UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

RITCHIE CAPITAL MANAGEMENT, L.L.C., 

RITCHIE RISK-LINKED STRATEGIES 

TRADING (IRELAND), LIMITED, RITCHIE 

RISK-LINKED STRATEGIES TRADING 

(IRELAND) II, LIMITED, WALKERS SPV 

LIMITED, as trustee for Ritchie Risk-Linked 

Life Strategies Trust I and Ritchie Life 

Strategies Master Trust, and RITCHIE RISKLINKED STRATEGIES TRADING, LTD., 

Plaintiffs, 

v. 

COVENTRY FIRST LLC, THE COVENTRY 

GROUP, INC., MONTGOMERY CAPITAL, 

INC., LST I LLC, ALAN BUERGER, 

CONSTANCE BUERGER, REID S. 

BUERGER, ANTONIO MUNIZ, ALEX 

SELDIN, NEAL JACOBS, EILEEN SHOVLIN, 

and JIM DODARO, 

Defendants. 

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07 Civ. 3494 (DLC) 

ECF Case 

COMPLAINT 

 Plaintiffs, through their attorneys, for their complaint against defendants allege as 

follows: 

NATURE OF THE ACTION

1. This is an action under the federal Racketeer Influenced and Corrupt 

Organizations Act (“RICO”), and for fraud, fraudulent inducement, breach of fiduciary 

duty, and breach of contract. This action is brought to recover damages caused to 

Plaintiffs by Defendants’ pervasive fraud in the “life settlements” industry – that is, the 

secondary market for life insurance policies. In a life settlement transaction, an investor 

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buys a life insurance policy from the policy’s owner at a discount, pays the policy’s 

premiums as they come due, and then collects the death benefits. 

2. Defendant Coventry First LLC owns Defendant LST I LLC and is owned 

by Defendant Montgomery Capital, Inc. and affiliated with Defendant The Coventry 

Group, Inc. (all four entities, together with affiliates, to be referred to collectively as 

“Coventry”). Coventry is a major player in this industry. Coventry is owned and 

controlled by the Buerger family, which includes Defendants Alan Buerger, Constance 

Buerger, and Reid S. Buerger. Defendant Antonio Muniz is the chief financial officer of 

Coventry First LLC and Montgomery Capital, Inc. The other individual defendants are or 

were executives and employees of Coventry. 

3. Coventry partnered with Plaintiffs (collectively “Ritchie Capital”) and 

their affiliates to invest in life insurance policies with a view toward re-selling them 

through a securitization transaction. Defendants, however, concealed from Ritchie 

Capital that Defendants were systematically defrauding the owners of the policies, and 

then further deceived Ritchie Capital as to the existence of an investigation by the 

Attorney General of New York into Defendants’ misconduct. Coventry, moreover, 

falsely represented on numerous occasions that Coventry was in compliance with all 

applicable laws and regulations. Coventry’s misconduct has damaged Plaintiffs, as 

described herein. 

JURISDICTION AND VENUE

4. The Court has jurisdiction over the subject matter of this action pursuant 

to 28 U.S.C. § 1331 because Plaintiffs bring claims under RICO, 18 U.S.C. § 1962. The 

Court has supplemental jurisdiction over the Plaintiffs’ state-law claims pursuant to 28 

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U.S.C. § 1367(a). In the alternative, the Court has original subject matter jurisdiction over 

the state-law claims pursuant to 28 U.S.C. § 1332(a). While Plaintiffs cannot yet 

calculate their damages with precision, it is likely at least 700 million dollars. 

5. The Court has personal jurisdiction over Defendants because: (1) 

Defendants regularly transact business in New York and have entered into contracts with 

Plaintiffs in New York; (2) Defendants have committed tortious acts within New York; 

(3) Defendants have committed tortious acts outside New York causing injury to 

Plaintiffs and others in New York as set forth in this complaint, and regularly do business 

and derive substantial revenue from services rendered in New York, and expect or should 

reasonably expect their acts to have consequences in New York. Defendants derive 

substantial revenue from interstate commerce. Coventry, moreover, submitted in a series 

of agreements with Plaintiffs to the jurisdiction of the courts sitting in the State of New 

York for purposes of disputes arising out of Coventry’s relationship with Plaintiffs. 

6. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b)(2) and 

1965(a). In the alternative, venue is proper in this District pursuant to 28 U.S.C. 

§ 1391(a)(2). Coventry waived any objection to venue in this Court in a series of 

agreements with Plaintiffs. 

THE PARTIES

7. Plaintiff Ritchie Capital Management, L.L.C. (“RCM”) is a limited 

liability company with its principal place of business in Geneva, Illinois. Its members are 

citizens of Illinois, Wyoming, Utah, and Arizona. 

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8. Plaintiffs Ritchie Risk-Linked Strategies Trading (Ireland), Limited 

(“Ritchie I”) and Ritchie Risk-Linked Strategies Trading (Ireland) II, Limited (“Ritchie 

II”) are Irish corporations with offices in Ireland. 

9. Plaintiff Walkers SPV Limited, a Cayman Islands company with its 

principal place of business in the Cayman Islands, is sole trustee of Ritchie Risk-Linked 

Life Strategies Trust I (“Ritchie Trust I”) and Ritchie Life Strategies Master Trust 

(“Ritchie Master Trust”), each of which is a class of Ritchie Risk-Linked Strategies 

Series Trust, a Cayman Islands unit trust. 

10. Plaintiff Ritchie Risk-Linked Strategies Trading, Ltd. (“Ritchie RiskLinked”) is a Bermudan limited company with its principal place of business in Bermuda. 

11. Defendant Coventry First LLC (“Coventry First”) is a limited liability 

company with its principal place of business in Fort Washington, Pennsylvania. Coventry 

First’s sole member is Montgomery Capital, Inc., a Delaware corporation with its 

principal place of business in Pennsylvania. The officers of Coventry First include Alan 

Buerger, CEO and Treasurer; Constance Buerger, President and Secretary; and Reid S. 

Buerger, Vice President. 

12. Defendant Montgomery Capital, Inc. is a Delaware corporation with its 

principal place of business in Fort Washington, Pennsylvania. The shareholders of 

Montgomery Capital, Inc. are Alan Buerger, Constance Buerger, Reid S. Buerger, and the 

Reid S. Buerger Trust. The officers of Montgomery Capital, Inc. include Alan Buerger, 

Constance Buerger, and Reid Buerger. 

