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Exhibit C

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#:6853

' CEI

UNITED STATES DISTRICT [eH a

WESTERN DIVISION

JOYCE WALKER, ET AL.,

PLAINTIFFS,

CASE NO. CV 10-9198-JVS (RNBX)
SANTA ANA, CALIFORNIA
AUGUST 30, 2011

VS.

LIFE INSURANCE COMPANY

OF THE SOUTHWEST, (9:59 A.M. TO 11:49 A.M.)
(2:14 P.M. TO 2:17 P.M.)
(4:44 P.M. TO 5:45 P.M.)

DEFENDANT .

‘
se es ee ee ee es ee

DISCOVERY CONFERENCE

BEFORE THE HONORABLE ROBERT N. BLOCK
UNITED STATES MAGISTRATE JUDGE

APPEARANCES : SEE NEXT PAGE

COURT REPORTER: RECORDED; COURT SMART
COURTROOM DEPUTY: JOE ROPER
TRANSCRIBER: DOROTHY BABYKIN

COURTHOUSE SERVICES

1218 VALEBROOK PLACE
GLENDORA, CALIFORNIA 91740
(626) 963-0566

PROCEEDINGS RECORDED BY ELECTRONIC SOUND RECORDING;
TRANSCRIPT PRODUCED BY TRANSCRIPTION SERVICE.

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MR. SHAPIRO: THAT MAKES SENSE, YOUR HONOR. ‘THANK
YOU.

MR. FOSTER: THANK YOU.

THE CLERK: THIS COURT IS IN RECESS.

(RECESS, 11:39 A.M. TO 2:14 P.M.)

THE CLERK: PLEASE REMAIN SEATED AND AGAIN COME TO
ORDER. THIS COURT IS ONCE AGAIN IN SESSION. THE HONORABLE

MAGISTRATE JUDGE ROBERT N. BLOCK PRESIDING.

THE COURT: ALL RIGHT. BACK ON THE RECORD.

WHO WANTS TO TALK?

MR. SHAPIRO: IF I MAY, YOUR HONOR, WE HAVE CONTINUED
OUR DISCUSSIONS ON THE SOFTWARE ISSUE, WHICH IS EMBRACED BY
PLAINTIFFS’ REQUEST NUMBER 63. THE PARTIES HAVE REACHED AN
AGREEMENT AS TO AN ALTERNATIVE DISCOVERY REQUEST -- FUNCTIONAL
EQUIVALENT OF AN INTERROGATORY WITH A COUPLE OF SUBPARTS.

AND IF IT’S OKAY WITH YOUR HONOR, WE’D LIKE TO BE
ABLE TO PUT THE -- THAT PROSE ON THE RECORD.

IN EXCHANGE THE PLAINTIFFS HAVE AGREED WITHOUT
PREJUDICE TO WITHDRAW REQUEST NUMBER 63.

THE COURT: OKAY. LET’S HEAR IT.

MR. FOSTER: YOUR HONOR, AS MR. SHAPIRO HAS
INDICATED, THE PLAINTIFFS WILL WITHDRAW REQUEST NUMBER 63
WITHOUT PREJUDICE IN EXCHANGE FOR LSW’S PRODUCTION WITHIN TWO
WEEKS OF, FIRST, AN EXPLANATION OF THE DERIVATION OF THE

ACCUMULATED VALUES SET FORTH ON ONE ANNUAL STATEMENT FOR EACH

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NAMED PLAINTIFF. THE SPECIFIC ANNUAL STATEMENT TO BE SPECIFIED
BY PLAINTIFFS NO LATER THAN THE CLOSE OF BUSINESS TOMORROW,
INCLUDING DESCRIPTION OF ANY FORMULAS USED TO DERIVE SUCH
ACCUMULATED VALUES.

SECOND, AN EXPLANATION OF THE DERIVATION OF THE

SURRENDER VALUES CALCULATED FOR PLAINTIFF WALKER AND PLAINTIFF

SPOONER, INCLUDING DESCRIPTION OF ANY FORMULAS USED TO DERIVE
SUCH SURRENDER VALUES.

THIRD, AN EXPLANATION OF THE DERIVATION OF THE
ACCUMULATED VALUE AS OF TODAY'S DATE FOR PLAINTIFF HOWLETT,
INCLUDING DESCRIPTION OF ANY FORMULAS USED TO DERIVE SUCH
ACCUMULATED VALUES.

AND, FOURTH, ALL DATA INPUT FILES FROM WHICH VALUES
USED IN THE CALCULATIONS OF NUMBERS 1 THROUGH 3 ABOVE WERE
DRAWN, E.G., COST OF INSURANCE TABLES.

THE COURT: SO, MR. SHAPIRO, HAS MR. FOSTER
ACCURATELY RECITED WHAT LSW HAS AGREED TO DO?

MR. SHAPIRO: YES, THOSE ARE THE INTERROGATORIES.

THE COURT: ALL RIGHT. AND YOU’RE GOING TO DO THAT
WITHIN TWO WEEKS?

MR. SHAPIRO: YES.

THE COURT: THAT'S THE AGREEMENT. ALL RIGHT.

THE COURT ORDERS LSW TO COMPLY WITH ITS AGREEMENT.

IF THE PARTIES -- YOU KNOW, IT’S BEEN RECITED ON THE

_

RECORD. IT'S BREN RECORDED. IF THE PARTIES WANT SOMETHING