Free Notice (Other) - District Court of Delaware - Delaware

Case 1:05-cv-00699-SLR-MPT

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EXHIBIT A

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ROBERT N. HUGHES, CPCU, ARM
Home Address: Office Address: 7732 Briaridge Road Dallas, TX 75248 Robert Hughes Associates, Inc. 508 Twilight Trail, Suite 200 Richardson, TX 75080

EXPERIENCE ROBERT HUGHES ASSOCIATES, INC. (1979 to date)

Mr. Hughes founded RHA in 1979 and has served continuously since as its President and Chairman. RHA is a broadly based insurance consulting firm providing insurance consultations, litigation support, actuarial services, product design and insurance company administration. In addition to his responsibilities as the chief operating officer of the company, Mr. Hughes acts as a consultant and expert witness. Since 1990 he has been retained to assist policyholders, insurers and their attorneys in more than 600 cases. He has testified in 170 of those cases and has testified at trial/arbitration/mediation 53 times in numerous states. RIMCO, INC. (1972 ­ 1979) Mr. Hughes served as Executive Vice President of Rimco, Inc., a large Dallas-based insurance consulting firm. His consulting specialties included banking, energy, property management and development, contractors and transportation. Mr. Hughes' banking clients included most of the larger banks in Texas and their holding companies. He was responsible for reviewing and negotiating all coverages including property, bankers' blanket bonds, general liability, directors' and officers' liability, workers' compensation, etc. HUGHES INSURANCE AGENCY (1960 ­ 1972)

Hughes was the owner of a local insurance agency in Pecos, Texas. The agency served a farming and oil & gas related economy and also wrote a book of personal lines coverages. U.S. ARMY AND ARMY NATIONAL GUARD (1960 ­ 1968)

Served as a cavalry officer, achieving the rank of 1st Lieutenant.

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Bachelor of Business Administration . . . With Honors (Cum Laude) Southern Methodist University - 1960 PROFESSIONAL Chartered Property & Casualty Underwriter - 1973 Associate in Risk Management - 1976 Member, Society of CPCU Texas Licensed Risk Manager New Jersey Producers License Fellow, Institute of Directors, London, England Diplomate, American Board of Forensic Examiners Fellow, American Academy of Forensic Examiners Member, Academy of Experts (London) Judge for the 2001 Business Insurance Risk Manager of the Year and Risk Management Honor Roll Texas Local Recording Agent Texas Managing General Agent Texas Surplus Lines Agent OTHER BUSINESS AFFILIATIONS Vice President and Director - British American Insurance Company (Formerly) Director - Alexander Howden Group, U.S. (Formerly) Director - Financial Casualty & Surety Company (Formerly) Director - Risk Management Assurance Corporation (Formerly) SPEAKING/TEACHING
Adjunct Faculty, Southern Methodist University MBA Program, "Introductory Risk Management" Speaker, Australian Risk and Insurance Managers Association, "Quantitative Risk Management Techniques" Seminar Chairman, "Scientific Risk Management," Sydney and Melbourne, Australia Speaker, Second Annual Construction Insurance Conference, "Developing a Risk Management Philosophy for the Contractor" Seminar Chairman and Speaker, "How to Profit for the London Market by Improving Coverages and Lowering Costs" 1978, 1979, 1980 Speaker, Fourth Annual Invitational Seminar on Engineering Geophysical and Soils Data, "Offshore Risk Management" 1979 Speaker, "How to Reduce Your Municipal Insurance Costs While Improving Your Coverage" 1979 Speaker, American Management Association - "The Captive Insurance Company Movement: New Changes and Opportunities" 1980 Seminar Chairman and Speaker, American Management Association - "Workers' Compensation: Costs, Coverages and Problems" 1980 Speaker, National Conference on Risk and Insurance Management, "Product and General Liability Cost and Coverage" 1981 Speaker, Society of Fellows, Calgary, Canada, "The Insurance Market Cycle" 1982 Speaker, Canadian Risk Management Conference, "Risk Retention" 1982 Speaker, International Risk Management Institute, Inc.'s, General Liability Conference II, "Special Hazards Coverage" 1982

