CTQ-2015-00003
Court of Appeals
STATE OF NEW YORK
In the Matter of Viking Pump, Inc. and Warren Pumps LLC,
Insurance Appeals,
VIKING PUMP, INC. and WARREN PUMPS LLC,
Appellants,
against
TIG INSURANCE COMPANY, et al.,
Respondents.
>> >>
SURREPLY BRIEF FOR RESPONDENTS
Mary Kay Vyskocil
Summer Craig
Alexander Li
SIMPSON THACHER & BARTLETT LLP
425 Lexington Avenue
New York, New York 10017
212-455-2000
Attorneys for Respondents Certain
Underwriters at Lloyd’s, London
On Appeal from the Questions Certified by the Supreme Court of the State of Delaware
(Docket Nos. 518, 2014; 523, 2014; 525, 2014; 528, 2014)
(Counsel Continued on the Reverse)
Date Completed: November 11, 2015
To Be Argued By:
Mary Kay Vyskocil
Time Requested: 30 minutes
Jonathan D. Hacker
Time Requested: 30 minutes
Jonathan D. Hacker (pro hac vice)
O’MELVENY & MYERS LLP
1625 Eye Street, N.W.
Washington, D.C. 20006
202-383-5300
and
Tancred Schiavoni
Gary Svirsky
Anton Metlitsky
Brad M. Elias
O’MELVENY & MYERS LLP
7 Times Square
New York, New York 10036
212-326-2000
Attorneys for Respondents
Century Indemnity Company,
ACE Property & Casualty
Insurance Company, and
Westchester Fire Insurance Company
Laura S. McKay (pro hac vice)
HINKHOUSE WILLIAMS WALSH LLP
180 North Stetson Avenue, Suite 3400
Chicago, Illinois 60601
312-784-5400
Attorneys for Respondents Certain London
Market Insurance Companies, Granite State
Insurance Company, Lexington Insurance
Company, National Union Fire Insurance
Company Of Pittsburgh, Pa., OneBeacon
America Insurance Company n/k/a
Lamorak Insurance Company (as successor
to Commercial Union Insurance Company),
XL Insurance America, Inc. (as successor to
Vanguard Insurance Company), Republic
Insurance Company n/k/a Starr Indemnity
& Liability, and The Continental Insurance
Company (as successor by merger to Fidelity
& Casualty Company of New York)
Kathleen D. Monnes (pro hac vice)
Joseph K. Scully (pro hac vice)
John W. Cerreta
DAY PITNEY LLP
242 Trumbull Street
Hartford, Connecticut 06103
860-275-0100
Attorneys for Respondent
Travelers Casualty and Surety Company f/k/a
The Aetna Casualty and Surety Company
Amy R. Paulus (pro hac vice)
Mark D. Paulson (pro hac vice)
Don R. Sampen (pro hac vice)
CLAUSEN MILLER P.C.
10 South LaSalle Street
Chicago, Illinois 60603
312-855-1010
Attorneys for Respondent
Old Republic Insurance Company
Kristin Suga Heres (pro hac vice)
ZELLE HOFMANN VOELBEL
& MASON LLP
600 Worcester Road, Suite 101
Framingham, Massachusetts 01702
781-466-0700
Attorneys for Respondent
Westport Insurance Corporation
Christopher R. Carroll
Heather E. Simpson
CARROLL, MCNULTY & KULL LLC
120 Mountain View Boulevard
P.O. Box 650
Basking Ridge, New Jersey 07920
908-848-6300
Attorneys for Respondent
TIG Insurance Company (as successor
by merger to International Insurance
Company, as successor by merger to
International Surplus Lines Insurance
Company (Policy No. XSI 5217 only))
CORPORATE DISCLOSURE STATEMENT
Due to the number of respondents, and for the convenience of the
Court, the statement required by Section 500.1(f) of the Rules of Practice for this
Court is appended to the end of this brief.
ii
STATUS OF RELATED CASES
This case is before the Court on certified questions from the Supreme
Court of the State of Delaware. A number of issues not certified to this Court
remain on appeal to the Delaware Supreme Court. The Delaware Supreme Court
has advised the parties that it will take no further action in that appeal until this
Court resolves the certified questions.
iii
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES .................................................................................... iv
ARGUMENT ............................................................................................................. 1
I. CON ED RESOLVED THE MEANING OF THE WORDS
“DURING THE POLICY PERIOD” .............................................................. 1
II. LIBERTY’S UNILATERAL CONDUCT HAS NO BEARING
UPON THE INTERPRETATION OF THE EXCESS POLICIES ................. 2
III. OLIN III PROPERLY APPLIED NEW YORK LAW IN HOLDING
THAT PRO RATA ALLOCATION IS CONSISTENT WITH
CONDITION C ............................................................................................... 3
IV. UNDER PRO RATA ALLOCATION, NON-CUMULATION AND
PRIOR INSURANCE PROVISIONS ARE NOT SURPLUSAGE
AND DO NOT PROVIDE INSURERS A WINDFALL ................................ 5
A. Non-Cumulation Clause In Liberty Follow-Form Policies................... 6
B. Condition C In Non-Liberty Policies .................................................... 9
V. ALLOCATION OF DEFENSE COSTS IS NOT BEFORE THIS
COURT .......................................................................................................... 10
CONCLUSION ........................................................................................................ 12
iv
TABLE OF AUTHORITIES
Page
CASES
Allmerica Fin. Corp. v. Certain Underwriters at Lloyd’s,
871 N.E.2d 418 (Mass. 2007). ............................................................................... 3
Bahar ex rel. Johnson v. Allstate Ins. Co.,
2004 WL 1782552 (S.D.N.Y. Aug. 9, 2004), aff’d,
159 F. App’x 311 (2d Cir. 2005) ........................................................................... 5
Consol. Edison Co. of New York v. Allstate Ins. Co.,
98 N.Y.2d 208 (2002) ............................................................................................ 1
Hanover Ins. Co. v. Vermont Mut. Ins. Co.,
69 F. Supp. 3d 302 (N.D.N.Y. 2014) ..................................................................... 5
Joseph v. United States,
135 S. Ct. 705 (2014) ............................................................................................. 9
Liberty Mut. Fire Ins. Co. v. J.&S. Supply Corp.,
No. 1:13-cv-04784, slip op. (S.D.N.Y. June 29, 2015) ......................................... 7
Olin Corp. v. Am. Home Assurance Co. (Olin III),
704 F.3d 89 (2012) ........................................................................................ 3, 4, 5
Outboard Marine Corp. v. Liberty Mut. Ins. Co.,
670 N.E.2d 740 (Ill. App. Ct. 1996). ..................................................................... 5
Persky v. Bank of Am. N.A.,
261 N.Y. 212 (1933) .............................................................................................. 2
Spaulding Composites Co. v. Aetna Cas. & Sur. Co.,
819 A.2d 410 (N.J. 2003) ...................................................................................... 5
ARGUMENT
I. CON ED RESOLVED THE MEANING OF THE WORDS “DURING
THE POLICY PERIOD”
Plaintiffs
1
contend that in Consolidated Edison Co. of New York v.
Allstate Insurance Co. (Con Ed), 98 N.Y.2d 208 (2002), this Court did not actually
hold that the words “during the policy period” require pro-rata allocation, but
merely determined that “the allocation issue, like any other issue of policy
interpretation under New York law, depends on a plain reading of the policy
language as a whole.” Reply Brief for Appellant Warren Pumps LLC (“Warren
Reply”) at 6–7. Plaintiffs attack a straw man. It is of course true that this Court
analyzed “the policy language as a whole.” Id. at 7. But in conducting that
analysis, this Court expressly held that joint and several allocation “is not
consistent” with the words “during the policy period,” and that pro rata allocation,
while not “explicitly mandated,” is “consistent” with those words. 98 N.Y.2d at
224. Thus, this Court indeed interpreted the words “during the policy period” to
require pro rata allocation as a matter of New York law. For the reasons stated in
1
Capitalized terms have the same meaning as in the Brief for Respondents unless
otherwise indicated.
2
Point I of the Brief for Respondents, and elaborated infra at 3–10, neither the Non-
Cumulation clause nor Condition C changes that result.
2
II. LIBERTY’S UNILATERAL CONDUCT HAS NO BEARING UPON
THE INTERPRETATION OF THE EXCESS POLICIES
Plaintiffs’ opening brief included discussion of Liberty’s alleged
conduct only as mere “background,” in tacit recognition that Liberty’s conduct has
no bearing on the legal arguments at issue here. In their reply, however, Plaintiffs
for the first time argue affirmatively that this Court should consider “a primary
insurer’s policy interpretation in a follow form program.” Compare Brief for
Appellant Warren Pumps LLC at 11–12 with Warren Reply at 9–12. Plaintiffs’
argument has no merit.
Plaintiffs concede that the Excess Insurers are not bound by Liberty’s
conduct, see Warren Reply at 10–11, but nevertheless contend that Liberty’s
supposed interpretation of the Liberty umbrella policies “sheds light . . . [on] how
2
Plaintiffs urge the Court to disregard the undisputed fact that Condition C was in the
policies interpreted in Con Ed because the Excess Insurers did not point that fact out to
the Delaware courts. Warren Reply at 2–3 & n.3. But this is not a direct appeal — it is a
certified question concerning the substance of New York law, which cannot change
depending on what was or was not argued in Delaware courts. Further, even if traditional
waiver principles applied, they would not affect the Excess Insurers’ argument
concerning Con Ed, because waiver applies only to the “the questions raised or argued”
below, and “not to the arguments there presented.” Persky v. Bank of Am. N.A., 261 N.Y.
212, 218 (1933) (emphasis in original). The Excess Insurers plainly raised the allocation
question in Delaware — the fact that Con Ed addressed Condition C policies is at most an
argument relevant to that question.
