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Case 2:O4—cv—OO424—ROS Document 387-2 Filed O1/25/2008 Page 1 of 4
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§`Ti£¥i»E`(iE7N T";
LEE. z}.l;E.l?.9,§_l
TZTY Ml David B. Rosenbaum, Atty. No. 009819
,Dawn L. Dauphine, Atty. N0. 010833
2 Z OSBORN MALEDON, P.A.
—~--—-—--— 2929 North Central Avenue, Suite 2100
3 Phoenix, AZ 85012-2794
Telephone: (602) 640-9000
d;[email protected] A
°’2`? _ddauphine@omlavx#.com
I ¤il\/Iichael L. Banks, Pro Hac Vice Am Covert, Pro Hac Vice
6 Azeez Hayne, Pm Hcic Vice PROISKAUER ROSE LLP
7 LEZWIS & BOCKIUS LLP gne Niwlayrik g%16e2r, 18th Floor
at et treet ewar ,
Philadelphia, PA 19103 Telephone: (973) 274-3258
8 Telegcioée: (215)l963-5000 [email protected]
ni a. s morgan ew1s.com
9 ahayne @n1organ1ewis.com
10 , Vice Christopher Landau, P.C., Pro Hac Vice
· ‘ · __ Craig S, Primis, P.C., Pro Hac Vice
11 P3y§l;§SS¥tr1
howsha iro@ roskauer com 655 Fifteenth SHEEP N°W` A
13 _ P P · washington, nc. 20005-5793 ,
Telephone: (202) 879~5000
14 [email protected]
· cptimis @kirkland.com
15 [email protected]
, 16 ¤¤Attorneys for Defendants ·
17 0 IN THE UNITED STATES DISTRICT COURT
18 POR THE DISTRICT OP ARIZONA I
19 Barbara Allen, Richard Dzpold, No. CV04-0424 PHX ROS
Melvin Jones, Donald Mc arty, l
20 Richard Scates and Walter G. West, 1
individually and on behalf of all others {
21 similarly situated, DECLARATION OF KURT _
_ _ DENLINGER IN SUPPORT OF
22 Plaintiffs, REPLY BRIEF IN SUPPORT OF
DEFEN`DANTS’ MOTION FOR
23 §%%‘8P€t%1“1Erii’i8§S 1
24 Honeywell Retirement Earnings Plan,
Honeywell Secured Benefit Plan,
25 Plan Administrator of Honeywell
Retirement Earnings Plan, and Plan
26 Administrator of Honeywell Secured 2 1
Benefit Plan,
27
Defendants.
28 .
Case 2:O4—cv—OO424—FlOS Document 387-2 Filed O1/25/2008 Page 2 of 4 5
1 ?· I, Kurt Denlinger, depose and state pursuant to 28 U.S.C. § 1746 as follows:
2 I. I am employed by Hewitt Associates as a Consultant in the Retirement i
3 and Financial Management practice. I have 27 years of experience in the design,
4 funding and accounting of traditional and hybrid defined benefit plans, Supplemental
5 Executive Retirement Plans (SERPs), post—retirement medical programs, and defined
6 { contribution plans for large companies.
7 i 2. I am a Fellow of the Society of Actuaries, an Enrolled Actuary, and a
8 member of the American Academy of Actuaries. I earned a B.S. degree in
9 mathematics and computer science from Manchester College.
10 3. I am the Enrolled Actuary for Honeywell's defined benefit plans. I have
_` 11 provided actuarial services to Honeywell, and its predecessor, Allied-Signal Inc.
12 ;p (collectively "I-Ioneywell"), since 1986. I have performed many actuarial functions
13 :1 for the Honeywell Retirement Earnings Plan (together with its predecessor plans, the _
. . 14 I "Retirement Plan"), including annual valuations, administrative consulting, plan ·
15 amendment costing, and Retirement Plan benefit calculations.
16 4. In performing my actuarial functions during the course of this litigation, I
17 have reviewed the historical plan documents and amendments related to the
18 Retirement Plan and its predecessors including the Garrett Retirement Plan ("Garrett
19 I Plan"), The Signal Companies, Inc., Retirement Plan ("Signal Plan"), the merger of
the Garrett Retirement Plan into the Signal Plan, and the amendments to the Si-gnal
20 " Retirement Plan, effective January 1, 1984.
i; 5. In the course of my actuarial work for the Retirement Plan, under my
direction, 13,705 Retirement Plan participant calculations were performed and
23 verified. Of those 13,705 participants, 8,345 have entered pay status and have begun
24 receiving retirement benefits.
25 6. Of the 8,345 Retirement Plan participants who have received or are
26 receiving retirement benefits, 5,500 had entered pay status and had begun receiving
27 their retirement benefits prior to January 1, 1997.
28 I declare under penalty of perjury that the foregoing is true and correct.
2
Case 2:O4—cv—OO424—ROS Document 387-2 Filed O1/25/2008 Page 3 of 4 E
3 Executed: January _g_5_; 2008.
4
6 Kurt Dcnlinger
7 2
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18
19 is
21
22 §
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26
28
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Case 2:04-cv-00424-ROS
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