This argument must be rejected. The facts proved in the criminal proceedings and in the multidistrict litigation have thoroughly established that those documents were false. Indeed, the data upon which the statements were based was entirely fabricated, and Poulsen knew this; he was the one who ordered that the data be falsified. See, e.g., Poulsen, 568 F.Supp.2d at 894-99; Poulsen, 2009 WL 1604975, at **10-11; In re Nat’l Century Fin. Enterprises, 783 F.Supp.2d at 1007-10. Further, it is uncontroverted that Poulsen’s representations about National Century’s financial condition were material to, and reasonably relied upon by, Great American in deciding whether to issue the policy. See, e.g., Nat’l Union Fire Ins. Co. of Pittsburgh, P.A. v. Sahlen, 999 F.2d 1532, 1536 (11th Cir.1993) (<HOLDING>); Jaunich II v. Nat’l Union Fire Ins. Co. of
holding that financial documents specifically required as part of the application were patently critical to the insurers decision to provide   o coverage holding that insurers failure to deny existence of insurance coverage under policy at issue was to admit that coverage existed holding that the language of  9133 applies only to insurers and not to the insurers employees holding that none of the physicians insurers had a duty to provide coverage since the effects of the negligence first manifested themselves prior to the coverage periods of any of the three policies holding defendants were required to provide certified english language translation of documents