13. The Coventry Group, Inc. is a Pennsylvania corporation with its principal 

place of business in Fort Washington, Pennsylvania. Its shareholders are Alan and 

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Constance Buerger. Its officers include Alan Buerger, President, and Constance Buerger, 

Treasurer and Vice President. 

14. Defendant LST I LLC (“LST”) is a limited liability company. It is a 

wholly-owned subsidiary of Coventry First, which on information and belief is its sole 

member. LST’s chief executive officer is Alan Buerger. 

15. Defendants Alan Buerger, Constance Buerger, and Reid S. Buerger are 

individuals residing in Pennsylvania. They own and control Coventry. Reid Buerger is 

the son of Alan Buerger, the founder and chief executive of the Coventry group. 

Constance Buerger, Alan Buerger’s wife and Reid Buerger’s step-mother, is president of 

Coventry First and chief operating officer of the Coventry group. 

16. Defendant Antonio Muniz has served as chief financial officer of 

Coventry First and of Montgomery Capital, Inc. since 2003. On information and belief, 

he is a resident of Pennsylvania. 

17. Defendant Alex Seldin is General Counsel of Coventry. On information 

and belief, he is a resident of Pennsylvania. 

18. Defendant Neal Jacobs is Coventry’s Director of Financial Underwriting. 

On information and belief, he is a resident of Pennsylvania. 

19. Defendant Jim Dodaro is Coventry’s Vice President of Financial 

Underwriting. On information and belief, he is a resident of Pennsylvania. 

20. Eileen Shovlin is a Coventry Regional Vice President. On information and 

belief, she is a resident of Pennsylvania. 

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BACKGROUND: THE SECONDARY MARKET FOR LIFE INSURANCE

21. The life insurance policies at issue in this case insured persons, typically 

wealthy individuals 65 years of age and older, who have determined that they prefer (a) 

an immediate, lump-sum payment to (b) a payment to their beneficiaries when they die, 

along with the ongoing expense of premium payments. In a typical situation, a policy 

owner’s children have become financially independent, or the policy was purchased by a 

corporation that hired the insured as an executive but for which the insured no longer 

works. 

22. The life settlement payment will be more than the “surrender value” of the 

policy – the contractual price at which a policy owner can return the policy to the 

insurance company that issued it – but less than the death benefit. The buyer of the policy 

continues to pay premiums until the insured’s death, at which point the buyer claims the 

death benefit. Thus the investor is wagering that the value of the future death benefit will 

exceed the life settlement payment and the costs of paying premiums until the insured’s 

death. 

23. An insured can enter into a life settlement transaction in one of two ways. 

First, the insured (typically through a representative such as a financial advisor or 

planner, insurance agent, accountant, or attorney) might hire a life settlement broker to 

mount the equivalent of an auction, collecting bids on the policy from buyers (or from 

other brokers who in turn represent buyers). Second, the insured (again through a 

representative) might make direct contact with a buyer. 

24. Coventry is one such buyer. Coventry’s work force includes persons with 

deep experience in the life insurance industry. Coventry specializes in understanding life 

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insurance policies. Coventry’s expertise includes, among other things, the actuarial and 

financial knowledge required to optimize the profitability of a life insurance policy by 

minimizing premium payments. 

25. Coventry is a leading player in the secondary market for life insurance 

policies. Coventry entered that market as a buyer in 2001, purchasing 436 policies 

representing $720 million in total death benefits in 2002. By 2005, Coventry had 

purchased 1,318 life insurance policies representing more than $3 billion in death 

benefits. 

26. Coventry sells the policies that it purchases to institutional investors. Such 

investors have included the American International Group (“AIG”), Citigroup, Berkshire 

Hathaway, and Ritchie Capital. 

DEFENDANTS’ ILLEGAL CONDUCT

A. Coventry Partners With Ritchie Capital

27. Beginning in 2005, Ritchie Capital began negotiating with Defendants an 

arrangement under which Ritchie Capital would partner with Coventry for the purpose of 

investing in life insurance products and then re-selling them at a future point through a 

securitization transaction. 

28. In the spring and summer of 2005 and afterwards, Alan Buerger, Reid 

Buerger, Constance Buerger, and Antonio Muniz, in connection with the negotiations 

with Ritchie Capital, represented to Ritchie Capital and its representatives (including 

John (“Jeff”) Mulholland, Duncan Goldie-Morrison, and Thane Ritchie) that the life 

insurance policies in which Coventry transacts have no legal taint and that Coventry 

purchases policies and otherwise conducts itself in accordance with law. 

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29. Rounds of negotiations were concluded in June 2005, September 2005, 

December 2005, and June 2006. Each round culminated in the commitment by Ritchie 

Capital of additional capital. 

30. The purchasers of the policies were Plaintiffs Ritchie I and Ritchie II. 

Ritchie Capital (specifically, through Ritchie Trust I and Ritchie Master Trust, whose 

sole beneficiary is Plaintiff Ritchie Risk-Linked) and Coventry jointly committed capital 

to, and became owners of subordinated securities in, Ritchie I and Ritchie II, which 

entitled Ritchie Capital and Coventry to receive the profits of Ritchie I and Ritchie II 

after other debts have been paid. 

31. Ritchie Capital was a partner, joint venturer, and co-venturer of Coventry. 

While Ritchie Capital’s representatives contributed the great majority of the financing to 

the partnership and venture, Coventry’s specialty was in analyzing and servicing life 

insurance policies. 

32. Plaintiffs relied at all times on Defendants’ expertise, as well as their 

honesty and integrity. It was Coventry’s responsibility to seek out and purchase 

individual policies that met certain pre-defined criteria that the parties had agreed on. 

Each month, pursuant to contractual arrangements, Coventry would notify Ritchie I and 

Ritchie II that Coventry had a certain dollar amount’s worth of qualifying policies to sell. 

Ritchie I and Ritchie II then would pay the necessary funds to Coventry, which would 

transfer the policies to Plaintiffs. 

33. It was, moreover, Coventry’s responsibility to service the policies, 

including, among other things, tracking premium payments and claims for death benefits 

from the issuing life insurance companies, determining when a claim for a death benefit 

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could be made and placing the claim, monitoring the health of the insureds, and 

maintaining current information on the issuing life insurance companies. Day-to-day 

administration of the policies, in other words, was in the hands of Coventry. Ritchie I and 

Ritchie II had only to send to a third-party intermediary a check for the total premium 

payments due each month, and Coventry First directed the intermediary to disburse the 

appropriate amounts to each issuing life insurance company. 

