Exhibit 116 - Life Partners Official Committee Of Unsecured … Appendix.pdf · 2016-03-18 ·...

Exhibit 116

App. 1834

Case 15-40289-rfn11 Doc 1584-10 Filed 03/05/16 Entered 03/05/16 12:06:49 of 197

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Exhibit 117

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From: [email protected]: Thursday, November 07, 2013 4:46 PMTo: Deborah Carr; Brian D. Pardo; Scott PedenCc: [email protected]: Problems with premium billing

Debra, Scott, and Brian: First -- let me once again say "thank you" for the amazing product you have created and made available to individual investors. I was introduced to you back in the fall of 2006 and have been a devoted investor and licensee since then. In the past 6 months, you have totally changed how the company handles premium calls. I truly understand "why" you now send 3 bills and then the "Notice of Abandonment". I suspect the main reason is that while originally, the company was only closing 2-3 policies a month back in 2006, by early 2009, you were closing 10-15 policies a month. That equates to HUGE numbers of policies now needing to be billed each month as the escrow accounts for each policy are exhausted. Furthermore, the SEC law suit questions any "effort" by LPI in helping investors achieve a return. Therefore "if" you advance premiums on behalf of an investor, that "could" be deemed by some judge, as "management effort" as part of a ruling to make the life settlement from LPI a "security". So -- all that being said, we have a problem with the premium billing department & process. I say "we" because I truly am a team player, and want to help LPI in any way I can. But you can't fix a problem if you aren't aware of it. The problem? In "some" cases, you are NOT sending out either a "first" or a "second" notice of premium due. "Suddenly", a client is receiving a Notice of Abandonment, threatening to take their investment away from them. In some cases, this is the FIRST time they learn that a premium is due. (And "yes", I send all my clients an annual HARD COPY of their premium obligation report, plus do regular email updates referring to the LPI-policies web site.) Earlier this spring/summer, bills were being sent out for premiums NOT actually due. But to clients who I have worked extremely hard on, telling them to "keep their faith in Life Partners and Brian Pardo", this is a very harsh situation. From their perspective, LPI is threatening to take their investment from them when they didn't receive appropriate notice first. (Yes, I know that's not your intent -- you just want timely payment of the premium obligation.) But nonetheless, that is some of the feedback I'm starting to get from a few of my 50+ clients. (As an aside -- the majority of my clients are either active or retired pilots for Delta Airlines. Many fly long international trips, sometimes gone from home for up to 12 or 13 days.) Maybe you're not getting accurate information from the escrow agent (PES or ATLES). More likely, its due to hundreds of individuals being invested in any particular policy, and one or two slip thru the crack. Furthermore, the entire process is complicated due to most investors using IRA or qualified funds, necessitating the use of several IRA custodians. Earlier this summer, a couple of my clients experienced getting no 1st or 2nd notice, but received the Notice of Abandonment from you. In more than one case, it was sent totally in error. The problems initially seemed to stem from PES policies. But later, my client John Thompson had one, and then I personally had one. I wrote to you about these situations a couple months ago. In all cases, the premium department was wonderful, when the problem was pointed out. But there never was a written letter or email acknowledgement sent to any investor who had a problem. I mentioned my client, John Thompson for a reason. He was so scared of losing his investment after receiving the notice of abandonment on the Piano policy, that he spent $75.74 to not only FedEx funds and paperwork to his IRA custodian, IRA Services, but also paid additional fees for IRA Services to wire the funds "immediately" to the escrow agent. Now if he'd received the 1st Notice, and the 2nd Notice and ignored them, then I would say that it was his fault. But it was not, he keeps meticulous records, and never received the notices. (Hint of the problem somewhere in the billing cycle/process). Shortly after John went thru this, I experienced the same problem in my personal portfolio.

