On November 25, 2024, the Welfare Fund sent a formal Notice of Claim to Berkley Insurance Company, seeking $97,511.81 in unpaid contributions. Berkley acknowledged the claim by letter on December 2, 2024, and requested supporting documentation. The Welfare Fund asserts it provided additional documents on December 6, 2024, January 14, 2024, and April 1, 2025, but Berkley did not respond to the April or May 2025 follow-ups.