Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page 1of9 Page ID #:12467

EXHIBIT B

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page 2of9 Page ID #:12468

KASOWITZ, BENSON, TORRES & FRIEDMAN up A NEW YORK LIMITED LIABILITY PARTNERSHIP

tOl CALIFORNIA STREET

SUITE 2300 ATLANTA SAN FRANCISCO, CALIFORNIA 94111 SS eKOG 415-421-6140 MIAMI NEWARK FACSIMILE: 415-398-5030 NEW YORK

June 4, 2012

By Federal Express

Esquire Deposition Solutions 44 Montgomery Street

Suite 1100

San Francisco, CA 94104

Re: Deposition of Kim Bruce Howlett Walker et al. v. Life Insurance Company of the Southwest USDC Case No. CV 10-9198-JVS (RNBx)

To whom it may concern: Enclosed please find the Errata Sheets for the deposition of Kim Bruce Howlett, the second volume of which was taken on May 10, 2012 and recorded by Mr. Corey Anderson of

Esquire Deposition Solutions.

Sincerely,

Jeauette T. Barzelay

Enclosures

CC: Jonathan A. Shapiro, Esq. (w/ enclosures, via Federal Express) nitty Perla, Esq, sft email only)

James Lux, Esq. (via email only)

Andrea Robinson, Esq. (via email only)

Joel Fleming, Esq. (via email only)

Charles N. Freiberg, Esq. (via email only)

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page 3of9 Page ID #:12469

ERRATA SHEET

CORRECTIONS TO DEPOSITION OF KIM BRUCE HOWLETT April 26, 2012; May 10, 2012

'No.| Page | Line Corrections/Insertions: |

aaa 12-13 |Q: Were you surprised that you didn’t find any notes? A: No.

iF would approximate sometime in the earlymid nar of 2008. After reviewing the documents further, I now recall it was in the mid/late part | of 2008.

At this point in time, I have not been contemplating talking to the press | about this lawsuit.

lie S ‘beet some time ago. Y Believe it was in the \ winter, | November/December, time frame. After further review, I now recall it was earlier, approximately 1 in September and October.

E-mails related to this case, prior to the initiation of the case, were either deleted or stored on a personal folder within the e-mail program.

company where there’s request for e-mails and he could assist with retrieving them.

I have no reason to think that he wouldn’t have responded to the questions I raised at that point in time.

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page4of9 Page ID #:12470

FE EE

that we discussed the IGLI with you prior to purchasing

Yes, that’s correct. I have searched for them, and we no longer fave the | notes.

Line “ again, the specific implementation of the LSW product. 74 I don’t recall reading either my September illustration or my wife’s

| paw ws ND

jo _—_

September illustration.

return on that money based ¢ on the S&P 500 10 index. meaabee of the class’s motivation would be.

individual within the class’s motivation would bei in

Seniember 27th, as compared to the July 27th

| And also it did not disclose all of the Prior to eine with my legal counsel us the first time It was probably arbitrary. I may have

the disclosure of costs. And it turns out there are other

a aN Go

29.

sa.f27 [2

)31.f277 fo I really don’t recall him providing this HORmAdon!

“et fe I do not now where those meeting notes ae I have searched for them, . and we no a Tonge have them.

retirement income that we were e led to ‘believe we

I have read the foregoing transcript and found it to be a truthful and accurate representation of the testimony I gave in connection with the captioned matter on April 26, 2012 and May 10, 2012.

Mace 31, Zora, Date

I —I don’t recall him providing this information.

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page5of9 Page ID #:12471

WHLLS

WoW an @s@.

All-purpose Acknowledgment California only

State of California

County of San Dp

Z\ Jo\2— | v7 VL t— | of Wee ee "before me, <. ba \LeasteovoS, | a noi | (here insert name and title of the officer),

personally appeared Fim Ale Hewlett

nam fare subscribed to the within instrument and acknowledged té me that ey executed the same ela authorized capacity(jeS), and that by hisher/their signature) on the i ment the person{sj, or the erftity upon behalf W

hich the person(J acted, executed the instrument.

who Oy to me on the basis of satisfactory evidence to be the person(s/whose

| certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

ITNESS my hand and official seal.