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I communicated this, knowing you had hired more people for the premium department, and are working thru the issues. Two days ago, I received the licensee notice of a 2nd Notice for a premium due in my personal portfolio. It is copied below. I keep paper records for every premium call I have received (I have over 50 policies in my portfolio). I spent considerable time going thru my files. I never received a 1st Notice of premium due for the Schimmel policy. I even called Provident Trust to see if I had received and signed a premium bill from LPI, returned it for payment by my IRA, and not kept a copy. No -- Provident had not received anything on Schimmel. I never received a 1st Notice. Therefore there is STILL a problem. (That's OK, I'll still make payment when the paper bill arrives.) But I remain concerned, especially for my clients. I dutifully forward ALL email notices I receive as licensee to each client. I remain concerned that several have received 2nd notices. For many, it's appropriate, but not always. I remained concerned, for those who receive the Notice of Abandonment. In some cases, it's appropriate, but not always. Bottom line, is that I would like to make a couple suggestions. Can we STOP sending the Notice of Abandonment with the 3rd Premium Due notice? THAT is the thing that ticks off my clients when they have not received the first two notices. I'm suggesting we insure we "fix" the process first; giving clients and their IRA custodians plenty of legitimate time, to make payment. We truly need to make sure that ALL investors are, in fact, receiving ALL THREE (if needed) invoices for premiums due on their policies, before undertaking such drastic action as implied in the Notice of Abandonment. Or perhaps you could add an additional 30 days AFTER sending the 3rd notice, before sending a separate notice of abandonment. Second, I would like to "suggest" that a written letter be sent to an investor when there is a "goof" where they either haven't received all the proper notices, or they receive one in error. It's the classy thing to do, admitting you did something wrong, or that the "service" wasn't up to your standards. This would go a long way to showing what a first class company we all know you are. (And yes, I can see the lawyers to scream bloody murder about putting anything in writing about being "wrong".) Next, I want to provide some feedback from my client, John Thompson. John Thompson was hoping to receive some type of apology from LPI over his lack of receiving the 1st and 2nd notices on his premium due last August. He was also hoping that LPI would reimburse him for the extra expenses he incurred, over his fear you would confiscate his investment in that particular policy. I told him I would cover reimbursing him for that $75.74 if you didn't. As fate would have it, John was invested in the Reuben policy, which matured about 2 months ago. I emailed him the notice of payout the other day and here is his email response to me:

Thanks John – When the funds arrive, I’d like your help in selecting/buying another policy (assuming they reimburse me the $75.74 for extra charges – as a matter of principle; it’s really not that big a deal, but they should respond to the issue –it was totally unsat, and their failure to followup is aggravating). Thank you – that IS great news, esp after all the premium calls! John As you can see, he is still unhappy with the lack of response from LPI. He is considering NOT reinvesting. Not because he doesn't believe in the product -- the life settlement, but because of the treatment he has received from Life Partners. I would like to ask "if" you are willing to write him some type of apology for his inconvenience and the stress caused by thefailure to properly notify him regarding premiums due for the Piano policy. If you're willing to reimburse him for the $75.74 he spent for the "last minute" effort to cover the Piano policy premium, that would be the best in his mind. If not, please let me know and I will write the check. I am even willing to reimburse YOU, just so that John sees the check coming from LPI. Bottom line -- I want to encourage that you continue working on "fixing" the problem regarding premium bills, and hope that when there is a problem or error pointed out, some type of communication is sent to the investor. Please forgive this lengthy and possibly rambling email. I just want to make sure you have all the facts. Thank you for your diligence in addressing this matter.

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Sincerely, John Ley NW Safe Retirements, LLC and Cantata, LLC 444 NW Fremont St. Camas, WA 98607

-----Original Message----- From: Premiums Customer Service <[email protected]> To: nwretirement <[email protected]> Cc: joe <[email protected]> Sent: Tue, Nov 5, 2013 12:40 pm Subject: SECOND NOTICE ATLES Premium Report 120647 Terence

Dear Terence Ley , The following report is a summary of the premiums due from your investors for a policy they are invested in. This list will be automatically emailed to you when letters are sent to the investors. If you have any questions regarding this report, please call the Premium Department or email [email protected]. Explanation of abbreviation in Balance Due column: A - Annually, Q - Quarterly, SA - Semi-annually, M - Monthly.

