Case 2:10-cv-09198-JVS-RNB Document 421-7 Filed 04/29/13 Page 1of3 Page ID
#:18786

Jonathan A. Shapiro (257199)

Mintz Levin Cohn Ferris Glovsky and Popeo PC
44 Montgomery Street

San Francisco, California 94104

Tel: (415) 432-6000

Fax: (415) 432-6001

JAShapiro@mintz.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 Case No.: CV 10-9198-JVS(RNBx)
HOWLETT, and MURIEL SPOONER, on .
behalf of themselves and all others

similarly situated, DECLARATION OF SETH A.
| MOSKOWITZ IN SUPPORT OF
Plaintiffs, LSW’S RESPONSE TO COURT’S
ORDER TO SHOW CAUSE RE:

VS. DECERTIFICATION
LIFE INSURANCE COMPANY OF THE
SOUTHWEST, a Texas corporation, and
DOES 1-50
Defendant.

DECLARATION OF SETH A. MOSKOWITZ IN SUPPORT OF LSW’S RESPONSE
TO COURT’S ORDER TO SHOW CAUSE RE: DECERTIFICATION, 10-09198-JVS(RNBx)

Case 2:10-cv-09198-JVS-RNB Document 421-7 Filed 04/29/13 Page 2 of 3 Page ID
#:18787

DECLARATION OF SETH A. MOSKOWITZ

I, Seth A. Moskowitz, declare as follows: |

1. I am an attorney duly licensed to practice law in the Commonwealth of
Massachusetts and the State of New York. Lama Senior Associate at the law firm of
Wilmer Cutler Pickering Hale and Dorr LLP, counsel for Defendant Life Insurance
Cae of the Southwest (“LS W”) in the above-entitled action. I have personal
knowledge of the facts stated herein and, if eatied as a witness, I could and would testify
competently thereto.

2 I arranged in a Microsoft Excel spreadsheet a list of all Paragon or Provider
universal life insurance policies produced to Plaintiffs as described in the Declaration of
Caitlin Monahan. |

3. I used a random number generator located at www.random.org to generate a
randoni number (the “Random Number”). I then matched that Random Number to the
number assigned to each row in the Excel spreadsheet containing the list of policy numbers.
I repeated this process once more to identify another sample poliey file to submit to the
Court. |

4, Attached hereto as Exhibit A is a true and correct copy of the sigliey file for an
indexed universal life insurance policy bearing Polley No. LS0285665 that was produced in

this litigation.

DECLARATION OF SETH A. MOSKOWITZ IN SUPPORT OF LSW’S RESPONSE
TO COURT’S ORDER TO SHOW CAUSE RE: DECERTIFICATION, 10-09198-JVS(RNBx)

Be WN NO —

oOo BA JN HN ON

Case 2:10-cv-09198-JVS-RNB Document 421-7 Filed 04/29/13 Page 3of3 Page!D
#:18788

5. Attached hereto as Exhibit B is a true and correct copy of the policy file for an
indexed universal life insurance policy bearing Policy No. LS0287586 that was produced in
this litigation.

6. Attached hereto as Exhibit C is a true and correct copy of the policy file for an
indexed universal life insurance policy purchased by Joyce Walker that was produced in
this litigation. |

| I declare under the penalty of perjury that the foregoing is true and correct. Executed

this 29" day of April, 2013, at Boston, Massachusetts.

By: /s. Seth A. Moskowitz
Seth A. Moskowitz

ae
DECLARATION OF SETH A. MOSKOWITZ IN SUPPORT. OF LSW’S RESPONSE
TO COURT’S ORDER TO SHOW CAUSE RE: DECERTIFICATION, 10-09198-JVS(RNBx)