ok - I know of a VSX setup where it was upgraded from R80.10, to R80.30, then to R81, all the Jumbos are still installed and eating diskspace, hence unless a new jumbo or newer version of Checkpoint correctly uninstalls previous jumbo I think its better to uninstall the Jumbo first. There is really no right or wrong here, just preference based on local installation considerations.
One thing I have noted ina recent migration attempt:
When from R80.30 > R81.10 clean build so I can use xfs. Then had to do a full rollback which meant restoring snapshot I took. This failed (after it spent 2.5hrs uploading and then importing into the repository for restore).
I found out after (and I have sent my observations to TAC) is that the snapshot could not restore due to the xfs filesystem, even if I did a clean install of R80.30 using the T200.iso, so watch out for this.