3
the Liberty policy language was intended to operate,” id. at 11. But it is the excess
policies, not the Liberty policies, that are at issue here. Although the excess
policies follow form to the Liberty umbrella policies in relevant part, “[a]n excess
carrier’s intent to incorporate the same words used in a separate agreement
between the primary insurer and the insured does not imply an intent by the excess
carrier to accept decisions made by the primary carrier about the extent of its
obligations under its own agreement.” Allmerica Fin. Corp. v. Certain
Underwriters at Lloyd’s, 871 N.E.2d 418, 428 (Mass. 2007). Indeed, Plaintiffs’
own words make the point: “[T]he parties’ course of performance under the
contract is considered the most persuasive evidence of the agreed intention of the
parties.” Warren Reply at 11 (quotation marks omitted; emphases added).
Because Liberty was not a party to the excess policies, its conduct is irrelevant to
their interpretation.
III. OLIN III PROPERLY APPLIED NEW YORK LAW IN HOLDING
THAT PRO RATA ALLOCATION IS CONSISTENT WITH
CONDITION C
In Olin III, the Second Circuit explained why Condition C — present
in only 11 of the 34 excess policies here — is perfectly consistent with pro rata
allocation. 704 F.3d 89, 103 (2012). The Second Circuit explained that the second
paragraph of Condition C — the “continuing coverage” clause — “applies only to
damages continuing after the termination of the policy and is silent regarding
4
damages occurring before the policy period,” id. at 103 (emphasis in original),
which is directly contrary to the premise of joint and several liability that the
policy pays for injuries before, during, and after the policy period. The court
therefore reasoned that if the insured proved a loss continuing after the expiration
of the policy period, “the continuing coverage provision of Condition C [would]
extend[] liability temporally by providing that the insurer will cover damage
allocated pro rata to years after the termination of the policy.” Id. (emphasis
altered).
The Second Circuit also explained that the non-cumulation language
of Condition C’s first paragraph serves as an “express[] limit” on the scope of the
“continuing coverage provision.” Id. at 104 n.20. That is, the non-cumulation
provision does not expand liability under a Condition C policy to pre-policy losses,
as Plaintiffs here contend, but rather “reduces [the insurer’s] liability” under the
Condition C policy where a “prior insurance policy at the same level of coverage”
provides for indemnification for loss arising from the same occurrence. Id. at 104.
Plaintiffs urge the Court to ignore Olin III because the policyholder in
that case purportedly “had no reason to argue for . . . aggregation of pre-policy
losses.” Warren Reply at 14. It is indisputable, however, that the Second Circuit
expressly held that Condition C’s non-cumulation provision — the only part of
Condition C that Plaintiffs say requires “aggregation of pre-policy losses,” id. —
5
“reduces” (not expands) an insurer’s liability, Olin III, 704 F.3d at 104. That
conclusion is central to the Second Circuit’s analysis, not mere dictum.
3
Alternatively, Plaintiffs suggest that the Second Circuit simply got it
wrong, citing their own brief and the decisions of out-of-state courts. Warren
Reply at 15, 17-21. These cases show only that different jurisdictions have
reached different results. See, e.g., Spaulding Composites Co. v. Aetna Cas. & Sur.
Co., 819 A.2d 410 (N.J. 2003) (New Jersey law); Outboard Marine Corp. v.
Liberty Mut. Ins. Co., 670 N.E.2d 740 (Ill. App. Ct. 1996) (Illinois law). Unlike
these out-of-state courts, the Second Circuit in Olin III construed New York law —
and it is New York law that controls this case.
IV. UNDER PRO RATA ALLOCATION, NON-CUMULATION AND
PRIOR INSURANCE PROVISIONS ARE NOT SURPLUSAGE AND
DO NOT PROVIDE INSURERS A WINDFALL
Plaintiffs’ core argument is that under pro rata allocation, the Non-
Cumulation clause and Condition C serve no purpose, such that enforcing them in
3
Plaintiffs also misread two federal district court cases to endorse “allocating the entire
judgment amount to just one policy period” where a single occurrence implicates
multiple policies. Warren Reply at 16 (citing Hanover Ins. Co. v. Vermont Mut. Ins. Co.,
69 F. Supp. 3d 302 (N.D.N.Y. 2014) and Bahar ex rel. Johnson v. Allstate Ins. Co., 2004
WL 1782552 (S.D.N.Y. Aug. 9, 2004), aff’d, 159 F. App’x 311 (2d Cir. 2005)). To the
contrary, in both cases the courts simply applied the non-cumulation clause to prevent the
insured from cumulating multiple policy limits for a single occurrence, just as the Excess
Insurers have argued here. See Hanover, 69 F. Supp. 3d at 313 (“Vermont is liable only
to the limits of one policy.”); Bahar, 2004 WL 1782552 at *4 (“Allstate fulfilled its
obligation when it paid one policy limit of liability.”).
6
a pro rata jurisdiction gives the insurer a windfall. As was just demonstrated, the
Second Circuit rejected that argument in Olin III, and the argument has not
improved with time. Although Plaintiffs try to obscure the distinctions, different
policies and separate policy provisions are at issue here, and each must examined
independently. That examination shows that each provision operates fully and
properly under pro rata allocation.
A. Non-Cumulation Clause In Liberty Follow-Form Policies
The 23 policies in this case that do not contain Condition C instead
follow form to the underlying Liberty umbrella polices’ Non-Cumulation clause.
That clause provides that when a single occurrence results in injury “partly before
and partly within” the policy period, “the each occurrence limit and the applicable
aggregate limit or limits of this policy shall be reduced by the amount of each
payment made by [Liberty] with respect to such occurrence.” A-518. Plaintiffs
misread the Non-Cumulation clause as expanding the policy’s coverage to
encompass injury occurring before the policy period, but the opposite is true: The
clause plainly provides that to the extent injuries from a covered occurrence
happen partly before the policy period, the policy’s coverage is not expanded to
encompass that injury, but instead the policy’s limit applicable to that occurrence
is reduced to account for payments made by the same insurer under prior policies.
Plaintiffs inexplicably assert that adjusting the policy limit to account for such
7
payments “is not what the Provisions say,” Warren Reply at 25, but the language
could not be clearer.
Nor does enforcing the Excess Policies according to their plain terms
create any windfall for the insurer. See, e.g., Liberty Mut. Fire Ins. Co. v. J.&S.
Supply Corp., No. 1:13-cv-04784, slip op. at 15-16 (S.D.N.Y. June 29, 2015)
(rejecting policyholder argument that Liberty Non-Cumulation provision “would
make pro rata allocation unfair and provide Liberty Mutual with a windfall”).
4
The
Non-Cumulation clause merely holds the insured to its initial bargain of a single
limit for each occurrence, even if the occurrence causes injuries in multiple policy
periods. If the Non-Cumulation clause were ignored when allocating pro rata, then
the insured would receive a windfall, because it could cumulate or “stack”
successive policies and successive limits to cover a single occurrence. The Excess
Insurers agree with Plaintiffs that “true equity lies in holding the contracting
parties to the bargains they made,” Warren Reply at 36, but it is Plaintiffs who
seek to escape the bargain these policies reflect: if an insured wants the right to
4
In J&S Supply, Liberty successfully argued that the same Liberty Non-Cumulation
provision at issue here was entirely consistent with pro rata allocation, thereby again
refuting Plaintiffs’ assertion that Liberty reads the Non-Cumulation provision to require
all sums allocation. The fact that Plaintiffs say Liberty sometimes has adopted a different
approach as a business compromise has no bearing on the correct legal construction of
the provision.
8
cumulate the limits of successive policies implicated by a single occurrence, the
insured should not agree to a Non-Cumulation clause.
Plaintiffs’ own chart illustrates how the Non-Cumulation clause
operates under pro rata allocation to avoid recovery of multiple per occurrence
limits for a single occurrence. See Warren Reply at 30. As the chart shows, the
insured recovers the full $2 million it contracted to receive for any one occurrence.
Plaintiffs suggest that because the hypothetical injuries in the chart resulted in $5
million in liabilities, the insured’s recovery of its maximum per occurrence limit
leaves an “unpaid $3 million balance,” id. at 31, as if an insured has a natural right
to avoid all the costs of its own injury-causing conduct. If an insured wants
maximum protection against potential single-occurrence liabilities, it can always
purchase higher per occurrence limits, or it can obtain higher-level policies that
cover single-occurrence liabilities that remain uncovered at lower levels.
5
In the
end, whether the insured ultimately recovers such amounts from higher-level
policies (which depends on the specific language of those policies) does not mean
that a lower-level insurer whose policies contain Non-Cumulation clauses receives
5
Plaintiffs cite a case in which an excess insurer successfully argued against a duty to
“drop down” and provide coverage for an unexhausted policy due to a lower-level
insurer’s insolvency. Warren Reply at 33. The Excess Insurers’ responsibility for
coverage owed by insolvent lower-level insurers is not at issue here. And the fact that
coverage might not be available in a given case because of particular policy language
does not undermine the point that an insured can always obtain excess policies that do
cover the kind of losses reflected in Plaintiffs’ chart.
9
a “windfall,” as Plaintiffs suggest. To the contrary, both parties receive what they
bargained for — a single limit for each occurrence, no matter whether the
occurrence results in damage during one or more policy periods.
6
B. Condition C In Non-Liberty Policies
Condition C, included in 11 of the 34 policies, also functions
effectively in a pro rata allocation regime.
The first paragraph — the “Prior Insurance” provision — operates like
the Non-Cumulation clause of the other policies in all respects relevant here.
Plaintiffs do not disagree — they simply misread and misapply the Prior Insurance
provision just as they do the Non-Cumulation clause.
