KR WO NO

Case 2:10-cv-09198-JVS -RNB Document 279 Filed 07/31/12 Page 1of3 Page ID
#:12437

Jonathan A. Shapiro (257199)

WILMER CUTLER PICKERING HALE AND DORR LLP

950 Page Mill Road

Palo Alto, California 93304

Tel: (650) 858-6101

Fax: (650) 858-6100
jonathan.shapiro @ wilmerhale.com

Andrea J. Robinson (pro hac vice)
Timothy J. Perla (pro hac vice)

WILMER CUTLER PICKERING HALE AND DORR LLP

60 State Street

Boston, Massachusetts 02109

Tel: (617) 526-6000

Fax: (617) 526-5000
andrea.robinson @wilmerhale.com
timothy.perla@ wilmerhale.com

Attorneys for Defendant Life Insurance
Company of the Southwest

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION

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, and
DOES 1-50

Defendant.

Case No.: CV 10-9198-JVS(RNBx)

DECLARATION OF TIMOTHY
PERLA IN SUPPORT OF MOTION TO
STRIKE

DECLARATION OF TIMOTHY PERLA IN SUPPORT OF MOTION TO STRIKE, 10-09198-JVS(RNBx)

BR WwW NO

ao NN DWN NN

—
Go oO

Case 2:10-cv-09198-JVS -RNB Document 279 Filed 07/31/12 Page 2of3 Page ID
#:12438

DECLARATION OF TIMOTHY PERLA

I, Timothy Perla, declare as follows:

1. I am an attorney duly licensed to practice law in the Commonwealth
of Massachusetts. I am a Counsel at the law firm of Wilmer Cutler Pickering Hale
and Dorr LLP, counsel for Defendant Life Insurance Company of the Southwest
(“LSW’”’) in the above-entitled action. I have personal knowledge of the facts
stated herein and, if called as a witness, I could and would testify competently
thereto.

2. Attached hereto as Exhibit A is a true and accurate copy of excerpts
from the Testimony of Kim Bruce Howlett.

a: Attached hereto as Exhibit B is a true and accurate copy of an errata
sheet to the Deposition Transcript of Kim Bruce Howlett.

4. Attached hereto as Exhibit C is a true and accurate copy of a letter
from Charles Freiberg dated June 22, 2012.

a Attached hereto as Exhibit D is a true and accurate copy of Exhibit 11
introduced during the Deposition of Kim Bruce Howlett.

6. Attached hereto as Exhibit E is a true and accurate copy of Exhibit 12
introduced during the Deposition of Kim Bruce Howlett.

I declare under the penalty of perjury that the foregoing is true and correct.

Executed this 19th day of July, 2012, at Boston, Massachusetts.

=D.
DECLARATION OF TIMOTHY PERLA IN SUPPORT OF MOTION TO STRIKE, 10-09198 JVS(RNBx)

BR WO NO

Case 2:10-cv-09198-JVS -RNB Document 279 Filed 07/31/12 Page3of3 Page ID
#:12439

By: /s/ Timothy Perla
Timothy Perla

232
DECLARATION OF TIMOTHY PERLA IN SUPPORT OF MOTION TO STRIKE, 10-09198 JVS(RNBx)