Final Joint Pretrial Order - Reinsurance Focus

XV. DEMONSTRATIVE EXHIBITS. (Demonstrative exhibits are to be made
available for review or specifically described. Each demonstrative exhibit is
to be separately set forth.)
A. Plaintiff.
1. Exhibit(s) setting forth relationships among the parties and other
participants in the Unicover business.
2. Exhibit(s) setting forth chronologies of relevant events.
3. Exhibit(s) demonstrating the flows of funds among the participants
in the Unicover business.
4. Exhibit(s) demonstrating the volume of business written by
Unicover and ceded to the Whole Account.
B. Defendants.
1. Exhibit(s) setting forth the relationships among the parties and
other key players involved in the Unicover Pool or the
retrocessional agreements covering the Unicover Pool.
2. Exhibit(s) setting forth the responsibilities of each of the agents
and sub-agents.
3. Exhibit(s) setting forth the facts known to ReliaStar Life Insurance
before it joined the Unicover Pool.
4. Exhibit(s) setting forth chronologies of relevant events.
5. Exhibit(s) setting forth communications between the relevant
players.
6. Exhibit(s) setting forth the facts known to Pallat and Unicover or
Mays and Rattner Mackenzie during the relevant time period.
The parties agree that the demonstrative exhibits described herein are
preliminary only and that the parties may supplement or edit same until they exchange
such demonstratives in advance of their anticipated use. The parties will exchange
demonstrative exhibits __ in advance of their anticipated use. Opposing counsel will
advise of any objections within ____.
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