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
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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)