The second paragraph — the “Continuing Coverage” provision —
appears only in the non-Liberty policies. As explained above, Olin III
6
Plaintiffs criticize the Excess Insurers for purportedly changing their position after
“represent[ing] to the Delaware Chancery Court for years that the Non-Cumulation and
Prior Insurance Provisions could not be applied in the context of a pro-rata allocation.”
Warren Reply at 4. This criticism is inaccurate, unfair, and irrelevant. It is inaccurate
because, contrary to Plaintiffs’ out-of-context quotation of Travelers’ argument, see
Warren Reply at 27, Travelers actually explained that “there may be scenarios in which
the Non-Cumulation Provision would apply to an asbestos products loss even in a pro
rata jurisdiction” and explained how the Liberty Non-Cumulation clause applied to the
hypothetical posited by the Chancery Court. A-1483. It is unfair because the Second
Circuit decided Olin III — one of the Excess Insurers’ principal authorities — in 2012,
more than two years after the briefing in the Chancery Court. See Joseph v. United
States, 135 S. Ct. 705, 706 (2014) (Kagan, J., concurring, respecting denial of certiorari)
(appellate courts routinely accept new arguments in cases where intervening precedent
“provides an appellant with a new theory or claim”). Finally, what was argued in the
Delaware courts is irrelevant because this is a certified question (not a direct appeal) and
because arguments (unlike issues) cannot be waived. See supra note 2.
10
demonstrates how this provision operates under pro rata allocation — it is neither
superfluous nor the source of any windfall, but instead simply applies in the
narrow set of instances where injuries existing at the end of a policy period
continue into the next period. See supra at 3–5. Its presence is in no way
inconsistent with pro rata allocation.
7
V. ALLOCATION OF DEFENSE COSTS IS NOT BEFORE THIS
COURT
Neither of the two certified questions says anything about the distinct
issue of allocating defense costs. Plaintiffs suggest that by its very silence, the first
certified question actually invited full briefing and argument on this separate issue,
Warren Reply at 41, even though neither party addressed it before the court that
certified the question. Plaintiffs say they did mention defense costs in the
Delaware litigation, id. at 40, but every statement they cite merely asserted that if
indemnity costs were subject to joint and several allocation, then defense costs also
7
Plaintiffs insist that, as a factual matter, the injuries here were continuing. Warren Reply
at 22–23. But the Delaware trial court rejected Plaintiffs’ continuing-injury argument
and held that they were required to establish significant exposure within a given policy’s
period to trigger coverage under that policy. Plaintiffs have appealed that ruling in
Delaware, but they did not seek certification of that issue to this Court. In any event, the
issue of when or how a particular type of injury triggers policy coverage has no bearing
on the legal meaning of “during the policy period” and whether it compels pro rata
allocation as Con Ed held. These commercial general liability policies cover myriad
different losses beyond long-tail liabilities from asbestos exposure. What matters is that
the Continuing Coverage provision operates meaningfully under pro rata allocation, not
whether these particular injuries implicate that provision.
11
should be allocated jointly and severally. Nowhere did Plaintiffs in the Delaware
Supreme Court make the completely different argument they raise now, viz., that
even if indemnity costs are allocated pro rata, defense costs should be allocated
differently, on a joint and several basis. That argument implicates distinct
precedents, policies, and provisions that no party has briefed and argued in the
Delaware litigation. The issue accordingly is not hidden within the silence of the
certified questions, and so this Court lacks jurisdiction to consider it.
13
14
15
16
17
18
CORPORATE DISCLOSURE STATEMENT
Pursuant to Section 500.1(f) of the Rules of Practice for this Court,
Respondents state as follows:
1. ACE Property and Casualty Insurance Company is a wholly owned
subsidiary of INA Holdings Company, which is a wholly owned subsidiary of INA
Financial Corp. INA Financial Corp. is a wholly owned subsidiary of INA
Corporation, which is a wholly owned subsidiary of ACE INA Holdings, Inc.
ACE INA Holdings, Inc. is 80% owned by ACE Group Holdings Inc. and 20%
owned by ACE Limited. ACE Group Holdings, Inc. is a wholly owned subsidiary
of ACE Limited. ACE Limited, the ultimate parent corporation, is publicly traded
(NYSE: ACE). A list of ACE Limited affiliated entities is appended hereto as
Annex A.
2. Century Indemnity Company is a wholly owned subsidiary of
Brandywine Holdings Corp., which is a wholly owned subsidiary of INA Financial
Corp. INA Financial Corp. is a wholly owned subsidiary of INA Corporation,
which is a wholly owned subsidiary of ACE INA Holdings, Inc. ACE INA
Holdings, Inc. is 80% owned by ACE Group Holdings Inc. and 20% owned by
ACE Limited. ACE Group Holdings, Inc. is a wholly owned subsidiary of ACE
Limited. ACE Limited, the ultimate parent corporation, is publicly traded (NYSE:
ACE). A list of ACE Limited affiliated entities is appended hereto as Annex A.
2
3. The Continental Insurance Company is a wholly owned subsidiary of
the Continental Casualty Company, which is a wholly owned subsidiary of the
Continental Corporation, which is a wholly owned subsidiary of CNA Financial
Corp., which is a publicly traded corporation. Affiliated entities are: American
Casualty Company of Reading, Pennsylvania, CNA Insurance Company Limited,
Columbia Casualty Company, Continental Reinsurance Corporation International,
Ltd., Hardy Guernsey Limited, National Fire Insurance Company of Hartford,
North Rock Insurance Company Limited, Surety Bonding Company of America,
The Continental Insurance Company of New Jersey, Transportation Insurance
Company, Universal Surety of America, Valley Forge Insurance Company, and
Western Surety Company.
4. Certain Underwriters at Lloyd’s, London are individual persons and
no parents, affiliates or subsidiaries exist.
5. Certain London Market Insurance Companies are as follows:
Accident & Casualty Company of Winterthur, n/k/a AXA
Winterthur, which is part of the AXA Group.
American Home Insurance Company, a wholly-owned subsidiary of
American International Group, Inc. A list of affiliated entities is
appended hereto as Annex B.
Argonaut Insurance Company, a wholly-owned subsidiary of Argo
Group. A list of affiliated entities is appended hereto as Annex C.
3
Assicurazioni Generali S.p.A. Affiliated entities are: Delta
Generali, Future Generali, Genertellife, INA Assitalia, Alleanza -
Toro, Genertel, Europ-Assistance, and Banca Generali.
Bishopsgate Insurance Company, n/k/a Fortis Insurance Limited.
Bishopsgate is affiliated with Northern Star Insurance Company
Limited.
Britamco Pool.
Companhia De Seguros Imperio S.A.
CNA Reinsurance Company Limited (UK), a subsidiary of Tawa
UK Ltd., a subsidiary of Artemis Group, a diversified French
holding company.
Dominion Insurance Co. Ltd.
Excess Insurance Company Limited, a wholly-owned subsidiary of
Heritage Reinsurance Company Ltd., whose ultimate holding
company is the Hartford Financial Services Group, Inc. A list of
affiliated entities is appended hereto as Annex D.
London and Edinburgh (General) Insurance Company Limited, part
of Aviva Insurance Limited. Affiliated entities are: Gresham
Insurance Company Ltd., and The Ocean Marine Insurance
Company Ltd.
National Casualty Company of America Limited, plc., which is a
wholly-owned subsidiary of National Casualty Company, which is a
wholly-owned subsidiary of Scottsdale Insurance Company, which is
a wholly-owned subsidiary of Nationwide.
New London Reinsurance Company Limited.
River Thames Insurance Company Limited, a subsidiary of Enstar
Group Limited. A list of affiliated entities is appended hereto as
Annex E.
St. Katherine Insurance Company Limited, predecessor-in-interest to
UnionAmerica Insurance Company Limited, a subsidiary of Enstar
4
Group Limited. A list of affiliated entities is appended hereto as
Annex E.
Stronghold Insurance Company Limited.
Terra Nova Insurance Company Limited.
Turegum Insurance Company n/k/a/ Harper Insurance Limited, a
subsidiary of Enstar Group Limited. A list of affiliated entities
appended hereto as Annex E.
Yasuda Fire & Marine Insurance Company (UK) Limited, a
subsidiary of Yasuda Fire & Marine Insurance Company. Affiliated
entities are: Yasuda Building Management Co., Ltd., Yasuda Kasai
Information Technology Co., Ltd., Yasuda Claims Research Co.,
Ltd., Yasuda Agency Association Ltd., The Yasuda Marine Service
Co., Ltd., Yasuda Business Service Co., Ltd., The Yasuda Training
and Planning Co., Ltd., Yasuda Loan Service Co., Ltd., Yasuda
System Development Co. Ltd., Yasuda Credit Card Co., Ltd.,
Yasuda Career Bureau Co., Ltd., The Yasuda International
Investment Management Co., Ltd., Yasuda Research Institute Co.,
Ltd., Yasuda General Finance Co., Ltd., Yasuda Credit Co., Ltd.,
Yasuda Kasai International (U.S.A.), Inc., Yasuda Kasai Realty, Ind.
(U.S.A.), Yasuda Fire & Marine Insurance Company of America
(U.S.A.), Yasuda Claims Limited (U.K.), PanFinancial Insurance
Co., Ltd. (U.K.), The Yasuda Fire Investment (Europe) S.A.
(Luxembourg), Companhia de Seguros America do Sul Yasuda
(Brazil), The Yasuda Management Service Co. Ltd. (Bermuda), The
Yasuda Fire Bahama Ltd., William S.T. Lee Insurance Co., Ltd.
(Hong Kong), The Yasuda Fire Asset Management Co., Ltd. (Hong
Kong), The Yasuda Reinsurance Co., Ltd. (Hong Kong), P.T.
