anonymous letters in January, 1996, purportedly from a source close to the EMLICO matter, that alleged the insurer's move to Bermuda in the summer of 1995 was a "scam''.

The "whistleblower letters'', which appeared to have been written by someone within the EMLICO corporate structure, were just made public as a result of the HPAO bureau investigation into EMLICO.

The letters allege that EMLICO's ultimate parent, General Electric Co. (GE) was directly involved in the redomestication of the company from Beverly, Massachusetts to Bermuda.

One to the commissioner dated January 6, 1996 stated: "It's only too obvious to many of us that there is a paper trail, second to none, that would probably go a long way to answer any questions you have, yet you seem to want to avoid it.

"At this point in time, it is only fair to let you proceed with your investigation, however there are more than a few people that question whether the Insurance Division is truly trying to get to the bottom of what occurred here.

"If you do not probe as to who all the participants were and what exactly was the driver for the redomestication (HINT: FOLLOW THE TAX IMPACT TO GE), you will be missing the boat.'' A second letter, dated January 18, apparently from the same source, alleges that key executives involved "collectively conspired to withhold important information from you (Commissioner Ruthardt) during the course of the EMLICO redomestication hearings''.

COURTS CTS