Final Joint Pretrial Order - Reinsurance Focus

XVIII. PLAINTIFF’S IN LIMINE MOTIONS
1. Motion to preclude various portions of the expert report of E.W.
Blanch, Jr. and any testimony reflecting or relating to such
portions.
2. Motion to preclude statements made by counsel for ReliaStar in the
arbitration and certain pleadings filed in the arbitration.
3. Motion to preclude ReliaStar's settlement agreements with the
settling defendants and testimony related thereto.
4. Motion to preclude ReliaStar’s first complaint.
XIX. DEFENDANTS’ IN LIMINE MOTIONS
1. Motion to preclude ReliaStar Life Insurance from offering
testimony in its case in chief as to the standard of care owed by
Aon Re or Smith to ReliaStar Life Insurance.
2. Motion to preclude ReliaStar Life Insurance from offering
testimony to support its damages claim that would expand the
scope of deposition testimony offered by ReliaStar Life
Insurance’s corporate designees.
3. Motion to preclude ReliaStar Life Insurance from offering
evidence of any IBNR damages it purports to have suffered.
4. Motion to preclude ReliaStar Life Insurance from offering
evidence of its claim for attorneys fees and expenses.
5. Motion to preclude ReliaStar Life Insurance from introducing
evidence of the decision in the Sun Life Arbitration or the basis for
that decision.
6. Motion for an instruction to the jury regarding certain positions
taken by ReliaStar Life Insurance in this litigation or, in the
alternative, to preclude ReliaStar Life Insurance from denying
positions it took in this litigation.
7. Motion to preclude ReliaStar Life Insurance from introducing
evidence that Roger Smith avoided service in the Sun Life
Arbitration and/or that he refused to produce documents in
connection with that arbitration.
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