EXHIBIT A

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UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF KENTUCKY 

LOUISVILLE DIVISION

LEXINGTON INSURANCE COMPANY, 

 Plaintiff, 

v. 

THE AMBASSADOR GROUP, LLC d/b/a 

AMBASSADOR CAPTIVE SOLUTIONS; 

GAGLIARDI INSURANCE SERVICES, INC.; 

GOLDENSTAR SPECIALTY INSURANCE, 

LLC; PERFORMANCE INSURANCE 

COMPANY SPC on behalf of GOLDENSTAR 

HOLDINGS COMPANY SP and on behalf of 

SMART INSURE SP; and BRANDON WHITE, 

 Defendants. 

 

Case No. ________________ 

DECLARATION OF JOSEPH DAVINA 

IN SUPPORT OF PLAINTIFF’S MOTION 

FOR A TEMPORARY RESTRAINING ORDER 

AND PRELIMINARY INJUNCTION 

I, Joseph Davina, declare as follows: 

1. I am currently the Vice President of AIG Captive Solutions, a division of American 

International Group, Inc. (“AIG”), a publicly traded insurance holding company. AIG directly or 

indirectly owns a number of insurance companies, including Lexington Insurance Company 

(“Lexington”). I have been employed by AIG subsidiary companies since 2006. Since 2018, I 

have had managerial oversight of certain of AIG’s group captive reinsurance programs. I submit 

this declaration, of my own personal knowledge and based upon AIG’s books and records, in 

support of Lexington’s motion for a temporary restraining order and preliminary injunction. 

3:20-cv-330-JRW

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2. As set forth below, AIG and Lexington are the victims of an ongoing scheme 

involving (a) the sale of numerous counterfeit insurance policies to unsuspecting consumers who 

have been defrauded, (b) the forgery of my signature on a facultative reinsurance agreement, and 

(c) the infringement of Lexington’s registered trademark for an unlawful and fraudulent purpose. 

Lexington seeks injunctive relief enjoining the parties responsible for this unlawful conduct from 

continuing their scheme and further harming Lexington and the public. 

A. “Captive Reinsurance” 

3. The Defendants’ fraud scheme involves an area of insurance known as “captive 

reinsurance.” Captive reinsurance arrangements are complex, requiring specialized expertise and 

significant underwriting capacity. 

4. In the type of captive reinsurance program at issue in this lawsuit, an insurance 

broker or other company (the “Broker/Owner”) forms and owns a captive reinsurance company 

(the “Captive”). The Captive is ultimately responsible to pay some or all of the losses on policies 

sold by the Broker/Owner. 

5. Because Captives are not licensed direct insurers, the Broker/Owner seeks to 

engage a commercial insurer (such as Lexington, AIG’s subsidiary surplus lines insurer) (the 

“Issuing Carrier”) to issue the insurance policies to be sold and then reinsure such policies to the 

Captive. 

6. The apportionment of risk between the Issuing Carrier and the Captive is typically 

documented in a reinsurance agreement through which the Captive (as the reinsurer) agrees to 

reimburse the Issuing Carrier for some or all of the losses incurred under the policies. 

7. Typically, the Captive pays the Issuing Carrier a “fee” or “commission payment” 

for acting as the Issuing Carrier. In addition, the Captive provides collateral to the Issuing Carrier 

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to secure, among other things, the Captive’s obligation to reimburse the Issuing Carrier for any 

reinsured losses that the Issuing Carrier incurs. 

8. These multi-party transactions are often facilitated by a “captive intermediary” – 

an entity that assists a Broker/Owner in developing an actuarial model and business plan, forming 

the Captive, and—most importantly—identifying and engaging an Issuing Carrier to issue the 

policies to be sold by the Broker/Owner and reinsured to the Captive. 

9. AIG is often approached by captive intermediaries soliciting an AIG-affiliated 

insurer to act as an Issuing Carrier on captive reinsurance deals. Through my role at AIG, I 

routinely interact with captive intermediaries, who seek to develop business relationships with 

AIG. 

B. Brandon White, Ambassador, and the Gagliardi Insurance Program 

10. I first became acquainted with Brandon White, the founder and a principal of a 

captive intermediary, The Ambassador Group, LLC (“Ambassador”) in early 2018. 

11. Mr. White initially reached out to my supervisor, Mark Benz, to solicit AIG’s 

involvement in a number of captive reinsurance deals. Mr. Benz instructed me to address 

Ambassador’s proposals. I then had several telephone conversations with Mr. White in early 2018 

about potential captive arrangements in Ambassador’s portfolio for which an AIG-affiliated 

insurer could act as the Issuing Carrier. 

12. During my calls with Mr. White, he explained that QBE Insurance Group, Ltd. 

(“QBE”) was the carrier for most captive arrangements in Ambassador’s portfolio, but that 

Ambassador was looking for a change. Mr. White told me that he was interested in moving 

Ambassador’s entire captive portfolio to AIG. 

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13. On June 18, 2018, Mr. Benz and I visited Mr. White and his Ambassador 

colleagues, Aaron Lubbers and Darin Smith, in Louisville, Kentucky, where Ambassador is based. 

During our visit, Ambassador made a presentation to me and Mr. Benz regarding Ambassador’s 

business model and captive portfolio. 

14. Following our visit, we agreed to have an AIG-affiliated insurer (not Lexington) 

act as the Issuing Carrier for two different group captive programs in Ambassador’s portfolio. 

Both programs successfully launched in 2018 and, from AIG’s perspective, operated smoothly. 

