh'; Jack Strother; Philip D. Nizialek
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking
To:
Ironshore Specialty Insurance Company/FARA $25,000,000 xis $25,000,000
Adjuster: Mary Ann Matthiessen
Claim Number: FARA 3927045

Alterra Excess & Surplus Insurance Co. $25,000,000 xis $50,000,000
Adjuster: Nokomis Lemons
Claim Number: XUL25756

FARA004037
Axis Surplus Insurance Company $25,000,000 xis $75,000,000
Adjuster: Pamela Mitchell
Claim Number: Unknown (Please provide Claim Number)

Starr Surplus Lines Insurance Company/FARA $25,000,000 xis $100,000,000
Adjuster: Mary Ann Matthiessen
Claim Number: FARA 3927048

Arch Insurance Company $25,000,000 xis $125,000,000
Adjuster: Paula Stefanou, Esq.
Claim Number: 000012573230

Liberty Surplus Insurance Corp $25,000,000 xis $150,000,000
Adjuster: Brandy Henderson
Claim Number: DALCAS0000038756

Per the attached correspondence from Zurich's coverage counsel, Zurich has
rescinded its coverage denial of the claims associated with the Delhi release.
Denbury is providing the requisite documentation to Zurich in order to collect its
policy limit of $25,000,000. Denbury anticipates that it will have an additional
$50,000,000 in cleanup costs and third party property damages for which it will be
seeking reimbursement from its excess insurers. Once Zurich exhausts, Denbury
will be looking to the upper layers of coverage to respond quickly to Denbury's
request for payment. Thank you.

Jeff Higgins, CPCU
Senior Vice President~ Claims Services
Lockton Companies
5847 San Felipe, Suite 320
Houston, TX 77057
Tel: 713.458.5270
Mobile: 832.563.9936
Fax: 713.430.5270
E-mail: jhiggins@lockton.com

Date 06/18/2014 Type: General
By Michael Springmann
Subject: Reserves as of 06/18/14

Reserves as of 06/18/2014

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved:

Status:

Reason:

- - - -
FARA004038

Date 06/09/2014 Type: General
By Mary Ann Matthiessen
Subject: EM to/from Markel

From: Matthiessen, MaryAnn
Sent: Mon 6/9/2014 11:17 AM
To: Nokomis Lemons
Cc: Springmann, Michael
Subject: RE: South Delhi Field Incident - Your File #: FARA3927045 - Alterra File
#: MXUL25756

Hi Nokomis~
There has been recent activity, Zurich has retracted their disclaimer.
This file has been referred to Mike Springmann for handling, I have copied him on
this email. I know he has been out of the office so please give him some time to
respond.
Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster
609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Nokomis Lemons [mailto:Nokomis.Lemons@markelcorp.com]
Sent: Fri 6/6/2014 12:12 PM
To: Matthiessen, MaryAnn
Subject: South Delhi Field Incident - Your File #: FARA392544 - Alterra File #:
MXUL25756

I am considering closing my file. Are there any updates that would indicate I
should not?

Nokomis

Nokomis F. Lemons

Sr. Claims Examiner

FARA004039
 Markel Corporation

4521 Highwoods Parkway, Glen Allen, VA 23060

Direct: (804) 287-6979

Toll Free: (888) 629-8848 ext. 6979

Fax: (804) 287-6933

nokomis.lemons@markelcorp.com

www.markelcorp.com

Date 06/05/2014 Type: General
By Mary Ann Matthiessen
Subject: EM from Ironshore.

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thu 6/5/2014 9:02 AM
To: Sanford Oster; Matthiessen, MaryAnn; Springmann, Michael
Cc: Ronzello, Ronald; Randy Treadaway
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

I understand you now have this matter.

SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thu 6/5/2014 9:00 AM
To: Matthiessen, MaryAnn
Cc: Ronzello, Ronald; Randy Treadaway
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

MaryAnn,

.-<
"i"
.-<

Sandy

SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

FARA004040
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

Date 06/05/2014 Type: General
By Mary Ann Matthiessen
Subject: Zurich withdraws coverage position

From: Matthiessen, MaryAnn
Sent: Thu 6/5/2014 8:56 AM
To: Sanford.Oster@ironshore.com; Springmann, Michael
Subject: FW: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

Hi Sandy,
I just realized this is now Mike Springmann's case.
Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster
609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Matthiessen, MaryAnn
Sent: Thu 6/5/2014 8:28 AM
To: Sanford.Oster@ironshore.com
Cc: Ronzello, Ronald
Subject: FW: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

Hi Sandy,
This is the old Denbury case, apparently Zurich sits below Ironshore and has
reviewed and changed their coverage opinion, (as well as their policy?)
At this time, I think we need to discuss to see which counsel needs to handle and
evaluate this matter on behalf of Ironshore.
Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster
609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Higgins, Jeff [mailto:JHiggins@lockton.com]
Sent: Tue 6/3/2014 4:25 PM
To: Matthiessen, MaryAnn; 'Regina.Francis@markelcorp.com';
'pamela.mitchell@axiscapital.com'; 'brandy.henderson@libertymutual.com';
'nokomis.lemons@alterra-us.com'; 'PStefanou@archinsurance.com'
Cc: 'Martha Balogh'; Jack Strother; Philip D. Nizialek
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Action Plan & Cost Tracking

To:
Ironshore Specialty Insurance Company/FARA $25,000,000 xis $25,000,000
Adjuster: Mary Ann Matthiessen
Claim Number: FARA 3927045

Alterra Excess & Surplus Insurance Co. $25,000,000 xis $50,000,000
Adjuster: Nokomis Lemons
Claim Number: XUL25756

Axis Surplus Insurance Company $25,000,000 xis $75,000,000
Adjuster: Pamela Mitchell
Claim Number: Unknown (Please provide Claim Number)

FARA004041
 Starr Surplus Lines Insurance Company/FARA $25,000,000 xis $100,000,000
Adjuster: Mary Ann Matthiessen
Claim Number: FARA 3927048

Arch Insurance Company $25,000,000 xis $125,000,000
Adjuster: Paula Stefanou, Esq.
Claim Number: 000012573230

Liberty Surplus Insurance Corp $25,000,000 xis $150,000,000
Adjuster: Brandy Henderson
Claim Number: DALCAS0000038756

Per the attached correspondence from Zurich's coverage counsel, Zurich has
rescinded its coverage denial of the claims associated with the Delhi release.
Denbury is providing the requisite documentation to Zurich in order to collect its
policy limit of $25,000,000. Denbury anticipates that it will have an additional
$50,000,000 in cleanup costs and third party property damages for which it will be
seeking reimbursement from its excess insurers. Once Zurich exhausts) Denbury
will be looking to the upper layers of coverage to respond quickly to Denbury's
request for payment. Thank you.

Jeff Higgins, CPCU
Senior Vice President, Claims Services
Lockton Companies
5847 San Felipe, Suite 320
Houston, TX 77057
Tel: 713.458.5270
Mobile: 832.563.9936
Fax: 713.430.5270
E-mail: jhiggins@lockton.com

Date 04/24/2014 Type: General
By Michael Springmann
Subject: EM-from CC acknowledg receipt of assignm

From: Randy Treadaway [mailto:randy@ztlalaw.com]
Sent: Thursday, April 24, 2014 8:30 AM
To: Springmann, Michael
Cc: sanford.oster@ironshore.com
Subject: 04-24-14 Springmann-Oster RE: NEW ASSIGNMENT 3927045 South Delhi
Field/Denbury Resources

Good morning Mike and Sandy.

Best Regards,

Randell E. Treadaway, Esq.
Zaunbrecher Treadaway, L.L.C.
406 N. Florida Street, Suite 2
Covington, LA 70433
Telephone: (985) 871-8787
Direct Dial: (985) 273-3122
.."...
Mobile: (504) 583-3999
o Telefax: (985) 871-8788
o Email: randy@ztlalaw.com
o Website: www.ztlalaw.com

Date 04/24/2014 Type: General
By
Subject: Michael
EM to CC SjPlrli.ndg.mialnlnllllllllllllllllllllll
~

Sent: Thursday, April 24, 2014 8:17 AM
To: Randy Treadaway
Cc: Sanford "Sandy" Oster (sanford.oster@ironshore.com)
Subject: NEW ASSIGNMENT 3927045 South Delhi Field/Denbury Resources

FARA004042
 Thanks.

Michael K. Springmann, J.D.
Senior Environmental Adjuster
Please send all attachments to: claimattachments@fara.com
985.674.4802 office
985.624.8684 fax
michael.springmann@fara.com email
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 04/24/2014 Type: General
By Michael Springmann
Subject: EM from prior adj re Zurich info

From: Matthiessen, MaryAnn
Sent: Friday, March 87, 281412:15 PM
To: Springmann, Michael
Subject: Re: 3927045 South Delhi Field/Denbury Resources

Mike
We have all updated info from Zurich in the file that is the only one. So ok to
send.
Thank you
MaryAnn Matthiessen
Senior Environmental Adjuster

689.618.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 83/87/2814 Type: General
By Michael Springmann
Subject: EM to prior adjuster: re Zurich denialfor cvg atty

From: Springma~n, Michael
Sent: Friday, March 07, 2814 18:88 AM
To: Matthiessen, MaryAnn
Subject: 3927845 South Delhi Field/Denbury Resources

MaryAnn, this file was discussed briefly during todayUs Monthly Call-In with
Ironshore.

Sandy and John want to refer this to Randy Treadaway, coverage counsel, for a
ume-toou following form declination to be issued, if applicable, I note from your
claim review that same is your plan but that you are waiting for ZurichUs
disclaimer. I note that the file does contain one, attached to the file on
12/12/2813. Is that the document we were looking for? Are we still waiting for
anything from Zurich? Let me know so that the referral to Randy can be made.
Thanks.
4-;
o
,...,
o
Date 82/11/2014 Type: Plan To Conclude
By Mary Ann Matthiessen
Subject: Claim Review - Plan To Conclude

Action Plan:
Follow for:
1.) Zurich coverage evaluation.
2.) further details of loss.
3.)If Zurich's disclaimer is straighforward then we might be able to send a simple
"me too" coverage letter to Denbury, as per Ironshore's advise of 8/6/2813.

Date 82/11/2814 Type: Exposure Evaluation
By Mary Ann Matthiessen
Subject: Claim Review - Exposure Evaluation

Upadated as of 2/11/2814:

Louisiana Environmental Exposure.

FARA004043
 We still do not have the underlying controlling Insurer's evaluation-
Zurich/American Guarantee & Liability Insurance Company- we have requested same
again from Carrie Hoff of Zurich.

We suspect that the Lloyds well policy is affording coverage for the remediation
on the Denbury site.

Damages and liability:
The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in Lousina involved, but this is as per Denbury and the facts
still are not developed.

The property is leased from private owners (unknown to us at this time) and is
private property.
Currently, As of July 30, 2013- the incurred for remediation is $42,436,886.88.
They are only in the early stages of the cleanup as this loss just occurred on
June 14, 2013.

RESERVES:

RECOMMENDATIONS:
,,~~~jI~~~~~~~~~~~~~~zurich as the lead had previously advised
that they disclaimed to Denbury. Lloyds appears to have the well policy.
Ironshore has authorized the use of Randy Treadway to evaluate the coverage if
needed once we get a copy of Zurich's position, (denial).
It seems that the Zurich policy may provide coverage for liability losses to
persons and or property, assuming that this incident meets the definition of an
occurrence, which Zurich appears to be disputing.

Denbury has a response team in place as provided by their Lloyds well policy, and
provides weekly reports to all carriers of their efforts and exposure. Initial
discussions with Denbury Martha Balogh- Risk Management Specialist Denbury
Resources Inc. indicates that Denbury will be responsible for this loss; however,
we suggest that there remains much investigation that is necessary before this
matter can be fully evaluated, as such we will be following with Denbury, Lockton
(formerly Marsh) and Zurich to determine the cause.

Remediation costs now exceed 88 million.

Date 02/11/2014 Type: Subrogation
By Mary Ann Matthiessen
Subject: Claim Review - Subrogation and SIF

No subrogation identifiable at this time.

Date 02/11/2014 Type: Facts Summary
By Mary Ann Matthiessen
Subject: Claim Review - Summary Of Facts

Update 2/11/2013
At this time we await Zurich as the primary carrier's coverage opinion.We have
again requested from Carrie Hoff of Zurich.
The remediation costs are now at $88 million, but we suspect the Lloyds well
policy is paying for them.

"-'
o
N THE IRONSHORE SPECIALTY ISURANCE COMPANY POLICY:
o Policy Number: 000988602 RENEWAL OF: 000988601
Named Insured: Denbury Resources Inc.
5320 Legacy Drive
Plano, TX 75024
Policy Period: April 01, 2013 Expiration: April 01, 2014
Limits of Liability: $25,000,000 per occurrence and in the aggregate.

UNDERLYING:
Ironshore Provides follow form on the underlying.
Coverage: Excess Policy- not certain as to coverage afforded by controlling
underlying at this time. Controlling policy has been requested.
Underlying Insurer: American Guarantee & Liability Insurance Company (Zurich)
Policy Number: AUC 9242673-01
Limits: $25,000,000 per occurrence limit
**Defense Expenses are outside the Limits.

There is a $500k SIR and a primary Zurich policy GL09242578-01 of $500k.
Ironshore policy is in excess of $26,ee0,000 in underlying.

COVERAGE ANALYSIS: We have requested the American Guarantee & Liability Insurance

FARA004044
 Company (Zurich) controlling policy and have been advised that they have
disclaimed.
After seeing the well policy and comparing it to the Zurich policy, it seems that
the Lloyd's policy affords clean up coverage while the Zurich policy affords
coverage under the "Blended Pollution" Endorsement, for claims of BI and PD as a
result of certain pollution conditions, and one of the requirements must be that
the occurrence must be "instantaneous" and having first commenced on a "specific
date and time" which is noticed by the insured within 313 days of the event. This
is apparently going to be Zurich's position, as explained via telephone, that this
was no an instantaneous event as there have been slow leaks from this well over
the past several months that have gone unnoticed.

My intent is to submit all documents to Randy once we have the coverage position
from Zurich, which should be shortly.

LOSS FACTS: **MUCH IS STILL NOT KNOWN. WE ARE UNSURE OF THE CAUSE OF THE LOSS,
THE DETAILS OF HOW MUCH PRODUCT HAS BEEN LOST AND WHO THE PROPERTY OWNERS ARE AND
THE DETAILS OF THE WELL OPERATION.

Denbury is an oil and gas company who leases and operates wells from private
landowners. At 3:113pm CT, Mr. Ryan Jacob, Denbury Onshore, LLC, received a call
from US Environmental Services QUSESu confirming that C02, oil, and saltwater was
present on the TransCanada Right of Way. Large release of carbon-dioxide is a by
product of the process at the source used to extract oil and bitumen (a sludgy
form of petroleum) from the earth. Formal responsibilities for the South Delhi
Field, LA Incident were transferred from TransCanada Pipeline to Denbury Onshore,
LLC.

The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in northeast Louisiana. The property is leased from private
owners and is private property.

Ms. Dawn Williams Louisiana Department of Environmental Quality briefed personnel
that 17 residences had been evacuated on 6/13/2813, *(indicates prior to the June
14, date of loss as reported), which included 34 residents, (17 residences remain
evacuated). Richland and Franklin Parish off-duty Sherriffus deputies secured the
scene, and road closures were active on Antley Road and Highway 132 in the region.

An initial air monitoring team was sent to Test Site· 1 and all well location
adjacent to the release and determined that the site was safe to access

ENVIRONMENTAL
USES personnel are monitoring chloride levels in Swamp Slough.

RECOVERY & CONTAINMENT
USES and Hancock personnel recovered, and will continue to recover, fluids from
the Swamp Slough at Burke Road Bridge using vacuum trucks.
All recovered liquids are being placed in S813-barrel frac tanks for temporary
storage.

Key contacts:
On 7/8/2813 at 11:lSam I contacted Ms. Martha Balogh- Risk Management Specialist
Denbury Resources Inc.
S328 Legacy Drive
Plano, Texas 751324
Office: 972-673-21376 (number called)
Cell: 469-693-1132
Email: martha.balogh@denbury.com

--""'" Date 132/11/2814 Type: General
By Mary Ann Matthiessen
Subject: TC with Nokomis Lemons of Markel

Discussed the matter today via telephone with adjuster Nokomis Lemons of
Markel.
Markel bought out Alterra Excess & Surplus Insurance Company which is why we see
Markel on the file now.

Alterra Excess & Surplus Insurance Company sits on top of the Ironshore layer.
We have confirmed with the lead excess, Carrie Von Hoff of Zurich today that
Zurich is maintaining their denial but is evaluating the information submitted by
Denbury.
Zurich's denial is based on the fact that the claims for cleanup are not covered
under the policy; however, it is possible that third party claims for pollution
may be covered, but as of now there are no third party claims.
Jeff Higgins of Lockton (insured broker) continually tries to advise us that
Zurich is changing their coverage opinion. Von Hoff informs us that this is not
so.
Below is an email sent by Lemons to/from Lockton.