34. In drafts of an agreement between Ritchie I and LST sent by email on, 

among other occasions, June 20, 24, and 30, 2005, to Ritchie Capital’s representatives, 

including, among others, John (Jeff) Mulholland, Coventry represented that: 

(a) “The consummation of the transactions contemplated by this 

Agreement and the fulfillment of the terms hereof will not violate any 

United States federal, state or local law or regulation, violate, result in 

the breach of any terms and provisions of, nor constitute an event of 

default under, the certificate of formation or the operating agreement 

of the Seller, or violate or breach any of the terms or provisions of, or 

constitute an event of default under, any agreement to which the Seller 

is a party or by which it shall be bound; nor violate any order, 

judgment or decree applicable to the Seller of any United States 

federal or state court, regulatory body, administrative agency or other 

United States federal or state government instrumentality having 

jurisdiction over the Seller or its properties.” 

(b) “There is no action, suit or proceeding before or by any court, 

regulatory body, administrative agency or other governmental agency 

or body . . . now pending, or to the Seller’s knowledge, threatened, 

against or affecting the Seller or its assets or properties: . . . seeking to 

prevent the consummation of any of the transactions contemplated by 

this Agreement, or . . . seeking any determination or ruling that might 

materially and adversely [a]ffect the performance by the Seller of its 

obligations under, or the validity and enforceability of, this 

Agreement.” 

(c) “With respect to each Life Settlement Policy: . . . Prior to the transfer 

of each Life Settlement Policy to [Ritchie I], the Seller shall have 

taken all action under applicable law in each relevant jurisdiction in 

order to protect and perfect the ownership of the Seller in such policy . 

. . .” 

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(d) “All Life Settlement Policies the purchases of which are being funded . 

. . have been (A) Originated by the Seller or an Affiliate of the Seller 

in one or more transactions that in all material respects were in 

accordance with and in compliance with all applicable United States 

federal, state and local laws, rules and regulations applicable to life 

settlement transactions and the purchase and resale of life insurance 

policies, or (B) purchased from an unaffiliated third party in one or 

more transactions that, to the Seller’s knowledge, were in accordance 

with and in compliance with, in all material respects, all applicable 

United States federal, state and local laws, rules and regulations 

applicable to the purchase of life insurance policies from third persons 

that are not the Original Sellers.” 

35. These drafts culminated in an agreement between Ritchie I and LST for 

the sale of policies. The amended and restated version of that agreement, dated as of 

September 8, 2005 (the “Ritchie I Policy Purchase Agreement”) was signed for Coventry 

by Alex Seldin. In this document, Coventry made representations substantially identical 

to those referred to in paragraph 34 above. 

36. In drafts of an agreement between Ritchie II and LST sent by email on, 

among other occasions, December 7, 2005, to Ritchie Capital’s representatives, 

including, among others, John (Jeff) Mulholland, Coventry made representations 

substantially identical to those referred to in paragraph 34 above. 

37. These drafts culminated in a Master Policy Purchase Agreement between 

Ritchie II and LST dated as of December 15, 2005 (the “Ritchie II Policy Purchase 

Agreement”), and signed for Coventry by Alex Seldin. In this document, Coventry made 

representations identical to those made in the Ritchie I Policy Purchase Agreement. 

38. Plaintiffs reposed their trust and confidence in Defendants, who were in a 

position of superior knowledge and information with respect to the purchase of the 

policies. Plaintiffs were not involved in the purchase of the policies from the insureds and 

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had no information about what the insureds were told and what they knew in connection 

with the sale of their policies. 

39. Plaintiffs had no reason to believe that Defendants were engaging in 

misconduct in the purchase of the policies, much less that Coventry was under 

investigation for that misconduct. Ritchie Capital had conducted due diligence on 

Defendants and relied on them precisely because they had a reputation for integrity in the 

life settlements industry and projected an image of cleanliness. The Coventry executives 

with whom Ritchie Capital dealt – in particular Defendants Reid Buerger, Antonio 

Muniz, and Alan Buerger – appeared to be legitimate businessmen and frequently assured 

Ritchie Capital that Coventry, unlike some of its competitors, was scrupulous about 

complying with regulatory requirements. 

B. Defendants’ Fraud

40. In fact, however, Defendants were engaged in pervasive fraud. The fraud 

was three-fold: first, Defendants systematically defrauded the insureds from whom 

Coventry purchased policies; second, Defendants defrauded Plaintiffs in concealing from 

them the dishonest and unlawful conduct; and third, Defendants defrauded Plaintiffs in 

concealing from them that Coventry was under investigation by the Attorney General of 

New York. 

Defendants’ Fraud Against Sellers of Policies

41. Coventry’s fraud against those from whom it purchased policies took two 

general forms. First, when life settlement brokers pretended to conduct auctions, 

Coventry would pay the brokers undisclosed fees not to relay or otherwise act on offers 

from Coventry’s competitors. Second, Coventry would provide brokers with a “gross 

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offer” – a lump sum to be divided between a broker and policy owner with the seller 

never learning the amount of the sum and therefore the amount retained by the broker – 

and then falsify documentation in order to conceal from the seller part or all of the 

broker’s compensation. 

42. Following are some illustrative examples, taken from the complaint filed 

by the Attorney General of New York in October 2006, of the first category of fraud 

against those from whom Coventry purchased policies. 

(a) In 2003, a 79-year-old living in Hawaii decided to sell his 

$400,000 life insurance policy. He sold the policy to Coventry on April 16, 2003 for 

$102,000, of which he received $78,000 and a broker received $24,000. But another 

broker, Life Settlement Alliance (“LSA”), had a better offer, for $108,000, from another 

buyer. Coventry paid $12,000 to Life Settlement Alliance not to present the higher bid, 

and never disclosed the fee to the seller of the policy. 

(b) A family trust hired a broker to put on the market a $4.9 million 

policy insuring an 80-year-old woman. The broker solicited bids from Coventry and from 

AllSettled, a broker. In September 2004, Coventry submitted an offer of $705,000 and 

learned the next month of a competing offer for $880,000 submitted by AllSettled. Neal 

Jacobs, Coventry’s Director of Financial Underwriting, contacted AllSettled’s President 

Michael Krasnerman to work out a deal, and Krasnerman requested a 1.5% payoff to step 

aside. Coventry and AllSettled eventually agreed that Coventry would pay $49,000, or 

1% of the death benefit, and in exchange AllSettled would stand down. An email from 

Jacobs to Krasnerman on November 2, 2004 stated: “for [insured’s initials], the number 

is 49.” On November 11, 2004, Lenore Saracino, a vice president at AllSettled, wrote a 

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note: “Close file[.] Have a co-brokering fee with Coventry.” On December 28, 2004, the 

trust received $800,000, of which $142,500 went to the broker. 