Throughout 2018 and 2019, Mr. Benz and I regularly communicated with Mr. White and his 

Ambassador colleagues regarding these two group captive programs, including two additional inperson meetings with Mr. White. 

15. In August 2018, Mr. White solicited me to have an AIG-affiliated insurer act as the 

Issuing Carrier for a different captive program in Ambassador’s portfolio—a captive reinsurance 

program involving policies that would be sold by a broker, Gagliardi Insurance Services, Inc. 

(“Gagliardi Insurance”), and reinsured to Goldenstar Holdings Company SP (“Goldenstar 

Holdings”), which is a segregated cell of Ambassador’s Cayman Island captive reinsurer, 

Performance Insurance Company SPC (“Performance”) (the “Gagliardi Insurance Program”). 

16. Mr. White provided me with the submission documents for the proposed 

reinsurance program, including unaudited financial statements and an actuarial analysis. In short, 

the program contemplated a captive reinsurance arrangement in which Gagliardi Insurance, as the 

Owner/Broker, would sell policies issued by an AIG insurer, which in turn would be reinsured by 

the segregated cell of Performance, Goldenstar Holdings, which is ultimately owned by Gagliardi 

Insurance. 

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17. The Gagliardi Insurance Program that Mr. White and Ambassador pitched to AIG 

contemplated the execution of a Managing General Agent Agreement (“MGA Agreement”) or 

Program Administration Agreement (“PA Agreement”) under which Gagliardi Insurance would 

have the “power of the pen”—a term of art meaning that Gagliardi Insurance would have the ability 

to issue policies in the name of the AIG-affiliated insurance company serving as the Issuing 

Carrier. 

18. While the Issuing Carrier typically directly issues the policies, for some programs 

the Broker/Owner has the authority pursuant to an MGA or PA Agreement to issue policies in the 

name of the Issuing Carrier, subject to specific guidelines set forth in the MGA or PA Agreement. 

19. Mr. White explained to me that the Gagliardi Insurance Program would provide 

accident and health (“A&H”) coverage for various youth and professional sports teams and 

leagues. Mr. White explained to me that the Gagliardi Insurance Program had launched in March 

2018 with QBE as the Issuing Carrier but that Gagliardi quickly became unhappy with QBE and 

wanted a new Issuing Carrier. 

20. Mr. White also informed me that the designated third-party administrator (“TPA”) 

for the Gagliardi Insurance Program was Health Special Risk, Inc. (“HSR”). A TPA adjusts and 

administers insurance claims on behalf of a carrier. AIG maintains a list of approved TPAs and 

has a business division that vets, approves, and monitors TPAs. 

21. Because HSR was not on AIG’s list of approved TPAs, I informed Mr. White at 

the outset that, if AIG agreed to participate in the Gagliardi Insurance Program, HSR would need 

to undergo AIG’s rigorous approval and onboarding process, which could take months. 

22. Because this type of transaction is not the type typically written by my business 

unit, the submission documents were forwarded to others at AIG who would be responsible for 

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approving or declining AIG’s participation in the Gagliardi Insurance Program. Among others, 

the A&H underwriting team received the submission documents for review because the Gagliardi 

Insurance Program was an A&H program. 

C. AIG’s Declination of the Gagliardi Insurance Program 

23. After reviewing the submission materials, the A&H underwriting team quickly 

reported that it was not interested in the program. 

24. Accordingly, in or around October 2018, I informed Mr. White that AIG’s affiliated 

companies were not interested in the Gagliardi Insurance Program. After I communicated AIG’s 

affiliated companies’ declination to Mr. White, Mr. White asked me on several more occasions 

over the following months to revisit the opportunity. Each time, I told Mr. White that AIG was 

not interested in having any of its affiliates participate as the Issuing Carrier. 

25. I never signed any agreement in connection with the Gagliardi Insurance Program. 

I never authorized anyone to sign an agreement on my behalf in connection with the Gagliardi 

Insurance Program. As set forth above, AIG’s affiliated companies declined the opportunity to act 

as the Issuing Carrier for this program. 

D. HSR Contacts Me as if AIG Was the Issuing Carrier, and Mr. White Tells 

Me That It Was a Simple Mistake 

26. In December 2018, I received an email from Tom Lenihan at HSR requesting to 

move forward with the TPA agreement for the Gagliardi Insurance Program, stating that the deal 

went into effect with Lexington on July 1, 2018. 

27. I immediately questioned Mr. White (by email) about Mr. Lenihan’s email because 

neither Lexington nor AIG had agreed to act as the program’s Issuing Carrier, so Mr. Lenihan’s 

email to me made no sense. 

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28. Mr. White responded by asking me not to contact HSR and explaining that it was 

just a miscommunication “on the client side.” That is, Mr. White was telling me that HSR simply 

made a mistake and contacted the wrong Issuing Carrier. A copy of this email chain is attached 

hereto as Exhibit 1. 

E. HSR Sends Me an Email That I Purportedly Sent but Did Not Send 

29. A week later, I received another email from Mr. Lenihan, forwarding to me an email 

that he received from Mr. White. Mr. White’s email to Mr. Lenihan, in turn, forwarded an email 

that appeared to be from my AIG email account to Mr. White and Mr. Smith (one of Mr. White’s 

colleagues at Ambassador). But I did not write or send that email. 

30. The fabricated email purportedly coming from my email account ostensibly granted 

HSR “conditional approval” to manage claims until AIG formally approved HSR. Mr. White 

forwarded the fabricated email to HSR, which then forwarded it to me. 