Asuransi Yasuda Indonesia, People's Trans-East Asia Insurance
Corporation (Philippines), Yasuda Management (Singapore) Private
Limited, Yasuda International Services Co., Ltd. (Thailand), Yasuda
Bahrain Kuwait Insurance Company (E.C.)
6. Granite State Insurance Company is a wholly owned subsidiary of
New Hampshire Insurance Company, which is a wholly owned subsidiary of AIG
Property Casualty U.S., Inc., which is a wholly-owned subsidiary of AIG Property
5
Casualty Inc., which is a wholly-owned subsidiary of AIUH LLC, which is a
wholly-owned subsidiary of American International Group, Inc. A list of affiliated
entities is appended hereto as Annex B.
7. Lexington Insurance Company is owned 70% by National Union Fire
Insurance Company of Pittsburgh, Pa, 20% by the Insurance Company of the State
of Pennsylvania, and 10% by AIG Property Casualty Company. Each of these
parent companies is a wholly owned subsidiary of AIG Property Casualty U.S.,
Inc., described above. A list of affiliated entities is appended hereto as Annex B.
8. National Union Fire Insurance Company of Pittsburgh, Pa is a wholly
owned subsidiary of AIG Property Casualty U.S., Inc., described above. A list of
affiliated entities is appended hereto as Annex B.
9. Lamorak Insurance Company, formerly known as OneBeacon
America Insurance Company, is a wholly owned subsidiary of Bedivere Insurance
Company, which is a wholly owned subsidiary of Trebuchet US Holdings, Inc.,
which is a wholly owned subsidiary of Trebuchet Investments, Limited, which is a
wholly owned subsidiary of Armour Group Holdings, Limited. Affiliated entities
are: A. W. G. Dewar, Inc., Atlantic Specialty Insurance Company, AutoOne
Insurance Company, AutoOne Select Insurance Company, The Camden Fire
Insurance Association, EBI Claims Services, LLC, The Employers’ Fire Insurance
Company, Essentia Insurance Company, Homeland Insurance Company of
6
Delaware, Homeland Insurance Company of New York, Houston General
Insurance Company, Houston General Insurance Exchange, Houston General
Insurance Management Company, Mill Shares Holdings (Bermuda) Ltd., National
Marine Underwriters, Inc., The Northern Assurance Company of America, OBI
National Insurance Company, OneBeacon Entertainment, LLC, OneBeacon
Holdings (Gibraltar) Limited, OneBeacon Holdings (Luxembourg) S.à r.l.,
OneBeacon Insurance Company, OneBeacon Insurance Group LLC, OneBeacon
Midwest Insurance Company, OneBeacon Professional Insurance, Inc.,
OneBeacon Risk Management, Inc., OneBeacon Select Insurance Company,
OneBeacon Services, LLC, OneBeacon Specialty Insurance Company, OneBeacon
Sports and Leisure, LLC, OneBeacon U.S. Enterprises Holdings, Inc., OneBeacon
U.S. Financial Services, Inc., OneBeacon U.S. Holdings, Inc., Pennsylvania
General Insurance Company, Potomac Insurance Company, Traders & General
Insurance Company, WM Belvaux (Luxembourg) S.à r.l., WM Findel
(Luxembourg) S.à r.l., WM Kehlen (Luxembourg) S.à r.l., and WM Queensway
(Gibraltar) Limited.
10. Old Republic Insurance Company is a Pennsylvania Corporation
which is a wholly owned subsidiary of Old Republic International Corporation, a
publicly traded company on the New York Stock Exchange. No publicly-held
corporation other than Old Republic International Corporation directly or indirectly
7
owns 10% or more of the stock of Old Republic Insurance Company, and no other
such parents, subsidiaries and affiliates exist.
11. Republic Insurance Company, n/k/a Starr Indemnity & Liability
Company, Inc., is a wholly owned subsidiary of Starr International USA, Inc.,
which is a wholly owned subsidiary of Starr International Company, Inc., a
privately held foreign insurance holding company. Affiliated entities are: C.V.
Starr & Co., Inc., Starr Syndicate Limited, Starr Surplus Lines Insurance
Company, Starr International Insurance (Asia) Limited, and Starr Insurance and
Reinsurance Limited.
12. TIG Insurance Company is the successor by merger to International
Insurance Company, which is successor by merger to International Surplus Lines
Insurance Company, with respect to Policy No. XSI 5217 in this action. TIG
Insurance Company is a wholly-owned subsidiary of TIG Insurance Group, Inc.,
which is owned by TIG Holdings, Inc., which is owned by Fairfax (US) Inc.,
which is owned by FFHL Group, Ltd., which is owned by Fairfax Financial
Holdings Limited, which is listed on The Toronto Stock Exchange under the
symbol FFH (Canadian dollars) and FFH.U (US Dollars). A list of TIG Insurance
Company’s affiliated entities is appended hereto as Annex F.
13. Travelers Casualty and Surety Company, f/k/a The Aetna Casualty
and Surety Company (“Travelers”), is a wholly-owned subsidiary of Travelers
8
Insurance Group Holdings, Inc., which is a wholly-owned subsidiary of Travelers
Property Casualty Corp., which is a wholly-owned subsidiary of The Travelers
Companies, Inc., a publicly traded company. A full listing of Travelers’ parents,
subsidiaries, and affiliates as June 30, 2015 is appended hereto as Annex G.
14. XL Insurance America, Inc., as successor to Vanguard Insurance
Company, is a subsidiary of XL Group plc, which is part of XL Catlin. A list of
affiliated entities is appended hereto as Annex H.
15. Westchester Fire Insurance Company (which in addition to being
financially responsible for policies novated to itself is also financially responsible
for several policies issued by TIG Insurance Company, an unaffiliated entity) is a
wholly owned subsidiary of ACE US Holdings, Inc., which is a wholly owned
subsidiary of ACE Group Holdings, Inc. ACE Group Holdings, Inc. is a wholly
owned subsidiary of ACE Limited. ACE Limited, the ultimate parent corporation,
is publicly traded (NYSE: ACE). A list of ACE Limited affiliated entities is
appended hereto as Annex A.
16. Westport Insurance Corporation (“Westport”)’s direct parent is SR
Corporate Solutions America Holding Corporation. SR Corporate Solutions
America Holding Corporation is in turn owned by Swiss Re Corporate Solutions
Ltd. Swiss Re Corporate Solutions Ltd is owned by Swiss Re Ltd. Swiss Re Ltd is
the ultimate corporate parent of Westport. Westport has five subsidiaries: North
9
American Specialty Insurance Company, North American Elite Insurance
Company, North American Capacity Insurance Company, and Washington
International Insurance Company. Each of these companies is a direct subsidiary,
except for Washington International Insurance Company, which is in turn owned
by North American Specialty Insurance Company.
10
ANNEX A
Affiliates of ACE Limited
ACE Life Insurance Company Egypt S.A.E.
ACE London Aviation Limited
ACE London Group Ltd.
ACE London Holdings Limited
ACE London Investments Limited
ACE London Services Limited
ACE London Underwriting Limited
ACE Marketing Group C.A.
ACE Property and Casualty Insurance Company
Cover Direct, Inc.
Cover-All Technologies Inc.
Cravens, Dargan & Company, Pacific Coast
Delpanama S.A.
ESIS, Inc.
ACE Insurance Company Limited
ACE Insurance Company of the Midwest
ACE Insurance Limited
ACE Insurance Limited
Ventas Personales Limitada
ACE Insurance Limited
ACE Insurance Limited
ACE Insurance Limited
ACE Insurance Limited
Westchester Fire Insurance Company
Westchester Specialty Insurance Services, Inc.
ACE Insurance S.A.-N.V.
ACE International Management Corporation
Westchester Surplus Lines Insurance Company
ACE Leadenhall Limited
ACE Capital V Ltd.
ACE INA Excess and Surplus Insurance Services, Inc. (CA)
Pembroke Reinsurance, Inc.
ACE INA International Holdings Ltd., Agencia En Chile
ACE INA International Holdings, Ltd.
Brandywine Holdings Corporation
PT. ADI Citra Mandiri
11
ACE INA Overseas Holdings, Inc.
Rain and Hail Insurance Service, Inc.
ACE INA Properties, Inc.
Recovery Services International, Inc.
ACE INA Services U.K. Limited
Century Indemnity Company
Ridge Underwriting Agencies Limited
ACE Insurance (Japan)
RIYAD Insurance Company Ltd.
ACE Insurance Agency, Inc.
ACE Insurance Company
Century Inversiones, S.A.
Servicios ACE INA, S.A. de C.V.
Siam Liberty Insurance Broker Co., Ltd.
Sovereign Risk Insurance Ltd.
Combined Insurance Company of America
Combined Life Insurance Company Of New York
Conference Facilities, Inc.
Illinois Union Insurance Company
INA Corporation
ACE Seguros S.A.
INA Financial Corporation
INA Holdings Corporation
ACE Seguros S.A.
ACE (CIDR) Limited
ACE (CR) Holdings
INA Tax Benefits Reporting, Inc.
ACE (RGB) Holdings Limited
ACE Asia Pacific Services Pte. Ltd.
ACE Seguros S.A.
ACE Asia Pacific Services Sdn. Bhd.
ACE Seguros S.A.
ACE Seguros S.A.
ACE Asset Management Inc.
INACOMB S.A. De C.V.
ACE Seguros, S.A.
ACE Australia Holdings Pty Limited
INAMAR Insurance Underwriting Agency, Inc.
ACE Servicios S.A.
12
ACE Bermuda International Insurance Limited
ACE Canada Holdings, Inc.
ACE Structured Products, Inc.
ACE Capital II Limited
INAMAR Insurance Underwriting Agency, Inc. Of Texas
ACE INA Berhad
ACE Capital III Limited
INAMEX S.A.
ACE Tarquin
ACE Capital IV Ltd.