From: Higgins, Jeff [mailto:JHiggins@lockton.com]
Sent: Tue 2/11/2814 3:28 PM
To: Nokomis Lemons

FARA004045
Cc: carrie.vonhoff@zurichna.com; Matthiessen, MaryAnn
Subject: RE: Denbury Resources - South Delhi field, LA Spill - File #: MXUL25756 -
Zurich File #: York Risk Claim #FARA3925455

Denbury has recently provided an extensive amount of technical data to Zurichus
consultant which Denbury believes will clearly identify the commencement of the
pollution event.

Jeff Higgins, CPCU
Senior Vice President, Claims Services

Lockton Companies
5847 San Felipe, Suite 320
Houston, TX 77057
Tel: 713.458.5270
Mobile: 832.563.9936
Fax: 713.430.5270
E-mail: jhiggins@lockton.com

From: Nokomis Lemons [mailto:Nokomis.Lemons@markelcorp.com]
Sent: Tuesday, February 11, 2014 2:08 PM
To: Higgins, Jeff
Cc: carrie.vonhoff@zurichna.com; Matthiessen, MaryAnn
Subject: Denbury Resources - South Delhi field, LA Spill - File #: MXUL25756 -
Zurich File #: York Risk Claim #FARA3925455

Jeff,

I have reached out to both Zurich and York regarding status of this case. Do you
have any updates? The last we spoke it was felt that Zurich might be rescinding
their coverage position.

Thank you,

Nokomis

Nokomis F. Lemons

Sr. Claims Examiner

Markel Corporation

4521 Highwoods Parkway

Glen Allen, VA 23060-6148

Direct: (804) 287-6979

Toll Free: (888) 629-8848 ext. 6979

Fax: (804) 287-6933

nokomis.lemons@markelcorp.com

Date 01/03/2014 Type: Supervisory Claim Review
By Ronnie Ronzello
Subject: Supervisory Review

Mike,
Claim reassigned to you. Zurich has issued coverage denial letter. We may be able
to issue a "me too". See MaryAnn's claim review.
Thanks

Email was sent to michael.springmann@fara.com regarding these instructions.

Date 12/12/2013 Type: General
By Mary Ann Matthiessen

FARA004046
 Subject: EM to Nokomis Lemons of Markel

From: Matthiessen, MaryAnn
Sent: Thu 12/12/2013 11:55 AM
To: Nokomis.Lemons@markelcorp.com
Cc: Carrie.von.hoff@zurichna.com
Subject: Denbury Resources claim-south Delhi Field, LA Spill FARA 3927045

Nokomis~

We have learned that Zurich has disclaimed. They continue to investigate the
matter, but at this time their declination remains, as for other policies in
place, there was a Lloyds well policy, but I am not certain if it is paying for
the loss.

Since your policy follows form to Ironshore's I have attached a copy of the
Zurich disclaimer that was obtained from Lockton.

MaryAnn Matthiessen
Senior Environmental Adjuster
609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Nokomis Lemons [mailto:Nokomis.Lemons@markelcorp.com]
Sent: Wed 12/11/2013 10:21 AM
To: 'brandy.henderson@libertymutual.com'; "Carrie Von';
edmund.papazian@libertyIU.com; Matthiessen, MaryAnn; Nokomis Lemons;
'pamela.mitchell@axiscapital.com'; pamemla.mithcell@axiscapital.com;
psteanoU@archinsurance.com; 'PStefanou@archinsurance.com'; Regina Francis;
regina.francis@markelcorp.com
Cc: martha.balogh@denbury.com
Subject: Denbury Resources claim-south Delhi Field, LA Spill

Please note confirmation of my email and contact information below and correct
file # to reflect MXUL25756.

I am looking for a status in update to Ms. Matthiessen's email dated November 15,
2013 regarding other potential coverage.

Thank you,
Nokomis

Nokomis F. Lemons
Sr. Claims Examiner
Markel Corporation
4521 Highwoods Parkway
Glen Allen, VA 23060-66148
D (804) 287-6979
nokomis.lemons@markelcorp.com
www.markelcorp.com

t;...;
o
V)
o
Date 12/12/2013 Type: General
By Mary Ann Matthiessen
Subject: Report to Ironshore #2

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thu 12/12/2013 4:13 PM
To: Matthiessen, MaryAnn
Cc: Ronzello, Ronald
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 Claim Number: FARA 3927045

MaryAnn:

Sounds like you are very well versed in this drill and by all means proceed as
outlined and keep me in the loop.

Great file handling!

FARA004047
SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Matthiessen, MaryAnn
Sent: Thu 12/12/2013 11:37 AM
To: Sanford.Oster@ironshore.com
Subject: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill -
D/A: 6/14/13 Claim Number: FARA 3927045

Good Morning Sandy,

I wanted to bring you up to date on this file. Although I have attached a formal
report, below are just the highlights.

Background:

Denbury Resources Inc. is an independent oil and natural gas company, whose
primary emphasis is on carbon dioxide (GC02u) enhanced oil recovery (GEORu) and
the redevelopment of older, depleted oil fields to recover stranded reserves of
oil that cannot otherwise be recovered by conventional methods. This is an
extensive oil spill submitted by Denbury in which they claim cleanup costs nearly
$40mm, (the figures have varied widely). It appears that a well policy may be
paying as Denbury is not asking payment for the time being. As we previously
discussed it may be that third party claims, if presented, may not be covered
under the Denbury well policy issued through Lloyds, but for now, no-one is
pressing a third party claim that we know of.

Policy general info:

As you may recall, Ironshore sits above 26mm in excess an underlying (issued by
Zurich-attached). Ironshore also follows form to the Zurich excess policy. I have
received Zurich's coverage letter dated July 9, 2013, (attached) and I have spoken
with Carrie Von Hoff, the adjuster who penned the letter. As of today, 12/12/2013,
Zurich's coverage denial remains, largely based on the time element pollution
endorsement. Zurich is taking the position that this loss was not sudden, but
rather due to a failure in the GZaplocku system which leaked over a significant
period of time. Zurich has retained Vertex Engineering to inspect the system
onsite; however, they are not expecting the engineer's report until January, and
will advise if there is any change to their July 2013 declination.

Clarification as to claims:

You will notice in Zurich's coverage letter that there were three incidents in the
Delhi Field, in Ascension Parish, Louisiana. It appears that Denbury may have
agreed with Zurich's position on this and therefore since the July 2013
disclaimer, Denbury has withdrawn the first two claims as. The third is the
largest and the subject of this file.

1.) Denbury discovered a leak at Delhi test site # 4 on March 20, 2013, which was
caused by the failure of a GZaplocku connection. Approximately 75 barrels of
saltwater and 2 barrels of oil were released into the right of way and adjoining
property. Cleanup is under $200,000. (This claim has no been withdrawn).

2.) On March 26, 2013, Denburyus foreman was notified of a leak at DFU 125-1. A
landowner reported an undetermined amount of saltwater on his property, caused by
a GZaplocku flow line failure. Expenses are approximately $1.5 million. (This
claim has been withdrawn).

3.) On June 14, 2013, Denbury received a call that C02, saltwater and oil were
present on the TransCanada right of way, which is an indicator that there was a
leak. Fluid containment and recovery continued at least until June 25, 2013. (We
have been updated by Lockton, the new broker, who took the account over from
Marsh, and they suggest that the cleanup costs total approximately $49 million,
and source control efforts to stop the flow was $16 million. Denbury is
evaluating other possible expenses as part of the claim and anticipate third party

FARA004048
 claims from TransCanada and possibly others, but to date we know of none.)

Recommendations:

Since Ironshore follows form to the Zurich excess policy, and a disclaimer has
been issued by Zurich, Ironshore may also follow the same terms as outlined by
Zurich. At this time no underlying carrier has tendered the matter, therefore
since Zurich has issued the denial, no response is currently pending from
Ironshore, unless you see some other reason to respond. We will follow with Carrie
Von Hoff of Zurich to see once their engineer constructs a report, if it may
change their coverage position. On June 18, 2013, Fara, on behalf of Ironshore,
acknowledged the claim to Denbury and expressly reserved all rights under the
Ironshore policy. Denbury had a response team in place and provided reports to all
carriers of their efforts and exposure. Initial discussions with Denbury Martha
Balogh- Risk Management Specialist Denbury Resources Inc., indicated that Denbury
will be responsible for this loss; however, we suggest that there remains much
investigation that is necessary before this matter can be fully evaluated, as such
we will be following with Denbury, Marsh and Zurich to determine the cause and see
if ZurichUs denial will be challenged.

Reserves:

MaryAnn Matthiessen
Senior Environmental Adjuster

609.618.4497 office
866.575.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 12/12/2813 Type: General
By Mary Ann Matthiessen
Subject: TC with Carrie Von Hoff of Zurich

Today I placed a call to Carrie Von Hoff who is the adjuster for Zurich.
Environmental Claims Specialist Carrie.von.hoff@zurichna.com
847-413-5465.

She is handling the claim on the primary layer and the initial excess for Zurich,
in which Ironshore's excess policy follows form.
I spoke with her in detail about her disclaimer, and she advised that at this time
Zurich's disclaimer of coverage remains) based on the time element pollution
endorsement that this event was not sudden nor accidental.
She has sent an engineering firm to the site and if they find anything different,
she will re-evaluate her coveage poisiton) but for now it remains.
I advised that I probably would check back with her in January 2814, as she did
not expect a report from her engineer prior to then.

..-o They are looking at a failure in the zaplock system which has caused multiple
leaks all along this same South Delhi field line.
r--
o
Date 12/12/2813 Type: General
By Mary Ann Matthiessen
Subject: Reserves as of 12/12/13

Reserves as of 12/12/21313

Claim Id: 39271345

Claimant: South Delhi Field, LA Spill

Accident Date: 06/14/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

FARA004049
 Sub Line: Liability - Property Damage

111
Reserved: • • • •

Status:

Date 12/12/2013 Type: General
By Mary Ann Matthiessen
Subject: EM from Jeff HIggins -Lockton- Zurich's disclaimer

From: Higgins, Jeff [mailto:JHiggins@lockton.com]
Sent: Mon 11/25/2013 5:23 PM
To: Matthiessen, MaryAnn
4-;
Cc: 'Martha Balogh'
o Subject: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill -
00 D/A: 6/14/13 Claim Number: FARA 3927045
o

Insured: Denbury Resources

Ironshore Specialty Insurance Company/FARA
Adjuster: Mary Ann Matthiessen
Claim Number: FARA 3927045

Starr Surplus Lines Insurance Company/FARA
Claim Number: FARA 3927048

MaryAnn,

Per your request, attached is the Zurich coverage letter pertaining to the Delhi
release~ We are working with Carrie now to resolve the reservations and coverage
questions she raised. Please let me know if you have any questions about this.
Thank you.

Jeff Higgins, CPCU
Senior Vice President, Claims Services
Lockton Companies

FARA004050
5847 5an Felipe, Suite 320
Houston, TX 77057
Tel: 713.458.5270
Mobile: 832.563.9936
Fax: 713.430.5270
E-mail: jhiggins@lockton.com

Date 11/25/2013 Type: General
By Mary Ann Matthiessen
Subject: Call from Jeff Higgins of Lockton

Rec'd a call this afternoon from Jeff Higgins, the new broker for Denbury, he
is with Lockton.Tel: 713.458.5270.
He wanted to be sure that I was aware of this claim as it has a potential to get
into Ironshore's layer.Although there will be some continuing expenses relating to
groundwater monitoring, these additional costs will not be ,tracked on a
spreadsheet going forward. Cleanup costs totaled approximately $49 million and
source control efforts to stop the flow was $16 million. Denbury is evaluating
other possible expenses as part of the claim and anticipate third party'claims
from TransCanada and possibly others.

I advised him that Ironshore would not be issuing a coverage evaluation until such
time we were presented with Zurich's position.
He advised that Zurich disclaimed and that he thinks it was wrong and done too
prematurely.

The well policy was not affording coverage either accoring to him.

He will contact Denbury and see if he can forward to me a copy of the Zurich
coverage position.

Zurich has the primary layer of $lmm and then the primary excess layer, below the
Ironshore layer.

Date 11/19/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to/from Zurich -still need coverage opinion

From: Matthiessen, MaryAnn
Sent: Tue 11/19/2013 1:35 PM
To: Carrie Von Hoff
Cc: Nokomis.Lemons@markelcorp.com
Subject: Denbury- South Delhi Field, LA Spill - D/A: 6/14/13 - FARA 3927045

Hi Carrie.,
Thank you for the response.

Ironshore has a follow form to the controlling Zurich policy, although we are not
certain why you need approval to release this coverage opinion to us, we will
await your further investigation, so that you can evaluate your coverage position
and then provide it to us at that time.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.com]
Sent: Tue 11/19/2013 1:16 PM
To: Matthiessen, MaryAnn
Subject: Re: Denbury- South Delhi Field, LA Spill - D/A: 6/14/13 - FARA 3927045

Hi MaryAnn,

Our consultant was just at the site last week, and I await his report so I
may review coverage. I do not have approval to release my coverage letter
at this time. I will continue to keep you advised.

FARA004051
 Sincerely,

Carrie A. Von Hoff, JD, SCLA
Zurich North America
Environmental Claims Specialist
Pollution Group
1400 American Lane, T2/F7
Schaumburg, Illinois 60196
847-413-5465

Date 11/19/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to/from Alterra- carrier above Ironshore

-----------------------------------------------------------------------------
From: Matthiessen, MaryAnn
Sent: Tue 11/19/2013 7:53 AM
To: Nokomis Lemons
Subject: RE: South Delhi Field Incident - Your File #: FARA3927045 - Alterra File
#: MXUL25756

Hi Nokomis.,

Will do. Please note I gave you the incorrect file number it is
3927045 for future reference.
Thank you.
MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Nokomis Lemons [mailto:Nokomis.Lemons@markelcorp.com]
Sent: Fri 11/15/2013 8:34 AM
To: Matthiessen, MaryAnn
Subject: RE: South Delhi Field Incident - Your File #: FARA3925455 - Alterra File
#: MXUL25756

Thank you for the follow up. From your email, it appears there is other coverage
available which may limit any potential exposure to Alterraus excess policy. Once
you have determined the other layers and their limits, as well as any coverage
letters obtained, please forward to my attention.

Nokomis F. Lemons

4-<
Sr. Claims Examiner
o
o
Markel Corporation

4521 Highwoods Parkway

Glen Allen, VA 23060-6148

Direct: (804) 287-6979

Toll Free: (888) 629-8848 ext. 6979

Fax: (804) 287-6933

nokomis.lemons@markelcorp.com

www.markelcorp.com

FARA004052
From: Matthiessen, MaryAnn [mailto:MaryAnn.Matthiessen@FARA.com)
Sent: Friday, November 15, 2013 7:58 AM
To: Nokomis Lemons
Subject: Re: South Delhi Field Incident - Your File #: FARA3925455 - Alterra File
#: MXUL25756

Hi Nokomis,

Ironshore follows Zurich. We are waiting on their coverage letter issued to
Denbury which I have again requested from Carrie VonHoff. Additionally, I
understand there is a well site policy with other carriers that may be affording
coverage for the remediation although I am not certain that it has responded.

I do not know anymore at this time.

Regards

MaryAnn Matthiessen
Sent from my iPhone

Date 11/14/2013 Type: Plan To Conclude
By Mary Ann Matthiessen
Subject: Claim Review - Plan To Conclude

Action Plan:
Follow for:
1.) Zurich coverage evaluation.
2.) further details of loss.
3.)If Zurich's disclaimer is straighforward then we might be able to send a simple
"me too" coverage letter to Denbury, as per Ironshore's advise of 8/6j2013.

Date 11/14/2013 Type: Exposure Evaluation
By Mary Ann Matthiessen
Subject: Claim Review - Exposure Evaluation

Upadated as of 11/14/2014:

Louisiana Environmental Exposure.
We still do not have the underlying controlling Insurer's evaluation-
Zurich/American Guarantee & Liability Insurance Company- we have requested same
again from Carrie Hoff of Zurich.

We suspect that the Lloyds well policy is affording coverage for the remediation
on the Denbury site.

Damages and liability:
The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in Lousina involved, but this is as per Denbury and the facts
still are not developed.

The property is leased from private owners (unknown to us at this time) and is
private property.
Currently, As of July 30, 2013- the incurred for remediation is $42,436,886.88.
They are only in the early stages of the cleanup as this loss just occurred on
June 14, 2013.

RESERVES:

RECOMMENDATIONS:
Zurich as the lead had previously advised
that they disclaimed to Denbury. Lloyds appears to have the well policy.
Ironshore has authorized the use of Randy Treadway to evaluate the coverage if
needed once we get a copy of Zurich's position, (denial).
It seems that the Zurich policy may provide coverage for liability losses to
persons and or property, assuming that this incident meets the definition of an
occurrence, which Zurich appears to be disputing.

Denbury has a response team in place as provided by their Lloyds well policy, and
provides weekly reports to all carriers of their efforts and exposure. Initial
discussions with Denbury Martha Balogh- Risk Management Specialist Denbury
Resources Inc. indicates that Denbury will be responsible for this loss; however,
we suggest that there remains much investigation that is necessary before this
matter can be fully evaluated, as such we will be following with Denbury, Lockton
(formerly Marsh) and Zurich to determine the cause.

