Ms. Kramer has been retained on numerous occasions by both the plaintiff and defense bars when there is a tender of policy limits and a need for a neutral to opine as to a pro rata distribution of the limits. One of her cases involved 15 heirs whom were entitled to two different insurance policies due to a catastrophic accident which resulted in the deaths of two family members. Ms. Kramer was asked to assist the parties in reaching an agreement as to the division of the proceeds. The parties designated seven (7) representatives, some as far away as Spain and England and who appeared via Zoom. Ms. Kramer was able to work out an amicable distribution in varying amounts. Another division of settlement matter Ms. Kramer worked on involved a tire blow-out on an SUV which caused a single vehicle rollover accident. The car’s occupants were a mix of family and friends and one individual had died due to her injuries, leaving heirs.