As part of AEGIS' goal to anticipate the needs of its Members, and to better serve its Members in the area of risk management services regarding electric and magnetic fields (EMF), AEGIS has sponsored the development of this litigation service.

EMF litigation involves complex scientific, medical and legal issues which are specific to the EMF controversy. AEGIS sponsors a litigation information and assistance service for its Members and policyholders who are in EMF litigation or are imminently threatened by such litigation. While the service was created for AEGIS Members and policyholders, it may also be made available to electric utilities which are neither AEGIS Members nor policyholders, but are faced with EMF litigation.

The EMF litigation service helps avoid duplication of effort by individual utilities and provides access to key information in the quickest and most cost-effective manner possible. This has been achieved by centralizing EMF scientific and legal information, and by building on the EMF experience and knowledge accumulated to date. The purposes of this service are to ensure that AEGIS Members, policyholders and others have ready access to the information and resources needed for EMF litigation, and to reduce the costs of such litigation.

DESCRIPTION OF SERVICE
The service includes computerized EMF science and litigation databases supported by hardcopy libraries of materials useful in litigation These science and litigation databases have been developed by the law firm of Dewey & LeBoeuf. The science database includes over 20,000 references and is continually updated as new information becomes available. The litigation database is a computer directory and hardcopy library of legal motions, pleadings, testimony, exhibits, and other documents from previous and pending EMF cases. These documents can save utilities and in-house or outside counsel time and money when preparing for EMF litigation by building upon the successful approaches in prior cases, and by reducing the need to "reinvent the wheel."

This service is sponsored by AEGIS and is available through Dewey & LeBoeuf. The databases and libraries themselves are the work product of Dewey & LeBoeuf and will remain in the possession of Dewey & LeBoeuf. They will not be available for downloading by users of the service.

INTENDED USE OF SERVICE
This service is intended to support AEGIS Members and policyholders by providing specialized risk management tools and services for EMF litigation. It will help utilities identify and interpret relevant scientific and legal issues that may appear in lawsuits. It is meant to provide an organized structure through which utilities and their counsel can quickly get the expertise and knowledge they need.

SERVICE WILL NOT PROVIDE

This service is not a general EMF information service. It is not meant to replace the legal counsel that is presently serving the utility. Nor is its purpose to sell or otherwise distribute the databases, or provide unauthorized access to copyrighted information. It is not intended to be used as a resource for AEGIS Members or others who may want background material on EMF matters for general purposes.

SERVICE USERS
To use this service, parties must be in active EMF litigation or anticipate such litigation in the immediate future. All Members of AEGIS are eligible. Other utilities also may be eligible to use this service.

PROTOCOL FOR UTILIZING THE SERVICE
When a utility is engaged in or threatened by an EMF lawsuit, the following protocol should be followed to utilize this service:
AEGIS is contacted. The purpose of this contact is to evaluate several circumstances including the utility's status as a Member and/or policyholder, relationship to the electric utility industry and the status of pending litigation or the nature of anticipated litigation.

The appropriate persons to contact are:

AEGIS approves the use of the service and notifies the company and Dewey & LeBoeuf of its decision. At this point, the utility will have access to the service.

The utility representative and/or its legal counsel (either in-house or outside) contacts Robert J. Alessi at Dewey & LeBoeuf's Albany, New York offices at (518) 465-1500, to obtain the desired information and/or other services. At this time, the utility will enter into an attorney-client relationship with Dewey & LeBoeuf to maintain the attorney-client privilege, the joint defense privilege, and/or the attorney work product protection. Individual utilities, of course, will decide the scope/nature of the services or database information to be provided by Dewey & LeBoeuf as well as the terms/scope of the attorney-client relationship within which such services and/or information will be provided.

Dewey & LeBoeuf will provide an introductory consultation session for the qualified utility to familiarize it with the types of EMF information and assistance that are available. The initial consultation will be used to address the immediate needs of counsel and the utility and provide them with tools to begin development of their strategy. There is no cost to the utility for this introductory consultation session.

Beyond the introductory consultation session, Dewey & LeBoeuf will invoice individual utilities directly for fees and expenses to provide any additional requested services and/or database information.

SUMMARY OF KEY POINTS ABOUT THE SERVICE

• AEGIS sponsors this service to meet the demand for EMF risk management products and services enabling its Members to achieve the lowest long-term cost of risk.
• This is strictly a litigation service, and is not a general EMF information or EMF database access service.
• This service is for those electric utilities which are in active EMF litigation or which are imminently threatened with such litigation.
• The purpose is to provide ready access to needed EMF scientific and litigation information, and to reduce litigation costs by centralizing EMF litigation resources.
• The service is not just available to AEGIS Members and policyholders. Other utilities involved in EMF litigation can request access to this service by contacting AEGIS.
• This service is being sponsored by AEGIS for the benefit of the electric utility industry. The concept has been endorsed by a number of EMF counsel who regularly represent electric utilities in EMF litigation.
• Communications with Dewey & LeBoeuf regarding the database will be made within the context of the attorney-client relationship so that confidentiality will be preserved.<br>

TEAM
This service is overseen by a team of individuals who not only have been involved with the electric industry for years, but who have extensive experience and knowledge concerning EMF and EMF litigation.

The team consists of Robert J. Alessi, H.B. Graves, and Jeffrey Schupack and Stanley Schuldiner from AEGIS Insurance Services, Inc. (AEGIS Services). Dewey & LeBoeuf EMF Practice Group includes both litigators and scientists with extensive experience litigating EMF cases throughout the United States.

Mr. Alessi, who is the head of Dewey & LeBoeuf's EMF Practice Group, obtained a pharmacology degree before commencing his practice of law. He has successfully litigated EMF and numerous other human health and environmental cases on behalf of utilities, other major industries, and governmental entities in state and federal trial and appellate courts.

Dr. Graves, the Director of Environmental and Health Services at Dewey & LeBoeuf, has over 20 years experience in EMF issues, including over a decade as the Director of an EMF Research Laboratory at The Pennsylvania State University.

Mr. Schupack is Vice President/Senior Counsel of AEGIS Services, where he has worked since 1988, and been actively involved with EMF litigation and EMF issues.

Mr. Schuldiner is a Senior Litigation Counsel at AEGIS Services, where he has worked since 1989. He is AEGIS' representative to Edison Electric Institute's EMF Task Force.

Together, Messrs. Schupack and Schuldiner are responsible for the management of EMF claims for AEGIS, and are AEGIS' liaison to the utility industry on EMF issues.