(c) In late 2004, Coventry offered a broker $3.1 million for a policy 

with a $10 million death benefit. The policy insured a 79-year-old man from New Jersey 

and was owned by a family member. Near the end of the bidding process, AllSettled’s 

Saracino forwarded a competing offer of $3,525,000 to Coventry’s Jacobs, who 

forwarded it to Reid Buerger. Rather than compete with AllSettled, Coventry entered into 

a side deal under which AllSettled would receive $200,000 in exchange for not 

presenting the higher offer. Jacobs sent AllSettled’s Krasnerman an email on December 

16, 2004 stating “number is 200” and then followed up with an email to Coventry’s 

accounting department: “[AllSettled is] now co-broker for $200K.” The purchase closed 

on December 28, 2004 with Coventry paying $3.1 million, of which the seller’s broker 

received $153,053 and the seller received the remainder without ever learning of the 

better offer. 

43. The foregoing are merely illustrative examples. The New York Attorney 

General’s complaint (attached hereto as Exhibit A) sets forth many more examples of 

bid-rigging, and notes (at paragraph 46) that beyond those, the Attorney General’s office 

“has revealed literally dozens of other examples of bid rigging by Coventry and Brokers.” 

Plaintiffs hereby incorporate by reference paragraphs 27 to 45 of the New York Attorney 

General’s complaint as if fully set forth herein. 

44. The second type of fraud against those from whom Coventry purchased 

policies involved the allocation of payments as between policy sellers and their brokers. 

As the New York Attorney General’s complaint explains, brokers, with the knowledge 

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and assistance of Coventry, frequently concealed from policy sellers the gross payment 

from Coventry – and thus concealed as well the amount of their compensation. 

45. In some states – including Arkansas, Florida, Indiana, Kansas, Kentucky, 

Nebraska, Nevada, North Carolina, North Dakota, Ohio, Pennsylvania, Tennessee, and 

Utah – buyers of life insurance policies are required to disclose to sellers the amount of 

the broker’s compensation. In other states, there is no such requirement. In both types of 

states, however, Coventry presented sellers with false documentation. 

46. For example, in one case Coventry purchased a policy insuring an 80-

year-old man in New York. The seller of the policy received $317,000, the primary 

broker received $11,250, and another broker received $3,750. On July 27, 2004 Coventry 

sent offer sheets to the brokers reflecting this compensation. The brokers signed and 

returned the sheets to Coventry, and that ended the bidding process. But later an advisor 

of the seller inquired of the first broker how much compensation the broker had or would 

receive. At the broker’s request, Coventry supplied falsified offer sheets making it appear 

as if the first broker had received only $1,250 in compensation instead of the $11,250 he 

actually received. On August 31, 2004 Coventry emailed the falsified offer sheets to the 

second broker for his signature. The second broker signed and returned the new offer 

sheets on September 2, 2004. 

47. In another case involving a policy insuring an 87-year-old man from 

Nevada, Coventry agreed to pay $42,000 in broker compensation: $21,000 to LSA and 

$21,000 to a brokerage known as Advanced. A Coventry vice president named Jim 

Dodaro emailed Reid Buerger and others at Coventry on December 22, 2004 to suggest 

that they falsify the disclosure forms attached to the purchase agreement: “Total comp is 

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42K to LSA (they were paying Advanced 21K of it). Looks like we have to do a new Ex 

A disclosing comp. Can we lower the gross offer by 22K, put 20K comp on the Ex A, 

defer 1K to LSA and pay 21K to Advance as a co-broker?” Following Dodaro’s 

suggestion, Coventry disclosed only $20,000 on the “Exhibit A” disclosure form attached 

to the purchase agreement. The remaining $22,000 was paid to the brokers as a co-broker 

payment and deferred compensation but was never disclosed to the seller. 

Defendants’ Fraud Against Ritchie Capital

48. Defendants deceived Plaintiffs as to Defendants’ practices in the purchase 

of life insurance policies. Plaintiffs knew nothing of, and in fact had no reason to know 

of, Defendants’ systemic misconduct. Plaintiffs learned of the misconduct only when the 

Attorney General of New York brought suit against Coventry in October 2006. 

49. Defendants also deceived Plaintiffs as to the existence and target of the 

Attorney General’s investigation. Defendants first of all failed to disclose to Plaintiffs 

that an investigation was under way. Plaintiffs learned of the investigation from the 

Attorney General’s lawsuit. In fact, the investigation began in or about June 2005, and 

Defendants, on information and belief, knew of it no later than August 2006 and quite 

possibly earlier. 

50. Coventry received a subpoena requesting documents from the New York 

Attorney General in March 2006 but did not disclose the subpoena to Plaintiffs until a 

telephone conference on June 26, 2007, and even then did not describe the subpoena fully 

and accurately. 

51. During this telephone conference and one held the next day, Coventry’s 

counsel stated on behalf of Coventry had “received requests for additional information” 

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and that “NFP was likely the target.” (“NFP” is National Financial Partners, a network of 

financial planners that, according to a June 12, 2006 article in TheStreet.com, was being 

investigated by the New York Attorney General. NFP owns a brokerage specializing in 

life settlements. On information and belief, some of NFP’s members had worked with 

Coventry on the sale of life insurance policies.) Coventry’s counsel stated, among other 

things, that the focus of the Attorney General’s request was compensation arrangements 

between providers and brokers, as well as disclosure to sellers; that one question on the 

subpoena asked whether Coventry had paid fees to brokers to provide non-competitive 

bids; that the Attorney General was interested in suppression of competition through 

commissions; and that the Attorney General was looking for bid-rigging. Coventry’s 

disclosures to Plaintiffs about the subpoena were false and misleading, because, among 

other reasons, Coventry did not disclose that it was engaged in precisely the conduct 

targeted by the subpoena, and in fact affirmatively implied the opposite. Participants in 

these telephone conferences included Coventry’s in-house counsel Alex Seldin as well as 

Coventry’s outside counsel; Mulholland, who represented Plaintiffs; and Ritchie 

Capital’s counsel. 