Signature

Notary Seal

Mansal Sebmdesion fawte to Bopaslt Gperutians FO01-000DSG5350CA-01

0565356 CA (12-07 113424)

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page6of9 Page ID #:12472

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP A NEW YORK LIMITED LIABILITY PARTNERSHIP

1Ol CALIFORNIA STREET

SUITE 2300

ATLANTA SAN FRANCISCO, CALIFORNIA 94111 HOUSTON 415-421-6140 MIAMI NEWARK FACSIMILE: 415-398-5030 NEW YORK

June 4, 2012

By Federal Express Litigation Support Veritext

550 South Hope Suite 1775 Los Angeles, CA 90017

Re: Deposition of Kim Bruce Howlett Walker et al. v. Life Insurance Company of the Southwest USDC Case No. CV 10-9198-JVS (RNBx)

To whom it may concern:

Enclosed please find the Errata Sheets for the deposition of Kim Bruce Howlett, the first volume of which was taken on April 26, 2012 and recorded by Ms. Lynne Ledanois of Veritext.

Sincerely,

Jeanette T. Barzelay

Enclosures

CC:

onathan A. Shapiro, Esq. (w/ enclosures, via Federal aENDICSS) Timothy P Perla, Bsa, "(via email only) James Lux, Esq. (via email only) Andrea Robinson, Esq. (via email only) Joel Fleming, Esq. (via email only) Charles N. Freiberg, Esq. (via email only)

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page 7of9 Page ID #:12473

ERRATA SHEET

CORRECTIONS TO DEPOSITION OF KIM BRUCE HOWLETT April 26, 2012; May 10, 2012

pag be toe Corrections/Insertions:

Q: Were you surprised that you didn’t find any notes? A: No.

31; 32 25; 1 I would approximate sometime in the early/mid part of 2008. After | reviewing the documents further, I now recall it was in the mid/late part of 2008.

41 At this point in tite, I have not been contempléting talking to the press | about this ee

eR fee

It’s been some time ago. I believe it was in the winter, | November/December, time frame. After further review, I now recall it | was earlier, approximately in September and October.

fee 87 |company where there’s request for e-mails and he could assist with retrieving them.

—_ respect to investments that fad tax aavantages

i oe I have no reason to think that he wouldn’t have responded to the questions f raised at that point in time.

freien fie frvewlotemis ulns fio further, and so it seemed © that we — ~ool ria [ns [22 [eommene tert So foment ni ofa |e fwenmers [i [2 arwertintewr iva

sist |:

E-mails related to this case, prior to the initiation of the case, were either deleted or stored on a personal folder within the e-mail program.

| general about IGLI.

ricwces it’s to both the LSW ant to OIGLT in general, IGLI.

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page 8of9 Page ID #:12474

eh that we discussed jae IGLI with you prior to purchasing

pw) fe Yes, that’s correct. I have searched for fem and we no isngee have the notes.

Piaf again, the specific implementation of the LSW product.

20. | 174 I don’t recall reading either my September illustration or my wife’s er illustration. 21. | 204 |

8 | retum on that money based : on the S&P 500 index,

member of the class’s motivation would be.

Co individual within the class’ Ss motivation would be j in

September 27th, as compared to the J ay 27th aa ffs And also it did not disclose all of the

Prior to meeting with my fewal eouneel for the first time

the disslosats ofc costs. And it turns out hee are soiier

Sale te I —I don’t recall him providing this information. [ofp fo I really don’t recall him providing this jnformation:

32. | 281 I do not know where those meeting notes are. I have searched for then, | | a we no longer have them.

| retirement income that we were led to believe v we

I have read the foregoing transcript and found it to be a truthful and accurate representation of the testimony I gave in connection with the captioned matter on April 26, 2012 and May 10, 2012.

ae 31, Ore Date

Case 2:10-cv-09198-JVS -RNB Document 279-2 Filed 07/31/12 Page9of9 Page ID #:12475

WELLS

FARGO

All-purpose Acknowledgment California only

State of California

County of San Dp _ , We'g B\W7O\ ES ag <<. Ballesions, a ae |

personally appeared Fim rile tewretl—

0

—

(here insert name and title of the officer),

nam fare subscribed to the within instrument and acknowledged t6 me that ey executed the same Cetera authorized capacity(jeS), and that by hiser/their signature on the i ment the person, or the erftity upon behalf

which the person(yj acted, executed the instrumen

who O to me on the basis of satisfactory evidence to be the person(s/'whose

| certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

ESS my hand and official seal.

Signature

Notary Seal

anual Submission Route te Deposit Operations | | | FO01-000DSG5350CA-01

0565956 CA (12-07 113424)