ACE American Insurance Company
ACE Arabia Cooperative Insurance Company
ACE Capital Limited
INAVEN, C.A.
ACE Tempest Re Escritorio De Representacao No Brasil Ltda.
Indemnity Insurance Company of North America
ACE Capital Title Reinsurance Company
ACE Underwriting Agencies Limited
Insurance Company of North America
ACE Capital VI Limited
ACE Underwriting Services Limited
ACE US Holdings, Inc.
ACE Chintai SSI
Inversiones Continental, S.A. de C.V.
AFIA (ACE) Corporation, Limited
AFIA (INA) Corporation, Limited
AFIA Finance Corp. Chile Limitada
AFIA Finance Corporation
AFIA Finance Corporation Agencia En Chile
AFIA Venezolana, C.A.
ACE European Group Limited
ACE European Holdings Limited
ACE European Holdings No. 2 Limited
American Lenders Facilities, Inc.
ACE Financial Solutions, Inc.
ACE Fire Underwriters Insurance Company
ACE Global Markets Limited
NewMarkets Insurance Agency, Inc.
ACE Group Holdings Ltd.
13
ACE Group Holdings, Inc.
ACE INA Excess and Surplus Insurance Services, Inc. (PA)
Pacific Employers Insurance Company
Atlantic Employers Insurance Company
ACE INA Financial Institution Solutions, Inc.
Bankers Standard Fire and Marine Company
ACE INA G. B. Holdings, Ltd
Paget Reinsurance Ltd.
Bankers Standard Insurance Company
ACE INA Holdings Inc.
ACE Direct Marketing Company, Ltd.
ACE Seguros Soluções Corporativas S.A.
ACE Intermediaries (Bermuda) Ltd.
ABR Reinsurance Capital Holdings Ltd.
William Investment Holdings Corporation
ACE Serviços para Seguradoras e Resseguradoras Ltda.
ACE Corretora de Seguros Ltda.
CoverHound, Inc.
ACE Servicios S.A.
ACE Servicios Regionales Limitada
ACE Fianzas Monterrey, S.A.
Operadora FMA, S.A. de C.V.
Ally Insurance Holdings LLC
ABA Mexico Holdings LLC
ABA Seguros, S.A. de C.V.
ABA Servicios Corporativos, S.A. de C.V.
ABA Garantias S.A. de C.V.
Huatai Property & Casualty Insurance Co., Ltd.
Samaggi Insurance PCL
ACE Brazil Holdings, Ltd.
PT ACE Jaya Proteksi
PT Jaya Proteksi Takaful
PT Jaya Prima Auto Center
Siam Marketing & Analytics Company Limited
ACE Servicios, S.A.
Penn Millers Holding Corporation
PMMHC Corporation
Penn Millers Insurance Company
Penn Millers Agency, Inc.
14
ACE Russia Investments Limited
Russian Reinsurance Company
H.S. Life Small Amount & Short Term Insurance Co., Ltd.
ACE Resseguradora S.A.
ACE Risk Solutions, Inc.
ACE Seguradora S.A. (Brazil)
ACE Seguradora S.A.
ACE Seguros De Vida S.A.
ACE Seguros S.A.
ACE Capital VII Limited
ACE Europe Life Limited
Agri General Insurance Company
Agri General Insurance Service, Inc.
Rain and Hail Financial, Inc.
Huatai Insurance Group Co., Ltd.
Rain and Hail Insurance Service International, Inc.
Sovereign Risk Insurance (Dubai) Limited
ACE Life Insurance Company
Combined Insurance Company of Europe Limited
Combined Life Insurance Company of Australia Limited
Chiewchanwit Company Limited
S.E.O.S. Limited
Proclaim America, Inc.
ACE Arabia Insurance Company Limited B.S.C.(C)
ACE Jerneh Insurance Berhad
ACE Pension Trustee Limited
ACE Insurance Management (DIFC) Limited
ACE Insurance Company Egypt S.A.E.
Rain and Hail L.L.C.
LLC ACE Life Insurance
PT. ACE Life Assurance
ACE Life Fund Management Company Limited
FM HoldCo LLC
Nam Ek Company Limited
ACE Tempest Re USA, LLC
INA International Holdings, LLC
LLC ACE Insurance Company
ACE Life Assurance Public Company Limited
ACE Life Insurance Company Limited
15
Freisenbruch-Meyer Insurance Limited
Freisenbruch-Meyer Insurance Services Ltd.
ESIS Asia Pacific PTE. Ltd.
ESIS Canada Inc.
ACE Realty Holdings Limited
Corporate Officers & Directors Assurance Ltd.
Scarborough Property Holdings Ltd.
Century International Reinsurance Company Ltd.
Rhea International Marketing (L) Inc.
ACE INA Overseas Insurance Company Ltd.
ACE INA Life Insurance
Oasis Real Estate Company, Ltd.
Oriental Equity Holdings Limited
ACE Tempest Reinsurance Ltd.
ACE Alternative Risk Ltd.
ACE Services Limited
ACE Bermuda Insurance Ltd.
ACE Tempest Re Canada Inc.
INACAN Holdings Ltd.
ACE Tempest Life Reinsurance Ltd.
ACE Financial Solutions International, Ltd.
ACE Environmental Health And Safety Consulting (Shanghai) Company Limited
ACE INA Insurance
Oasis Insurance Services Ltd.
ACE Holdings Limited
Oasis Investments 2 Ltd.
Oasis Investments Limited
ACE Life Insurance Company Ltd.
ACE Life Insurance Company Ltd.
ACE Limited
ACE Insurance (Switzerland) Limited
ACE Reinsurance (Switzerland) Limited
Rain and Hail Insurance Service, Ltd.
Huatai Life Insurance Company, Limited
Rain and Hail Insurance Service de Mexico, S.A. de C.V.
ACE Group Management and Holdings Ltd.
ESIS Academy PTE. Ltd.
16
ANNEX B
Affiliates of American International Group, Inc.
AIG Capital Corporation
AIG Credit Corp.
AIG Global Asset Management Holdings Corp.
AIG Asset Management (Europe) Limited
AIG Asset Management (U.S.), LLC
AIG Global Real Estate Investment Corp.
Mt. Mansfield Company, Inc.
AIG Federal Savings Bank
AIG Financial Products Corp.
AIG-FP Matched Funding Corp.
AIG Management France S.A.
AIG Matched Funding Corp.
AIG Funding, Inc.
AIG Global Services, Inc.
AIG Shared Services Corporation
AIG Life Insurance Company (Switzerland) Ltd.
AIG Markets, Inc.
AIG Trading Group Inc.
AIG International Inc.
AIUH LLC
AIG Property Casualty Inc.
AIG Claims, Inc.
Health Direct, Inc.
AIG PC Global Services, Inc.
AIG North America, Inc.
AIG Property Casualty International, LLC
AIG APAC HOLDINGS PTE. LTD.
AIG Asia Pacific Insurance Pte. Ltd.
AIG Australia Limited
AIG Insurance Hong Kong Limited
AIG Insurance New Zealand Limited
AIG Malaysia Insurance Berhad
AIG Philippines Insurance, Inc.
AIG Taiwan Insurance Co., Ltd.
AIG Vietnam Insurance Company Limited
PT AIG Insurance Indonesia
17
Thai CIT Holding Co., Ltd
AIG Insurance (Thailand) Public Company Limited
AIG Central Europe & CIS Insurance Holdings Corporation
UBB-AIG Insurance Company AD
AIG Egypt Insurance Company S.A.E.
AIG Europe Holdings Limited
Ageas Protect Limited
AIG Europe Limited
AIG Germany Holding GmbH
AIG Investments UK Limited
AIG Israel Insurance Company Limited
AIG Japan Holdings Kabushiki Kaisha
American Home Assurance Co., Ltd.
AIU Insurance Company, Ltd.
The Fuji Fire and Marine Insurance Company, Limited
AIG Fuji Life Insurance Company, Limited
AIG MEA Holdings Limited
AIG CIS Investments, LLC
AIG Insurance Company, CJSC
AIG Insurance Limited
AIG Sigorta A.S.
Johannesburg Insurance Holdings (Proprietary) Limited
AIG Life South Africa Limited
AIG South Africa Limited
Private Joint-Stock Company AIG Ukraine Insurance Company
AIG PC European Insurance Investments Inc.
Ascot Corporate Name Limited
AIG Insurance Company China Limited
American International Overseas Limited
AIG Chile Compania de Seguros Generales S.A.
AIG Cyprus Limited
AIG Seguros, El Salvador, Sociedad Anonima
AIG Vida, Sociedad Anonima, Seguros de Personas
CHARTIS Takaful-Enaya B.S.C. (c)
La Meridional Compania Argentina de Seguros S.A.
American International Reinsurance Company, Ltd.
Chartis Latin America Investments, LLC
AIG Brazil Holding I, LLC
AIG Seguros Brasil S.A.
18
AIG Insurance Company-Puerto Rico
AIG Latin America I.I.
AIG Seguros Colombia S.A.
AIG Seguros Guatemala, S.A.
AIG Seguros Mexico, S.A. de C.V.
AIG Seguros Uruguay S.A.
AIG Uganda Limited
American International Underwriters del Ecuador S.A.
AIG-Metropolitana Cia de Seguros y Reaseguros S.A.
Inversiones Segucasai, C.A.
C.A. de Seguros American International
Underwriters Adjustment Company, Inc. (Panama)
AIG MEA Investments and Services, Inc.
AIG Lebanon SAL
AIG MEA Limited
AIG Kenya Insurance Company Limited
CHARTIS Investment Holdings (Private) Limited
Chartis Kazakhstan Insurance Company Joint Stock Company
AIG Travel, Inc.
AIG Travel Assist, Inc.