31. Again, I immediately questioned Ambassador, and emailed Mr. White and Mr. 

Smith. Mr. Smith denied that he or Mr. White had any knowledge of the fabrication and vowed 

to get to the bottom of it. A true and accurate copy of this email chain is attached as Exhibit 2. 

32. Shortly thereafter, in January 2019, I had a meeting with Mr. White at AIG’s office 

in New York to discuss, among other things, the two group captive arrangements for which another 

AIG company (not Lexington) was acting as the Issuing Carrier. During that meeting, I again 

inquired about the fabricated email purportedly sent from my email account. Mr. White assured 

me that no one from Ambassador was involved in the fabrication and that Ambassador would 

never engage in such conduct. 

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F. Atlas Seeks Information from Me Concerning Collateral for the Gagliardi 

Insurance Program 

33. In February 2019, Beth Biega from Atlas Insurance Management (“Atlas”), the 

captive manager for Goldenstar Holdings, emailed me seeking language for a letter of credit, which 

ostensibly was to serve as Lexington’s collateral from Goldenstar Holdings for the Gagliardi 

Insurance Program. 

34. I sent Atlas’ email to Mr. White, asking him why I was continuing to receive 

correspondence about a program AIG’s affiliated companies had declined. Mr. White apologized 

that AIG kept “getting tagged” and passed it off as a “miscommunication on the clients [sic] part 

and messaging from the captive manager.” A true and accurate copy of this email chain is attached 

as Exhibit 3. 

G. The Unsigned Reinsurance Agreement 

35. Also in February 2019, Adrian Marshall from Helmsman Management Services 

(“Helmsman”) emailed me introducing Helmsman as the new TPA for the Gagliardi Insurance 

Program. 

36. When I replied to Mr. Marshall that no AIG-affiliated insurance carrier was the 

Issuing Carrier for the Gagliardi Insurance Program, he provided me with an unsigned draft of a 

facultative reinsurance agreement between Goldenstar Holdings and Lexington. 

37. I forwarded the draft agreement to Mr. White to find out what was going on. Mr. 

White responded that it was a draft based on a template that had been prepared earlier in the year 

when Mr. White asked AIG to participate in the Gagliardi Insurance Program, but that it was “not 

in effect, obviously.” A true and accurate copy of this email chain is attached as Exhibit 4. 

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H. The Forged Reinsurance Agreement

38. On November 19, 2019, Ms. Biega from Atlas emailed me (copying Mr. White) a 

“fully executed Facultative Reinsurance Agreement” with a signature purporting to be mine on 

Lexington’s behalf dated August 17, 2018 (the “Forged Reinsurance Agreement”). A true and 

accurate copy of the Forged Reinsurance Agreement that Ms. Biega emailed to me is attached as 

Exhibit 5. 

39. The signature on the Forged Reinsurance Agreement is not mine. I never signed 

any agreement with Goldenstar Holdings and never authorized anyone to do so on my behalf. 

Someone forged my signature on that document. 

40. In the body of her email to me, Ms. Biega requested wiring instructions for 

Lexington’s “commission payment.” In other words, Ms. Biega sought details on how to send 

Lexington its commission payment for acting as the Issuing Carrier for the Gagliardi Insurance 

Program. 

41. I responded by telling Ms. Biega that the reinsurance agreement was forged and 

demanded that Mr. White explain the forgery. 

I. Mr. White Admits That the Agreement Was Forged 

42. Mr. White responded by apologizing for the “misrepresentation” and advising that 

Ambassador was “working to track down the genesis of this document.” Mr. White further assured 

me that the forged contract “did not come from Ambassador in any way.” He promised to “get to 

the bottom” of the forgery. A true and accurate copy of this email chain is attached as Exhibit 6. 

J. The Counterfeit Insurance Policies 

43. Subsequently, on March 3, 2020, AIG’s outside counsel, Adam Kaiser, provided 

me with eleven insurance policies (which I understood were given to him by Ambassador’s 

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counsel) issued in connection with the Gagliardi Insurance Program. These are attached to the 

Complaint as Exhibits I-S (the “Counterfeit Insurance Policies”). Each of these policies was issued 

in the name of Lexington. 

44. Lexington did not authorize Gagliardi Insurance or anyone else to issue these 

policies in Lexington’s name. What’s more, Lexington was not aware of the existence of the 

Counterfeit Insurance Policies until March 3, 2020. 

45. To be clear, no AIG-affiliated insurance company ever agreed to act as the Issuing 

Carrier for the Gagliardi Insurance Program; Lexington never received any commission payment 

or premiums in connection with the Counterfeit Insurance Policies; it never received any collateral 

in connection with the Forged Reinsurance Agreement; it never authorized any TPA to administer 

claims on the Counterfeit Insurance Policies; and it was never even aware of the Counterfeit 

Insurance Policies until March 2020, when it was investigating Ambassador’s fraud in connection 

with the Forged Reinsurance Agreement. 

46. Significantly, captive reinsurance programs are complex, multi-party arrangements 

that take months to analyze and document. These are not “off-the-shelf” products. Before one of 

AIG’s affiliated insurers would agree to act as the Issuing Carrier for a program such as the 

Gagliardi Insurance Program, it would conduct robust diligence involving multiple business units. 

Among other things, it would conduct detailed actuarial, financial and credit analyses; it would 

calculate the required collateral; it would enlist counsel to assist in drafting documents; and it 

would generate and provide the captive intermediary with a quote, and, if the quote is accepted, 

develop and provide a detailed binder setting forth the terms of the AIG affiliate’s engagement. 

This process is multi-step, intensive, and typically takes many months to complete. 