Remediation costs now exceed 88 million.

FARA004053
Date 11/14/2013 Type: Subrogation
By Mary Ann Matthiessen
Subject: Claim Review - Subrogation and SIF

No subrogation identifiable at this time.

Date 11/14/2013 Type: Facts Summary
By Mary Ann Matthiessen
Subject: Claim Review - Summary Of Facts

Update 11/14/2013
At this time we await Zurich as the primary carrier's coverage opinion.We have
again requested from Carrie Hoff of Zurich.
The remediation costs are now at $88 million, but we suspect the Lloyds well
policy is paying for them.

THE IRONSHORE SPECIALTY ISURANCE COMPANY POLICY:
Policy Number: 000988602 RENEWAL OF: 000988601
Named Insured: Denbury Resources Inc.
5320 Legacy Drive
Plano, TX 75024
Policy Period: April 01, 2013 Expiration: April 01, 2014
Limits of Liability: $25,000,000 per occurrence and in the aggregate.

UNDERLYING:
Ironshore Provides follow form on the underlying.
Coverage: Excess Policy- not certain as to coverage afforded by controlling
underlying at this time. Controlling policy has been requested.
Underlying Insurer: American Guarantee & Liability Insurance Company (Zurich)
Policy Number: AUC 9242673-01
Limits: $25,000,000 per occurrence limit
**Defense Expenses are outside the Limits.

There is a $500k SIR and a primary Zurich policy GL09242578-01 of $500k.
Ironshore policy is in excess of $26,000,000 in underlying.

COVERAGE ANALYSIS: We have requested the American Guarantee & Liability Insurance
Company (Zurich) controlling policy and have been advised that they have
disclaimed.
After seeing the well policy and comparing it to the Zurich policy, it seems that
the Lloyd's policy affords clean up coverage while the Zurich policy affords
coverage under the "Blended Pollution" Endorsement, for claims of BI and PD as a
result of certain pollution conditions, and one of the requirements must be that
the occurrence must be "instantaneous" and having first commenced on a "specific
date and time" which is noticed by the insured within 30 days of the event. This
is apparently going to be Zurich's position, as explained via telephone, that this
was no an instantaneous event as there have been slow leaks from this well over
the past several months that have gone unnoticed.

My intent is to submit all documents to Randy once we have the coverage position
from Zurich, which should be shortly.

LOSS FACTS: **MUCH IS STILL NOT KNOWN. WE ARE UNSURE OF THE CAUSE OF THE LOSS,
THE DETAILS OF HOW MUCH PRODUCT HAS BEEN LOST AND WHO THE PROPERTY OWNERS ARE AND
THE DETAILS OF THE WELL OPERATION.

Denbury is an oil and gas company who leases and operates wells from private
landowners. At 3:10pm CT, Mr. Ryan Jacob, Denbury Onshore, LLC, received a call
from US Environmental Services uUSESu confirming that C02, oil, and saltwater was
present on the TransCanada Right of Way. Large release of carbon-dioxide is a by
product of the process at the source used to extract oil and bitumen (a sludgy
form of petroleum) from the earth. Formal responsibilities for the South Delhi
Field, LA Incident were transferred from TransCanada Pipeline to Denbury Onshore,
LLC.

The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in northeast Louisiana. The property is leased from private
owners and is private property.

Ms. Dawn Williams Louisiana Department of Environmental Quality briefed personnel
that 17 residences had been evacuated on 6/13/2013, *(indicates prior to the June
14, date of loss as reported), which included 34 residents, (17 residences remain
evacuated). Richland and Franklin Parish off-duty SherriffGs deputies secured the
scene, and road closures were active on Antley Road and Highway 132 in the region.

An initial air monitoring team was sent to Test Site 1 and all well location
adjacent to the release and determined that the site was safe to access

ENVIRONMENTAL

FARA004054
USES personnel are monitoring chloride levels in Swamp Slough.

RECOVERY & CONTAINMENT
USES and Hancock personnel recovered, and will continue to recover, fluids from
the Swamp Slough at Burke Road Bridge using vacuum trucks.
All recovered liquids are being placed in 500-barrel frac tanks for temporary
storage.

Key contacts:
On 7/8/2013 at 11:15am I contacted Ms. Martha Balogh- Risk Management Specialist
Denbury Resources Inc.
5320 Legacy Drive
Plano, Texas 75024
Office: 972-673-2076 (number called)
Cell: 469-693-1132
Email: martha.balogh@denbury.com

Date 11/14/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to Carrie Voh Hoff of Zurich for coverage op,

From: Matthiessen, MaryAnn
Sent: Thu 11/14/2013 4:46 PM
To: Carrie Von Hoff
Subject: Denbury- South Delhi Field, LA Spill - D/A: 6/14/13 - FARA 3927045

Ironshore INSURED: DENBURY RESOURCES, INC.
DATE OF LOSS: 06/16/2013
TYPE OF COVERAGE: *Umbrella, & Excess Liability Coverage
LOCATION OF LOSS: SOUTH DELHI FIELD, LA SPILL
FILE NUMBER: MARSH 13HOUS096165 FARA 3925455

Hi Carrie~

As you know FARA Insurance Services (uFARAu) is the designated claims adjusting
service (nTPA n) for certain matters involving Ironshore Specialty Insurance
Company, (uIronshoreu). We have acknowledged receipt of this loss ( June 16, 2013
spill incident in SOUTH DELHI FIELD, LA) to Denbury Resources Inc.

Effective for the term of April 1, 2013 to April 1, 2014, Ironshore provides
Denbury Resources Inc., under policy number 000988602 , with excess liability
coverage in the amount of $25,000,000. This excess layer would apply only after
$25,000,000 of primary and underlying insurance has been exhausted. As we
discussed previously, the Zurich policy # AUC 9242673-01 is the controlling policy
form to which the Ironshore policy follows form and we are awaiting Zurich's
coverage opinion.

It also appears that Denbury had an additional well policy issued by Lloyds, that
may have afforded coverage for the remediation of this loss, we are concerned
because we see the costs projected near $80,000,000 for the remediation and want
to be certain that Denbury understands the position of the underlying carrier.
Please advise if Denbury has pressed Zurich for reimbursement of remediation
costs.

Finally, You had been waiting for approval to issue me a copy of Zurich's coverage
opinion, at this time we again renew our request for Zurich's coverage opinion
issued to Denbury.

Thank you,
MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.com]
Sent: Fri 10/11/2013 1:49 PM
To: Martha.Balogh@denbury.com
Cc: Matthiessen, MaryAnn; Richard Burgess; Higgins, Jeff
Subject: Re: FW: South Delhi Field Incident - Cost Tracking Spreadsheet

FARA004055
Hi Martha,

Not at this point. I will keep in touch as David's investigation
progresses.

Sincerely,

Carrie A. Von Hoff, JD, SCLA
Zurich North America
Environmental claims Specialist
Pollution Group
1400 American Lane, T2/F7
Schaumburg, Illinois 60196
847-413-5465

MarthaBalogh
, PM
"MaryAnn .Matthiessen@FARA.com"
Richard Burgess

Subject South
Delhi Field Incident - Cost Tracking

Carrie"

An update on the cost tracking sheet. I understand most of the cleanup
should be completed by end of next week. Also, David Codero has a call set
up with Ryan Jacob, our manager on the incident, tomorrow to discuss and
confirm a time to visit the field.

Is there anything else you need from me at this time?

Regards,

Martha
Martha Balogh

Risk Management Specialist

Denbury Resources Inc.

Date 11/14/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to from Nokomis Lemons- Markel

From: Matthiessen, MaryAnn
Sent: Thu 11/14/2013 4:21 PM
To: Nokomis Lemons
Subject: RE: South Delhi Field Incident - Your File #: FARA3925455 - Alterra File
#: MXUL25756

Dear Nokomis"
Please advise as to your relation to Denbury.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Nokomis Lemons [mailto:Nokomis.Lemons@markelcorp.com]

FARA004056
Sent: Tue 10/8/2013 7:21 PM
To: Matthiessen, MaryAnn
Subject: South Delhi Field Incident - Your File #: FARA3925455 - Alterra File #:
MXUL25756

Please provide a status of your claim investigation or what has been provided by
underlying carrier. Have you been provided with defense counsel reports and/or
underlying carrier reports? If so, please provide to my attention.

Thank you,

Nokomis

Nokomis F. Lemons

Sr. Claims Examiner

Markel Corporation

4521 Highwoods Parkway

Glen Allen, VA 23060-6148

Direct: (804) 287-6979

Toll Free: (888) 629-8848 ext. 6979

Fax: (804) 287-6933

nokomis.lemons@markelcorp.com

www.markelcorp.com

Date 08/06/2013 Type: General
By Mary Ann Matthiessen
Subject: EM from Zurich -awaiting copy of coverage opinion

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.com]
Sent: Tue 8/6/2013 11:19 AM
To: Matthiessen, MaryAnn
Subject: RE: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

I just received a note from Martha - she is heading into a meeting now and
will look at this and get back to me.

Sincerely"

Carrie A. Von Hoff, JD, SCLA
Zurich North America
Environmental Claims Specialist
Pollution Group
1400 American Lane, T2/F7
Schaumburg, Illinois 60196
847-413-5465

Date 08/06/2013 Type: Plan To Conclude
By Mary Ann Matthiessen
Subject: Claim Review - Plan To Conclude

Action Plan:
Follow for:
1.) controlling policy form and coverage evaluation if and when one is complete.
2.) further details of loss.
3.)If Zurich's disclaimer is straighforward then we might be able to send a simple
"me too" coverage letter to Denbury, as per Ironshore's advise of 8/6/2013.

FARA004057
Date 08/06/2013 Type: Exposure Evaluation
By Mary Ann Matthiessen
Subject: Claim Review - Exposure Evaluation

Louisiana Environmental Exposure.
We still do not have the underlying controlling policy form from American
Guarantee & Liability Insurance Company- we have requested same along with
coverage positions when completed.

Damages and liability:
The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in Lousina involved, but this is as per Denbury and the facts
still are not developed.

The property is leased from private owners (unknown to us at this time) and is
private property.
Currently, As of July 30, 2013- the incurred for remediation is $42,436,886.88.
They are only in the early stages of the cleanup as this loss just occurred on
June 14, 2013.

RESERVES:

RECOMMENDATIONS:
"~~~~~~~~~~~~I1~~~~~zurich as the lead as disclaimed to Denbury.
Lloyds appears to have the well policy.
Ironshore has authorized the use of Randy Treadway to evaluate the coverage if
needed once we get a copy of Zurich's position, (denial).
It seems that the Zurich policy may provide coverage for liability losses to
persons and or property, assuming that this incident meets the definition of an
occurrence, which Zurich appears to be disputing.

Denbury has a response team in place as provided by their Lloyds well policy, and
provides weekly reports to all carriers of their efforts and exposure. Initial
discussions with Denbury Martha Balogh- Risk Management Specialist Denbury
Resources Inc. indicates that Denbury will be responsible for this loss; however,
we suggest that there remains much investigation that is necessary before this
matter can be fully evaluated, as such we will be following with Denbury, Marsh
and Zurich to determine the cause.

Date 08/06/2013 Type: Subrogation
By Mary Ann Matthiessen
Subject: Claim Review - Subrogation and SIF

No subrogation identifiable at this time.

Date 08/06/2013 Type: Facts Summary
By Mary Ann Matthiessen
Subject: Claim Review - Summary Of Facts

Update given to Sandy Oster on 8/6/2013

THE IRONSHORE SPECIALTY ISURANCE COMPANY POLICY:
Policy Number: 000988602 RENEWAL OF: 000988601
Named Insured: Denbury Resources Inc.
5320 Legacy Drive
Plano, TX 75024
Policy Period: April 01, 2013 Expiration: April 01, 2014
Limits of Liability: $25,000,000 per occurrence and in the aggregate.

UNDERLYING:
Ironshore Provides follow form on the underlying.
Coverage: Excess Policy- not certain as to coverage afforded by controlling
underlying at this time. Controlling policy has been requested.
Underlying Insurer: American Guarantee & Liability Insurance Company (Zurich)
Policy Number: AUC 9242673-01
Limits: $25,000,000 per occurrence limit
**Defense Expenses are outside the Limits.

There is a $500k SIR and a primary Zurich policy GL09242578-01 of $500k.
Ironshore policy is in excess of $26,000,000 in underlying.

COVERAGE ANALYSIS: We have requested the American Guarantee & Liability Insurance
Company (Zurich) controlling policy and have been advised that they have
disclaimed.
After seeing the well policy and comparing it to the Zurich policy, it seems that

FARA004058
the Lloyd's policy affords clean up coverage while the Zurich policy affords
coverage under the "Blended Pollution" Endorsement, for claims of BI and PD as a
result of certain pollution conditions, and one of the requirements must be that
the occurrence must be "instantaneous" and having first commenced on a "specific
date and time" which is noticed by the insured within 313 days of the event. This
is apparently going to be Zurich's position, as explained via telephone, that this
was no an instantaneous event as there have been slow leaks from this well over
the past several months that have gone unnoticed.

My intent is to submit all documents to Randy once we have the coverage position
from Zurich, which should be shortly.

LOSS FACTS: **MUCH IS STILL NOT KNOWN. WE ARE UNSURE OF THE CAUSE OF THE LOSS,
THE DETAILS OF HOW MUCH PRODUCT HAS BEEN LOST AND WHO THE PROPERTY OWNERS ARE AND
THE DETAILS OF THE WELL OPERATION.

Denbury is an oil and gas company who leases and operates wells from private
landowners. At 3:113pm CT, Mr. Ryan Jacob, Denbury Onshore, LLC, received a call
from US Environmental Services GUSESu confirming that C02, oil, and saltwater was
present on the TransCanada Right of Way. Large release of carbon-dioxide is a by
product of the process at the source used to extract oil and bitumen (a sludgy
form of petroleum) from the earth. Formal responsibilities for the South Delhi
Field, LA Incident were transferred from TransCanada Pipeline to Denbury Onshore,
LLC.

The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in northeast Louisiana. The property is leased from private
owners and is private property.

Ms. Dawn Williams Louisiana Department of Environmental Quality briefed personnel
that 17 residences had been evacuated on 6/13/21313, '(indicates prior to the June
14, date of loss as reported), which included 34 residents, (17 residences remain
evacuated). Richland and Franklin Parish off-duty Sherriffus deputies secured the
scene, and road closures were active on Antley Road and Highway 132 in the region.

An initial air monitoring team was sent to Test Site 1 and all well location
adjacent to the release and determined that the site was safe to access

ENVIRONMENTAL
USES personnel are monitoring chloride levels in Swamp Slough.

RECOVERY & CONTAINMENT
USES and Hancock personnel recovered~ and will continue to recover, fluids from
the Swamp Slough at Burke Road Bridge using vacuum trucks.
All recovered liquids are being placed in See-barrel frac tanks for temporary
storage.

Key contacts:
On 7/8/21313 at 11:15am I contacted Ms. Martha Balogh- Risk Management Specialist
Denbury Resources Inc.
53213 Legacy Drive
Plano, Texas 751324
Office: 972-673-21376 (number called)
Cell: 469-693-1132
Email: martha.balogh@denbury.com

Date 138/136/21313 Type: General
By Mary Ann Matthiessen
Subject: TC with Sandy Oster

Updated Sandy Oster of Ironshore on the status of this claim, it appears that
the well carrier- Lloyds will pick up the remediation of the spill, while Zurich
has disclaimed as the primary underlying.
I am awaiting a copy of Zurich's coverage evaluation, Sandy advised that if
Zurich's disclaimer is straighforward then we might be able to send a simple "me
too" coverage letter to Denbury.
Awaiting a copy of Zurich's letter.

Date 138/136/21313 Type: General
By Mary Ann Matthiessen
Subject: EM to Carrie Von Hoff of Zurich underlying

From: Matthiessen, MaryAnn
Sent: Tue 8/6/21313 11:133 AM
To: Carrie Von Hoff
Subject: RE: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 39271345

Hi Carrie,

FARA004059
 Any word on getting Ironshore a copy of your coverage evaluation?

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Matthiessen, MaryAnn
Sent: Mon 7/22/2e13 1e:22 AM
To: Carrie Von Hoff
Subject: RE: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927e45

Thank you Carrie.

MaryAnn Matthiessen
Senior Environmental Adjuster

6e9.61e.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 7e471

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.com]
Sent: Mon 7/22/2e13 9:57 AM
To: Matthiessen, MaryAnn
Subject: Re: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Good morning J MaryAnn~

Just wanted to let you know I am still waiting for Denbury's approval. I
hope to be able to respond soon.

Carrie

Carrie A. Von Hoff, JD, SCLA
Zurich North America
Environmental Claims Specialist
Pollution Group
1400 American Lane, T2/F7
Schaumburg, Illinois 6e196
847-413-5465

..""..
o
00 Date 07/22/2e13 Type: General
...... By Mary Ann Matthiessen
......
Subject: EM from Zurich waiting on coverage opinion

From: Matthiessen, MaryAnn
Sent: Mon 7/22/2e13 1e:22 AM
To: Carrie Von Hoff
Subject: RE: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Thank you Carrie.