AIG Travel Asia Pacific Pte. Ltd.
AIG Travel EMEA Limited
Travel Guard Americas LLC
AIG Travel Insurance Agency, Inc.
Livetravel, Inc.
Travel Guard Group, Inc.
WINGS International SAS
AIG Property Casualty U.S., Inc.
AIG Aerospace Insurance Services, Inc.
AIG Assurance Company
AIG Canada Holdings Inc.
AIG Insurance Company of Canada
AIG Property Casualty Insurance Agency, Inc.
AIG Property Casualty Company
AIG Specialty Insurance Company
American Home Assurance Company
Commerce and Industry Insurance Company
Eaglestone Reinsurance Company
Granite State Insurance Company
19
Illinois National Insurance Co.
Lexington Insurance Company
Chartis Excess Limited
Morefar Marketing, Inc.
National Union Fire Insurance Company of Pittsburgh, Pa.
American International Overseas Association
American International Realty Corp.
National Union Fire Insurance Company of Vermont
Pine Street Real Estate Holdings Corp.
New Hampshire Insurance Company
New Hampshire Insurance Services, Inc.
Risk Specialists Companies, Inc.
Risk Specialists Companies Insurance Agency, Inc.
Agency Management Corporation
The Gulf Agency, Inc.
Design Professionals Association Risk Purchasing Group, Inc.
The Insurance Company of the State of Pennsylvania
AM Holdings LLC
American Security Life Insurance Company Limited
Chartis Azerbaijan Insurance Company Open Joint Stock Company
Maiden Lane III LLC
MG Reinsurance Limited
SAFG Retirement Services, Inc.
AIG Life Holdings, Inc.
AGC Life Insurance Company
AIG Life of Bermuda, Ltd.
American General Life Insurance Company
AIG Advisor Group, Inc.
Financial Service Corporation
FSC Securities Corporation
Royal Alliance Associates, Inc.
SagePoint Financial, Inc.
Woodbury Financial Services, Inc.
SunAmerica Asset Management, LLC
The United States Life Insurance Company in the City of New York
The Variable Annuity Life Insurance Company
Valic Retirement Services Company
SunAmerica Life Reinsurance Company
United Guaranty Corporation
20
AIG United Guaranty Agenzia di Assicurazione S.R.L.
AIG United Guaranty Insurance (Asia) Limited
AIG United Guaranty Mexico, S.A.
AIG United Guaranty Re Limited
United Guaranty Insurance Company
United Guaranty Mortgage Insurance Company
United Guaranty Mortgage Insurance Company of North Carolina
United Guaranty Partners Insurance Company
United Guaranty Residential Insurance Company
United Guaranty Commercial Insurance Company of North Carolina
United Guaranty Credit Insurance Company
United Guaranty Mortgage Indemnity Company
United Guaranty Residential Insurance Company of North Carolina
United Guaranty Services, Inc.
21
ANNEX C
Affiliates of Argo Group
The Argo Foundation
PXRE Capital Statutory Trust II
PXRE Capital Statutory Trust V
PXRE Capital Trust VI
Argo International Holdings AG
Argonaut Services GmbH
Argo Re, Ltd.
Argo Irish Holdings I, Ltd.
Argo Irish Holdings II
Argo Brasil Participacões Ltd.
Argo Re Escritório de Representação no Brasil Ltda.
PXRE Reinsurance (Barbados), Ltd.
Mid Atlantic Risk Systems, Ltd.
Argo Re DIFC, Ltd.
Argo International Holdings, Ltd.
Argo Underwriting Agency, Ltd.
Argo Management Services, Ltd.
Argo Management Holdings, Ltd.
Argo Managing Agency, Ltd.
Argo Direct, Ltd.
Argo (No. 604), Ltd.
Argo (No. 616), Ltd.
Argo (No. 607), Ltd.
Argo (No. 617), Ltd.
Argo (No. 703), Ltd.
Argo (No. 704), Ltd.
Argo (Alpha), Ltd.
Argo (Beta), Ltd.
Argo (Chi), Ltd.
Argo (Delta), Ltd.
Argo (Epsilon), Ltd.
ArgoGlobal Underwriting Asia Pacific Pte Ltd.
ArgoGlobal Holdings (Malta) Ltd
ArgoGlobal SE
Argo Financial Holding, Ltd. (Ireland)
Argo Solutions, SA
22
Argo Financial Holding (Brazil) Limited
Argo Seguras Brasil, SA
Argo Group US, Inc.
Argonaut Group Statutory Trust
Argonaut Group Statutory Trust III
Argonaut Group Statutory Trust IV
Argonaut Group Statutory Trust V
Argonaut Group Statutory Trust VI
Argonaut Group Statutory Trust VII
Argonaut Group Statutory Trust VIII
Argonaut Group Statutory Trust IX
Argonaut Group Statutory Trust X
Argonaut Management Services, Inc.
Argus Reinsurance Intermediaries, Inc.
Argo Group Fund to Secure the Future
Alteris, Inc
Sonoma Risk Management, LLC
John Sutak Insurance Brokers, Inc.
Trident Insurance Services, LLC
Alteris Insurance Services, Inc.
Canterbury Claims Services, Inc.
Colony Management Services, Inc.
Colony Agency Services, Inc.
Argonaut Claims Management, LLC
Argonaut Claims Services, Ltd.
Colony Insurance Company
Colony Specialty Insurance Company
Colony National Insurance Company
Argonaut Insurance Company
Argonaut-Midwest Insurance Company
Argonaut-Southwest Insurance Company
Argonaut Great Central Insurance Company
Insight Insurance Services, Inc.
Select Markets Insurance Company
Argonaut Limited Risk Insurance Company
Central Insurance Management, Inc.
Grocers Insurance Agency, Inc.
AGI Properties, Inc.
Rockwood Casualty Insurance Company
23
Somerset Casualty Insurance Company
Coal Operators Indemnity Company
ARIS Title Insurance Corporation
24
ANNEX D
Affiliates of Hartford Financial Services Group, Inc.
Hartford Accident and Indemnity Company
Hartford Casualty Insurance Company
Hartford Fire Insurance Company
Hartford Insurance Company of Illinois
Hartford Insurance Company of the Midwest
Hartford Insurance Company of the Southeast
Hartford Lloyd’s Insurance Company
Hartford Underwriters Insurance Company
Nutmeg Insurance Company
Omni Indemnity Company
Omni Insurance Company
Pacific Insurance Company, Ltd.
Property and Casualty Insurance Company of Hartford
Trumbull Insurance Company
Twin City Fire Insurance Company
The Hartford International Financial Services Group, LLC. (U.S.)
Hartford International Mangement Services Company, LLC (U.S.)
Hartford Life Insurance K.K. (Japan)
Hartford Life International, Ltd. (U.S.)
Hartford Management, Ltd. (Bermuda)
Heritage Reinsurance Company, Ltd. (Bermuda)
Icatu Hartford Capitalizaçao, S.A. (Brazil)
New Ocean Insurance Company, Ltd. (Bermuda)
Hartford Investments Canada Corp. (Canada)
Hartford Life and Accident Insurance Company
Hartford Life and Annuity Insurance Company
Hartford Life Insurance Company
Hartford International Life Reassurance Corporation
The Hartford Mutual Funds, Inc.
PLANCO Financial Services, Inc.
Woodbury Financial Services, Inc.
HartRe Company, LLC
Hartford Investment Financial Services, LLC
Hartford Investment Management Company
Hartford Investment Services, Inc.
1st Ag Choice, Inc.
25
Business Management Group, Inc.
Hartford - Comprehensive Employee Benefit
Service Company
Hartford Risk Management, Inc.
Horizon Management Group, LLC
Specialty Risk Services, Inc.
Trumbull Services, LLC
26
ANNEX E
Affiliates of Enstar Group Limited
Cumberland Holdings Limited
Enstar Australia Holdings Pty Limited
Enstar Australia Limited
Cranmore (Australia) Pty Limited
AG Australia Holdings Limited
Gordian Runoff Limited
Shelly Bay Holdings Limited
Harrington Sound Limited
Enstar Limited
Enstar (EU) Holdings Limited
Enstar (EU) Limited
Cranmore (UK) Limited
Enstar (EU) Finance Limited
Cranmore (Bermuda) Limited
Cranmore (Asia) Limited
Cranmore (Asia) Pte Limited
Enstar Brokers Limited
Castlewood Limited
Bantry Holdings Ltd.
Blackrock Holdings Ltd.
Kinsale Brokers Limited
Enstar Insurance Management Services Ireland Limited
Enstar Investment Management Limited
Cranmore Insurance & Reinsurance Services Europe Limited
B.H. Acquisition Limited
Brittany Insurance Company Ltd.
Paget Holdings GmbH Limited
Kenmare Holdings Limited
Fitzwilliam Insurance Limited
Revir Limited
River Thames Insurance Company
Hillcot Underwriting Management Limited
Overseas Reinsurance Corporation Limited
Regis Agencies Limited
Hudson Reinsurance Company Limited
Global Legacy Acquisition LP
27
Chatsworth Limited
Harper Holding Sarl
Harper Insurance Limited
Enstar Holdings (US) Inc.
Enstar (US) Inc.
Enstar New York, Inc
Cranmore (US) Inc.
Enstar Investments, Inc.
Sun Gulf Holdings, Inc.
Capital Assurance Services, Inc.
CLIC Holdings, Inc.
PWAC Holdings, Inc.
PW Acquisition Co.
Providence Washington Insurance Company
Clarendon Holdings, Inc.
Clarendon National Insurance Company
Clarendon America Insurance Company
SeaBright Holdings, Inc.
SeaBright Insurance Company
Paladin Managed Care Services, Inc.
Point Sure Insurance Services, Inc.
Sussex Holdings, Inc.
