101 CALIFORNIA STREET, SUITE 2300

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

Case 2:10#cv-09198-JVS-RNB Document 410 Filed 03/25/13 Page1of3 Page ID #:18308

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

BRIAN P. BROSNAHAN (SBN 112894)

JACOB N. FOSTER (SBN 250785)

101 California Street, Suite 2300

San Francisco, California 94111

Telephone: (415) 421-6140

Facsimile: (415) 398-5030

LAW OFFICES OF CRAIG A. MILLER
CRAIG A. MILLER (SBN 116030)

225 Broadway, Suite 1310

San Diego, CA 92101

Telephone: (619) 231-9449

Facsimile: (619) 231-8638

Attorneys for Plaintiffs

JOYCE WALKER, KIM BRUCE HOWLETT,
and MURIEL SPOONER, on behalf of themselves
and all others similarly situated

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

CLASS ACTION
CASE NO.: CV 10-9198 JVS (RNBx)

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

JOINT STIPULATION FOR AN
ORDER CONCERNING
COMMUNICATIONS BETWEEN
DEFENDANT LIFE INSURANCE
COMPANY OF THE SOUTHWEST
AND CLASS MEMBERS

JOYCE WALKER, KIM BRUCE
HOWLETT, and MURIEL
SPOONER, on behalf of themselves
and all others similarly situated,

Plaintiffs,

V.

LIFE INSURANCE COMPANY OF
THE SOUTHWEST, a Texas
corporation,

Defendant.

JOINT STIPULATION RE COMMUNICATION BETWEEN LSW AND ABSENT CLASS MEMBERS
ase No. CV 10-9198 JVS (RNBx)

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

Case 2:

Nn nN BP W WN

-cv-09198-JVS-RNB Document 410 Filed 03/25/13 Page 2of3 Page ID #:18309

Pursuant to Local Rule 7-1, Plaintiffs Joyce Walker, Kim Bruce Howlett,
and Muriel Spooner (“Plaintiffs”) and Defendant Life Insurance Company of the
Southwest (“LSW’’) (collectively, the “parties”), by and between their undersigned
counsel, submit the following stipulation:

WHEREAS, the parties have agreed that the initial class notice to be
disseminated to members of the class will contain the following language on the
first page of the notice: “This lawsuit has not changed the terms of your insurance
policy if it is in force, and all contractual guarantees remain in place and are not at
risk. If you have any questions about your insurance policy other than about this
Notice or this Class Action, you should contact LSW or your insurance agent as
usual (contact information is below).”

WHEREAS, Plaintiffs believe that the inclusion of this information presents
concerns regarding the communications that may occur between absent class
members and employees or agents of LSW;

WHEREAS, the parties reached agreement on a form of an order regarding
the scope of proper communications on Sunday, March 24, 2013;

WHEREAS, good cause exists to enter an order clarifying the scope of
proper communications between LSW’s employees and agents with absent class
members;

IT IS HEREBY STIPULATED AND AGREED, by and between the
undersigned counsel for the parties:

1. LSW shall instruct its agents and employees not to discuss the class
notice or this lawsuit with class members throughout the remainder of this lawsuit,
unless otherwise ordered by the Court. LSW shall disseminate this instruction to
all of its agents and employees by mass email or by such other method ordinarily
used by LSW in the course of its business to send mass communications to its
agents and employees that best ensures that this instruction is received by LSW’s
agents and employees. LSW shall send this instruction by no later than 10 days

JOINT STIPULATION RE COMMUNICATION BETWEEN LSW AND ABSENT CLASS MEMBERS

Case No. CV 10-9198 JVS (RNBx)
1

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

Case 2:

-cv-09198-JVS-RNB Document 410 Filed 03/25/13 Page3o0f3 Page ID #:18310

prior to the date that the class notice is mailed to the class. Nothing in this order
shall prevent LSW or its agents or employees from continuing to communicate

with class members in the ordinary course of its business.

DATED: March 25, 2013 KASOWITZ BENSON TORRES &
FRIEDMAN LLP

By: /s/ Charles N. Freiberg
Charles N. Freiberg

Attorneys For Plaintiffs

JOYCE WALKER, KIM BRUCE HOWLETT,
and MURIEL SPOONER, on behalf of
themselves and all others similarly situated

WILMER CUTLER PICKERING HALE AND
DORR LLP

By: /s/ Jonathan A. Shapiro
Jonathan A. Shapiro

Attorneys For Defendant
LIFE INSURANCE COMPANY OF THE
SOUTHWEST

JOINT STIPULATION RE COMMUNICATION BETWEEN LSW AND ABSENT CLASS MEMBERS
Case No. CV 10-9198 JVS (RNBx)
2