TAILIEUCHUNG - IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION LAURA PENDERGEST-HOLT, R. ALLEN STANFORD, GILBERT0 LOPEZ, JR. and MARK KUHRT

Tham khảo sách 'in the united states district court for the southern district of texas houston division laura pendergest-holt, r. allen stanford, gilbert0 lopez, jr. and mark kuhrt', kinh doanh - tiếp thị, quản trị kinh doanh phục vụ nhu cầu học tập, nghiên cứu và làm việc hiệu quả | Case 4 09-cv-03712 Document 113 Filed in TXSD on 05 24 10 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION LAURA PENDERGEST-HOLT R. ALLEN STANFORD GILBERTO LOPEZ JR. and MARK KUHRT Plaintiffs vs. CIVIL ACTION NO. 4 09-cv-03712 CERTAIN UNDERWRITERS AT LLOYD s OF LONDON and ARCH SPECIALTY INSURANCE COMPANY Defendants. RESPONSE TO LETTER SUBMITTED BY ALLEN STANFORD On May 21 2010 Plaintiff R. Allen Stanford submitted a letter requesting emergency relief from this Court. Docket No. 106 . The Court has ordered Certain Underwriters at Lloyd s of London and Arch Specialty Insurance Company collectively Underwriters to respond to Stanford s allegations during tomorrow s hearing. Docket No. 108 . Underwriters file this response and would show Preliminary Statement Although Allen Stanford protests having to litigate coverage issues in this case and particularly the issue of whether he engaged in acts of Money Laundering as defined in the D o Policy the Fifth Circuit has held that the terms of the D o Policy entitle Underwriters to a hearing on just this point. Specifically Underwriters are entitled to an expeditious coverage determination for their bargain sought to mitigate the risk of advancing substantial fees on behalf of policyholders should it be found that the insureds 6469109 1 Case 4 09-cv-03712 Document 113 Filed in TXSD on 05 24 10 Page 2 of 14 did in fact commit Money Laundering as defined by the policy. By the bargain Underwriters are not compelled to remain aboard an aircraft that has lost its wings. Stanford s letter is premised on an egregious misrepresentation. He alleges that Underwriters have thwarted his every attempt to obtain counsel of his choosing and have controlled his defense by denying payment to his attorneys of choice. Nothing could be further from the truth. In reality Stanford has cycled through more than 10 different law firms all of his own choosing and all at Underwriters expense in the .

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