MaryAnn Matthiessen
Senior Environmental Adjuster

6e9.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company

FARA004060
1625 west Causeway Approach
Mandeville, LA 70471

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.com]
Sent: Mon 7/22/2013 9:57 AM
To: Matthiessen, MaryAnn
Subject: Re: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Good morning, MaryAnn,

Just wanted to let you know I am still waiting for Denbury's approval. I
hope to be able to respond soon.

Carrie

Carrie A. Von Hoff, JD, SCLA
Zurich North America
Environmental Claims Specialist
Pollution Group
1400 American Lane, T2/F7
Schaumburg, Illinois 60196
847-413-5465

"Matthies sen"
MaryAnn"

cc
07/17/2013 08:18
AM Subject
Denbury Resources, Inc. - Matter:
South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Hi Carrie"
I know you have been out of the office and advised that you were waiting on
Denbury's approval to issue us a copy of your coverage position. But as you
know, Ironshore follows form to Zurich's policy and would request that we
see your position as soon as possible.
When you can please send me a copy of Zurich's coverage position on the
South Delhi Field matter.

It appears that the Lloyds policy (well policy) may be the primary for the
cleanup of the site.
Recent reports indicate that the cleanup has now approached $29mm.
Please let me know if you have had a chance to review Lloyds well policy
issued to Denbury as well.

Regards,

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

FARA004061

Date 07/17/2013 Type: General
By Mary Ann Matthiessen
Subject: EM response from Sandy Oster- file direction

From: Matthiessen, MaryAnn
Sent: Wed 7/17/2013 9:22 AM
To: Sanford Oster; Ronzello, Ronald
Cc: John Reusch
Subject: RE: South Delhi Field spill- Denbury Spill Claim FARA 3927045

Excellent. Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.comj
Sent: Wed 7/17/2013 9:21 AM
To: Matthiessen, MaryAnn; Ronzello, Ronald
Cc: John Reusch
Subject: Re: South Delhi Field spill- Denbury Spill Claim FARA 3927045

MaryAnn,
Fully concur.
I reviewed the Zurich lead umbrella and agree that the only coverage is for
consequential third party damage. There is no cleanup/remediation coverage.

The London policy clearly affords that cover as evidenced by the contractor
retention which is written into the policy.

Absent any stand alone language that is in our policy, I don't believe there is,
we look to be on solid footing.

Randy is a backstop in the event we have missed anything or there is pushback from
Denbury or an invite from Lloyd's to co-insure.

Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 100e4
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com
.-o
o From: Matthiessen, MaryAnn [mailto:MaryAnn.Matthiessen@FARA.comj
N Sent: Wednesday, July 17, 2e13 e9:12 AM
To: Sanford oster; Ronzello, Ronald
Cc: John Reusch
Subject: South Delhi Field spill- Denbury Spill Claim FARA 3927045

Good Morning Sandy,

I wanted to give you an update, right now I am waiting for Zurich's coverage
position, as the examiner has been out of the office for the last week, she
returned yesterday and is waiting on approval from Denbury to issue us a copy of
her coverage position to us. However, based on the correspondence received, it
appears that Denbury is pursing Lloyds under the well policy for the cleanup.
Denbury has not provided us with much information with respect to this matter, I
have no contracts with the property owner, no other investigation. When I have
called Denbury, I can't figure if they are being evasive or if they truly don't
know. It appears that Boots and Coots is coordinating all cleanup as per the terms
of the Lloyds well policy.

After seeing the well policy and comparing it to the Zurich policy, it seems that
the Lloyd's policy affords clean up coverage while the Zurich policy affords

FARA004062
 coverage under the "Blended Pollution" Endorsement, for claims of BI and PD as a
result of certain pollution conditions, and one of the requirements must be that
the occurrence must be "instantaneous" and having first commenced on a "specific
date and time" which is noticed by the insured within 30 days of the event. This
is apparently going to be Zurich's position, as explained via telephone, that this
was no an instantaneous event as there have been slow leaks from this well over
the past several months that have gone unnoticed.

My intent is to submit all documents to Randy once we have the coverage position
from Zurich, which should be shortly.

Regards,

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date
By Mary Ann Matthiessen
Subject: EM to Carrie Von Hoff- Zurich Lead Umbrella

-----------------------------------------------------------------------------

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.com]
Sent: Wed 7/17/2013 3:56 PM
To: Matthiessen, MaryAnn
Subject: Carrie Von Hoff is out of the office.

I will be out of the office starting 07/17/2013 and will not return until
07/22/2013.

If you need immediate attention, please contact Brad Rausa
(brad.rausa@zurichna.com; 847-605-3744) in our office for assistance.

From: Matthiessen, MaryAnn
Sent: Wed 7/17/2013 9:18 AM
To: carrie.von.hoff@zurichna.com
Subject: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Hi Carrie"
I know you have been out of the office and advised that you were waiting on
Denbury's approval to issue us a copy of your coverage position. But as you know,
Ironshore follows form to Zurich's policy and would request that we see your
position as soon as possible.
When you can please send me a copy of Zurich's coverage position on the South
Delhi Field matter.

...".. It appears that the Lloyds policy (well policy) may be the primary for the cleanup

--
o
C"1
of the site.
Recent reports indicate that the cleanup has now approached $29mm.
Please let me know if you have had a chance to review Lloyds well policy issued to
Denbury as well.

Regards,

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

FARA004063
 Date 07/17/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to Sandy Oster of file direction

From: Matthiessen, MaryAnn
Sent: Wed 7/17/2013 9:12 AM
To: Sanford Oster; Ronzello, Ronald
Cc: John Reusch
Subject: South Delhi Field spill- Denbury Spill Claim FARA 3927045

Good Morning Sandy,

I wanted to give you an update, right now I am waiting for Zurich's coverage
position, as the examiner has been out of the office for the last week, she
returned yesterday and is waiting on approval from Denbury to issue us a copy of
her coverage position to us. However, based on the correspondence received, it
appears that Denbury is pursing Lloyds under the well policy for the cleanup.
Denbury has not provided us with much information with respect to this matter, I
have no contracts with the property owner, no other investigation. When I have
called Denbury, I can't figure if they are being evasive or if they truly don't
know. It appears that Boots and Coots is coordinating all cleanup as per the terms
of the Lloyds well policy.

After seeing the well policy and comparing it to the Zurich policy, it seems that
the Lloyd's policy affords clean up coverage while the Zurich policy affords
coverage under the "Blended Pollution" Endorsement, for claims of BI and PD as a
result of certain pollution conditions, and one of the requirements must be that
the occurrence must be "instantaneous" and having first commenced on a "specific
date and time" which is noticed by the insured within 30 days of the event. This
is apparently going to be Zurich's position, as explained via telephone, that this
was no an instantaneous event as there have been slow leaks from this well over
the past several months that have gone unnoticed.

My intent is to submit all documents to Randy once we have the coverage position
from Zurich, which should be shortly.

Regards,

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thu 7/11/2013 9:09 AM
To: Matthiessen, MaryAnn; Ronzello, Ronald
Cc: John Reusch
Subject: RE: Denbury Spill Claim FARA 3927045

MaryAnn~ Ronnie~

I understand that there were discussions with Dawn Krigstin from our Environmental
group and I hope she was able to provide some additional guidance.

<;.... For now, Iud like to stick with our original game plan of waiting for Zurich to
o issue their coverage denial based upon the lack of a single episodiC event.
N
N Once that is received we can review and determine the efficacy of that
declination.

In the meantime, letus have Randy Treadaway review the Zurich lead umbrella in
conjunction with our follow-form and the GSR Policy. More specifically, the
following portion of the GSR policy-Section lC-Cleanup Expenses and Seepage,
Pollution & Containment Insurance,

Randy neednut issue a formal report and we can simply have a conference call after
heus had a chance to look over all the coverage and the interplay amongst them.

Sorry for all the confusion but I was out of the office and everyone was trying to
pitch in.

Feel free to call with any concerns or questions.

Sandy

SANFORD OSTER

FARA004064
Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

Date 07/17/2013 Type: General
By Mary Ann Matthiessen
Subject: EM from Sandy Oster to assign to Randy Treadaway

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Thu 7/11/2013 9:09 AM
To: Matthiessen, MaryAnn; Ronzello, Ronald
Cc: John Reusch
Subject: RE: Denbury Spill Claim FARA 3927045

MaryAnn~ Ronnie~

I understand that there were discussions with Dawn Krigstin from our Environmental
group and I hope she was able to provide some additional guidance.

For now, IUd like to stick with our original game plan of waiting for Zurich to
issue their coverage denial based upon the lack of a single episodic event.

Once that is received we can review and determine the efficacy of that
declination.

In the meantime, letUs have Randy Treadaway review the Zurich lead umbrella in
conjunction with our follow-form and the GSR Policy. More specifically, the
following portion of the GSR policy-Section lC-Cleanup Expenses and Seepage,
Pollution & Containment Insurance.

Randy need nUt issue a formal report and we can simply have a conference call after
heUs had a chance to look over all the coverage and the interplay amongst them.

Sorry for all the confusion but I was out of the office and everyone was trying to
pitch in.

Feel free to call with any concerns or questions.

Sandy

SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Matthiessen, MaryAnn [mailto:MaryAnn.Matthiessen@FARA.com]
Sent: Monday, July 08, 2013 1:42 PM
To: Sanford Oster; Ronzello, Ronald
Cc: John Reusch
Subject: Denbury Spill Claim FARA 3927045

Hello Sandy,

I have attached my preliminary report to you, along with Denbury's latest update.

While large remediation efforts have been underway, we still have limited details
as to the cause of the loss.

FARA004065
MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: EM fron Carrie Von Hoff of Zurich

From: Carrie Von Hoff [mailto:carrie.von.hoff@zurichna.comj
Sent: Tue 7/9/2013 4:03 PM
To: Matthiessen, MaryAnn
Subject: Carrie Von Hoff is out of the office.

I will be out of the office starting 07/09/2013 and will not return until
07/15/2013.

I will have limited access to email during my absence. If you need
immediate attention, please contact Brad Rausa (brad.rausa@zurichnna.com;
847-605-3744) in our office for assistance.

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: TC with Sandy Oster

This afternoon, the details of the case were discussed with Sandy Oster of
Ironshore.

At this time it was decided that we would wait for the Zurich coverage opinion,
(should be received within the week), then evaluate the Well Policy(no exposure
for Ironshore) in conjunction with the Zurich umbrella controlling policy to
determine:
1.) who may be primary for remediation, for both the wellsite and offsite
properties.
2.) who may be exposed by any potential third party claims from nearby property
owners for PD or BI.(to date no claims have been made.)

An evaluation of the policies may help us to better understand the type of
coverage each policy affords.

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: Lloyds well Policy

From: Matthiessen, MaryAnn
Sent: Tue 7/9/2013 1:47 PM
To: Sanford Oster
Cc: Ronzello, Ronald
Subject: RE: Denbury Spill Claim FARA 3927045

That is exactly what I was hoping they had. It was hard for me to believe that
Denbury only had the coverage as outlined.
I believe they are triggering this policy, I see the carriers participating on
the London slip noticed in emails.

MaryAnn Matthiessen
Senior Environmental Adjuster

FARA004066
609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tue 7/9/2013 1:43 PM
To: Matthiessen, MaryAnn
Cc: Ronzello, Ronald
Subject: Fw: Denbury Spill Claim FARA 3927045

Interesting second policy.

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Jordan Gantz
Sent: Tuesday, July 09, 2013 12:31 PM
To: Sanford Oster
Cc: Paul Garrot; Tim McAuliffe; Ben Beauvais; Ron Gleason; Charles Schraeder
Subject: FW: Denbury Spill Claim FARA 3927045

Sandy:

I believe you have already received the lead umbrella policy attached but also
attached is a Control of Well Policy that is in force. Perhaps there is
applicability for that policy in this situation.

JORDAN M. GANTZ

Chief Underwriting Officer

IRONSHORE SPECIALTY CASUALTY

ONE STATE STREET PLAZA [ 8TH FL [ NEW YORK, NY 10004

Office: 646.826.4877[ Mobile: 646.599.7122[ VCARD

From: Charles Schraeder
Sent: Tuesday, July 09, 2013 12:27 PM
To: Jordan Gantz
Cc: Paul Garrot; Tim McAuliffe; Ben Beauvais; Ron Gleason
Subject: RE: Denbury Spill Claim FARA 3927045

Jordan,

In addition to an umbrella, the insured maintains a control of well policy.
Attached is a copy of the umbrella and the control of well policy.

CHARLES SCHRAEDER

Senior Production Specialist

IRONSHORE SPECIALTY CASUALTY

FARA004067
ONE RIVERWAY 1 SUITE 1025 1 HOUSTON, TX 77056

Office: 713.343.89601 Mobile: 281.202.50831 VCARD

From: Ron Gleason
Sent: Tuesday, July 09, 2013 8:45 AM
To: Jordan Gantz; Charles Schraeder
Cc: Paul Garrot; Tim McAuliffe; Ben Beauvais
Subject: RE: Denbury Spill Claim FARA 3927045

Copy of the lead umbrella from Zurich is attached.

Marsh has confirmed that Denbury does not buy stand alone Environmental cover.

Ronald A. Gleason

Ironshore Insurance

Regional Executive

One Riverway, Suite 1025

Houston, TX 77056

Office: 713 343-8956

Cell: 281 389-3293

ron.gleason@ironshore.com

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to Zurich requesting coverage position

From: Matthiessen, MaryAnn
Sent: Tue 7/9/2013 2:27 PM
To: carrie.von.hoff@zurichna.com
Subject: Denbury Spill Claim - South Delhi Field, LA FARA 3927045

Hi Carrie . .

It was nice speaking with you this afternoon. FARA Insurance Services (uFARAu) is
the designated claims adjusting service for certain matters involving Ironshore
Specialty Insurance Company, (ulronshoreu). Ironshore previously acknowledged a
report of a June 16, 2013 spill incident in SOUTH DELHI FIELD, LA involving
Denbury Resources Inc .. FARA has set up a file # FARA-3927045 and is
investigating the loss as reported . .
As you indicated Zurich is in the process of issuing a coverage letter to Denbury,
when you can . . please provide me with your coverage position.
As you are aware Ironshore provides follow form coverage to the Zurich umbrella
policy.
Also, please find attached a Well Control Policy.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

FARA004068
Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: TC to Carrie Von Hoff of Zurich 847 413 5465

Placed a call at 2pm today to Carrie A. Von Hoff, JD, SCLA
Zurich North America
Environmental Claims Specialist
Pollution Group
1400 American Lane, T2/F7
Schaumburg, Illinois 60196
847-413-5465
E-mail: CarrieVonHoff

She has denied the claim to Denbury, it is going out today, there are multiple
reports of spillS throughout the month of May and June. For right now I am
concerned with the largest which is this South Delhi Field LA spill.
She advised that the loss was not sudden and accidental as defined in the timed
pollution endorsement.

She agreed to send me a copy of her denial, I will be sending her a copy of the
Lloyds well policy.
We discussed the potential of claims coming in from evacuated parties, currently
there are none, but this is a possibility. She informed me, if and when this
happens, Zurich will evaluate their position, but for right now this was not a
known spill that was sudden and accidental as per the terms of the Zurich policy.
She did advise me that Denbury was sending her in more information in which she
will further evaluate.

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: EM from Marsh with Zurich info

From: Lawrence, Jerry W [mailto:Jerry.W.Lawrence@marsh.com]
Sent: Tue 7/9/2013 1:57 PM
To: Matthiessen, MaryAnn
Cc: Williams, Alice 0
Subject: FW: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Carrie A. Von Hoff, JD, SCLA

Zurich North America

Environmental Claims Specialist

Pollution Group

1400 American Lane, T2/F7

Schaumburg, Illinois 60196

847-413-5465

E-mail: CarrieVonHoff

Jerry Lawrence) Senior Vice President

South Central Partnership Claims Leader

Marsh USA Inc.

1000 Main Street, Suite 30@0, Houston, Texas 77002, USA

+1 713 276 8432 I Mobile +1 713 319 6585 I Fax +1 713 276 8777 I
jerry.w.lawrence@marsh.com

Assistant: Alice Williams I +1 713 276 8438 I alice.o.williams@marsh.com

This document and any recommendations, analysis, or advice provided by Marsh
(collectively, the uMarsh Analysisu) are intended solely for the entity identified
as the recipient herein (uyouu). This document contains proprietary, confidential
information of Marsh and may not be shared with any third party, including other
insurance producers, without Marshus prior written consent. Any statements
concerning actuarial, tax, accounting, or legal matters are based solely on our
experience as insurance brokers and risk consultants and are not to be relied upon
as actuarial, accounting, tax, or legal advice, for which you should consult your
own professional advisors. Any modeling, analytics, or projections are subject to

FARA004069
 inherent uncertainty, and the Marsh Analysis could be materially affected if any
underlying assumptions) conditions, information, or factors are inaccurate or
incomplete or should change. The information contained herein is based on sources
we believe reliable, but we make no representation or warranty as to its accuracy.
Except as may be set forth in an agreement between you and Marsh, Marsh shall have
no obligation to update the Marsh Analysis and shall have no liability to you or
any other party with regard to the Marsh Analysis or to any services provided by a
third party to you or Marsh. Marsh makes no representation or warranty concerning
the application of policy wordings or the financial condition or solvency of
insurers or reinsurers. Marsh makes no assurances regarding the availability,
cost, or terms of insurance coverage.

