Case 2:10-cv-09198-JVS -RNB Document 280-4 Filed 07/31/12 Page 1of3 Page ID
#:12506

EXHIBIT D

101 CALIFORNIA STREET, SUITE 2300

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
SAN FRANCISCO, CALIFORNIA 94111

Cas@ 2:10-cv-09198-JVS -RNB Document 280-4 Filed 07/31/12 Page2of3 Page ID
#:12507

1 |} KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
CHARLES N. FREIBERG (SBN 70890)

2 || BRIAN P. BROSNAHAN (SBN 112894)

JACOB N. FOSTER (SBN 250785)

101 California Street, Suite 2300

4 || San Francisco, California 94111

Telephone: (415) 421-6140

5 || 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

10 || Facsimile: (619) 231-8638

Attorneys for Plaintiffs
12 || JOYCE WALKER, KIM BRUCE HOWLETT,
and MURIEL SPOONER, on behalf of themselves
13 || and all others similarly situated

14
15 :
UNITED STATES DISTRICT COURT
16
CENTRAL DISTRICT OF CALIFORNIA
17
18

19 || JOYCE WALKER, KIM BRUCE CASE NO.: CV 10-9198 JVS (RNBx)

HOWLETT, and MURIEL SPOONER, on
behalf of themselves and all others similarly
1 situated

Formerly Case No.: 3:10-cv-04852 JSW
from Northern District of California

PLAINTIFFS JOYCE WALKER’S, KIM
BRUCE HOWLETT’S, AND MURIEL
73 ie: SPOONER’S RESPONSES TO LIFE
INSURANCE COMPANY OF THE
SOUTHWEST?’S THIRD SET OF
INTERROGATORIES, NUMBER 9

Be: Plaintiffs,

24 || LIFE INSURANCE COMPANY OF THE
95 || SOUTHWEST, a Texas corporation,

26 Defendant.

Plaintiffs’ Responses to LSW’s Interrogatories, Set Three Case No. CV 10-9198 JVS (RNBx)

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

101 CALIFORNIA STREET, SuITE 2300
SAN FRANCISCO, CALIFORNIA 94111

CasH

oO SN DH SN

‘oO

10
1]
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
at
28

2:10-cv-09198-JVS -RNB Document 280-4 Filed 07/31/12 Page 3of3 Page ID

#:12508
PROPOUNDING PARTY DEFENDANT LIFE INSURANCE COMPANY OF THE
SOUTHWEST
RESPONDING PARTY PLAINTIFFS JOYCE WALKER, KIM BRUCE
HOWLETT, AND MURIEL SPOONER
SET NUMBER ; THREE @)

RESPONSES TO INTERROGATORIES

INTERROGATORY NO. 9:

State the name(s) of the person(s) whose handwriting appears on HOWLETT EXHIBIT 12
and the date(s) on which the handwritten markings were made.
RESPONSE TO INTERROGATORY NO. 9:

Plaintiffs object to this interrogatory on the grounds that it seeks information that is
irrelevant.

Subject to and without waiving the foregoing objection, Plaintiffs respond as follows:

The handwritten markings contained under the headings “Premium Expense Charge,”
“Cost of Insurance,” “Other Deductions,” and “Total Expense and Deductions,” were made by
Jo Anne Childress, a secretary employed by Kasowitz, Benson, Torres & Friedman LLP.
Ms. Childress made the handwritten markings at the direction of Brian P. Brosnahan, Esq.,
because her handwriting is more legible than Mr. Brosnahan’s. Ms. Childress copied handwritten
markings that Mr. Brosnahan had made on a different copy of HOWLETT EXHIBIT 12. The
handwritten markings in the form of “Ex. 12” contained above the Bates No. LSW 00094172 were
made by Charles N. Freiberg, Esq. The handwritten markings contained on the exhibit sticker
affixed to HOWLETT EXHIBIT 12 were made by the court reporter, Corey W. Anderson. All of
the handwritten markings were made on the date of the deposition, May 10, 2012.

Dated: June 14, 2012 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP,

JACOB N. FOSTER

Attorneys for Plaintiffs

Plaintiffs’ Responses to LSW’s Interrogatories, Set Three Case No. CV 10-9198 JVS (RNBx)