to AON Natural Resources Risk Services (AON)

which provided information in relation to its pipeline leaks in Hartford. According to the

letter, the EPA ordered many of the other entities affiliated with the contamination to take

emergency response actions which commenced "as early as the Fall of 2003." Sinclair

was added as a participant in the cleanup as of November 18, 2005. At the time of the

letter, it appears there were two property damage lawsuits on file naming Sinclair as a

defendant, one which was styled as a class action and one that was filed by a group of

individuals, but not in class action form. However, from the letter itself, one is not able

to discern to which specific lawsuits the letter is referring.

¶ 21   On January 11, 2006, AON, on behalfwith the notice terms of each policy." The letter states that a

compact disc is enclosed containing copies of the complaints in Sparks, Bedwell, and

Abert, as well as the EPA administrative order and a document explaining the status of

the litigation in Village of Hartford. According to the letter, a review of these documents

shows that Sinclair has been named as a defendant in lawsuits by owners of property in

Hartford who allege Sinclair contributed to cause a toxic plume which allegedly consists

of an estimated four million gallons of petroleum and/or petroleum byproducts which lie

beneath their property, and that said plume has caused property damage and bodily injury

to persons living in Hartford.

¶ 22   The remaining correspondence between the parties that is contained in the record

took place between 2008 and 2010,