ROWAN / LEGAL WORKSPACEMatters   Documents   Correspondence

WITHOUT PREJUDICE SAVE AS TO COSTS

28 September 2026

Dear Counsel,

Proposed settlement of Matter LT-884

Our client offers to resolve all claims and counterclaims in the above matter on the following terms.

Settlement payment: $18,500,000

Payment timing: Five business days after execution

Release: Mutual release of all known and unknown claims

Confidentiality: Standard mutual confidentiality

Offer expiry: 17:00 on 30 September 2026

This offer is capable of acceptance by countersigned copy. We look forward to your response.

Rowan & Finch LLP