From: Williams, Alice 0
Sent: Tuesday, July 09, 2013 12:54 PM
To: Lawrence, Jerry W
Subject: Re: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

FYI

From: Matthiessen, MaryAnn [mailto:MaryAnn.Matthiessen@FARA.com]
Sent: Tuesday, July 09, 2013 12:43 PM
To: Williams, Alice 0
Cc: martha.balogh@denbury.com
Subject: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Good Afternoon Alice,

I have obtained a copy of the American Guarantee & Liability Insurance Company
(Zurich) controlling policy form, but I am still seeking the name of the primary
adjuster who is handling this loss.

Do you have the details of the adjuster for Zurich so that I may contact them?

Ironshore wishes to discuss this matter this afternoon and I would like some more
details regarding this matter.

Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com
..""..
o
00
N FARA, A York Risk Services Company
,.....;
1625 West Causeway Approach
Mandeville, LA 70471

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: TC and EM to Alice Williams

Placed a call today to Alice Williams
MCP Claim Advisor
Marsh USA , Inc
1000 Main Street
Suite 3000
Houston, TX 77002-5008
(713) 276-8438 Fax (713) 276-8777

FARA004070
Alice.O.Williams@marsh.com

She was not in, so I followed with an email.

From: Matthiessen, MaryAnn
Sent: Tue 7/9/2013 1:43 PM
To: Williams, Alice 0
Cc: martha.balogh@denbury.com
Subject: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - FARA 3927045

Good Afternoon Alice,

I have obtained a copy of the American Guarantee & Liability Insurance Company
(Zurich) controlling policy form, but I am still seeking the name of the primary
adjuster who is handling this loss.
Do you have the details of the adjuster for Zurich so that may contact them?

Ironshore wishes to discuss this matter this afternoon and I would like some more
details regarding this matter.

Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Matthiessen, MaryAnn
Sent: Mon 7/8/2013 12:51 PM
To: Williams, Alice 0
Cc: martha.balogh@denbury.com
Subject: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - South Delhi Field Incident Cost Tracking

Hello Alice,

Thank you for the updated report.
I think I might be missing something, do you have the initial notice of loss that
tells the exact location and the size of the spill? I see reports of remediation,
but I don't see the initial incident report advising of the most basic
information, i&e.: location, well owner, size of spill.

We are trying to determine just how large was this spill and from what location
did it originate.

Can you please provide a copy of the American Guarantee & Liability Insurance
Company (Zurich) controlling policy form # AUC 9242673-01, and any contact
information for the adjuster.

I have corrected my file number to 3927045 for the Ironshore claim. I apologize
for any confusion.

Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

Date 07/09/2013 Type: General
By Mary Ann Matthiessen
Subject: Lead Umbrella Policy -info

FARA004071
 From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Tue 7/9/2013 1:33 PM
To: Matthiessen, MaryAnn
Cc: Ronzello, Ronald
Subject: Re: Denbury Spill Claim FARA 3927045

MaryAnn,
I agree and look forward to discussing later in the afternoon

Sandy

Sanford Oster, VP
Casualty Claims
Ironshore
One State Street Plaza
New York, NY 10004
646 826-4944-0ffice
347 759-1976-Cell
Sanford.oster@ironshore.com

From: Matthiessen, MaryAnn
Sent: Tue 7/9/2013 1:04 PM
To: Sanford Oster
Cc: Ronzello, Ronald
Subject: RE: Denbury Spill Claim FARA 3927045

Hi Sandy,

Thank you for the Zurich policy.

I took a look and I see the Blended Pollution Exclusion which gives back some
pollution coverage, particularly since there doesn't appear to be separate
pollution coverage, according to the prior emails.

I don't think we have enough facts right now to determine if there are coverage
concerns. We don't know all the details surrounding the loss, nor do we know the
area that is being remediate, i.e.: is it Denbury controlled property or property
of neighboring parties. I will press Zurich for this information. I am waiting on
the name of their adjuster.

I think maybe we should wait to see Zurich's position and interpretation of the
policy. We can use their opinion as a starting point for Ironshore. I think this
would be prudent to avoid a potential conflict in position between the two
carriers. At that time, then if we don't agree with their position, then
definitely we would want coverage counsel to take a look.

We can discuss more this afternoon.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

4-<
o
o From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
M Sent: Tue 7/9/2013 10:52 AM
To: Matthiessen, MaryAnn
Cc: Ronzello, Ronald
Subject: FW: Denbury Spill Claim FARA 3927045

MaryAnn,

Please see attached lead umbrella for your review.

Let me know if you want coverage counsel to review.

Sandy

SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

FARA004072
ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

From: Tim McAuliffe
Sent: Tuesday, July 09, 2013 9:49 AM
To: Sanford Oster; Ron Gleason
Cc: Jordan Gantz
Subject: FW: Denbury Spill Claim FARA 3927045

Sandy see attacheda.do we have any other description of facts/circumstances around
this onea.we looked online and saw nothing regarding a major spill etca

From: Ron Gleason
Sent: Tuesday, July 09, 2013 9:45 AM
To: Jordan Gantz; Charles Schraeder
Cc: Paul Garrot; Tim McAuliffe; Ben Beauvais
Subject: RE: Denbury Spill Claim FARA 3927045

Copy of the lead umbrella from Zurich is attached.

Marsh has confirmed that Denbury does not buy stand alone Environmental cover.

Ronald A. Gleason

Ironshore Insurance

Regional Executive

One Riverway, Suite 1025

Houston, TX 77056

Office: 713 343-8956

cell: 281 389-3293

ron.gleason@ironshore.com

From: Jordan Gantz
Sent: Monday, July 08, 2013 2:20 PM
To: Charles Schraeder; Ron Gleason
Cc: Paul Garrot; Tim McAuliffe; Ben Beauvais
Subject: FW: Denbury Spill Claim FARA 3927045

Charles:

Have you received the current term Zurich lead umbrella policy? If not, please
get a status update of its availability.

Also, please find out from the broker if this insured purchases separate
environmental coverage. If so, what are the details of this coverage?

JORDAN M. GANTZ

Chief Underwriting Officer

FARA004073
IRONSHORE SPECIALTY CASUALTY

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.48771 Mobile: 646.599.71221 VCARD

From: Tim McAuliffe
Sent: Monday, July 08, 2013 2:56 PM
To: Paul Garrot; Michael Gill
Cc: Jordan Gantz
Subject: Fw: Denbury Spill Claim FARA 3927045

FYI any idea on separate Environmental cover?

From: Sanford Oster
Sent: Monday, July 08, 2013 02:10 PM
To: Charles Schraeder
Cc: Tim McAuliffe
Subject: FW: Denbury Spill Claim FARA 3927045

Chuck,

Do you have the lead umbrella on Denbury. Looks like a time element pollution
coverage but there may be other limiting language.

Thanks,

SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

Date 07/08/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to from Ironshore with Zurich binder

From: Matthiessen, MaryAnn
Sent: Mon 7/8/2013 2:17 PM
To: Sanford Oster
Cc: Ronzello, Ronald
Subject: RE: Zurich Binder-Denbury

Thank you Sandy,
While this is just the binder, I don't see pollution or site pollution noted on
the underlying.
We will have to look into this further.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

FA~004074
From: Sanford oster [mailto:Sanford.Oster@ironshore.com]
Sent: Mon 7/8/2013 2:06 PM
To: Matthiessen, MaryAnn
Cc: Ronzello, Ronald
Subject: Zurich Binder-Denbury

Date 07/08/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to Marsh - Alice Williams for info

From: Matthiessen, MaryAnn
Sent: Mon 7/8/2013 12:51 PM
To: Williams, Alice 0
Cc: martha.balogh@denbury.com
Subject: Denbury Resources, Inc. - Matter: South Delhi Field, LA Spill - D/A:
6/14/13 - South Delhi Field Incident Cost Tracking

Hello Alice,

Thank you for the updated report.
I think I might be missing something, do you have the initial notice of loss that
tells the exact location and the size of the spill? I see reports of remediation,
but I don't see the initial incident report advising of the most basic
information~ i~e.: location) well owner) size of spill.

We are trying to determine just how large was this spill and from what location
did it originate.

Can you please provide a copy of the American Guarantee & Liability Insurance
Company (Zurich) controlling policy form # AUC 9242673-01, and any contact
information for the adjuster.

I have corrected my file number to 3927045 for the Ironshore claim. I apologize
for any confusion.

Thank you.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Williams, Alice 0 [mailto:Alice.O.Williams@marsh,com]
Sent: Mon 7/8/2013 11:20 AM
To: Matthiessen, MaryAnn; pamela.mitchell@axiscapital.com;
brandy.henderson@libertymutual.com; Stefanou, Paula (PStefanou@archinsurance.com);
nokomis.lemons@alterra-us.com
Cc: martha.balogh@denbury.com; Lawrence, Jerry W
Subject: Re: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/14/13 - South Delhi Field Incident Cost Tracking

To:

Alterra Excess & Surplus Insurance Co.

Adjuster: Nokomis Lemons

Claim Number: MXUL25756

FARA004075
Arch Insurance Company

Adjuster: Paul Stefanou, Esq.

Claim Number: 008012573230

Axis Surplus Insurance Company

Adjuster: Pamela Mitchell

Claim Number: Unknown (Please provide Claim Number)

Ironshore Specialty Insurance Company/FARA

Adjuster: Mary Ann Matthiessen

Claim Number: FARA 3927045

Starr Surplus Lines Insurance Company/FARA

Claim Number: FARA 3927048

Liberty Surplus Insurance Corp

Adjuster: Brandy Henderson

Claim Number: DALCAS0000038756

Dear Sir/Madam,

Attached is the latest cost tracking sheet on the South Delhi Field Incident.

For additional information, please contact Ms. Martha Balogh:

Ms. Martha Balogh

Risk Management Specialist

Denbury Resources Inc.

5320 Legacy Drive

Plano, Texas 75024

Office: 972-673-2076

Cell: 469-693-1132

Email: martha.balogh@denbury.com

Please acknowledge receipt at your earliest opportunity.

Sincerely ~

Alice Williams

Marsh USA, Inc.

1800 Main Street, Suite 3008

FARA004076
Houston, Texas 77002

Phone: 713-276-8438

Fax: 713-276-8777

Date 07/08/2013 Type: Plan To Conclude
By Mary Ann Matthiessen
Subject: Claim Review - Plan To Conclude

Action Plan:
Follow for:
1.) controlling policy form and coverage evaluation if and when one is complete.
2.) further details of loss.
3.) with Sandy Oster on how Ironshore would like to proceed- ie- counselor
outside audit company.

Date 07/08/2013 Type: Exposure Evaluation
By Mary Ann Matthiessen
Subject: Claim Review - Exposure Evaluation

(xmp>Louisiana Environmental Exposure.
We still do not have the underlying controlling policy form from American
Guarantee & Liability Insurance Company- we have requested same along with
coverage positions when completed.

Damages and liability:
The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in Lousina involved, but this is as per Denbury and the facts
still are not developed.

The property is leased from private owners (unknown to us at this time) and is
private property.
Currently, the .incurred for remediation is $16,047,132. They are only in the
early stages of the cleanup as this loss just occurred on June 14, 2013.

RESERVES:

RECOMMENDATIONS:
we do not yet have a copy yet of the
controlling policy, it appears that baring any coverage questions, this loss may
breach the Ironshore excess layer. We suggest that Ironshore may seek to retain
its own attorney for monitoring of underlying erosion as well as auditing the
expenses submitted for reimbursement to Denbury as a result of the remediation
efforts if and when this matter is tendered to the Ironshore layer. Denbury has a
response team in place and provides weekly reports to all carriers of their
efforts and exposure. Initial discussions with Denbury Martha Balogh- Risk
Management Specialist
Denbury Resources Inc. indicates that Denbury will be responsible for this loss;
however~ we suggest that there remains much investigation that is necessary before
this matter can be fully evaluated, as such we will be following with Denbury,
Marsh and Zurich to determine the cause.

We have requested a copy of the controlling policy as well as the name of the
adjuster handling and will also request a copy of their coverage opinion once
render'ed.

Date 07/08/2013 Type: Subrogation
By Mary Ann Matthiessen
Subject: Claim Review - Subrogation and SIF

No subrogation identifiable at this time.

Date 07/08/2013 Type: Facts Summary
By Mary Ann Matthiessen
Subject: Claim Review - Summary Of Facts

Initial report was sent to Ironshore on July 8, 2013.

THE IRONSHORE SPECIALTY ISURANCE COMPANY POLICY:
Policy Number: 000988602 RENEWAL OF: 000988601
Named Insured: Denbury Resources Inc.
5320 Legacy Drive

FARA004077
Plano, TX 75024
Policy Period: April 01, 2013 Expiration: April 01, 2014
Limits of Liability: $25,000,000 per occurrence and in the aggregate.

UNDERLYING:
Ironshore Provides follow form on the underlying.
Coverage: Excess Policy- not certain as to coverage afforded by controlling
underlying at this time. Controlling policy has been requested.
Underlying Insurer: American Guarantee & Liability Insurance Company (Zurich)
Policy Number: AUC 9242673-01
Limits: $25,OOO,000 per occurrence limit
**Defense Expenses are outside the Limits.

There is a $500k SIR and a primary Zurich policy GL09242578-01 of $500k.
Ironshore policy is in excess of $26,000,000 in underlying.

COVERAGE ANALYSIS: We have requested the American Guarantee & liability Insurance
Company (Zurich) controlling policy and have been advised that no coverage
analysis by the underlying has been composed as of yet.

LOSS FACTS: **MUCH IS STILL NOT KNOWN. WE ARE UNSURE OF THE CAUSE OF THE LOSS,
THE DETAILS OF HOW MUCH PRODUCT HAS BEEN LOST AND WHO THE PROPERTY OWNERS ARE AND
THE DETAILS OF THE WELL OPERATION.

Denbury is an oil and gas company who leases and operates wells from private
landowners. At 3:10pm CT, Mr. Ryan Jacob, Denbury Onshore, LLC, received a call
from US Environmental Services GUSESu confirming that C02, oil, and saltwater was
present on the TransCanada Right of Way. Large release of carbon-dioxide is a by
product of the process at the source used to extract oil and bitumen (a sludgy
form of petroleum) from the earth. Formal responsibilities for the South Delhi
Field, LA Incident were transferred from TransCanada Pipeline to Denbury Onshore,
LLC.

The cause of the spill has not yet been determined. At this time there does not
appear to be any other parties involved aside from Denbury, who is the operator of
a oil well located in northeast Louisiana. The property is leased from private
owners and is private property.

Ms. Dawn Williams Louisiana Department of Environmental Quality briefed personnel
that 17 residences had been evacuated on 6/13/2013, *(indicates prior to the June
14, date of loss as reported), which included 34 residents, (17 residences remain
evacuated). Richland and Franklin Parish off-duty Sherriff Us deputies secured the
scene, and road closures were active on Antley Road and Highway 132 in the region.

An initial air monitoring team was sent to Test Site 1 and all well location
adjacent to the release and determined that the site was safe to access

ENVIRONMENTAL
USES personnel are monitoring chloride levels in Swamp Slough.

RECOVERY & CONTAINMENT
USES and Hancock personnel recovered, and will continue to recover, fluids from
the Swamp Slough at Burke Road Bridge using vacuum trucks.
All recovered liquids are being placed in 500-barrel frac tanks for temporary
storage.

Key contacts:
On 7/8/2013 at 11:15am I contacted Ms. Martha Balogh- Risk Management Specialist
Denbury Resources Inc.
5320 Legacy Drive
Plano, Texas 75024
Office: 972-673-2076 (number called)
Cell: 469-693-1132
Email: martha.balogh@denbury.com

Date 07/08/2013 Type: General
By Mary Ann Matthiessen
Subject: TC to Marth Balough 972 673 1132- Denbury

On 7/8/2013 at 11:15am I contacted Ms. Martha Balogh- Risk Management
Specialist
Denbury Resources Inc.
5320 Legacy Drive
Plano, Texas 75024
Office: 972-673-2076 (number called)
Cell: 469-693-1132
Email: martha.balogh@denbury.com

She informed me of the following. The cause of the spill has not yet been
determined. At this time there does not appear to be any other parties involved
aside from Denbury, who is the operator of a oil well located in Lousina.
The property is leased from private owners and is private property.

FARA004078
Currently. the incurred for remediation is $16,047,132. They are only in the
early stages of the cleanup as this loss just occurred on June 14, 2013.

Date 07/08/2013 Type: General
By Mary Ann Matthiessen
Subject: Initial loss report to Ironshore.

-----------------------------------------------------------------------------
From: Matthiessen, MaryAnn
Sent: Mon 7/8/2013 1:41 PM
To: Sanford Oster; Ronzello, Ronald
Cc: John Reusch
Subject: Denbury Spill Claim FARA 3927045

Hello Sandy,

I have attached my preliminary report to you, along with Denbury's latest update.
While large remediation efforts have been underway, we still have limited details
as to the cause of the loss.