Investor List:

Invested Name

Account Policy

ID

Policy Number -

Ins. Company

Insured Last

Name Invested

Invoice Amount

Balance Due*

Proj. Payout

Pay ID Due Date

John P Ley

IRA 52618

8173590 -Penn

Mutual Life

Insurance Company

Schimmel $10,000.00 $996.75A $996.76 $18,181.85 162683 12/03/2013

*Additional Custodian fees may apply. Thank you very much for being a valued licensee. We appreciate your business and look forward to serving you! Sincerely Yours, Premium Department (254)751-7797 Life Partners Inc.

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Exhibit 118

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From: G Russell Hagan <[email protected]>Sent: Wednesday, May 21, 2014 10:53 AMTo: Deborah CarrSubject: Re: Henry Huff Chiles/ Puzio

Debbie, Lindy has not been copied on this correspondence. Let me clarify; they were clients when the premiums were put as a lien against the policy proceeds and they werent concerned. It is understand that was not what was in the contract, however; that what was being done for some time. They certainly could be paying, but werent based upon what they had actually seen occur. So, their question to me already has been, if the procedure had changed internally from LPI why did we not know they "procedurally" made a change. Of course the letters were sent, but this leads them to the conclusion of "selection". To them it appeared as a "picked" abandonment. In addition; they also noticed that polices that were older viatical policies the abandonment procedure was not occurring, only in the instances of senior settlements. So their question was how could one class of policies be treated one way and another class of policies be treated another. I really could not answer either one, except point them to the original agreement. I really do not know how I am going to tell them they lost 50k without them putting up a fight based upon the above an anything else they might come up with. I have maintained a good relationship with them, but this is one that will probably go nuclear. They already mentioned they know how to contact OAG and TSSB and anyone else they need. Is there any possibility of giving them another abandoned policy position, anything to prevent a real problem? If not, then I will handle them as professionally as possible and try to divert a full fledge war. Lastly, they are in VA, and my dealing with VA have always been difficult and least cooperative when a complaint surfaces. Sure Scott can confirm that first hand. -Russ m On 5/21/2014 11:08 AM, Deborah Carr wrote:

Russ, Policies are not picked for abandonment. There is a process as to how policies are billed and when a position goes into the abandonment queue.

Deborah Carr Life Partners, Inc.

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From: G Russell Hagan [mailto:[email protected]] Sent: Tuesday, May 20, 2014 7:10 PM To: Lindy Gulebian

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Cc: Deborah Carr Subject: RE: Henry Huff Chiles/ Puzio

Well one of the issues is why some policies are " Picked" for abandonment and other policies arent. Example; life settlements are, older viaticals are not. The client will be asking me why this policy was singled out.

We are not discussing silberstein which payment arrangement has been notated in your file.

On May 20, 2014 12:40 PM, "Lindy Gulebian" <[email protected]> wrote:

Mr. Hagan,

With the information available to me I do not show that we received payments for premiums billed in 2012, and 2013 for the Puzio & Puzio policy. Please see the attached premium notices for the Puzio & Puzio policy.

Please keep in mind the Silberstein policy is currently in the abandonment process. Please make sure the payment is remitted by 5:00 p.m. CST by 06/02/2014 in order to avoid foreclosure on this policy. Please see the attached report that shows premiums billed and paid from 2007‐05/20/2014. Thank you and have a great day!

Sincerely,

Lindy Gulebian Life Partners, Inc.


From: G Russell Hagan [mailto:[email protected]] Sent: Tuesday, May 20, 2014 8:59 AM To: Amanda Weir Cc: Deborah Carr Subject: Re: Henry Huff Chiles/ Puzio

These are the largest Orchard Farmers in the State of VA and extremely wealthy who can afford and know how to fight. Had a suspicion that this happened and was hoping it was not the case. Well this is going to get ugly. We need a paperwork trail and audit the premium due

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notices, to prove it to them. I will do the best I can to mediate it. How long do you think it will take to send the history of abandonment over to me? -Russ On 5/20/2014 9:49 AM, Amanda Weir wrote:

Good morning Russ, Mr. Chiles’s position in Puzio was abandoned in October 2013 for non‐payment of premiums.

