2011 1107 - DOC 748-2 - Deposition of Donna Morgan - 46p

  • Chief Compliance officer for the Life Insurance Company of the Southwest, and National Life Insurance Company.  (p9)
  • Q:  Why are the costs and expenses important to that informed decision?
  • Q: ...provide services on behalf of Life Insurance
    Company of the Southwest?
  • MS. ROBINSON: Objection.
  • A: What do you mean by "services"?
  • Q: Do your job responsibilities encompass work on behalf of Life Insurance Company of the Southwest?
  • MS. ROBINSON: Objection.
  • A: What do you mean by "work"?
  • Q:   How would you interpret the meaning of the word "work"?
  • A:  I don't understand the question.
  • Q:  You don't understand what it would mean to work for Life Insurance Company of the Southwest?
  • A:  I don't understand your question.
  • Q:  Okay. What leads you to believe you're employed by the Life Insurance Company of the Southwest as well as National Life Group?
  • A: I'm the chief compliance officer for the Life Company Life Insurance Company of the Southwest, and National Life Insurance Company.  (p9)

  • MS. ROBINSON: Objection.
  • A:  Could you repeat the question?
  • Q:  If you were considering purchasing an equity indexed universal life policy or investing in a mutual fund, would you want to know the costs and expenses of each?
  • A:  You're talking me personally?
  • Q:  Yes.
  • A:  Yes.
  • Q:  Why?
  • A: So I know I'd have an informed decision as far as what I was buying.
  • Q:  Why are the costs and expenses important to that informed decision?
  • MS. ROBINSON: Objection.
  • A: Are you asking me personally?
  • Q:  You personally.
  • A:  I don't know.
  • Q:  You don't know why they are important to you?
  • A:  Correct.

2011 1107 - DOC 748-2 - Deposition of Donna Morgan - 42p

Verbatim: What Is a Photocopier? | Op-Docs - The New York Times - https://www.youtube.com/watch?v=PZbqAMEwtOE