MaryAnn Matthiessen
Senior Environmental Adjuster

609.610.4497 office
866.675.3192 toll free
985.624.8684 fax
MaryAnn.Matthiessen@Fara.com

FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471

From: Sanford Oster [mailto:Sanford.Oster@ironshore.com]
Sent: Mon 7/8/2013 12:57 PM
To: Ronzello, Ronald; Matthiessen, MaryAnn
Cc: John Reusch
Subject: Denbury Spill Claim

Ronnie:

Sorry I missed your call this AM

John and I are going to be at York in Parsippany tuesday for an audit and it might
be a good idea to have us all on the call to discuss.

I understand Ironshore has a $25M layer xs of Zurichus $25M lead and that
remediation costs are already at $16Masounds like a Humdinger of a claim.

lull assume our follow form policy has no stand alone pollution exclusions and the
lead umbrella is properly applying the pollution coverage afforded on that
policya. ?

Let us know when is a good time to chat? Ium assuming the PM is better for us as
weull probably be running around meeting in the AM.

If you have any file material to forward that would be fine.

Regards,

Sandy

SANFORD OSTER

Vice President

IRONSHORE SPECIALTY CASUALTY CLAIMS

ONE STATE STREET PLAZA 18TH FL 1 NEW YORK, NY 10004

Office: 646.826.49441 Mobile: 347.759.19761 VCARD

Date 07/08/2013 Type: General
By Mary Ann Matthiessen·
Subject: Reserves as of 07/08/13

FARA004079
Reserves as of 07/08/2013

Claim Id: 3927045

Claimant: South Delhi Field, LA Spill

Accident Date: 06/16/2013

Description: Excess Claim Insured had a spill of C02,

Line Of Coverage: Commercial Excess Liability (Umbrella) I

Sub Line: Liability - Property Damage

Reserved:

Status:

-- -- -

Date
By
07/03/2013
Mary Ann Matthiessen
Type: General
- -
Subject: Contacts for Denbury

From: Lawrence, Jerry W [mailto:Jerry.W.Lawrence@marsh.com]
Sent: Fri 6/28/2013 2:00 PM
To: Williams, Alice 0
Cc: Matthiessen, MaryAnn; Martha Balogh
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/16/13 - South Delhi Field Incident Action Plan

MaryAnn:

The status update is the most current information that has been provided to Marsh.
For additional information, please contact Ms. Martha Balogh or Jack Strother.

Ms. Martha Balogh

Risk Management Specialist

Denbury Resources Inc.

FARA004080
5320 Legacy Drive

Plano, Texas 75024

Office: 972-673-2076

Cell: 469-693-1132

Email: martha.balogh@denbury.com

Jack Strother

Denbury

Chief Corporate Counsel -

Litigation & Risk Management

5320 Legacy Drive

Plano, TX 75024

Office: 972.673.2617

Fax: 972-673-2460

E-mail: jack.strother@denbury.com

Jerry Lawrence~ Senior Vice President

South Central Partnership Claims Leader

Marsh USA Inc.

1000 Main Street, Suite 3000, Houston, Texas 77002, USA

+1 713 276 8432 I Mobile +1 713 319 6585 I Fax +1 713 276 8777 I
jerry.w.lawrence@marsh.com

Assistant: Alice Williams I +1 713 276 8438 I alice.o.williams@marsh.com

Date 06/27/2013 Type: General
By Mary Ann Matthiessen
Subject: File note

This Ironshore claim does have potential to breach the Ironshore layer,
however the loss is very new and it is too early to tell.
I will continue to monitor on an as needed basis, within the next 3-6 months we
should have a better idea as to claim development.
Ironshore does not trigger until after 25mm of excess which is in addition to the
underlying.
We will also have to see what the underlying coverage position has been.

Date 06/25/2013 Type: General
By Mary Ann Matthiessen
Subject: EM to Alice Williams of Marsh for more info

From: Matthiessen, MaryAnn
Sent: Tue 6/25/2013 9:02 PM
To: Williams, Alice 0
Subject: RE: Insured: Denbury Resources, Inc. - Matter: South Delhi Field, LA
Spill - D/A: 6/16/13 - South Delhi Field Incident Action Plan

Dear Ms. Williams,

I am handling for both Starr and Ironshore.

Please provide a brief description of exactly what happened and Denbury's role in
the incident.
I see many pages of documents, but I can't seem to understand what exactly
happened and how large the release actually was.

FARA004081
 Thank you.

MaryAnn Matthiessen
Sr. Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471
direct: 609-610-4497
fax:985-624-8684
toll free:866-675-3192
MaryAnn.Matthiessen@fara.com

Date 06/18/2013 Type: General
By Mary Ann Matthiessen
Subject: Ack and closing notice to Denbury

From: Matthiessen, MaryAnn
Sent: Tue 6/18/2013 1:32 PM
To: leona.maroney@denbury.com
Cc: Jerry.W.Lawrence@Marsh.com; Alice.O.Williams@marsh.com;
jack.strother@denbury.com
Subject: Ironshore- Ack of South Delhi Field spill- MARSH13HOUS096165
FARA3927045**'

June 18, 2013

Ms. Leona Maroney via email only:leona.maroney@denbury.com
Risk Management Specialist
Denbury Resources Inc.
5320 Legacy Drive
Plano, TX 75024

INSURED: DENBURY RESOURCES, INC.
DATE OF LOSS: 06/16/2013
TYPE OF COVERAGE: 'Umbrella, & Excess Liability Coverage
LOCATION OF LOSS: SOUTH DELHI FIELD, LA SPILL
FILE NUMBER: MARSH 13HOUS096165 FARA 3925455

Dear Ms. Maroney;

Please be advised that FARA Insurance Services (uFARAu) is the designated claims
adjusting service for certain matters involving Ironshore Specialty Insurance
Company, (QIronshoreu). This letter will acknowledge report of a June 16, 2013
spill incident in SOUTH DELHI FIELD, LA involving Denbury Resources Inc .. FARA
has set up a file for record purposesand given this a record locator number of
FARA-3927045.

Effective for the term of April 1, 2013 to April 1, 2014, Ironshore provides
Denbury Resources Inc., under policy number 000988602 , with excess liability
coverage in the amount of $25,000,000. This excess layer would apply only after
$25,000,000 of primary and underlying insurance has been exhausted.

Based on the exposure information supplied to date, it appears unlikely that the
4-<
Ironshore policy will be implicated in this matter, and as such we are recording
o this information for notice only. However, we understand that this matter recently
o occurred and that claim development may be necessary to estimate the full value of
"1- the potential losses; therefore, we would request that you notify us immediately
.-<
if there are any adverse developments. We would also request that we be notified
if the insurance layer beneath the Ironshore layer values the claim in excess of
50% of their underlying limit. If this is an aggregate policy, we request that you
advise if the aggregate has a potential to breach the underlying limit.

Because it appears that the exposure will not reach the Ironshore layer at this
time, we have not evaluated coverage as it relates to these matters; therefore,
Ironshore expressly reserves all rights under the policy. Any failure to cite
policy conditions or exclusions at this time shall not preclude Ironshore from
citing other policy conditions or exclusions as may be applicable to this claim.
Should you have any questions, please don't hesitate to contact me.

Sincerely)
MaryAnn Matthiessen
Sr. Environmental Adjuster
FARA, A York Risk Services Company
1625 West Causeway Approach
Mandeville, LA 70471
direct: 609-610-4497

FARA004082
fax: 985-624-8684
toll free:866-675-3192
MaryAnn.Matthiessen@fara.com

Date 06/18/2013 Type: Initial Contact - Insured
By Mary Ann Matthiessen
Subject: Initial Contact With Insured

Claim was ack. to Denbury timely on 6/18/2013.
File to be closed

Date 06/18/2013 Type: Initial Contact - Claimant
By Mary Ann Matthiessen
Subject: Initial Contact With Claimant

High level excess coverage, not expected to breach carriers layer, contact
waived.

Date 06/18/2913 Type: Coverage
By Mary Ann Matthiessen
Subject: IRONSHORE SPECIALTY - 25mm xs of 25mm

Policy # 909988602
IRONSHORE SPECIALTY INSURANCE CO
Effective 04/01/2913 - 04/01/2014
$25,090,000 xis $25,000,000

controlling policy:
GL09242578-01 ZURICH AMERICAN INS CO- $500k policy primary

AUC 9242673-01 -AMERICAN GUAR & LIAB 94/01/2913 - 04/91/2914$25,099,000 xis of
Underlying

Ironshore is next $25mm excess of $25mm.

Date 06/18/2013 Type: General
By Mary Ann Matthiessen
Subject: Response to Supervisor

Ron.,
Ack. new loss for Denbury I will handle accordingly.

Date 06/18/2013 Type: Supervisory Claim Review
By Ronnie Ronzello
Subject: Supervisory Review

MaryAnn,
New loss. Excess coverage.

Email was sent to maryann.matthiessen@fara.com regarding these instructions.

Date 06/17/2913 Type: General
By QRM 10
Subject: NOTICE TO ADJUSTER!

This is for Starr Surplus Lines Insurance. Claim taken by: ES-QRM

FARA004083
 I, Chris Daniel, District Clerk of Harris
County, Texas certify that this is a true and
conect copy of 111.e original record fl1ed and or
recorded in my office, electronically or hard
copy. as it appears on this date.
\'Viitness my official hand. and seal of office
tms, October 22.2015

Certitied Document Number: 67238734

Chris Daniel, DISTRICT CLERK
HARRIS COUNTY, TEXJili

In acc'Ordance with Texas Gmre:rnnlent Code 406JH3 electronically transmitted authenticated
documents are valid. If there is a question regarding the validity of this document and or seal
please e-mail suppoTt@hcdistridderk.com
 APPENDIX OF EXHIBITS
Exhibit A - 08.05.15 Letter to Randy fwd ANR Settlement Agreements

Exhibit B - 09.09.15 Letter to Ironshore re discovery deficiencies

Exhibit C -Ironshore's objections to NOD of Ironshore

Exhibit D -Ironshore's objections to NOD of FARA

st
Exhibit E - Denbury's 1 Set of RaGs and RFPDs

st
Exhibit F - Denbury's 1 Set for RFAs

nd
Exhibit G - Denbury's 2 RFPD

Exhibit H - 08.20.15 Ironshore Privilege Log - FARA Claims File Documents

Exhibit 1- 09.04.15 Ironshore Supplemental Privilege Log

Exhibit J - Ironshore's objections to 1st RaGs and RFPDs

Exhibit K -Ironshore's objections and response and supp answers dated 09.04.15

Exhibit L - Ironshore's objections and response and supp answers dated 09.18.15

Exhibit M - 06.16.15 Ironshore Letter denying coverage

Exhibit N -Ironshore's redacted Claims Note File

Exhibit a - Treadaway email dated 09.02.15 re blanket objections to NOD

Exhibit P - Corporate NOD of Sanford Oster of Ironshore

Exhibit Q - Corporate NOD of FARA

Exhibit R - lronshore's Response to NOD Requests with CVs

Exhibit S - Treadaway and Sheriden Affidavits

Exhibit T - Ironshore Amended Privilege Log

Exhibit U - Amended Production FARA3943-4083

Exhibit V - Appendix of Exhibits to Mtn to Compel and Opposition to Mtn for Protective Order

4824-0139-8313, v. 1
 1. Chris Daniel, District Clerk of Harris
County, Texas certify that this is a true and
correct copy of the original record filed and or
recorded in my office, electronically or hard
copy, as it appears on this date.
Witness my official hand and seal of office
this November 6.2015

Certified Document Number: 67238735 Total Pages: 1

Chris Daniel, DISTRICT CLERK
HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated
documents are valid. If there is a question regarding the validity of this document and or seal
please e~mail support@hcdistrictderk.com
 9/29/20154:02:38 PM
Chris Daniel - District Clerk
Harris County
Envelope No: 7152558
By: COOPER, USA l
Filed: 9/29/20154:02:38 PM
CAUSE NO. 2015-09546

DENBURY RESOURCES INC. and IN THE DISTRICT COURT
DENBURY ONSHORE, LLC

Plaintiffs,
HARRIS COUNTY, TEXAS
v.

IRONSHORE SPECIALTY INSURANCE
COMPANY, ALTERRA EXCESS & 157th JUDICIAL DISTRICT
SURPLUS INSURANCE COMPANY,
AXIS SURPLUS INSURANCE
COMPANY, AND MARSH USA INC.

Defendants

ORDER

Considering Ironshore's Motion for Protective Order and Objections to Plaintiffs' Notice

of Oral and Videotaped Deposition and Request for Documents of the Designated Corporate

Representative(s) ofF.A. Richard & Associates, Inc. ("FARA ");

IT IS HEREBY ORDERED that Ironshore' s Motion is DENIED.

JUDGE RANDY WILSON

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 I, Chris DroneI, District Clerk of Harris
CountYo Texas cenify that this is a trr.re and
correct copy of the original record filed and or
recorded in my office, electronically or hard
copy, as it appears on this date.
\'\I1tne55 my official h.and rold seal of oftlce
this October 22. 2015

CertifIed Document Number: 67238736

ChI]S Daniel, DISTRICT CLERK
Hil.RRIS COUNTY, TEJL.i\S

In aCC6l'cia.nce with Te:ns Government Code 406JH3 electronically fi'ansmitted authenticated
documents are yalid. H there is a question regarding the validity of this document and or seal
please e-mailsllpport@.hcdistridderk.com
 9/29/20154:02:38 PM
Chris Daniel - District Clerk
Harris County
Envelope No: 7152558
By: COOPER, LISA L
Filed: 9/29/20154:02:38 PM
CAUSE NO. 2015-09546

DENBURY RESOURCES INC. and IN THE DISTRICT COURT
DENBURY ONSHORE, LLC

Plaintiffs,
HARRIS COUNTY, TEXAS
v.
IRONSHORE SPECIALTY INSURANCE
COMPANY, ALTERRA EXCESS & 157th JUDICIAL DISTRICT
SURPLUS INSURANCE COMPANY,
AXIS SURPLUS INSURANCE
COMPANY, AND MARSH USA INC.

Defendants

ORDER

Considering Ironshore's Motion for Protective Order and Objections to Plaintiffs' Notice

of Oral and Videotaped Deposition and Request for Documents of Sanford Oster as the

Designated Corporate Representative(s) of Ironshore Specialty Insurance Company;

IT IS HEREBY ORDERED that Ironshore's Motion is DENIED.

JUDGE RANDY WILSON

60 1147 - 1148 11120114 Corresp. from Defense Counsel to FARA & Ironshore Work Product
;..; Re: Legal Memorandum
Work Product
Re: Joint Defense Agreement; Legal Memorandum Atty. Client
Joint Defense
82 1378 -1386 08/14/14 Draft of Legal Memorandum by Defense Counsel Work Product
83 1387 -1397 08114/14 Joint Defense Agreement Work Product
Atty. Client
Joint Defense
Irrelevant
84 1398 -1399 09/08/14 FARA Invoice to Ironshore Irrelevant
Atty. Client
85 1401 08112/14 Corresp. from Defense Counsel to F ARA & lronshore Work Product
Re: Draft Legal Memorandum Atty. Client
86 1402 - 1409 Undated Draft Legal Memorandum by Defense Counsel Work Product
87 1410·- 1412 08/13/14, Corresp. between Defense Counsel, FARA & Ironshore Work Product
08/12114 Re: Joint Defense Agreement Atty. Clierit
Joint Defense
Irrelevant
88 1413 - 1420 08111114 Joint Defense Agreement Work Product
Atty. Client
Joint Defense
Irrelevant
89 1421 08/12114 Corresp. from Defense Counsel to F ARA & Ironshore Work Product
Re: Joint Defense Agreement Atty. Client
Joint Defense
Irrelevant
N
90 1422 - 1429 08/11/14 Joint Defense Agreement Work Product
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EXHIBIT
65165511 Exhibit 1 04/2412015
65165532 Philip D Nizialek's Motion In Support Of Jacqueline M Brettner's Motion For Admission 04/24/2015 2
Pro Hac Vice
.> 65165534 Notice of Submission 0412412015

http://www.hcdistrictc1erk.com/edocs/public/CaseDetailsPrinting.aspx?Get=TMiLGbZliQ... 9/30/2015
 Ulllce ot Hams County DIstrIct Clerk - Chris Daniel Page 3 of3

-> 65165533 Proposed Order 04/24/2015
64380798 Notice of Intent to Dismiss-No Answer Filed , 0212412015 2
/

64340786 ORDER OF PARTIAL NONSUIT SIGNED 02120/2015 .1
64315162 Plaintiffs Nonsuit Against Defendants 02/19/2015 2
64315163 Proposed Order on Plaintiffs' Nonsuit 02119/2015
63203944 Civil Process Request 11117/2014 2
62762828 Denbury Petition 10/14/2014 26
·>62762837 Exhibit 1 10114/2014
·>62762833 Exhibit 2 1011412014 5
->62762834 Exhibit 3 1011412014 2
->62762836 Exhibit 4 10114/2014 98
-> 62762835 Exhibit 5 1011412014 54
·>62762830 Exhibit 6 10/1412014 2
·>62762831 Exhibit 7 10114/2014 23
·>62762832 Exhibit 8 1011412014 12
·>62762829 Exhibit 9 10114/2014 34