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47. No part of that detailed process occurred with respect to the Gagliardi Insurance 

Program, because, as stated above, AIG’s affiliated companies rejected the opportunity following 

the A&H team’s review of the submission documents. AIG never conducted any actuarial, 

financial or credit analysis of this program, never issued a quote or binder, and never agreed to act 

as the Issuing Carrier on this program. 

48. Furthermore, I did not have power of attorney to execute a reinsurance agreement 

for the type of agreement reflected by the Forged Reinsurance Agreement. What’s more, 

Lexington would not have been the AIG-affiliated insurance company that would have executed 

the reinsurance agreement had AIG decided to act as the Issuing Carrier for the Gagliardi Insurance 

Program. Rather, the reinsurance agreement for A&H policies would have been issued by an 

admitted carrier (not a surplus lines carrier like Lexington). 

49. Hence, not only was my signature on the reinsurance agreement forged, but the 

forgers forged the signature of the wrong AIG executive on behalf of the wrong AIG-affiliated 

insurance company. 

K. Lexington Discovers the Madera Residential Fraud 

50. While investigating the Gagliardi Insurance Program fraud, AIG discovered an 

entirely separate captive reinsurance program through which it appears that Mr. White and 

Ambassador have caused even more counterfeit Lexington policies to be fraudulently issued. 

51. In April 2019, Mr. White pitched a different captive reinsurance program to me 

involving property and personal liability insurance coverage to be issued to residents of properties 

operated by Madera Residential, Ltd. (“Madera Residential”) with Smart Insure SP (“Smart 

Insure”) as the captive reinsurance company (the “Madera Residential Insurance Program”). 

Smart Insure is another segregated cell of Performance, Ambassador’s Cayman captive reinsurer. 

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52. I referred Mr. White to my colleague, Vince Perrotta, to discuss the Madera 

Residential Insurance Program. As with the Gagliardi Insurance Program, AIG declined to provide 

an AIG-affiliated insurer to act as the Issuing Carrier for the Madera Residential Insurance 

Program. 

53. Not only did AIG (or its affiliates) never sign any agreements in connection with 

the Madera Residential Insurance Program but, as with the Gagliardi Insurance Program, AIG 

never even conducted an actuarial or credit analysis on the program and never provided 

Ambassador with a quote. 

54. Nevertheless, Broadspire Services, Inc. (“Broadspire”), a TPA, contacted AIG 

periodically regarding the Madera Residential Insurance Program, even though AIG was not the 

Issuing Carrier for that program. 

55. Ultimately, I was provided with an Evidence of Property Insurance (a certificate of 

insurance) that appears to have been issued in connection with the Madera Residential Insurance 

Program. A true and accurate copy of the Evidence of Property Insurance that I was provided is 

attached as Exhibit T to the Complaint. 

56. The Evidence of Property Insurance purports to reflect an insurance policy with 

Lexington as the insurer. 

57. Lexington did not issue any policies in connection with the Madera Residential 

Insurance Program and has not authorized anyone to issue any policies in Lexington’s name in 

connection with the Madera Residential Insurance Program. AIG declined Ambassador and Mr. 

White’s request to have an AIG-affiliated insurer act as the Issuing Carrier for this program. 

58. The address for Lexington on the Evidence of Property Insurance—3 Beaver Valley 

Road, Wilmington, Delaware—is not an address that Lexington has ever used for insurance 

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Exhibit 1

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From: Brandon White [mailto:brandon.white@ambassadorcaptive.com] 

Sent: Monday, December 03, 2018 11:04 AM 

To: Davina, Joseph 

Cc: Darin Smith 

Subject: Re: HSR - Gagliardi Captive 

Joe, 

This is the guy I left you a voicemail about on Friday evening. I would prefer you don’t call him back until 

we have clarity on what your team can do on the program. There is miscommunication here but it is on 

the client side. I can work through it but need your internal dialogue with Chris first so we know where to 

go from here. 

Thanks Joe! 

Sincerely, 

Brandon M. White, CIC, CRM, CWCA 

Founder/President 

Ambassador Captive Solutions 

9700 Park Plaza Avenue, Suite 201 

Louisville, KY 40241 

502.439.1555 

www.ambassadorcaptive.com 

"Everything should be made as simple as possible, but not simpler." - Roger Sessions, Composer 

Sent from my iPhone 

On Dec 3, 2018, at 10:42 AM, Davina, Joseph <Joseph.Davina@AIG.com> wrote: 

FYI, this isn’t in effect with us. Is there a miscommunication prior to me calling him?

Joseph Davina, Vice President

AIG Risk Management | Group Captives

175 Water Street, 26th Floor, New York, NY 10038 

Direct: (646) 857-1345 | Mobile: (917) 224-3451 

Joseph.Davina@aig.com | www.aig.com

From: Tom Lenihan [mailto:tomlenihan@hsri.com] 

Sent: Monday, December 03, 2018 10:39 AM 

To: Davina, Joseph 

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Cc: Marco Gagliardi 

Subject: HSR - Gagliardi Captive 

Mr. Davina: 

Good morning. I left you a voice message this morning introducing myself. I am the President of Health 

Special Risk, Inc. (HSR) the TPA for the Gagliardi Participant Accident Captive program. 

My contact information is below and I’d appreciate it greatly if we could talk today if at all possible. Best 

is via my cell – (972) 741-6507. 

As you know this program went into effective on 7/1/18 with y’all and we need to move forward on getting 

HSR’s TPA Agreement reactivated with AIG so that we can process and adjust claims that occurred since 

the move from QBE to AIG on July 1. 

