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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)
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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)
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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)