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SPEAKING/TEACHING (CONTINUED)
Speaker, International Risk Management Institute, Inc., "Risk Financing Conference" 1984 Speaker, American Bus Association Annual Meeting, "The Insurance Cycle and How It Affects You" 1984 Speaker, Governmental Risk Management, Insurance and Employee Benefits Conference, "Risk Funding for Governmental Entities" 1986 Planning Committee Member, 7th Annual Petroleum Insurance Conference, 1986 Seminar Chairman and Speaker, CPCU National Briefing on The Risk Retention Act of 1986 Speaker, 8th Annual Petroleum Insurance Conference, "Post Event Loss Control" 1987 Speaker, American Petroleum Institute Risk Management Section, "The Liability Risk Retention Act of 1986" 1988 Speaker, 15th Annual Petroleum Insurance & Environmental Protection Conference, "Pollution Coverage Found Within the General Liability Policy" 1994 Seminar Chairman and Speaker, Texas Department of Insurance Continuing Education Course, "Avoiding Insurance Litigation" 1994-95 Speaker, Strategic Research Institute's Contract Risk Management Conference, "Environmental Liability: Past, Present & Future" 1996 Speaker, 17th Annual Petroleum Insurance & Environmental Protection Conference, "Environmental Liability: Past, Present & Future" 1996 Speaker, Strategic Research Institute's Environmental Litigation in the Petroleum Industry Conference, "Insurance Recoveries for Environmental Liabilities" 1996 & 1997 Speaker, 10th Annual ABA Insurance Coverage Litigation Committee Mid-Year Meeting, "Effective Use of Experts" 1998 Speaker, Dallas/Fort Worth Chapter RIMS, "Enterprise Risk Management & Convergence" 1999 Speaker, Association of Energy Service Companies' National Winter Meeting, "Surviving the Insurance Crisis" 2002 Speaker, ABA Insurance Coverage Litigation Committee Annual CLE Meeting, "The Care and Feeding of Experts" 2005 Presenter, The American College of Forensic Examiners 13th National Conference, "Preparation of a Federal Rule 26 Expert Report" 2005

PUBLISHED ARTICLES
"Blowout: What Is Your Liability And What Can You Do About It?" Drilling-DCW (November 1977) "Buyer Demands Meld Functions Of Brokers And Risk Consultants" Business Insurance (June 11, 1979) "Financial Fright: Outside Audit Can Stop Potential Horror Show Of Unforeseen Problems" Business Insurance (February 18, 1980) "Rig Cost Versus Value: Better Understanding Of Insurance Assures Best Deal For The Money" DrillingDCW (March 1980) "Get Prepared For A Long Insurance Siege" The Bus Operator "The Polluter's Exclusion Was No `Accident'" CPCU Journal (June 1994) "Will The Parachute Open? -- Avoiding `Coverage Nullification Through Litigation'" The RHA Review (November 1994) and Texas Dealer (August 1997) and Texas Lawyer E-Alert/Insurance (January 2006) "Holes In The Parachute: Common Insurance Company Defenses" The RHA Review (February 1995) and Texas Lawyer E-Alert/Insurance (February 2006) "Landing On Your Feet In Liability Claims" Public Risk (November/December 1995) "More Holes In The Parachute" The RHA Review (November 1995) and Texas Lawyer E-Alert/Insurance (March 2006) "The Lowest Common Denominator Syndrome" Public Risk (March 1996) "Who's Afraid Of The Big Bad Wolf?" The RHA Review (May 1996) and CPCU Society E/S/SL Newsletter (February 1998) "Is `Big Brother' Becoming A Reality?" The RHA Review (November 1996) "Ambiguous Is As Ambiguous Does" The RHA Review (February 1997)