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0 NEWSPAPER OF YOUR CHOICE: _ _ _ _ _ _ _ _ _ _ _ _ __
[] OTHER,~n----------------------------__------____----__--~------___

ATTORNEY (ORATI'ORNEY'S AGENT) REQUESTING SERVICE:
NAME: E. Stogner
Sarah TEXAS BAR NO.IID NO. _2_4_0_9_1_1_3_9_ _ _ _ __
MAILlNGADDRESS: 1100 Poydras Street, Suite 3100, New Orleans, Louisiana 70163

PHONE NUMBER: 504 585-3845 FAX NUMBER: 504 585-3801
area code phone number area code fax number
EMAIL ADDRESS:stogner@carverdarden.com

Page 1 of2
INSTRU1y1ENTS TO BE SERVED: PROCESS mES;
(Fill In Instrument Sequence Number, i.e. 1st, 2nd, etc.)
NON WRIT:
ORIGINAL PETITION CITATION
AMENDED PEmION ALIAS CITATION
SUPPLEMENTAL PETITION PLURIES CITATION
SECRETARY TATE CITATION
COMMISSI OF INSURANCE
COUNTERCLAIM HIGHW SSIONER

;~~O~::;:ATION
AMENDED COUNTERCLAIM
SUPPLEMENTAL COUNTERCLAIM

CROSS-ACTION:
~F .
AMENDED CROSS-ACTION ~CEPT (SHOW CAUSE)
SUPPLEMENTAL CROSS-ACTION 'VKULE 106 SERVICE

THIRD-PARTY PEmION: ¢~
(~ SUBPOENA
~
AMENDED THIRD-PARTY PETITION
SUPPLEMENTAL THIRD~PARTY PETITION d'¢J .wBlIS.;
ATTACHMENT (pROPERTY)
INTERVENTION: ¢~ ATACHMENT (WITNESS)
AMENDED INTERVENTION
SUPPLEMENTAL INTERVENTION (/ ATTACHMENT (PERSON)

INTERPLEADER
AMENDED INTERPLEADER ~ CERTIORARI

SUPPLEMENTAL INTERPLEADER ~ EXECUTION
.~~ EXECUTION AND ORDER OF SALE

~ GARNISHMENT BEFORE JUDGMENT
INJUNCTION
~ GARNISHMENT AFTER JUDGMENT
MOTION TO MODIFY ~ HABEAS CORPUS
SHOW CAUSE ORDER tV INJUNCTION
TEMPORARY RESTRA1NINGO~ TEMPORARY RESTRAINING ORDER

~
PROTECTIVE ORDER (FAMILY CODE)
PROTECTIVE ORDER (CIVIL CODE)
©
B~LOFDffiCOVER~ _ ~~
ORDER TO: ____~
___________________ POSSESSION (PERSON)
(specify) POSSESSION (pROPERTY)
MOTION TO:
(specify)
SCIRE FACIAS
SEQUESTRATION
SUPERSEDEAS

Page 2 of2

I'"1T'tTf1'flO 1) ..... :" ... ...1 Of'lfnO
 10/14/20143:42:35 PM
Chris Daniel- District Clerk Harris County
Envelope No. 2828115
DDDODDDD DO []JI]DD By: Nelson Cuero
Filed: 10/14/20143:42:35 PM

CAUSE NO. _ _ _ _ __

DENBURY RESOURCES INC. and IN THE DISTRICT COURT
DENBURY ONSHORE, LLC

Plaintiffs,
I
HARRIS C~TY, TEXAS
v. ~.
IRONSHORE SPECIALTY INSURANCE (j
COMPANY, ALTERRA EXCESS & ~ICIAL DISTRICT
SURPLUS INSURANCE COMPANY,
AXlSSURPLUSINSURANCE ~
.o@
COMPANY, AND MARSH USA INC.

Defendants
o~
~
WI
DENBURY'S PE~ON
o~
Denbury Resources Inc. and Denbury o,~e, LLC (','Denbury") bring this petition for

breach of contract, declaratory judgment, sw.~ry penalties, and bad faith against Defendants
'rtf
Ironshore Specialty Insurance Comp~"Ironshore"), Alterra Excess & Surplus Insurance
~O
Company ("Alterra"), Axis S~ Insurance Company ("Axis"); and for negligence,

misrepresentation, breach of ~act, and breach of fiduciary duty against Defendant Marsh