52. On June 22, 2006, Alan Buerger had emailed to Mulholland the article 

from TheStreet.com, and led Mulholland to believe that the New York Attorney General 

was interested only in NFP, and that Coventry had nothing to do with the practices being 

investigated by the New York Attorney General. 

THE PATTERN OF UNLAWFUL RACKETERRING ACTIVITY

53. As described in the preceding paragraphs, the Defendants conspired with 

one another to defraud the Plaintiffs and the policy owners from whom Coventry 

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purchased life insurance policies. The Defendants participated in numerous racketeering 

activities in order to accomplish the purposes of their fraudulent scheme, namely, to 

induce policy owners to sell their policies in an unfairly rigged bidding process and to 

induce institutional investors, such as Ritchie Capital, to partner with Defendants to 

obtain those policies. 

54. As part of the scheme to defraud, Defendants conspired together to devise 

and participate in a plan of deception, whereby they would and did use false and 

fraudulent pretenses, representations, promises, and statements calculated to deceive 

persons of ordinary prudence and due care and make material nondisclosures and 

concealment of fact and information essential to policy owners in deciding whether and 

for how much to sell their policies, and essential to institutional investors in deciding 

whether and on what terms to partner with Coventry in the secondary life insurance 

market. 

55. Thus, Defendants unlawfully, intentionally, and willfully, and with the 

intent to defraud, that is, knowingly and with specific intent to deceive in order to cause 

financial gain, procured or caused Coventry to procure life insurance policies, and sold or 

caused Coventry to sell those policies to institutional investors to the detriment of such 

investors, including Plaintiffs. 

56. In carrying out the scheme to defraud policy owners and Plaintiffs, 

Defendants engaged in conduct in violation of the federal laws, including mail fraud in 

violation of 18 U.S.C. § 1341 and wire fraud in violation of 18 U.S.C. § 1343, as set forth 

below. 

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(a) Defendants have engaged in a scheme or artifice to defraud in 

which they have fraudulently and with fraudulent intent obtained 

life insurance policies and fraudulently induced institutional 

investors to purchase those policies from Defendants. This scheme 

entailed bid-rigging, bribery, and the falsification of documents 

pertaining to purchases of life insurance policies from policy 

owners. The scheme also included concealing from Plaintiffs both 

that conduct and the New York Attorney General’s investigation 

into that conduct. 

(b) Defendants’ fraud was material, in that it influenced whether and 

at what price policy owners sold life insurance policies to 

Defendants. Defendants’ fraud likewise influenced whether and on 

what terms Plaintiffs agreed to invest with Defendants in life 

insurance policies. 

(c) Defendants through their fraudulent scheme obtained property 

from policy owners and from Plaintiffs. From policy owners, 

Defendants obtained life insurance policies. From Plaintiffs, 

Defendants obtained payment for life insurance policies, and 

therefore a profit, because Plaintiffs paid Defendants more for each 

policy than Defendant had paid for it. 

(d) Defendants’ fraudulent scheme was furthered by numerous uses of 

interstate wires and mail, some of which are described below. 

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(e) Neal Jacobs’s e-mail message to Michael Krasnerman on 

November 2, 2004, described in paragraph 42(b) of this complaint 

and paragraph 30 of the New York Attorney General’s complaint, 

violated the federal wire fraud statute (18 U.S.C. § 1343) and 

constitutes a predicate act of racketeering under 18 U.S.C. 

§ 1961(b). 

(f) Neal Jacobs’s e-mail message to Michael Krasnerman on 

December 16, 2004, described in paragraph 42(c) of this complaint 

and paragraph 32 of the New York Attorney General’s complaint, 

violated the federal wire fraud statute (18 U.S.C. § 1343) and 

constitutes a predicate act of racketeering under 18 U.S.C. 

§ 1961(b). 

(g) The e-mailing of falsified offer sheets on August 31, 2004, 

described in paragraph 46 of this complaint and paragraph 62 of 

the New York Attorney General’s complaint, violated the federal 

wire fraud statute (18 U.S.C. § 1343) and constitutes a predicate 

act of racketeering under 18 U.S.C. § 1961(b). 

(h) Jim Dodaro’s e-mail message to Reid Buerger on December 22, 

2004, described in paragraph 47 of this complaint and paragraph 

64 of the New York Attorney General’s complaint, violated the 

federal wire fraud statute (18 U.S.C. § 1343) and constitutes a 

predicate act of racketeering under 18 U.S.C. § 1961(b). 

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(i) Jim Dodaro’s e-mail message to Reid Buerger on March 5, 2003, 

described in paragraph 28 of the New York Attorney General’s 

complaint, violated the federal wire fraud statute (18 U.S.C. 

§ 1343) and constitutes a predicate act of racketeering under 18 

U.S.C. § 1961(b). 

(j) Reid Buerger’s e-mail message to Jim Dodaro on or about 

November 18, 2004, described in paragraph 33 of the New York 

Attorney General’s complaint, in which Reid Buerger approved a 

co-broker payment to the East Coast Settlement Company, violated 

the federal wire fraud statute (18 U.S.C. § 1343) and constitutes a 

predicate act of racketeering under 18 U.S.C. § 1961(b). 

(k) Each and every e-mail message sent by Jim Dodaro described in 

paragraphs 37 to 39 of the New York Attorney General’s 

complaint violated the federal wire fraud statute (18 U.S.C. 

§ 1343) and constitutes a predicate act of racketeering under 18 

U.S.C. § 1961(b). 

(l) Jim Dodaro’s e-mail message to Coventry’s accountant on May 5, 

2005, described in paragraph 40 of the New York Attorney 

General’s complaint, violated the federal wire fraud statute (18 

U.S.C. § 1343) and constitutes a predicate act of racketeering 

under 18 U.S.C. § 1961(b). 

(m) Jim Dodaro’s e-mail message to Eileen Shovlin on July 20, 2005, 

described in paragraph 43 of the New York Attorney General’s 

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21 

complaint, violated the federal wire fraud statute (18 U.S.C. 

§ 1343) and constitutes a predicate act of racketeering under 18 

U.S.C. § 1961(b). 

(n) Eileen Shovlin’s e-mail message to Jim Dodaro on July 20, 2005, 

described in paragraph 43 of the New York Attorney General’s 

complaint, violated the federal wire fraud statute (18 U.S.C. § 

1343) and constitutes a predicate act of racketeering under 18 

U.S.C. § 1961(b). 