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PUBLISHED ARTICLES (CONTINUED)
"1998! Where Do We Go From Here?" The RHA Review (February 1998) and CPCU Society Agent/Broker Newsletter and CPCU Society Underwriting Trends Newsletter (March 1998) "Insurance and the Millennium Bug" The RHA Review (August 1998) "What's New in Who(m) to Sue" The RHA Review (May 1999) "Sophisticated Lady" The RHA Review (November 1999) and Texas Lawyer E-Alert/Insurance (July 2006) "A Hard Day's Night" The RHA Review (August 2000) "Welcome to Alice's World" The RHA Review (August 2001) "Jam Today, Tomorrow or Yesterday" The RHA Review (November 2001) "Top Ten Worst Excuses for Buying Lousy Insurance" The RHA Review (August 2003) "Risk Transfer? Maybe, Maybe Not" The RHA Review (August 2004) "Oh, Those Four Little Words!" The RHA Review (November 2004) "The Starr in Their Crown" The RHA Review (May 2005) "How Quickly We Forget" The RHA Review (November 2005) ) and Texas Lawyer E-Alert/Insurance (April 2006)

TESTIMONY EXPERIENCE Qualified by the court as an insurance expert in the following jurisdictions:
Arkansas Circuit Court, Sebastian County, Arkansas California Los Angeles Superior Superior Court of California, Alameda Superior Court of California, San Francisco County United States District Court, Central District of California Colorado District Court, City and County of Denver, State of Colorado Delaware Superior Court of the State of Delaware, New Castle County Illinois 17th Judicial Circuit of Winnebago County, Illinois Indiana Hendricks Superior County #1, Danville, Indiana Kansas US District Court, District of Kansas (Mediation) Louisiana 19th JD, East Baton Rouge, Louisiana Maryland Circuit Court for Baltimore County United States District Court for the District of Maryland Michigan Schoolcraft County Circuit Court, Michigan Minnesota District Court of the Second Judicial Circuit, Ramsey County, Minnesota Missouri Circuit Court of Jackson County, Missouri at Kansas City New Jersey Superior Court of New Jersey, Middlesex County US District Court of New Jersey (Arbitration) New York US District Court, Southern District of New York Supreme Court of the State of New York, County of New York (Arbitration)

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TESTIMONY EXPERIENCE (CONTINUED)
Oklahoma US Bankruptcy for the Northern District of Oklahoma Oklahoma County, State of Oklahoma Pennsylvania United States District Court for the Eastern District of Pennsylvania Texas 285th Judicial District Court ­ Dallas County, Texas District Court for the Southern District of Texas, Houston Division 116th Judicial Court, Dallas County District Court, Harris County, Texas, 80th Judicial District 398th Judicial District, Hidalgo County, Texas US District Court for the Northern District of Texas, Dallas Division District Court of Travis County, Texas, 201st Judicial District 259th Judicial District Court, Travis County, Texas 260th Judicial District Court of Travis County, Texas District Court of Travis County, Texa s, 53rd Judicial District US District Court for Northern Texas, Dallas Division (Arbitration) 151st Judicial District Court of Harris County, Texas (Mediation) Washington Superior Court of the State of Washington, in and for the County of King

Has also testified at deposition or offered opinions in matters litigated in the following jurisdictions:
Alabama US District Court, Southern District of Alabama Alaska Superior Court for the State of Alaska, 3rd Judicial District Arkansas Circuit Court of Union County, Arkansas Second Division Arizona US District Court for the District of Arizona (Phoenix) Division California Southern California, Los Angeles County Superior Court of the State of California, County of Los Angeles Superior Court of the State of California for the County of San Diego San Joaquin Superior Court, California Superior Court of the State of California for the County of San Francisco United States District Court, Central District of California United States Bankruptcy Court, Central District of California, Los Angeles Division United Stated Bankruptcy Court for the Northern District of California, Oakland Division Colorado US District Court of Colorado District of Columbia Superior Court of the District of Columbia, Civil Division Florida US District Court for the Middle District of Florida, Tampa Division 4th Judicial Circuit, Duval County, Florida US Bankruptcy Court, Middle District of Florida Georgia United States District Court for the Northern District of Georgia, Atlanta Division Illinois 118th Judicial District, DuPage County, Illinois Circuit Court of Cook County, Illinois, County Department, Chancery Division