Sussex Insurance Company
Sussex Specialty Insurance Company
Mercantile Indemnity Company Limited
Virginia Holdings Ltd.
Seaton Insurance Company
Cavell Holdings Limited
Courtenay Holdings Ltd
Enstar Acquisitions Limited
Goshawk Insurance Holdings Limited
Goshawk Holdings (Bermuda) Limited
Rosemont Reinsurance Ltd
Goshawk Dedicated Limited
Simcoe Holdings Limited
Electricity Producers Insurance Company (Bermuda) Limited
Royston Holdings Limited
Royston Run-off Ltd
Unionamerica Holdings Limited
28
Unionamerica Acquisition Company Limited
Unionamerica Insurance Company Limited
Rombalds Limited
Comox Holdings Ltd
Bosworth Run-Off Limited
Sundown Holdings Ltd
Oceania Holdings Ltd.
Inter-Ocean Holdings Ltd
Inter-Ocean Reinsurance Company Ltd.
Inter-Ocean Reinsurance (Ireland) Ltd.
Flatts Limited
Marlon Insurance Company Limited
The Copenhagen Reinsurance Company (UK) Limited
Shelbourne Group Limited
SGL No 1 Ltd.
SGL No 3 Ltd.
Shelbourne Syndicate Services Limited
Northshore Holdings Limited
Arden Reinsurance Ltd
Alopuc Limited
29
ANNEX F
Affiliates of TIG Insurance Company
Arbor Memorial Services Inc.
HWIC Asia Fund
105 Adelaide Partnership
H Investments Limited
Thomas Cook (India) Limited
Grivalia Properties Real Estate Investment Company
AgriGroupe Investments LP
Insurance Technology International Inc.
LSA Insurance Services Ltd.
The McLennan Group Insurance Inc.
The McLennan Group Life Insurance Inc.
Zenith Insurance Services Inc.
Northbridge Commercial Insurance Corporation
Cara Operations Limited
Gen5 Networks Ltd.
Causeway Restaurants Ltd.
0792688 B.C. Ltd.
2370040 Ontario Limited
2446502 Ontario Inc.
1762418 Ontario Inc.
2327632 Ontario Inc.
2329649 Ontario Inc.
Milestone’s Restaurants South Inc.
Kelsey’s Neighbourhood Bar & Grill Limited
Kelsey’s Neighbourhood Bar & Grill Inc.
Montana’s Cookhouse Saloon Limited
Montana’s Cookhouse Saloon Inc.
Montana’s Cookhouse (Michigan) Inc.
Montana’s Cookhouse (Tonawanda) Inc.
Montana’s Restaurants Group Inc.
Prime Restaurants of America, Inc.
Prime Pubs of America, Inc.
FKAPRA, LLC
Northbridge Professional Transport
Training Inc.
Federated Insurance Company of Canada
30
Keg Restaurants Ltd.
Keg Restaurants U.S., Inc.
Contact + Insurance Network Ltd.
Les services d’assurance le Carrefour Itee
170 University Partnership
1874616 Ontario Limited
Northbridge Financial Corporation
CRC Reinsurance Limited
Fairfax India Holdings Corporation
FIH Mauritius Investments Ltd.
FIH Private Investments Ltd.
Hamblin Watsa Investment Counsel Ltd.
Faircross Holdings Corporation
Noro Limited
MFXchange Holdings Inc.
MFXchange (Ireland) Limited
MFXchange US, Inc.
MFX Roanoke, Inc.
7948883 Canada Inc.
8810605 Canada Inc.
FFHL Limited Partnership
KSP Holdco Inc.
Kitchen Stuff Plus, Inc.
William Ashley China Corporation
William Ashley Canada Corporation
1865713 Ontario Inc.
Sporting Life Inc.
Tommy & Lefebvre Inc.
I Investments Limited
8653291 Canada Inc.
Pethealth Inc.
VioVet Ltd.
PetCare Insurance Holdings Ltd.
PTZ Insurance Brokers Ltd.
Pethealth Services Inc.
Pethealth Software Solutions Inc.
PTZ Insurance Agency
Pethealth Services (USA) Inc.
31
Pet Protect Limited
Pethealth Services (UK) Ltd.
Animal Dispensaries Limited
1823671 Ontario Limited
Advent Capital (Holdings) Ltd.
7817819 Canada Limited
Polskie Towarzystwo Reasekuracji Spolka Akcyjna
Fairfax Brasil Participagdes Ltda.
Fairfax Brasil Seguros Corporativos S.A.
FIHC Share Option Corp.
FFHIL Group Ltd.
Brit Limited
Brit Insurance Holdings Limited
Brit Insurance (Gibraltar) PCC Limited
Brit Group Finance (Gibraltar) Limited
Brit Group Finance Limited
Brit Group Services Limited
Brit Pension Trustee Limited
Brit Corporate Services Limited
Brit Corporate Secretaries Limited
Brit Insurance Services USA, Inc.
Brit Syndicates Limited
Brit Insurance Services Limited
Brit UW Limited
BGS Services (Bermuda) Limited
Brit Investment Holdings Limited
Brit Insurance Holdings B.V.
Brit Overseas Holdings S.i.r.l.
American Safety Insurance Holdings Ltd.
American Safety UK Limited
Fairfax Holdings Inc.
Fairfax (Barbados) International Corp.
TIG Insurance (Barbados) Limited
Fairfax Capital Private Limited
Mohawk River Insurance SCC Ltd.
Fairfax Middle East Holdings Inc.
Gulf Insurance Company
Petrochem Holding Co. Ltd.
Pakit International Trading
32
FFH Management Services Limited
Wentworth Insurance Company Ltd.
FFi Limited Partnership
Fairbridge Capital (Mauritius) Limited
Fairbridge Investments (Mauritius) Limited
Fairbridge Capital Private Limited
Thomas Cook (Mauritius) Holding Company Limited
Thomas Cook (Mauritius) Operations Co. Ltd.
Thomas Cook (Mauritius) Holidays Ltd.
Thomas Cook (Mauritius) Travel Ltd.
Travel Corporation (India) Limited
TC Visa Services (India) Limited
Thomas Cook Insurance Services (India) Limited
Sterling Holiday Resorts (India) Limited
Sterling Holiday Resorts (Kodaikanal) Limited
Sterling Holidays (Ooty) Limited
Thomas Cook Tours Ltd.
India Horizon Marketing Services Ltd.
Thomas Cook Lanka (Private) Limited
Quess Corp. Limited
Aravon Services Private Limited
QUESSCORP HOLDINGS PTE. LTD.
Quess Corp (USA) Inc.
Brainhunter Systems Ltd.
Mindwire Systems Ltd.
Brainhunter Companies, LLC
Brainhunter Companies Canada Inc.
Magne IKYA Infotech, Inc.
CoAchieve Solutions Private Limited
IKYA Business Services Pvt. Ltd.
MFX Infotech Private Limited
Fairfax Asia Limited
Union Assurance General Limited
FAL Corporation
ICICI Lombard General Insurance Company Limited
ANT Success Company Limited
Falcon Insurance Public Company Limited
First Capital Insurance Limited
Prime Underwriting Managers Pte. Ltd.
33
Singapore Reinsurance Corporation Limited
Falcon Insurance Company (Hong Kong) Ltd.
Falcon (1998) Company Limited
The Pacific Insurance Berhad
PT. Fairfax Insurance Indonesia
Colonnade Finance S.i.r.l.
Praktiker Hellas Commercial Societe
Anonyme
Stonebridge Holding S.i.r.l.
Stonebridge Re S.A.
TIG Bermuda Ltd.
Fairfax Luxembourg Holdings S.i.r.l.
RiverStone Holdings Limited
RiverStone Corporate Capital Limited
RiverStone Corporate Capital 2 Limited
RiverStone Managing Agency Limited
RiverStone Management Limited
Sphere Drake Leasing Limited
Sphere Drake Acquisitions (U.K.) Limited
RiverStone Insurance Limited
RiverStone Insurance (UK) Limited
Fairfax (US) Inc.
FMAH, LLC
Crum & Forster Holdings Corp.
United States Fire Insurance Company
Hartville Group, Inc.
Fairmont Specialty Insurance Agency
Wag’N Pet Club, Inc.
Crum & Forster Specialty Insurance Company
TRG Holding Corporation
Fairmont Specialty Insurance Managers, Inc.
Zenith National Insurance Corp.
American Underwriters Insurance Company
International Specialty, Inc.
Environmental Insurance Agency, Inc.
The Redwoods Group, Inc.
The North River Insurance Company
Seneca Insurance Company, Inc.
MTAW Insurance Company
34
Seneca Risk Services, Inc.
Seneca Specialty Insurance Company
Excelsior Claims Administrators, Inc.
Crum and Forster Insurance Company
Crum & Forster Indemnity Company
First Mercury Financial Corporation
First Mercury Insurance Company
First Mercury Emerald Insurance Services, Inc.
CoverX Corporation
FMR Real Estate LLC
RiverStone Group LLC
RiverStone Resources LLC
RiverStone Claims Management LLC
Zenith Insurance Company
ZNAT Insurance Company
Zenith of Nevada, Inc.
1390 Main Street LLC
Zenith Insurance Management Services, Inc.
Zenith Development Corp.
Cunningham Lindsey Claims Management, Inc.
RSKCO Services, Inc.
Fairfax Financial (US) LLC
American Safety Holdings II Corporation
American Safety Administrative Services, Inc.
American Safety Insurance Services, Inc.
American Safety Claims Services, Inc.
Bluestone Agency, Inc.
Bluestone Surety, Ltd.
TIG Holdings, Inc.
TIG Holdings 4, Inc.
Commonwealth Insurance Company of America
General Fidelity Insurance Company
American Safety Holdings Corp.