(o) Jim Dodaro’s e-mail message to Neal Jacobs on February 8, 2005, 

described in paragraph 44 of the New York Attorney General’s 

complaint, violated the federal wire fraud statute (18 U.S.C. 

§ 1343) and constitutes a predicate act of racketeering under 18 

U.S.C. § 1961(b). 

(p) The “co-broker” payments discussed in paragraphs 42 to 47 of this 

complaint and paragraphs 27 to 45 of the New York Attorney 

General’s complaint, as well as other such payments not 

specifically enumerated in the complaints, were made in 

furtherance of Defendants’ fraudulent scheme. To the extent that 

any of those “co-broker” payments were made by interstate wires 

or mail, defendants violated 18 U.S.C. § 1343 and 18 U.S.C. 

§ 1341, respectively. Each violation of these statutes is a predicate 

act of racketeering. 

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(q) The purchase agreements relating to the transactions described in 

paragraphs 42 to 47 of this complaint or paragraphs 27 to 45 of the 

New York Attorney General’s complaint, as well as other such 

purchase agreements not specifically enumerated in the 

complaints, made material misrepresentations and/or omissions of 

fact in furtherance of Defendants’ fraudulent scheme. In particular, 

the purchase agreements did not disclose to policy holders that 

Defendants had fraudulently influenced the purchase of their life 

insurance policies through tactics such as bid-rigging and cobroker payments. To the extent that any of those purchase 

agreements were transmitted by interstate wires or mail, 

defendants violated 18 U.S.C. § 1343 and 18 U.S.C. § 1341, 

respectively. Each violation of these statutes is a predicate act of 

racketeering. 

(r) In the negotiations that culminated in. among other things, the 

Ritchie I Policy Purchase Agreement and the Ritchie II Policy 

Purchase Agreement, as well as in the negotiations that culminated 

in the Ritchie IV arrangement (described and defined in paragraph 

64 below), Alex Seldin, Reid Buerger, and Antonio Muniz 

transmitted or caused to be transmitted over email documents 

containing the statements set forth in paragraphs 34 to 37 above. 

The transmission of these statements violated the federal wire 

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23 

fraud statute (18 U.S.C. § 1343) and constitutes predicate acts of 

racketeering under 18 U.S.C. § 1961(b). 

(s) During the interstate telephone conference occurring in or about 

June 2006, as described in paragraphs 50-51 of this complaint, 

Reid Burger and Coventry’s counsel acted in furtherance of 

Defendants’ fraudulent scheme by misrepresenting to Plaintiffs the 

nature of the New York Attorney General’s investigation. That 

misrepresentation violated the federal wire fraud statute (18 U.S.C. 

§ 1343) and constitutes a predicate act of racketeering under 18 

U.S.C. § 1961(b). 

57. This enumeration of predicate acts of racketeering is not exhaustive. As 

explained in the New York Attorney General’s complaint, Defendants used interstate 

wires and mail on numerous other occasions in furtherance of their fraudulent scheme. 

DAMAGE TO PLAINTIFFS CAUSED BY DEFENDANTS’ ILLEGAL CONDUCT

58. Ritchie I and Ritchie II own the life insurance policies at issue. The market 

value of those policies has greatly diminished since the New York Attorney General’s 

action was commenced. 

59. Each of the plaintiffs anticipated a profit from the planned sale of the 

policies in a securitization transaction. For purposes of completing the securitization 

transaction, Plaintiffs, with the support and encouragement of Coventry, had obtained a 

pre-sale report and a rating from the Moody’s service on a number of the policies. 

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24 

60. When the Attorney General’s action became public, Moody’s withdrew its 

rating “in light of the uncertainty surrounding the transaction in light of the complaint 

filed by the New York State Attorney General.” 

61. On information and belief, Moody’s had lost confidence in the health of 

the collateral – i.e., the policies. Specifically, Moody’s no longer believed in the 

representations and warranties made by Ritchie I and Ritchie II to potential investors in 

the securitization, which themselves relied on representations and warranties made by 

Coventry to Ritchie I and Ritchie II. Moody’s, that is, no longer believed that the policies 

had been purchased in compliance with applicable legal requirements. 

62. Defendants’ misconduct has thus directly interfered with the salability and 

value of the life insurance policies at issue. Defendants’ misconduct therefore harmed not 

only Ritchie I and Ritchie II, but the entities (such as Ritchie Trust I, Ritchie Master 

Trust, Ritchie Risk-Linked, and RCM) that own or are beneficially interested in Ritchie I 

and Ritchie II and that were owed fiduciary duties and other duties breached by 

Coventry. 

63. Ritchie I and Ritchie II continue to pay enormous amounts in premiums 

and fees to service the policies, the salability of which has been impaired by Defendants’ 

misconduct. 

64. Moreover, in or about June 2006, Ritchie Capital committed additional 

capital to the arrangement with Coventry. The June 2006 commitment was known as 

“Ritchie IV.” The Ritchie IV transaction never resulted in the purchase of policies, but 

Ritchie Capital (including Ritchie Trust I, Ritchie Master Trust, Ritchie Risk-Linked, and 

RCM) – which was induced to enter into the Ritchie IV arrangement by Coventry’s 

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fraudulent conduct in connection with Ritchie I and Ritchie II, including the 

representations described in paragraphs 34 to 37 above – suffered substantial transaction 

costs and opportunity costs in connection with Ritchie IV. 

65. It was entirely foreseeable that Defendants’ misconduct would damage 

Plaintiffs in these ways. Defendants represented that the policies had been purchased in 

compliance with law. Defendants knew that Plaintiffs’ reason for purchasing the policies 

was to realize a profit by securitizing and selling them. Defendants also knew that they 

were participating in fraud on the owners of the policies – fraud that, if it came to light, 

would greatly diminish the salability and value of the policies and destroy the possibility 

of realizing a profit through the securitization. Defendants therefore knew that they were 

creating serious risks for Plaintiffs. 

66. Coventry in substance was using Plaintiffs’ capital to acquire assets that, 

because of Coventry’s own misconduct, turned out to be worth far less than what 

Plaintiffs had reason to believe they were worth. At the same time, Coventry was 

profiting from its misconduct, because it sold the policies to Plaintiffs at prices higher 

than those Coventry paid. 

67. Had Plaintiffs known that Coventry engaged in bid-rigging and other 

illegal practices, Plaintiffs never would have done business with Coventry, let alone 

continued to commit additional capital to the arrangement with Coventry. 