USA Inc. ("Marsh"). U!fJ
~ I. PARTIES
o;f1~
1. Denbn-r~~sources
~~~
Inc. is a Delaware corporation with its principal place of business
.

i~O, Texas.
2. Denbury Onshore, LLC is a wholly-owned subsidiary of Denbury Resources Inc.

Page 10f26
 3. Defendant Ironshore Specialty Insurance Company is upon reasonable information

and belief a surplus lines company, an Arizona corporation with its principal place of

business in N ew York, New York.

4. Defendant Alterra Excess & Surplus Insurance Company is upon reasonable

information and belief a surplus lines company, a Delaware c~tion with its

principal place of business in Glen Allen, Virginia. (:}
. ~
5. Defendant Axis Surplus Insurance Company is upon ~able information and

belief a surplus lines carrier, a Geqrgia corporation ~~princiPal place of business

in Alpharetta, Georgia: <> ~
~ ,

6. Defendant Marsh USA Inc. is upon reasoJinformation and belief a Delaware
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company with its principal place of ~ess in New York, New York, and is a

wholly-owned subsidiary of Marsh~ a Delaware company with its principal place

of business in New York, New • • which is a wholly-owned subsidiary of Marsh &

Mclennan Companies, " , a r e corporation with it. principal place of business in

New York, New York.O

.
~DECLARATORY JUDGMENT
rg~ .
.

7. This suit is, ~Qrt, a claim for declaratory judgment pursuant to Tex. Civ. Prac. &
!f?&
Rem. Cg~"37.004.
N # III. JURISDICTION AND VENUE

~~ourt has jurisdiction over this matter as it relates to insurance policies issued to
M

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a~ments for the removal and
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replacement of certain damaged sections OR~NR pipelines. Denbury paid ANR
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for its costs to cut, cap, replace and J:~ir the pipelines. The Agreements were
~~
entered into with the knowledge ~onsent of American Guarantee & Liability

Insurance Company ("Zurich"), ~~ury' s umbrella carrier.
37. As a result of damage to Wtelines which occurred during the incident, ANR aIso

claims to have lost ~fS that would have been collected by the continued

transmission of na~gas
cg~
through the pipelines. These losses are a direct result of

the blOWOUt.~Ury has notified the Defendants of this pending claim.

38. Den~#aid ANR for the pipeline damage, and will attempt to resolve the tariff
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i~er, except under special circumstances which Marsh shall
en~~r to make known to you. Marsh shall not be responsible for the
s~cy of any insurer or its ability or willingness to pay claims, return
~miums or other financial obligations. Marsh does not guarantee or
~ake any representation or warranty that insurance can be placed on terms
acceptable to you. Marsh will not take any action to replace your insurers
unless you instruct Marsh to do so. You acknowledge that, in performing
Services, Marsh and affiliates are not acting as a fiduciary for you, except
to the extent required by applicable law, Any reports or advice provided
by Marsh should not be relied upon as accounting, legal, regulatory or tax
advice. In all instances, Marsh recommends that you seek your own

Page 11 of26
 advice on such matters from professional accounting, legal, regulatory and
tax advisors. '

55. Denbury was required by the Agreements to provide Marsh with 'accurate information

and review all policy documents. Denbury did so, and was therefore justified in
"

relying on Marsh's expertise to analyze Denbury's potential risks,~ct the proper

lines of insurance, select the proper terms and conditions, an~view the actual

forms, terms, and conditions contained in the policies to enstlk.Denbury's risks were

adequately covered by the policies issued. 01 o~~

56. Denbury provided Marsh with all information ri~ed by Marsh throughout the
_ 0 ~
2013 renewal process. Upon reasonable info~lon and belief, Marsh would take
. ~ ,

the information Denbury supplied and c~ insurance applications on behalf of
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Denbury, which it would then SUbm~ariOUS insurers to quote and bind coverage

whi~h Denbury intended to cov~9rational risks of loss, including but not limited
to the very risks which result~he Delhi Incident.
. 0 ~
The Primar men~iaI General Liabili
, ~
57. At all times materia~e, Denbury had in force a commercial general liability policy,

No. 9242578-~'CGL" policy) with effective dates of April I, 2013 to Aprill,
2014, whtc~)rovides coverage to Denbury for certain first party and third party

expen~ecl to the terms and conditions of that CGL policy. A copy oflhe CGL
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 59. The CGL policy, under Coverage 1, provides coverage for "those sums that the

insured becomes obligated to pay as damages because of 'bodily injury' or 'property

damage' to which this insurance applies."

60. The main body of the CGL policy contains an "absolute" pollution exclusion under

~2(f); however, the "Time Element Pollution Liability End~ent" ("CGL
~
pollution endorsement") replaces the policy's ~2(f) exclusion ~ provides coverage
~
for "bodily injury" or "property damage" caused by a "po~n incident" that meets
~
the following requirements: ::
forded except
for the exhaustion of the Limits of Insurance of unde g insurance.
, ' . . <>~

68, Because Zurich claims coverage is excluded by t~::::>~L
policy and Denbury is not
<>~
contesting that denial at this time, and the w~ntrol policy is not an underlying
tt~
policy, any pollution losses incurred by D~ry as a result of the Delhi incident are
<>~
recoverable under Coverage B of t~~brel1a policy subject to resolution of any

"other insurance" issues. ~U
69. "Property damage" is defmed~ger the umbrella policy as:
<>.~ .
a. Physical injury tJ:L~gible property, including aU resulting loss of use
of that propert(:}\11'such loss of use shall be deemed to occur at the
time of the p~ical injury that caused it; or
.~
b. Loss of~1tangible property that is not physically injured. All such
~oss ~~e deemed to occur at the time of the occurrence that caused
It. <> 'iJij} -
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70. EXclu~l::';.6. in the main body of th~ umbrella policy is an "absolute" pollution
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 Umbrella policy limits for total cumulative limits of $51 million. A copy of the

Ironshore policy is attached as Exhibit 7 and fully incorporated herein.

76. At all times material here, Denbury had in force a commercial excess liability policy

issued by Defendant Alterra Excess & Surplus Insurance Company, No.

MAX6XL0000443 (the "Alterra" policy) with effectiv~ dates of~il 1, 2013 to

Aprill, 2014. The Alterra policy provides $25 million f01104 co~erage
excess
~
of Ironshore's policy limits, up to a cumulative limit of ~i1lion. A copy of the
. . ~
Alterra policy is attached as Exhibit 9 and fully inco~d herein.

77. At all times material here, Denbury had in forcl(, ~ercial excess liability policy
~
iSSUed~y Defendant Axis Surplus Insur~~ompany, No. EAU766369/0112013

(the "Axis" policy) with effective dates,~prill, 2013 to April 1,2014. The Axis
.~
policy provides $25 million f01l0~ coverage excess of Alterra's policy limits,
up to a cumulative limit of $l.llion. A copy of the Axis policy is attached as

inCO~~herein. '
Exhibit 9 and fully .

78. On October 14, 2014, (~ury submitted its proof of loss to Ironshore, Alterra, and

Axis, and
.
demandR~ent
~
of the full limit of liability of each of those Policies as

indemnity f~Ynbury's covered pollution and contamination clean-up costs, and
or[@)
related t~~arty claims.
N
M 79. As 0 # filing, Ironshore, Alterra, or Axis policies (referred to collectively as the
"-' ~ .

'~ess" policies) have either denied coverage for,
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(!.)

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83. Pursuant to the'ter.msand conditio~he umbrella policy, the Excess carriers have
an obligation to indemnify De~ for the costs it incurred as a result of pollution
and related third-party ClWaused by fue Dethi incident up to fue full Policy limits

excess of theunderlYi~icies. "

84. Denbury is a prop~ to sue for breach of contract. '
(F~ ,
85. Denbury has~etf6nned all of its contractual obligations under the Excess policies.

86. There ate~~pp1icable policy provisions, conditions or exclusions which preclude or
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i~uding misrepresenting the scope and/or
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existence of coverage under these ~.

97. Excess carriers and Marsh eng~ in unconscionable conduct by selling insurance
·· WIt. h amb'19uOUS
po1lCles Frlif~111 usory coverage.

o IX. BAD FAITH

98. Denbury re-alleg~vers, and incorporates each of the foregoing paragraphs into
this section~~emand. , ' ,

99. Excess fs~rs bound the Excess policies, which created insurance contracts between
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~ant to the terms and conditions of the Excess policies, the Excess carriers are
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101. The Excess carriers failed to reasonably investigate. Denbury' s .claims for coverage

under their respective policies before wrongfully denying coverage ..

102. The Excess carriers knew or should have known that coverage of Denbury's claim

under each policy is reasonably clear, but have still denied and/or delayed payment.

103. The Excess carriers have breached their duty of good faith and fa~aling because
~
they failed to reasonably investigate Denbury's claim before ~ng coverage, and
~
because they refused and continue to refuse to pay Denbur~&{]alid claims.
. . ~~~

104. There is no reasonable basis for the Excess CarrierS~als to pay Denbury's entire
claim; the Excess carriers have failed an4, ~sed to perform an adequate
~
investigation, and/or the Excess carriers ~~or fairly dealt in good faith with
Q .
Denbury. <> 0
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105. The Excess carriers' refusals to p~recommended and valid claim are the direct
and proximate cause of harm ~enbUry, which has resulted in damages In an·
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amount to be proven at tr~~

106. Denbury has incurred ~ges as a result of the Excess qarriers' bad faith, including
but not limited to~~ased
©~
business expen~es, loss of business opportunities, and

other conse~Yl economic damages to be proven at the trial of this matter.
<>~,fjjj} .
I.~RSH'S NEGLIGENCE, BREACH OF CONTRACT,
~. & VIOLATION OF STATUTORY DUTIES

107. ~ re~alleges, re-avers, and incorporates each of the foregoing paragraphs into
this section of its Demand.

Page 21 of26
108. Marsh, as Denbury's insurance broker and risk management consultant, owed a duty

to use reasonable diligence in attempting to place the requested insurance and to

inform Denbury if it was unable to do so.

109. Denbury reasonably relied on Marsh's promise to procure the requested insurance,

which was selected by Denbury based on Marsh's expertise in placi~omprehensive
.

insurance coverage for oil and gas operators.
.
. U~~
~

110. Denbury reasonably relied on Marsh's 'representation~ts detriment, that the

insurance policies recommended, and ultimately Pl~y Marsh, insured Denbury
against the risks that caused the losses incurred ij"~he Delhi incident.
, ~~
111. Denbury also relied on Marsh to review av~~ policies and advise Denbury on the

terms included in those policies. UpQ~asonable information and belief, Marsh
~
misrepresented to,Denbury the te@ncluded in the CGL, Umbrella, and Excess

policies at issue he~e. . ~
112. Marsh, while ""ting on b r f Denbury in compiling its application for insurance,

failed to explain the ar@~tion or the terms of coverage being applied for.
lB. Over Denbury's ~ year relationship with Marsh, Denbury relied on Marsh to
perform its ~Qanagement functions, including but not limited to negotiating with
the "";~rectIY when both acquiring pOlicies as well as handling c)aims that
arose~g the relevant policy period.
114. ~'1is liable to Denbury for its failure to procure the proper insurance policies with
adequate coverage for Denbury's operations, including the Delhi incident. Marsh:

a. failed to properly procure insurance for Denbury;

Page 22 of26
b. failed to act as a reasonable and prudent broker would have under the same or

similar circumstances;

c. failed to ensure that Denbury would have proper insurance coverage afforded for

a pollution liability loss arising out of its operations;

d. allowed the policy coverage requested by Denbury, and which ~ury intended
/?'~
to Cover losses arising out of an incident such as the Delhi ~ent, to differ from
~
those proposed and explained to Denbury during the f!/Iral discussions without

advising Denbury; " \ ~,f!j;
e. failed to disclose that the CGL~ Umbrella, ~xcess policies may not include
~
. covemge for Denbury's operations in ~ field;
f. failed to properly explain the te~ ~d conditions of the CGL, Umbrella, and
~/~
Excess insurance policies; ~
g. failed to provide the stand~f care required of an insurance broker and risk
~(f72» '
management consulta~~er the terms of the Agreements and applicable law;

h. failed to advise, ex~, or disclose the coverages within the CGL, Umbrella, and
Excess pOlici~~
i. failed to ~Qde insurance coverage for Denbury's operations;

J. d~o~.
f:al'1e(j Investigate and understand th e operatIOns
. and Insurance
. nee ds 0f
~.

~@Ury;
~ailed to fully and accurately fill out the insurance application and convey to the
insurers the necessary information to protect the needs of Denbury;

Page 23 of26
I
 1. failed to maintain information provided to Denbury in such a way as to be able to

use that infonnation to accurately present Denbury to insurers in soliciting

coverage;

m. failed to use information in their possession to select proper insurance for

Denbury; ~
n. failing to know or understand that certain provision(s)
~
~e CGL, Umbrella,
~
andior Excess policies excluded coverage for Denbur~erations, and failing to
disclose to Denbury the impact of those provis~ a reasonable and prudent
insurance broker and risk management consw~ould have; and
~
be~~OVerage under the CGL, Umbrella,
o. failing to disclose to Denbury that it

.
Q
andior Excess policies to beambi~l&or illusory.
. §&.
115. Marsh is liable to Denbury for bre~the risk management Agreements.

116. Marsh is liable to Denbury for b~h of the fiduciary duty created by the confidential
relationship between Dewand Marsh in which Denbury was guided by the

judgment and advice ~arsh, and Denbury was justified in placing confidence in
the belief that Mar~~uld act in Denbury's best interest.
~.

~0 XI. ATTORNEYS' FEES

117. Denb,r~qreges, re-avers, and incorporates each of the foregoing paragraphs into
~ .
this s n of its Demand.
~ .

118. ~dition to the damages set forth above, Denbury seeks from Excess carriers and
Marsh recovery of all costs and attorneys' fees incurred in the defense of this action

and the prosecution of this Demand pursuant to relevant Texas statutes.

Page 24 of26
 XII. PRAYER

WHEREFORE, Denbury demands a trial by jury and requests that the Court render

judgment as follows:

1. That pursuant to the insuring conditions of the Excess policies, the Court declare that

Defendants have an obligation to indemnify Denbury for its costs in~ed in property
~
damage as a result ofthe Delhi incident covered under the Exc~olicies.
~
2. That Excess Carriers breached their duties to indemni:~ury under the Excess

policies' terms for costs incurred in property damag~result of the Delhi incident

covered under the Excess policies. (~
o~

3. That the Court award Denbury all actual and~imate damages by Excess carriers'
(J).
bad faith breach of the Excess policitt,s~'1 all statutory penalties consistent with
. .~
Texas law. . ~

4. That Excess Carriers have faile~imelY investigate and pay the claims under Texas

Insurance Code Chapter s~?!tJ;®;
.~ .

5. That Marsh breached ~dUCiary duty to Denbury, breached the risk management
Agreements, and n~entlY performed its insurance brokerage and risk management
©J~
duties owed ~~bury.

6. That ~~ers and Marsh have engaged in unfair or deceptive trade practices
under~as Insurance Code Chapter 541.

7. ~~he Court award Denbury its costs and attorneys' fees incurred in the

prosecution of this Demand.

8. That the Court grant to Denbury any and all other relief, at law or in equity, to which

it is entitled.

'Page 25 of 26
 Respectfully submitted,

PmLrP~l·~50)
SARAH E. STOGNER (#24091139)
/

JACQUELINE M. BRETTNER (pend~ro hac vice)
CARVER, DARDEN, KORETZKY, TE~R,
FINN, BLOSSMAN & AREAUX,~
1100 POYDRAS ST., sui. 31 odQ'"
NEW ORLEANS, LA 70163 ~
TELEPHONE: (504)585j£3
FACSIMILE: (504) 585-
19
EMAIL: NIZIALEK<>RDARDEN.COM
VERDARDEN.COM
BRE CARVERDARDEN.COM

'ATTORNE~ DENBURY RESOURCES INC, AND
DENB~NSHORE, LLC
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PLEASE WITHHOLD SERVICE AT Tm~

4830-3378-4095, v. 1~0757-9934, v. 2 ®>~

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Page 26of26
 I. Chris Daniel, District Clerk of Harris
County, Texas certify that this is a true and
coned copy of the original record filed and or
recorded in my office, electronically or hard
copy, as i.t appears on this date.
V¥'ttness my official hand and seal of oft1ce
this October 22.2015

Certified Document Number: 672:58530

Chris Daniel, DISTRICT CLERK
H.i\lUUS GOUNTI, IEX;\S

In acc:{}rda.nee with Tex.as Government Code 406JH3 eledronically transmitkid authenticated
documents are valid. If there is. a question regarding the validity of this, document and or seal
plea.s:e e-:ma.iJ. support@.hcdistrktderk.com
 9/18/20164:56:50 PM
Chris Daniel - District Clerk Harris County
Envelope No. 7002115
By: KATINA WILLIAMS
Flied: 9/18/20154:56:50 PM

CAUSE NO. 2015 09546
w

DENBURY RESOURCES INC. and § IN THE DISTRICT COURT
DENBURY ONSHORE, LLC §
§
Plaintiffs ! §
VS. § 157th JUDICIAL DISTRICT
§
IRONSHORE SPECIALTY INSURANCE §
COMPANY, ALTERRA EXCESS & §
SURPLUS INSURANCE COMPANY, §
AXIS SURPLUS INSURANCE § HARRIS COUNTY, TEXAS
COMPANY, and MARSH USA INC. §
§
Defendants §

IRONSHORE SPECIALTV INSURANCE COMPANY'S MOTION FOR PROTECTIVE
ORDER AND OBJECTIONS TO PLAINTIFFS' NOTICE OF ORAL AND . , !

VIDEOTAPED DEPOSITION AND REQUEST FOR DOCUMENTS OF SANFORD
OSTER AS THE DESIGNATED CORPORATE REPRESENTATIVE(S) OF
IRONSHORE SPECIALTY INSURANCE COMPANY

TO THE HONORABLE JUDGE OF THIS COURT:
COMES NOW, Defendant, Ironshore Specialty Insurance Company (hereinafter

"Defendant" or "Ironshore"), appearing by and through the assistance of undersigned counsel of

record, and files this Motion for Protective Order and Objections to Plaintiffs' Notice of Oral and

Videotaped Deposition and Request for Documents of Sanford Oster as the Designated

Corporate Representative(s) of Ironshore Specialty Insurance Company and in support thereof

will show unto the Court the following:

I.

This is an insurance coverage dispute arising out of a well blowout that occurred in

northeastern Louisiana on or about June 13,2013. In their current live pleading, Plaintiffs

Denbury Resources Inc. and Denbury Onshore, LLC (hereinafter "Plaintiffs" or "Denbury")

assert they selected umbrella insurance policies, based on insurance broker Marsh USA, Inc. 's

EXHIBIT

(
recommendations, to cover such losses as those Denbury experienced as a result of the well

blowout in northeastern Louisiana, known as the Delhi Incident. Plaintiffs seek a declaratory

judgment that Ironshore, Alterra Excess & Surplus Insurance Company, and AXIS Surplus

Insurance Company must indemnify Denbury for costs and expenses, not recoverable under the

well control policy, and in excess of the underlying policies that Denbury incurred in responding

to the pollution resulting from the Delhi Incident. Plaintiffs also assert claims for breach of

contract, Texas Insurance Code violations and bad faith.

On September 2, 2015, Plaintiffs noticed the oral and videotaped deposition of the

corporate representative of Ironshore, previously identified Sanford Oster, for the agreed upon

date and time of October 20, 2015 at 9:00 a.m. at the law offices of Pillsbury Winthrop Shaw

Pittman, LLP, 1540 Broadway Avenue, New York, New York 10036. A copy of the Notice of

Oral and Videotaped Deposition and Request for Documents of Sanford Oster as the Designated

Corporate Representative(s) of Ironshore Specialty Insurance Company is attached hereto as

Exhibit "A".

The parties have agreed toa date, time and location; however, the parties are unable to

agree to the scope of the deposition. Counsel for Ironshore and Denbury have in good faith

attempted to resolve this matter by correspondence as well as personal discussions, but are

unable to resolve all of the issues. Ironshore's counsel presented Denbury's counsel with draft

objections to certain examination topics out of the 110 served topics on September 10, 2015, and

counsel held a telephonic conference on September 15, 2015 in an attempt to resolve specific

issues and objections to certain topics. Ironshore now files this Motion for Protective Order and

Objections regarding those examination topics that could not be resolved.

2
 n.
Ironshore objects to Examination Topic Numbers 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13,

14,15,21,22,23,24,25,26,27,28,29,34,36,37,38,39, 40, 41, 43, 61, 74, 77, 78, 81, 82,83,

86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97, 98, 99, and 110 listed in Denbury's deposition

notice attached hereto as Exhibit "A" on the following grounds:

1. Denbury.

RESPONSE: Ironshore objects to this topic on the grounds that it is overbroad and
not limited in scope to the issues made the basis of this lawsuit. Inmshore further
objects pursuant to Rule 199.2 of the Texas Rules of Civil Procedure as the topic
does not describe with reasonable particularity the matter on which examination is
requested.

2. Denbury's operations.

RESPONSE: Irom;hore objects to this topic on the grounds that it is overbroad and
not limited in scope to the issues made the basis of this lawsuit. Ironshore further
objects pursuant to Rule 199.2 of the Texas Rules of Civil Procedure as the topic
does not describe with reasonable particularity the matter on which examination is
requested.

3. The risks presented by Denbury's operations.

RESPONSE: Ironshore objects to this topic on the grounds that it is overbroad and
not limited in scope to the issues made the basis of this lawsuit. Ironshore further
objects pursuant to Rule 199.2 of the Texas Rules of Civil Procedure as the topic
does not describe with reasonable particularity the matter on which examination is
requested.
4. The Delhi Incident.

RESPONSE: Ironshore objects to this topic pursuant to Rule 199.2 of the Texas
Rules of Civil Procedure as it does not describe with reasonable particularity the
matter on which examination is requested.

5. The Policies.

RESPONSE: Ironshore objects to this topic pursuant to Rule 199.2 of the Texas
Rules of Civil Procedure as it does not describe with reasonable particularity the
matter on which examination is requested.

3
 6. Reserves under the Policies.

RESPONSE: lronshore objects to this topic on the grounds that it seeks
information that is not relevant to this lawsuit and not reasonably calculated to lead
to the discovery of admissible evidence. Further, the topic is overbroad and,
pursuant to Rule 199.2 of the Texas Rules of Civil Procedure, it does not describe
with reasonable particul~lrity the matter on which examination is requested.

7. The Blended Pollution Endorsement.

RESPONSE: Ironshore objects to this topic on the grounds that it is overbroad and
pursuant to Rule 199.2 of the Texas Rules of Civil Procedure as it does not describe
with reasonable particularity the matter on which examination is requested.

8. The case Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960 (5th Cir. 2010).

RESPONSE: Ironshore objects to this topic on the grounds that it is overly broad
and exceeds the scope of discovery as it cans for a legal conclusion from a corporate
representative concerning case law.

9. The case Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL 3557541 (w.n. La.
2013).

RESPONSE: Ironshore objects to this topic on the grounds that it is overly broad
and exceeds the scope of discovery as it calls for a legal conclusion from a corporate
representative concerning case law.

10. The case Pioneer Exploration, L.L.C. v. Steadfast Ins. Co., 767 F.3d 503 (5th Cir. 2014).

RESPONSE: Ironshore objects to this topic on the grounds that it is overly broad
and exceeds the scope of discovery as it calls for a legal conclusion from a corporate
representative concerning case law.

II. Ironshore's application of the Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx.
960 (5th Cir. 2010) decision to its liability policies.
V)
C') RESPONSE: Ironshore objects to this topic on the grounds that it is overly broad
'-
0 and exceeds the scope of discovery as it calls for a legal conclusion from a corporate
"1-
! includes the word "each."
,
uu. The term "and" includes the word "or" and "or" includes the word "and."

vv. The term "including" shall be construed as broadly as possible and shall mean

"without limitation."

ww. "Person" shall mean any natural person, corporation, firm, association,

partnership, joint venture, proprietorship, governmental body, governmental agency, or any other

organization, business, or legal entity, and all predecessors or successors in interest.

xx. The phrase "related to or discussing," as used herein, shall mean all information

and an facts and/or Documents that directly, indirectly orin any other way support, negate, bear

upon, touch upon, incorporate, affect, include, pertain to, and/or are otherwise connected with the

subject matter about which a request is being made.

DOCUMENTS

1. Acopy of deponent's current resume or curriculum vitae;
2. A copy of deponent's current driver's license or government-issued photo identification;

3. A copy of each and every document reviewed in preparation for Your testimony at the
scheduled deposition; I).nd

4. All Documents responsive to Denbury's First and Second Sets of Requests for Production
served on May 18, 2015 and August 5, 2015; and

5. All Documents responsive to the Examination Topics listed below.

EXAMINATION TOPICS

1. Denbury.

2. Denbury's operations.

Page 12 of18
 3. The risks presented by Denbury's operations.

4. The Delhi Incident.

5. The Policies.

6. Reserves under the Policies.

7. The Blended Pollution Endorsement.

8. The caseAspen Ins. UK., Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960 (5th Cir. 2010).

9. The case Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL 3557541 (W.D. La.
2013).

)
10. The case Pioneer Exploration, L.L.c. v. Steadfast Ins. Co., 767 FJd 503 (5th Cir. 2014).

ll. Ironshore's application of the Aspen Ins. UK., Ltd. v. Dune Energy, Inc., 400 Fed. Appx.
960 (5th Cir. 2010) decision to its liability policies.

12. Ironshore's application of the Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL
3557541 (W.D. La. 2013) decision to its liability policies.

13. Ironshore's application ofthe Pioneer Exploration, L.L.C. v. Steadfast Ins. Co., 767 F.3d
503 (5th Cir. 2014) decision to its liability policies.

14. Ironshore's relationship with Denbury's Insurers.

15. Ironshore' ~ Communications with Denbury's Insurers.

16. Ironshore's review of any Adjustment of Denbury's Claim.

17. Ironshore's relationship with Marsh.

18. Ironshore's Communications with Marsh.

V) 19. Ironshore's relationship with Denbury.
M
'+-<
0
0\ 20. Ironshore's Communications with Denbury.
N
:1

;...;

c' as used herein, shall mean all information

and all facts andlor Documents that directly, indirectly or in any other way support, negate, bear

upon, touch upon, incorporate, affect, include, pertain to, andlor are otherwise connected with the

subject matter about which a request is being made.

DOCUMENTS

1. A copy of deponent's current resume or curriculum vitae;

2. A copy of deponent's current Qriver's license or government-issued photo identification;

3.' A copy of each and every document reviewed in preparation for Your testimony at the
scheduled deposition;

4. All Documents responsive to Denbury's First and Second Sets of Requests for Production
served on May 18, 2015 and August 5, 2015; and

5. All Documents related to or discussing the Examination Topics listed below.

EXAMINATION TOPICS

1. Denbury.

2. Denbury's operations.

Page 12 of20
 ".

3. The risks presented by Denbury's operations.

4. The Delhi Incident.

5. The Policies ..

6. Reserves under the Policies.

7. The Blended Pollution Endorsement.

8. The case Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960 (5th Cir. 2010).

9. The case Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL 3557541 (W.D. La.
2013).

10. The case Pioneer Exploration, L.I.e. v. Steadfast Ins. Co., 767 FJd 503 (5th Cir. 2014).

11. FARA's application of the Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960
(5th Cir. 2010) decision to the Ironshore Policy.

12. FARA's application of the Aspen Ins. UK, Ltd. v. Dune Energy, Inc., 400 Fed. Appx. 960
(5th Cir. 2010) decision to Other Liability Policies.

13. FARA's application of the Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL
3557541 (W.D. La. 2013) decision to the Ironshore Policy.

14. FARA's application of the Pioneer Exploration, LLC v. Steadfast Ins. Co., 2013 WL
3557541 (W.D. La. 2013) decision to Other Liability Policies.

15. FARA's application of the Pioneer Exploration, L.L.e. v. Steadfast Ins. Co., 767 FJd
503 (Sth Cir. 2014) decision to the Ironshore Policy.

16. FARA's application of the Pioneer Exploration, L.L.C. v. Steadfast Ins. Co., 767 FJd
503 (5th Cir. 2014) decision to the Other Liability Policies.

17. FARA's relationship with Denbury's Insurers.

18. FARA's Communications with Denbury's Insurers.

19. FARA' s review of any Adjustment of Denbury' s Claim.

20. Ironshorels relationship with Marsh.

21. Ironshore's Communications with Marsh.

22. FARA' s relationship with Marsh.

Page 13 of20
 23. FARA's Communications with Marsh.

24. Ironshore's relationship with Denbury.

25. Ironshore's Communications with Denbury.

26. FARA's relationship with Denbury.

27. FARA's Communications with Denbury.

28. .All Documents exchanged between Ironshore and any Person related to Denbury.

29. All Documents exchanged between Ironshore and any Person related to Denbury's Claim.

30. All Documents exchanged between Ironshore and any Person related to the Delhi
Incident.

31. All Documents exchanged between Ironshore and any Person related to the Policies.

32. All Documents exchanged between Ironshore and any Person related to the Litigation.

33. All Documents exchanged between FARA and any Person related to Denbury.

34. All Documents exchanged between FARA and any Person related to Denbury's Claim.

35. . All Documents exchanged between FARA and any Person related to the Delhi Incident.

36. . All Documents exchanged between FARA and any Person related to the Policies.

37. All Documents exchanged between FARA and any Person related to the Litigation.

38. FARA's communications with Ironshore regarding the Underwriting of theUmbreUa
Policy.

39. Ironshore's understanding of Blended Pollution Endorsement Form U~UMB-200-A CW
(7/99).
'T
'-+-
0
'T 40. Ironshore's understanding of Blended Pollution Endorsement Form U-EXS-200-A~CW
(")