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TESTIMONY EXPERIENCE (CONTINUED)
Indiana Circuit Court of Porter County, Valparaiso, Indiana Montgomery Circuit Court, County of Montgomery, State of Indiana County of Marion Superior Court, State of Indiana Louisiana 19th Judicial District, E. Baton Rouge, Louisiana US District Court, Western District of Louisiana, Lafayette-Opelousas Division Middle District of Louisiana Div. "N", Sec. 8, Civil District Court, Parish of Orleans, State of Louisiana Div. "M", Sec. 7, Civil District Court, Parish of Orleans, State of Louisiana Massachusetts US District Court, District of Massachusetts Michigan US District Court, Eastern District of Michigan, Northern Division US District Court for the Eastern District of Michigan, Southern Division State of Michigan in the Circuit Court for the County of Wayne State of Michigan, The Circuit Court for the County of Washtenaw Eastern District of Michigan, Northern Division Minnesota US District Court, District of Minnesota, Fifth Division Missouri US District Court, Western District of Missouri US District Court, Eastern District of Missouri, Eastern Division Montana US District Court for the District of Montana, Billings Division New Jersey Superior Court of New Jersey, Law Division, Union County Superior Court of New Jersey, Law Division, Middlesex County Superior Court of New Jersey, Law Division, Morris County Superior Court of New Jersey, Somerset County US District Court, District of New Jersey Ohio US District Court for the Southern District of Ohio Eastern Division State Court in Ohio, Monroe County Court of Common Pleas of Franklin County, Ohio Court of Common Pleas, Summit County, Ohio Oklahoma US District Court, Western District of Oklahoma Pennsylvania Court of Common Pleas of Chester County, Pennsylvania South Carolina Court of Common Pleas, South Carolina, Greenville County Texas US District Court for the Eastern District of Texas, Beaumont Division 73rd Judicial District Court, Bexar County, Texas 57th Judicial District Court of Bexar County, Texas 35th Judicial District Court of Cameron County, Texas 162nd Judicial District, Dallas County, Texas District Court of Dallas County, TX 298th JD 134th Judicial District Court, Dallas US District Court for the Northern District of Texas, Dallas Division County Court at Law Number Two, El Paso County, Texas US District Court for the Northern District of Texas, Fort Worth Division 10th Judicial Court, Galveston County, Texas District Court of Gregg County, TX 188th JD 127th District Court, Harris County, Texas

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TESTIMONY EXPERIENCE (CONTINUED)
Texas (continued) District Court of Harris County, TX 152nd JD District Court of Harris County, TX 189th JD 164th Judicial District Court of Harris County, Texas 215th Judicial District Court, Harris County, Texas District Court, Harris County Civil Court at Law #2 334th Judicial District Court of Harris County, Texas District Court of Harris County, Texas, 61st Judicial District 71st Judicial District Court of Harrison County, Texas US District Court for the Southern District of Texas, Houston Division District Court of Hunt County, 196th District Court District Court of Jefferson County, Texas District Court, Montgomery County, Texas 17th Judicial District Court, Tarrant County, Texas 236th Judicial District Court of Tarrant County, Texas 250th Judicial District Court of Travis County, Texas 201st Judicial District Court of Travis County, Texas 261st Judicial District, Travis County, Texas Washington Superior Court of the State of Washington, Spokane County Superior Court of the State of Washington in and for the County of King Supreme Court of the State of Washington West Virginia West Virginia Circuit Court Wisconsin Dane County, Circuit Court, Wisconsin United States Bankruptcy Court for the Eastern District of Wisconsin