COUNT ONE

(Violation of RICO, 18 U.S.C. § 1962(a) – against all defendants) 

68. Each of the foregoing allegations is incorporated herein by reference. 

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69. All Defendants are “persons” within the meaning of 18 U.S.C. §§ 1961(3) 

and 1964(a). 

70. Ritchie I and Ritchie II are enterprises within the meaning of 18 U.S.C. 

§ 1961(4). 

71. Ritchie I and Ritchie II engage in interstate commerce, as well as activities 

affecting interstate commerce, by obtaining life insurance policies from Coventry in 

Pennsylvania for the purpose of selling those policies in securitization transactions 

occurring in other states, such as New York. 

72. Defendants have received income or proceeds derived directly or 

indirectly from a pattern of racketeering activity within the meaning of 18 U.S.C. 

§§ 1961(1)and 1961(5) and § 1962(a), to wit: 

(a) Multiple instances of mail fraud in violation of 18 U.S.C. § 1341; 

and 

(b) Multiple instances of wire fraud in violation of 18 U.S.C. § 1343. 

73. Defendants used or invested the income and/or proceeds of this pattern of 

racketeering activity, namely insurance policies, in the acquisition of an interest in or the 

establishment or operation of, Ritchie I and Ritchie II, in violation of 18 U.S.C. § 

1962(a). 

74. Plaintiffs were injured in their business and property within the meaning 

of 18 U.S.C. § 1964(c) by reason of the violation of 18 U.S.C. § 1962(a) committed by 

Defendants. Specifically, because the insurance policies used or invested by Defendants 

were tainted by Defendants’ racketeering activities, the salability of those policies now is 

uncertain, and therefore the policies, for which Plaintiffs expended funds, now are worth 

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far less than what Plaintiffs expected to be able to sell them for and in any event what 

Plaintiffs paid for them. 

75. Plaintiffs were injured in an as yet undetermined amount, believed to be 

not less than approximately $700 million. Pursuant to 18 U.S.C. § 1964(c), Plaintiffs are 

entitled to recover treble damages and the cost of this suit, including a reasonable 

attorney’s fee. 

COUNT TWO

(Violation of RICO, 18 U.S.C. § 1962(c) – against all defendants) 

76. Each of the foregoing allegations is incorporated herein by reference. 

77. There is an enterprise within the meaning of 18 U.S.C. § 1961(4) 

consisting of all of the individual Defendants, or any combination thereof, or any of the 

corporate defendants alone. 

78. The enterprise referred to in the preceding paragraph is engaged in 

interstate commerce, as well as activities affecting interstate commerce, by purchasing 

life insurance policies in several states, including California, Hawaii, Nevada, and 

Florida, for the purpose of transferring those policies to Plaintiffs in Ireland and / or other 

states, such as New York. 

79. Defendants were all (subject to the exception in the final sentence of this 

paragraph) persons within the meaning of § 1962(c), distinct from the enterprise referred 

to in paragraph 77, and employed by or associated with that enterprise. Defendants did 

conduct or participate, directly or indirectly, in the conduct of the enterprise’s affairs 

through a pattern of racketeering activity within the meaning of 18 U.S.C. §§ 1961(1) and 

1961(5) and § 1962(c), to wit: 

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(a) Multiple instances of mail fraud in violation of 18 U.S.C. § 1341; 

and 

(b) Multiple instances of wire fraud in violation of 18 U.S.C. § 1343. 

To the extent that the enterprise consisted solely of one of the corporate defendants, that 

defendant was not distinct from the enterprise and did not conduct or participate in the 

enterprise’s affairs for purposes of this paragraph. 

80. Plaintiffs were injured in their business or property within the meaning of 

18 U.S.C. § 1964(c) by reason of the violation of 18 U.S.C. § 1962(c) committed by 

Defendants. Specifically, Plaintiffs were fraudulently induced to invest with Coventry in 

life insurance policies that, because of Defendants’ racketeering activity, actually were 

worth, unbeknownst to Plaintiffs at the time, either nothing or a tiny fraction of what 

Plaintiffs paid for the policies. Indeed, because of Defendants’ racketeering activities 

Plaintiffs have received essentially nothing in return for their investment. Moreover, 

Plaintiffs were injured when they committed capital to Ritchie IV, which turned out to be 

an abortive venture because of Defendants’ racketeering activities. 

81. Plaintiffs were injured in an as yet undetermined amount, believed to be 

not less than $700 million. Pursuant to 18 U.S.C. § 1964(c), Plaintiffs are entitled to 

recover treble damages and the cost of this suit, including a reasonable attorney’s fee. 

COUNT THREE

(Conspiracy to Violate RICO, 18 U.S.C. § 1962(d) – against all defendants) 

82. Each of the foregoing allegations is incorporated herein by reference. 

83. Defendants were all (subject to the exception in the final sentence of this 

paragraph) persons within the meaning of § 1962(d) and distinct from the enterprise 

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referred to in paragraph 77 above. Defendants conspired within the meaning of 18 U.S.C. 

§ 1962(d) to violate 18 U.S.C. §§ 1962(c). In particular, Defendants conspired to conduct 

or participate, directly or indirectly, in the conduct of the enterprise’s affairs through a 

pattern of racketeering activity within the meaning of 18 U.S.C. §§ 1961(1) and 1961(5) 

and § 1962(c), to wit: 

(a) Multiple instances of mail fraud in violation of 18 U.S.C. § 1341; 

and 

(b) Multiple instances of wire fraud in violation of 18 U.S.C. § 1343. 

To the extent that the enterprise consisted solely of one of the corporate defendants, that 

defendant was not distinct from the enterprise and did not conspire to conduct or 

participate in the enterprise’s affairs for purposes of this paragraph. 

84. Defendants are all persons within the meaning of 18 U.S.C. § 1962(a) who 

conspired to use or invest the income and/or proceeds of their pattern of racketeering 

activity, namely insurance policies, in the acquisition of an interest in or the 

establishment or operation of the enterprises described in paragraph 70 above, in 

violation of § 18 U.S.C. § 1962(a). 

85. Plaintiffs were injured in their business or property within the meaning of 

18 U.S.C. § 1964(c) in an as yet undetermined amount, believed to be not less than 

approximately $700 million, by reason of Defendants’ violation of § 1962(d). Pursuant to 

18 U.S.C. § 1964(c), Plaintiffs are entitled to recover treble damages and the cost of this 

suit, including a reasonable attorney’s fee. 