I look forward to speak with you at your earliest convenience. 

Best regards, 

Tom Lenihan 

Tom Lenihan 

President

Health Special Risk, Inc. 

HSR Plaza II 

4100 Medical Parkway, Suite 200 

Carrollton, Texas 75007 

Direct: (972) 512-5700 

Cell: (972) 741-6507

TomLenihan@hsri.com

(972) 512-5701 Direct Fax 

(972) 512-5600 Main 

(972) 512-5820 Main Fax 

www.HealthSpecialRisk.com

This message and any attachments are sent for HSR business purposes and may contain confidential 

information intended only for the individual(s) named herein. If you are not the named addressee, please 

do not disseminate, distribute, alter or copy this e-mail. Please notify me immediately if you have received 

this e-mail in error. HSR makes every effort to secure any confidential information but e-mail transmissions 

cannot be guaranteed to be secure or error-free, as information could be intercepted, corrupted, lost, 

destroyed, arrive late or incomplete, or contain viruses. Therefore, neither HSR nor I accept liability for any 

errors or omissions in the contents of this message which may arise during or as a result of e-mail 

transmission. Thank you & have a nice day.

IMPORTANT: Please note that coverage cannot be bound, altered, or cancelled via email without 

confirmation from an authorized representative of Health Special Risk, Inc. CONFIDENTIALITY NOTICE: 

The information contained in this communication, including attachments, is privileged and confidential. 

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3 

prohibited. If you have received this communication in error, please notify us by telephone immediately 

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Exhibit 2

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From: Darin Smith [mailto:darin.smith@ambassadorcaptive.com] 

Sent: Thursday, December 20, 2018 11:03 AM 

To: Davina, Joseph 

Cc: Brandon White 

Subject: Re: Gagliardi Captive 

Joe, 

Good morning and thanks for passing that along. I can assure you this is the first we have seen of this 

and would never act in this capacity. I believe Brandon left you a voicemail already and I am on the road 

to meet a client for lunch. Call me if you get this email soon or let’s aim for this afternoon to talk. 

We’re also at a loss of words and trying to figure out exactly how this occurred and who is responsible. 

Thanks again, 

Darin E. Smith 

Ambassador Captive Solutions 

9700 Park Plaza Avenue, Suite 201

Louisville, KY 40241

502.741.1883

www.ambassadorcaptive.com

darin.smith@ambassadorcaptive.com

Sent from my iPhone. This e-mail, including attachments, may include confidential and/or proprietary 

information, and may be used only by the person or entity to which it is addressed. If the reader of this 

e-mail is not the intended recipient or his or her authorized agent, the reader is hereby notified that any 

dissemination, distribution or copying of this e-mail is prohibited by law. If you have received this e-mail 

in error, please notify the sender by replying to this message and shred and/or delete this information 

immediately. 

On Dec 20, 2018, at 10:43 AM, Davina, Joseph <Joseph.Davina@aig.com> wrote: 

Guys,

This was sent to me. There is an email below from me to Brandon that I never sent. This is a bit 

disturbing to say the least. We need to discuss this as misrepresenting forged emails from me will not be 

tolerated. This is a serious violation and could result in a lot of trouble since I do not have any authority 

to grant this type of approval for A&H, approving TPA’s, fronted deals and backdating.

Can someone explain this to me please because I am at a loss of words on how this is ethical.

Thanks,

Joseph Davina, Vice President

AIG Risk Management | Group Captives

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175 Water Street, 26th Floor, New York, NY 10038 

Direct: (646) 857-1345 | Mobile: (917) 224-3451 

Joseph.Davina@aig.com | www.aig.com

From: Tom Lenihan [mailto:tomlenihan@hsri.com] 

Sent: Tuesday, December 18, 2018 4:28 PM 

To: Davina, Joseph 

Cc: Marco Gagliardi 

Subject: Gagliardi Captive 

Mr. Davina: 

I received a copy of your 12/10/18 email below to Darin Smith at Ambassador Captive giving HSR 

“conditional approval to manage the claims for Goldenstar going back to 7/1/18”. 

We would like to get the TPA Agreement process moving as fast as possible. Can you put me in direct 

touch with the appropriate person(s) at AIG that can make this happen? 

I would greatly appreciate your response as soon as possible. 

Thank you for your assistance. 

Regards, 

Tom 

Tom Lenihan 

President

Health Special Risk, Inc. 

Direct: (972) 512-5700 

Cell: (972) 741-6507 

Fax: (972) 512-5701 

This message and any attachments are sent for HSR business purposes and may contain confidential 

information intended only for the individual(s) named herein. If you are not the named addressee, please 

do not disseminate, distribute, alter or copy this e-mail. Please notify me immediately if you have 

received this e-mail in error. HSR makes every effort to secure any confidential information but e-mail 

transmissions cannot be guaranteed to be secure or error-free, as information could be intercepted, 

corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. Therefore, neither HSR nor I 

accept liability for any errors or omissions in the contents of this message which may arise during or as a 

result of e-mail transmission. Thank you & have a nice day.

From: brandon.white@ambassadorcaptive.com <brandon.white@ambassadorcaptive.com> 

Sent: Monday, December 17, 2018 8:55 AM 

To: Tom Lenihan <tomlenihan@hsri.com> 

Cc: mgagliardi@gsportsinsurance.com

Subject: FWD: RE: Gagliardi Captive 

Tom, 

Per my discussion with Marco, please see the email below that is gives HSRI permission to manage the 

claims until we get the formal agreement in place. I hope this, accompanied by the agreement will allow 

us to move forward on reimbursing claims to QBE. More to come as I am pushing them daily for action 

on the formal agreement. I was waiting to send this in the hopes that they would have sent you an email 

directly and am pushing for this as well. 

