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Are there still grounds for indemnification? If so state the grounds, and the basis for the indemnification. It’s the same thing. What are you asking?
Can you find another contract with other related entities? I’ve done this for 3rd tier subcontractors in construction cases. Not always successful but sometimes the prime contract refers to “all subcontractors” or something like that.
It’s a case were plumber came in to fix pipes and their broke. But no repair records and contract. Only a receipt
Honestly, just issue it. If they accept, great. If not, then make your argument to the court.
Sounds like it should be short and sweet. Send it then have your 3rd party complaint ready to file