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COUNT FOUR

(Fraud – against all corporate defendants, 

Alan Buerger, Reid S. Buerger, Antonio Muniz, and Alex Seldin) 

86. Each of the foregoing allegations is incorporated herein by reference. 

87. As detailed herein, Reid S. Buerger, Alan Buerger, Constance Buerger, 

and / or Antonio Muniz, acting for themselves and on behalf of Coventry First, The 

Coventry Group, Inc., Montomery Capital, Inc., and / or LST, made material 

misstatements to Plaintiffs, and omitted to disclose material information that they were 

obligated to disclose to Plaintiffs, regarding (1) the circumstances under which owners of 

life insurance policies were induced to part with their policies, and (2) the existence and 

target of the New York Attorney General’s investigation into Coventry. 

88. These misstatements and omissions were committed knowingly, 

intentionally, and willfully, and were intended to induce Plaintiffs to rely on them. 

89. Reasonably relying on these misstatements and omissions, Plaintiffs acted 

to their detriment by investing in life insurance policies worth much less than Plaintiffs 

had reason to believe they were worth, and committing capital to Ritchie IV. 

90. As a direct and proximate result of Defendants’ fraud, Plaintiffs have 

suffered damages in an amount believed to be not less than $700 million. 

COUNT FIVE

(Fraudulent Inducement – against all corporate defendants, 

Alan Buerger, Reid S. Buerger, Antonio Muniz, and Alex Seldin) 

91. Each of the foregoing allegations is incorporated herein by reference. 

92. As detailed herein, in connection with, among other agreements, the 

Ritchie I Policy Purchase Agreement and the Ritchie II Policy Purchase Agreement, Reid 

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S. Buerger, Alan Buerger, Constance Buerger, and / or Antonio Muniz, acting for 

themselves and on behalf of Coventry First, The Coventry Group, Inc., Montomery 

Capital, Inc., and / or LST knowingly or recklessly made false and misleading statements 

to, and knowingly or recklessly concealed information from and did not disclose 

information to Plaintiffs regarding Coventry’s practices in purchasing life insurance 

policies. 

93. Under the circumstances, Coventry had a duty to disclose the omitted 

information. 

94. The misstatements and omissions were intended to induce, and did induce, 

Plaintiffs to act to their detriment in that (1) Ritchie Capital caused Ritchie I and Ritchie 

II to enter into, and Ritchie I and Ritchie II in fact entered into, among other agreements, 

the policy purchase agreements, and (2) Ritchie Capital entered into the Ritchie IV 

arrangement. 

95. Plaintiffs entered into these arrangements to their detriment, as described 

herein. 

96. As a direct and proximate result of Defendants’ fraud, Plaintiffs have 

suffered damages in an amount believed to be not less than $700 million. 

COUNT SIX

(Breach of Fiduciary Duty – against all corporate defendants)

97. Each of the foregoing allegations is incorporated herein by reference. 

98. Coventry was the partner, joint venturer, and co-venturer of Ritchie 

Capital and in consequence owed Plaintiffs a duty of the highest loyalty. Coventry, 

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moreover, occupied a position of superior knowledge with respect to the purchase and 

servicing of life insurance policies. 

99. The fiduciary duty owed by Coventry to Plaintiffs obligated Defendants to 

make full disclosure of all material circumstances surrounding the purchase of life 

insurance policies, and of the existence of the New York Attorney General’s 

investigation. 

100. Defendants concealed this information and thereby misled Plaintiffs to 

their detriment in that they invested in life insurance policies worth much less than 

Plaintiffs had reason to believe they were worth, and committed capital to Ritchie IV. 

101. As a direct and proximate result of Defendants’ breach of fiduciary duty, 

Plaintiffs have suffered damages in an amount believed to be not less than $700 million. 

COUNT SEVEN

(Breach of Contract – against all corporate defendants) 

102. Each of the foregoing allegations is incorporated herein by reference. 

103. LST is a mere alter ego, agency, and instrumentality of Coventry First and 

the Coventry corporate family. The affairs of LST, which is wholly-owned by Coventry 

First, are completely dominated by Coventry First and the Coventry corporate family. On 

information and belief, LST has no assets of its own, and its officers and directors all are 

officers and directors of Coventry First and the Coventry corporate family. LST conducts 

no business of its own but was merely a conduit for Coventry’s sale of life insurance 

policies to Ritchie I and Ritchie II. 

104. Pursuant to the Ritchie I Policy Purchase Agreement and the Ritchie II 

Policy Purchase Agreement, Coventry represented, among other things, that: 

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(i) Coventry’s acquisition of policies was in compliance with all laws 

and regulations, there was no proceeding pending or threatened 

involving any agency or governmental body seeking to prevent the 

transactions contemplated by the agreements or seeking a 

determination that might affect the performance by Coventry of its 

obligations; 

(ii) before conveying the life insurance policies to Ritchie I or Ritchie II, 

Coventry would take all reasonable actions under applicable law to 

protect and perfect its ownership of the policy; and 

(iii) Coventry acquired the policies directly from the insureds in 

transactions that in all material respects complied with all applicable 

laws, or acquired the policies from third parties in transactions that 

to Coventry’s knowledge complied in all material respects with all 

applicable laws. 

105. Coventry breached its contracts with Ritchie I and Ritchie II in that these 

representations and warranties were false as to some or all of the policies purchased by 

Ritchie I and Ritchie II from Coventry. 

106. By reason of Coventry’s breach, Plaintiffs have suffered damages in an 

amount believed to be not less than $700 million. 

107. Plaintiffs are entitled pursuant to the policy purchase agreements to 

rescind the life settlement transactions through which Coventry transferred the life 

insurance policies to them. 

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 WHEREFORE, Plaintiffs pray for judgment against Defendants as follows: 

(a) All damages proven pursuant to RICO, trebled as permitted by law; 

(b) All other compensatory damages sustained by Plaintiffs; 

(c) Punitive damages, in an appropriate amount to be determined at trial; 

(d) Rescission of the relevant life settlement transactions between 

Plaintiffs and Defendants; 

(e) Attorneys’ fees and costs; 

(f) Prejudgment and post-judgment interest; and 

(g) Such other relief as the Court may deem just and proper. 

JURY DEMAND

 Plaintiffs demand a trial by jury on all issues so triable. 

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Exhibit A 

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