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Q. And liability insurance cases. Did you ever
request a legal opinion as to whether UPS's activity was
similar or distinguishable?
A. No.
Q. During the negotiations, did you ever request an
opinion regarding whether federal transportation law
preempted state regulation?
A. No, I didn't.
Q. Okay. At some point in late 1984, UPS decided to
go forward with the transaction. Correct?
A. 1983.
Q. 1983. I'm sorry.
A. 1983, yes.
Q. And it --
A. I don't know if it was late in 1983.
Q. It's not my intention to quibble about the date.
Sometime in 1983, UPS decided to go forward.
A. Yes.
Q. And at some point, the structure was fairly known
to you. National Union would be involved, and OPL would be
the reinsurer. Is that correct?
A. Yes.
Q. At that point in time, did you request a legal
opinion as to whether that satisfactorily alleviated your
concerns about state regulation?
A. No.
Q. Did UPS?
A. Not that I'm aware of.
Q. Now, was --
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