KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SuiTe 2300 SAN FRANCISCO, CALIFORNIA 94111 Case 2:10-cv-09198-JVS -RNB Document 175-2 Filed 03/23/12 Page 1of4 Page ID #:7416 oO NO A KASOWITZ, BENSON, TORRES & FRIEDMAN LLP CHARLES N. FREIBERG (SBN 70890) BRIAN P. BROSNAHAN (SBN 112894) JACOB N. FOSTER (SBN 250785) 101 California Street, Suite 2300 San Francisco, California 94111 Telephone: (415) 421-6140 Facsimile: (415) 398-5030 LEVINE & MILLER HARVEY R. LEVINE (SBN 61879) CRAIG A. MILLER (SBN 116030) LEVINE & MILLER 550 West C Street, Suite 1810 San Diego, CA 92101-8596 Telephone: (619) 231-9449 Facsimile: (619) 231-8638 Attorneys for Plaintiffs JOYCE WALKER, KIM BRUCE HOWLETT, and MURIEL SPOONER, on behalf of themselves and all others similarly situated UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JOYCE WALKER, KIM BRUCE HOWLETT, and MURIEL SPOONER, on behalf of themselves and all others similarly situated Plaintiffs, vs, LIFE INSURANCE COMPANY OF THE SOUTHWEST, a Texas corporation, Defendant. CASE NO.: CV 10-9198 JVS (RNBx) Formerly Case No.: 3:10-cv-04852 JSW from Northern District of California PLAINTIFFS JOYCE WALKER’S, KIM BRUCE HOWLETT’S, AND MURIEL SPOONER’S RESPONSES TO LIFE INSURANCE COMPANY OF THE SOUTHWEST’S FIRST SET OF INTERROGATORIES Plaintiffs’ Responses to LS W’s Interrogatories, Set One KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SUITE 2300 SAN FRANCISCO, CALIFORNIA 94111 Case 2:10-cv-09198-JVS -RNB Document 175-2 Filed 03/23/12 Page 2of4 Page ID #:7417 wa sa DN WN PROPOUNDING PARTY DEFENDANT LIFE INSURANCE COMPANY OF THE SOUTHWEST RESPONDING PARTY PLAINTIFFS JOYCE WALKER, KIM BRUCE HOWLETT, AND MURIEL SPOONER SET NUMBER : ONE (1) RESPONSES TO INTERROGATORIES INTERROGATORY NO. 1: Please state the name and street address of all persons to whom a LETTER was sent, and the date(s). RESPONSE TO INTERROGATORY NO. 1: Plaintiffs object to this interrogatory to the extent that it calls for disclosure of confidential or private information. Such information will be produced only pursuant to the terms of the parties’ Protective Order in this matter. Subject to and without waiving the foregoing objection, Plaintiffs respond: A LETTER was sent to 364 individuals contained in the policyholder sample produced by LSW. The names and street addresses for each of the 364 individuals, as well as the dates on which the LETTER was sent to each individual, are included in the list attached to these responses as Exhibit A. INTERROGATORY NO. 2: With respect to each person identified in response to Interrogatory No. 1, please state if the content and substance of the LETTER (i.e., everything other than the recipient’s name, address, etc.) was the same as that attached as Exhibit A; and if not, please state the content and substance of the LETTER. RESPONSE TO INTERROGATORY NO, 2: Yes. INTERROGATORY NO. 3: Please state the name and street address of all PUTATIVE CLASS MEMBERS who have had any COMMUNICATIONS with PLAINTIF re: Plaintiffs’ Responses to LSW’s Interrogatories, Set One Case No. CV 10-9198 JVS (RNBx) KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SUITE 2300 SAN FRANCISCO, CALIFORNIA 94111 Case 2:10-cv-09198-JVS -RNB Document 175-2 Filed 03/23/12 Page3of4 Page ID #:7418 co Oo NN DN A RESPONSE TO INTERROGATORY NO. 3: Plaintiffs object to this interrogatory on the grounds that it calls for the disclosure of privileged information, including without limitation information subject the work-product doctrine, including without limitation strategic decisions by Plaintiffs and their counsel regarding with which PUTATIVE CLASS MEMBERS, if any, to communicate and the subjects of any such communications (except with respect to the initial LETTER sent to the 364 individuals identified in Plaintiffs’ response to Interrogatory No. 1). Plaintiffs further object on the grounds that LSW already has disrupted Plaintiffs’ ability to