Sincerely, 

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3 

Brandon M. White, CIC, CRM, CWCA 

President/Founding Partner 

Ambassador Captive Solutions 

9700 Park Plaza Avenue, Suite 201 

Louisville, KY 40241 

502.439.1555 

www.ambassadorcaptive.com

"Everything should be made as simple as possible, but not simpler." -Roger Sessions, Composer 

--------- Original Message --------- 

Subject: RE: Gagliardi Captive 

From: "Davina, Joseph" <Joseph.Davina@AIG.com> 

Date: 12/10/18 12:03 pm 

To: "Darin Smith" <darin.smith@ambassadorcaptive.com> 

Cc: "Brandon White" <brandon.white@ambassadorcaptive.com> 

Hi Darin,

I will be communicating with HSRI this week that they have our conditional approval to manage the 

claims for Goldenstar going back to 7/1/18 until we get them formally back on our list of approved 

TPAs. We are working to get this done through all of the internal transition items and we have been 

delayed but our agreement is in force.

We are waiting to meet with Chris as we speak. We will circle back shortly.

Thanks,

Joseph Davina, Vice President

AIG Risk Management | Group Captives

175 Water Street, 26th Floor, New York, NY 10038 

Direct: (646) 857-1345 

Joseph.Davina@aig.com | www.aig.com

IMPORTANT: Please note that coverage cannot be bound, altered, or cancelled via email without 

confirmation from an authorized representative of Health Special Risk, Inc. CONFIDENTIALITY NOTICE: 

The information contained in this communication, including attachments, is privileged and confidential. 

It is intended only for the exclusive use of the addressee. If the reader of this message is not the 

intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you 

are hereby notified that any dissemination, distribution, or copying of this communication is strictly 

prohibited. If you have received this communication in error, please notify us by telephone immediately 

at 972-512-5600 or Toll-free at 800-328-1114 or by e-mail at CustomerService@HSRI.com. NOTE: 

Although we have taken steps to ensure that this e-mail and its attachments (if any) are free from any 

virus, the recipient should, in keeping with good computing practice, also check this e-mail and any 

attachments for the presence of viruses. 

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Exhibit 3

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Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 23 of 57
From: Brandon White [mailto:brandon.white@ambassadorcaptive.com] 

Sent: Friday, February 08, 2019 11:53 AM 

To: Davina, Joseph; darin.smith@ambassadorcaptive.com

Subject: Re: Goldenstar Insurance SP 

I am on this, Joe...sorry you keep getting tagged. It is a mix of miscommunication on the clients part and 

messaging from the captive manager. I am here in Cayman this week getting it straightened out on this 

side. 

Sincerely, 

Brandon M. White, CIC, CRM 

Founder/President 

Ambassador Captive Solutions 

9700 Park Plaza Avenue, Suite 201 

Louisville, KY 40241 

502.439.1555 

www.ambassadorcaptive.com

“Simplicity is the ultimate sophistication.” – da Vinci (or) Clare Boothe Luce 

From: "Davina, Joseph" 

Date: Friday, February 8, 2019 at 11:29 AM 

To: Brandon White , "darin.smith@ambassadorcaptive.com" 

Subject: Fwd: Goldenstar Insurance SP 

Hey Guys, 

Hope all is well. Can we figure this out? Does AIG write Goldenstar that I’m not aware of? This is 

Gagliardi which we do not write. We need to figure out why we keep getting asked about this. 

Thanks, 

Joseph Davina, Vice President

AIG Risk Management | Group Captives

175 Water Street, 26th Floor, New York, NY 10038

Direct: (646) 857-1345 | Mobile: (917) 224-3451

Joseph.Davina@aig.com | www.aig.com

Begin forwarded message: 

From: Beth Biega <BBiega@atlascaptives.com> 

Date: February 8, 2019 at 1:27:04 PM GMT-3 

To: "Davina, Joseph" <Joseph.Davina@AIG.com> 

Cc: "Rogers, Brian" <brian.rogers@aig.com>, Brenda Munnelly <bmunnelly@atlascaptives.com> 

Subject: RE: Goldenstar Insurance SP

Hi, 

Case 3:20-cv-00330-BJB-LLK Document 3-2 Filed 05/11/20 Page 23 of 56 PageID #: 548

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2 

Yes, it is Ambassador. Thank you for getting back so quickly. 

Kind regards, 

Beth 

Beth Biega 

Vice President

Tel: +1 345-945-5556 

This email and any files transmitted with it are confidential and intended solely for the use of the 

individual or entity to whom they are addressed. If you have received this email in error please notify the 

sender immediately and delete this e-mail from your system. If you are not the intended recipient you are 

notified that disclosing, copying, distributing or taking any action in reliance on the contents of this 

information is strictly prohibited.

From: Davina, Joseph <Joseph.Davina@AIG.com> 

Sent: Friday, February 08, 2019 11:18 AM 

To: Beth Biega <BBiega@atlascaptives.com> 

Cc: Rogers, Brian <brian.rogers@aig.com>; Brenda Munnelly <bmunnelly@atlascaptives.com> 

Subject: Re: Goldenstar Insurance SP 

Hi Beth, 

Can you advise who the captive intermediary is on this? Is it Ambassador? 