American Safety Casualty Insurance Company
American Safety Indemnity Company
Resolution Group Reinsurance (Barbados) Limited
Clearwater Insurance Company
Clearwater Insurance Trust I
The Resolution Group, Inc.
35
Resolution Reinsurance Services Corporation
St. John’s Insurance Company Limited
Odyssey US Holdings Inc.
Odyssey Re Holdings Corp.
Odyssey Reinsurance Company
Clearwater Select Insurance Company
Hudson Insurance Company
Hudson Crop Insurance Services, Inc.
Napa River Insurance Services, Inc.
Hudson Specialty Insurance Company
Hudson Excess Insurance Company
Newline Holdings UK Limited
Newline Underwriting Management Limited
Newline Corporate Name Limited
Newline Underwriting Limited
Newline Asia Services Pte. Ltd.
Newline Insurance Company Limited
Newline Australia Insurance Pty. Ltd.
Newline Malaysia Limited
Odyssey Holdings Latin America, Inc.
Odyssey Reinsurance Company Escrit6rio de
Representag Rono Brasil Ltda.
Odyssey Services, SA de CV
O.R.E Holdings Limited
Cheran Enterprises Private Limited
Cherraan Propertiees Limited
Vasantha Mills Limited
36
ANNEX G
Parents, Subsidiaries, and Affiliates of
The Travelers Casualty and Surety Company
350 Market Street, LLC
8527512 Canada Inc.
8527512 Canada Inc.
American Equity Insurance Company
American Equity Specialty Insurance Company
American Marine Management Services, Inc.
Aprilgrange Limited
Arch Street North LLC
Arrowhead Company, LLC
Auto Hartford Investments, LLC
Bayhill Restaurant II Associates
Black Mountain Ranch Limited Partnership
BMR Sports Properties, Inc.
Cadet Limited, LLC
Camperdown Corporation
Commercial Guaranty Insurance Company
Constitution Plaza, Inc.
Constitution State Services LLC
Crystal Brook, LLC
Discover Property & Casualty Insurance Company
Discover Specialty Insurance Company
Durham Holding, LLC
Eastern Asset, LLC
English Turn Fidelity Realty, Inc.
English Turn LLC
English Turn Realty Management, Inc.
F&G U.K. Underwriters Limited
Farmington Casualty Company
Fidelity and Guaranty Insurance Company
Fidelity and Guaranty Insurance Underwriters, Inc.
Fidelity English Turn Club LLC
First Floridian Auto and Home Insurance Company
Fog City Fund, LLC
Gulf Underwriters Insurance Company
J. Malucelli Controle de Riscos, Ltda.
37
J. Malucelli Latam, S.A.
J. Malucelli Participacoes em Seguros e Resseguros S.A.
J. Malucelli Ressegurador S.A.
J. Malucelli Seguradora S.A.
J. Malucelli Seguros S.A.
Jupiter Holdings, Inc.
Laurel Village Fidelity Realty, Inc.
Laurel Village I Limited Partnership
Laurel Village II Limited Partnership
Laurel Village III Limited Partnership
Laurel Village IV Limited Partnership
Laurel Village Joint Venture Partnership
Laurel Village Swinford Limited Partnership
Laurel Village Tower A Limited Partnership
Laurel Village Tower B Limited Partnership
Laurel Village Tower C Limited Partnership
Lone Rock Timber Investments I, LLC
Lone Rock Timber Investments II, LLC
MMI Capital Trust I
Northbrook Holdings, Inc.
Northfield Insurance Company
Northland Casualty Company
Northland Insurance Company
Oregon Evergreen Investor I, LLC
Phoenix UK Investments LLC
Promenade Partners, LLC
Redstart, LLC
Select Insurance Company
SPC Insurance Agency, Inc.
St. Paul Fire and Casualty Insurance Company
St. Paul Fire and Marino Insurance Company
St. Paul Guardian Insurance Company
St. Paul London Properties, Inc.
St. Paul Mercury Insurance Company
St. Paul Protective Insurance Company
St. Paul Surety Europe Limited
St. Paul Surplus Lines Insurance Company
Standard Fire Properties, LLC
Standard Fire UK Investments, LLC
38
Sutton Holdco, LLC
Symmetry Growth Capital II, LLC
TCI Global Services, Inc.
The Automobile Insurance Company of Hartford, Connecticut
The Charter Oak Fire Insurance Company
The Dominion of Canada General Insurance Company
The Phoenix Insurance Company
The Premier Insurance Company of Massachusetts
The Standard Fire Insurance Company
The Travelers Casualty Company
The Travelers Companies, Inc.
The Travelers Home and Marine Insurance Company
The Travelers Indemnity Company
The Travelers Indemnity Company of America
The Travelers Indemnity Company of Connecticut
The Travelers Lloyds Insurance Company
Tiercel, LLC
TINDY Foreign. Inc.
TPC Investments Inc.
TPC UK Investments LLC
TravCo Insurance Company
Travelers (Bermuda) Limited
Travelers Asia Pte. Ltd.
Travelers Brazil Acquisition LLC
Travelers Brazil Holding, LLC
Travelers Casualty and Surety Company
Travelers Casualty and Surety Company of America
Travelers Casualty and Surety Company of Europe Limited
Travelers Casualty Company of Connecticut
Travelers Casualty Insurance Company of America
Travelers Casualty UK Investments LLC
Travelers Commercial Casualty Company
Travelers Commercial Insurance Company
Travelers Constitution State Insurance Company
Travelers Corporate Trustee Ltd.
Travelers Distribution Alliance, Inc.
Travelers Excess and Surplus Lines Company
Travelers Global, Inc.
Travelers Indemnity U.K. Investments LLC
39
Travelers Insurance Company Limited
Travelers Insurance Company of Canada
Travelers Insurance Group Holdings Inc.
Travelers Lloyds Management Company
Travelers Lloyds of Texas Insurance Company
Travelers London Limited
Travelers Management Limited
Travelers Marine, LLC
Travelers MGA, Inc.
Travelers Personal Insurance Company
Travelers Personal Security Insurance Company
Travelers Professional Risks Limited
Travelers Property Casualty Company of America
Travelers Property Casualty Corp.
Travelers Property Casualty Insurance Company
Travelers Real Estate, LLC
Travelers Special Services Limited
Travelers Syndicate Management Limited
Travelers Texas MGA, Inc.
Travelers TLD, LLC
Travelers Underwriting Agency Limited
United States Fidelity and Guaranty Company
Upper Lake Growth Capital, LLC
USF&G Capital I
USF&G Capital III
USF&G Retail Associates GP, Inc.
USF&G/Fidelity Retail Associates Limited Partnership
USF&G/Fidelity Retail Associates Limited Partnership
Vesbridge Partners, LP
Windamere II, LLC
Windamere III, LLC
Windamere, LLC
Yonkers Financing Corp.
40
ANNEX H
Affiliates of XL Group plc
Cumberland Holdings Limited
XL Group plc
Green Holdings Limited
XLIT Ltd.
XL Company Switzerland LLC
EXEL Holdings Limited
X.L. Property Holdings Limited
XL Insurance (Bermuda) Ltd
Mid Ocean Holdings Ltd.
XL London Market Group Ltd
Dornoch Limited
XL London Market Ltd- Syndicate 1209
XL Re Ltd
ECS Reinsurance Company Inc.
Fundamental Insurance Investments Ltd.
XL Underwriting Managers Ltd.
New Ocean Capital Management Limited
New Ocean Market Value Cat Fund Ltd.
New Ocean Focus Cat Fund Ltd.
Vector Reinsurance Ltd.
XL Re Europe SE
XL Insurance (Gibraltar) Limited
XL Re Latin America Ltd
XL Latin America Investments Ltd
XL Resseguros Brasil S.A.
XL Re Latin America (Argentina SA)
XL Re Latin America Ltd Escritório de Representaçăo no Brasil Ltda
XL (Brazil) Holdings Ltda
XL Services (Bermuda) Ltd
XL Life Ltd
Reeve Court General Partner Limited
Reeve Court 4 Limited Partnership
Reeve Court 6 Limited Partnership
XL Gracechurch Limited
XL Insurance (UK) Holdings Limited
XL Insurance Argentina S.A. Compañia de Seguros
41
XL Services UK Limited
XL Insurance Company SE
XL Insurance (China) Company Ltd
XL Seguros Brasil S.A.
XL Holdings Proprietary Limited
XL AB (PTY) Ltd
XL Financial Holdings (Ireland) Limited
XL Finance (Ireland) Limited
XL Services Canada Ltd.
X.L. America, Inc.
XL Financial Solutions, Inc.
XLA Garrison L.P.
XL Reinsurance America Inc.
Greenwich Insurance Company
Global Asset Protection Services, LLC
Global Asset Protection Services Company Limited
Global Asset Protection Services Consultancy (Beijing) Company Limited
XL Insurance America, Inc.
XL Select Insurance Company
XL Insurance Company of New York, Inc.
XL Group Investments LLC
XL Group Investments Ltd
XL Specialty Insurance Company
Indian Harbor Insurance Company
Global Ag Insurance Services, LLC
XL Global, Inc.
X.L. Global Services, Inc.
Eagleview Insurance Brokerage Services, LLC
XL Life and Annuity Holding Company
XL Life Insurance and Annuity Company
ECS, Inc. (In Liquidation)
XL Investments Ltd
XL Capital Products Ltd
Blunt Underwriting Services Limited
XL Insurance Guernsey Limited
Garrison Investments Inc.
XL (SPECIALTY) S.a.r.l.
XL (WESTERN EUROPE) S.a.r.l.
XL Swiss Holdings Ltd
42
XL Re Latin America (Argentina SA)
XL Insurance Switzerland Ltd
XL Services Switzerland Ltd
XL India Business Services Private Limited
XL Seguros Mexico SA de CV