communicate with PUTATIVE CLASS MEMBERS to obtain evidence relevant to Plaintiffs’ claims concerning class certification and merits, and that providing the names of PUTATIVE CLASS MEMBERS with whom Plaintiffs have communicated and the content and substance(s) of Plaintiffs’ communications with those individuals would allow LSW further to disrupt Plaintiffs’ ability to pursue their claims. Plaintiffs further object to this interrogatory to the extent that it calls for disclosure of confidential or private information. Such information, if produced, will be produced only pursuant to the terms of the parties’ Protective Order in this matter. Plaintiffs also object to this interrogatory to the extent that it is duplicative of Interrogatory No. 1. Except as described in Plaintiffs’ response to Interrogatory No. | and as to the named Plaintiffs, Plaintiffs, relying on the foregoing objections, will not provide a response to this interrogatory. INTERROGATORY NO. 4: With respect to each person identified in response to Interrogatory No. 3, please state the content and substance(s) of all such communications. RESPONSE TO INTERROGATORY NO. 4: Plaintiffs object to this interrogatory on the grounds that it calls for the disclosure of privileged information, including without limitation information subject to the attorney-client privilege and/or the work-product doctrine, including without limitation strategic decisions by Plaintiffs and their counsel regarding with which PUTATIVE CLASS MEMBERS, if any, to communicate and the subjects of any such poi icatoes (except with respect to the initial Plaintiffs’ Responses to LSW’s Interrogatories, Set One Case No. CV 10-9198 JVS (RNBx) KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 CALIFORNIA STREET, SUITE 2300 SAN FRANCISCO, CALIFORNIA 94111 Case 2:10-cv-09198-JVS -RNB Document 175-2 Filed 03/23/12 Page 4of4 Page ID #:7419 LETTER sent to the 364 individuals identified in Plaintiffs’ response to Interrogatory No. 1). Plaintiffs further object on the grounds that LSW already has disrupted Plaintiffs’ ability to communicate with PUTATIVE CLASS MEMBERS for the purpose of obtaining evidence relevant to Plaintiffs’ claims concerning class certification and merits, and that providing the names of PUTATIVE CLASS MEMBERS with whom Plaintiffs have communicated and the content and substance(s) of Plaintiffs’ communications with those individuals would allow LSW further to disrupt Plaintiffs’ ability to pursue their claims. Plaintiffs further object to this interrogatory to the extent that it calls for disclosure of confidential or private information. Such information, if produced, will be produced only pursuant to the terms of the parties’ Protective Order in this matter. Relying on these objections, Plaintiffs will not provide a response to this interrogatory. INTERROGATORY NO. 5: Please state the name and street address of all PUTATIVE CLASS MEMBERS who have retained Kasowitz, Benson, Torres & Friedman LLP, or any attorney affiliated therewith, to represent them in connection with the above-captioned lawsuit. RESPONSE TO INTERROGATORY NO. 5: The following PUTATIVE CLASS MEMBERS have retained Kasowitz, Benson, Torres & Friedman LLP to represent them in connection with the above-captioned lawsuit: e Joyce Walker; 261 Sunswept Street, San Diego, CA 92114 e Kim Bruce Howlett; 5048 San Joaquin Drive, San Diego, CA 92109 e Muriel Spooner; 5048 San Joaquin Drive, San Diego, CA 92109 INTERROGATORY NO. 6: Please state the name and street address of all persons to whom YOU intend to send the LETTER or other COMMUNICATIONS that are substantively similar to the LETTER, including any COMMUNICATIONS with PUTATIVE CLASS MEMBERS that request that PUTATIVE CLASS MEMBERS contact YOU or that purport to summarize YOUR claims in this litigation. 3 Plaintiffs’ Responses to LSW’s Interrogatories, Set One Case No. CV 10-9198 JVS (RN Bx)