Thanks, 

Joseph Davina, Vice President

AIG Risk Management | Group Captives

175 Water Street, 26th Floor, New York, NY 10038

Direct: (646) 857-1345 | Mobile: (917) 224-3451

Joseph.Davina@aig.com | www.aig.com

On Feb 8, 2019, at 1:13 PM, Beth Biega <BBiega@atlascaptives.com> wrote: 

Good morning Brian & Joe, 

I’m trying to obtain the LOC wording for Goldenstar’s LOC to Lexington, can you please provide the 

required wording from Lexington? If you are not the correct contact for the above Captive please let me 

know who I should be speaking with. 

Kind regards, 

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3 

Beth 

Beth Biega 

Vice President

Whitehall House, 3rd Floor, 238 North Church Street 

PO Box 699, Grand Cayman, KY1-1107, Cayman Islands 

www.atlascaptives.com

Tel: +1 345-945-5556

Fax: +1 345-945-5557 

Skype: bethbiega 

bbiega@atlascaptives.com

Anguilla | Bahamas | Cayman Islands | Nevis | D.C. | Delaware | Georgia | Montana | North Carolina | 

Oklahoma | South Carolina | Tennessee | Texas | Utah 

This email and any files transmitted with it are confidential and intended solely for the use of the 

individual or entity to whom they are addressed. If you have received this email in error please notify the 

sender immediately and delete this e-mail from your system. If you are not the intended recipient you are 

notified that disclosing, copying, distributing or taking any action in reliance on the contents of this 

information is strictly prohibited.

Case 3:20-cv-00330-BJB-LLK Document 3-2 Filed 05/11/20 Page 25 of 56 PageID #: 550

Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 26 of 57
Exhibit 4

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Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 27 of 57
From: Brandon White [mailto:brandon.white@ambassadorcaptive.com] 

Sent: Thursday, February 14, 2019 5:28 PM 

To: Davina, Joseph 

Cc: Darin Smith 

Subject: Re: Goldenstar Insurance Holdings 

Joe, 

This is not an agreement within Lexington. This is the draft document built from the framework that 

David Branca sent me back in late-August/early-September when you mentioned that AIG could execute 

on Gagliardi as long as Performance 1 went also. We put drafts together to prep business plan changes 

and to confirm language with legal to determine if changes will need to be requested once a change is 

made. We do this pro-actively to get ahead of challenges. This is not in effect, obviously. Nor should a 

draft be in anyone’s hands. Not sure how this is out there. I have called Adrian to get clarity 

immediately. You won’t hear from him again. 

Helmsman is working on the GL side of things which we are placing through a broker...the captive 

manager must have sent this by mistake. It did not come from us. Sorry for the noise, Joe. 

Sincerely, 

Brandon M. White, CIC, CRM, CWCA 

Founder/President 

Ambassador Captive Solutions 

9700 Park Plaza Avenue, Suite 201 

Louisville, KY 40241 

502.439.1555 

www.ambassadorcaptive.com 

"Everything should be made as simple as possible, but not simpler." -Roger Sessions, Composer 

On Feb 14, 2019, at 4:41 PM, Davina, Joseph <Joseph.Davina@aig.com> wrote: 

Hey Guys,

Which unit within Lexington does this reinsurance agreement go with? Just not sure who wrote 

Goldenstar within Lexington.

Thanks,

Joe

Joseph Davina, Vice President

AIG Risk Management | Group Captives

175 Water Street, 26th Floor, New York, NY 10038

Direct: (646) 857-1345 | Mobile: (917) 224-3451

Joseph.Davina@aig.com | www.aig.com

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From: Marshall, Adrian [mailto:Adrian.Marshall@helmsmantpa.com] 

Sent: Thursday, February 14, 2019 4:29 PM 

To: Davina, Joseph 

Subject: RE: Goldenstar Insurance Holdings 

Thanks Joe. 

I dug up the attached, any chance you can point me in the right direction? 

Regards, Adrian 

From: Davina, Joseph [mailto:Joseph.Davina@AIG.com] 

Sent: Thursday, February 14, 2019 4:00 PM 

To: Marshall, Adrian <Adrian.Marshall@helmsmantpa.com> 

Subject: {EXTERNAL} RE: Goldenstar Insurance Holdings 

Hi Adrian,

Is this in regards to Gagliardi? If so we are not the carrier on this fronted program. I’m not sure why this 

is coming up as AIG but we never quoted the Goldenstar opportunity. I have brought this up to 

Ambassador multiple times so not sure where the disconnect is.

Thanks

Joe

Joseph Davina, Vice President

AIG Risk Management | Group Captives

175 Water Street, 26th Floor, New York, NY 10038

Direct: (646) 857-1345 | Mobile: (917) 224-3451

Joseph.Davina@aig.com | www.aig.com

From: Marshall, Adrian [mailto:Adrian.Marshall@helmsmantpa.com] 

Sent: Thursday, February 14, 2019 3:51 PM 

To: Davina, Joseph 

Subject: RE: Goldenstar Insurance Holdings 

Joseph, please get back to me at your earliest convenience. We have a contract in place effective 

1//1/2019 and need to connect with you re the loss billing and reporting issues. 

Thanks, Adrian 

Adrian Marshall 

Senior Account Executive 

HMS distribution & Service – East 

2530 Sever Rd, suite 200 

Lawrenceville, GA 30093 

Direct – 470-539-5895 

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Mobile – 678-644-7264 

Adrian.marshall@helmsmantpa.com

From: Marshall, Adrian 

Sent: Tuesday, February 05, 2019 3:49 PM 

To: 'Joseph.davina@aig.com' <Joseph.davina@aig.com> 

Subject: Goldenstar Insurance Holdings 

Good afternoon Joseph. 

We are the new TPA for the above client of your group. I was hoping you could put me in touch with the 

underwriter to go over the contractual requirements such as billing etc... 

Regards, Adrian 

Adrian Marshall 

Senior Account Executive 

HMS distribution & Service – East 

2530 Sever Rd, suite 200 

Lawrenceville, GA 30093 

Direct – 470-539-5895 

Mobile – 678-644-7264 

Adrian.marshall@helmsmantpa.com

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Exhibit 5

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Exhibit 6

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Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 54 of 57
From: Brandon White [mailto:brandon.white@ambassadorcaptive.com] 

Sent: Tuesday, December 03, 2019 3:05 PM 

To: Benz, Mark 

Cc: Darin Smith; Davina, Joseph 

Subject: [EXTERNAL] Re: Goldenstar Holdings Company SP 

This message is from an external sender; be cautious with links and attachments.

Mark & Joe, 

I apologize for this misrepresentation. We are working to track down the genesis of this document. I can 

assure you that this did not come from Ambassador in any way. This is not acceptable to us and we will 

get to the bottom of this and commit to return and report. I am sorry that I do not know more at this 

moment but didn’t want to remain silent on this matter. 

This partnership is important to us and we would not jeopardize it. More to come. 

Sincerely, 

Brandon M. White, CIC, CRM 

Founder/President 

Ambassador Captive Solutions 

9700 Park Plaza Avenue, Suite 201 

Louisville, KY 40241 

502.439.1555 

www.ambassadorcaptive.com

“Out of clutter, find simplicity.” - Einstein 

On Dec 3, 2019, at 12:52 PM, Benz, Mark wrote: 

 

Gentlemen, 

We need to know where this document came from ASAP. This is the second time within the past year 

there has been some type of misrepresentation in our workings. If we can’t get an explanation as to how 

this occurred, we will proceed to non-renew both captives effective 2020 and report this occurrence to 

the proper regulatory body to protect AIG’s interests.

Regards, 

Mark 

Mark Benz

AIG 

Senior Vice President 

Case 3:20-cv-00330-BJB-LLK Document 3-2 Filed 05/11/20 Page 54 of 56 PageID #: 579

Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 55 of 57
2 

Lexington Insurance Company | Group Captives 

175 Water Street, 26th Floor, New York, NY 10038 

T +1 212-458-3393 | M +1 646-592-1309 

Mark.Benz@aig.com | www.aig.com

AIG 100 | Celebrating 100 Years: Visit 100.aig to learn more.

From: Davina, Joseph 

Sent: Monday, December 02, 2019 6:52 PM 

To: Beth Biega 

Cc: Doug King; Brandon White; Darin Smith 

Subject: RE: Goldenstar Holdings Company SP 

Hi Beth,

This was never signed by me so not sure how you have a fully executed agreement that I never signed. If 

you want to see my handwriting and signature it is much nicer than that. Please stop sending over 

forged documents. This is the 2nd time AIG has been sent forged documentation including an email 

supposedly written by me over a year ago that was never sent from my email. 

Brandon/Darin,

I’d suggest figuring out what this document is and a very good explanation of it before I go to my legal 

counsel at AIG to figure out what this is. I took Chris Flatt off of this response to give you time to figure 

this out. I’m in Cayman and we can talk about this tomorrow at 10am. This is completely unacceptable 

and quite frankly a relationship breaker if not resolved ASAP. I will go to my Executive leadership if I 

don’t have a full response and explanation by EOD tomorrow.

Joe

Joseph Davina

AIG 

Vice President 

Lexington Insurance Company | Group Captives 

175 Water Street, 26th Floor, New York, NY 10038 

T: 646-857-1345 | M: 917-224-3451 

joseph.davina@aig.com | www.aig.com

From: Beth Biega [mailto:BBiega@atlascaptives.com] 

Sent: Tuesday, November 19, 2019 12:24 PM 

Case 3:20-cv-00330-BJB-LLK Document 3-2 Filed 05/11/20 Page 55 of 56 PageID #: 580

Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 56 of 57
3 

To: Davina, Joseph; Flatt, Christopher J 

Cc: Doug King; Brandon White; Darin Smith 

Subject: [EXTERNAL] Goldenstar Holdings Company SP 

This message is from an external sender; be cautious with links and attachments.

Dear Joe, 

Attached please find the fully executed Facultative Reinsurance Agreement. Please provide wiring 

instructions for the commission payment. 

Kind regards, 

Beth 

Beth Biega 

Vice President

Whitehall House, 3rd Floor, 238 North Church Street 

PO Box 699, Grand Cayman, KY1-1107, Cayman Islands 

www.atlascaptives.com

Tel: +1 345-945-5556

Fax: +1 345-945-5557 

Skype: bethbiega 

bbiega@atlascaptives.com

Anguilla | Bahamas | Cayman Islands | Nevis | D.C. | Delaware | Georgia | Montana | North Carolina | 

Oklahoma | South Carolina | Tennessee | Texas | Utah 

This email and any files transmitted with it are confidential and intended solely for the use of the 

individual or entity to whom they are addressed. If you have received this email in error please notify the 

sender immediately and delete this e-mail from your system. If you are not the intended recipient you are 

notified that disclosing, copying, distributing or taking any action in reliance on the contents of this 

information is strictly prohibited.

Case 3:20-cv-00330-BJB-LLK Document 3-2 Filed 05/11/20 Page 56 of 56 PageID #: 581

Case 21-12609-AJC Doc 32-1 Filed 07/12/21 Page 57 of 57