Thank you,

Amanda Weir Life Partners, Inc.


From: G Russell Hagan [mailto:[email protected]] Sent: Tuesday, May 20, 2014 7:11 AM To: Amanda Weir Subject: re: Henry Huff Chiles/ Puzio

Amanda, re: Henry Huff Chiles/ Puzio Case Attached are two reports. An old one in which I saved. The other in which is now in the placement records on the website. Curiously enough, the Puzio case is showing up on the older report and not on the current one on the website. The case has never been paid either. Would you kindly advise as to why it is not now showing up? thx-Russ

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Exhibit 119

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Exhibit 120

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From: Mark EmbrySent: Tuesday, October 18, 2011 8:26 AMTo: Kurt CarrCc: Scott Peden; Brian D. PardoSubject: RE: LPI PositionsAttachments: LPI-positions-in-policies-xx.pdf

Here are all the positions we own by policy. This is a report I already had created but we may need different info (current premium?). Let me know if you think we need other data for this report

Mark Embry Life Partners, Inc.

From: Brian D. Pardo Sent: Tuesday, October 18, 2011 6:40 AM To: Mark Embry Cc: Scott Peden; Kurt Carr Subject: Good morning Mark. Several weeks ago I asked Scott to begin selling off as many pieces of Life Settlements as possible from our holdings we currently carry at no less than 85% of the face value. This is very important 1) to raise capital and 2) to demonstrate that policies we hold are worth far more than the more or less arbitrary “impairment” auditors wish to assign to these holdings (number one being far more important). Will you take the lead in this process coordinating with Scott and Kurt. Thanks Brian D. Pardo CEO Life Partners, Inc. (254) 751-7797 www.lifepartnersinc.com

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Exhibit 121

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From: Brian D. Pardo <[email protected]>Sent: Tuesday, May 14, 2013 4:35 PMTo: [email protected]; Scott Peden; Deborah CarrCc: Joe Barkate; WRIGHT TIM; Stephen Ziadie; [email protected]: RE: No Good Deed Goes Unpunished

Rich – The Texas Courts and the AG agreed that our explanation and disclosure regarding premiums has been clear and concise since 1999. Some people who have ignored two letters a month apart now are upset over the final notice. You can make their payment and collect it from them if you wish. If you portray our process any differently you may find you are responsible, because we have made our premium disclosures perfectly clear for many years now. Unfortunately, a small percentage of investors have chosen to ignore the commonly known fact that to keep a policy in effect premiums must be paid. Brian

Brian D. Pardo Life Partners, Inc.

From: [email protected] [mailto:[email protected]] Sent: Tuesday, May 14, 2013 12:59 PM To: 'Mona Pollina' Cc: Joe Barkate; WRIGHT TIM; Stephen Ziadie; [email protected] Subject: RE: No Good Deed Goes Unpunished Mona, I totally understand your frustration and your husband’s voice mail is what prompted my email to all clients. Just to be clear, you did not send anything to ASR, I believe you meant LPI. We are the independent marketing arm for LPI. We are meeting this week with LPI to discuss and solve or improve this issue. My best, Rich DePaolo From: Mona Pollina [mailto:[email protected]] Sent: Tuesday, May 14, 2013 12:32 PM To: Rich DePaolo Subject: Re: No Good Deed Goes Unpunished Mr. DePaolo,

I did in fact send in my instructions for payment to you as requested. However, after many phone conversations with both LPI and Provident, I found that Provident had never received my instructions from LPI. LPI was not helpful at all regarding this and basically didn't care if I lost my policy or not. As far as they were concerned they sent the information to Provident and that is all they cared about. Provident on the other hand finally seemed to care about the situation and promised to get a check to you ASAP. I felt like LPI did a poor job to

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say the least. I did disregard the second notice because I had sent the information in as soon as I had received it. When the third notice came I was shocked and acted immediately by faxing the information directly to Provident, which I will do from now on in the future as it seems LPI doesn't care one way or the other. I seem to be the first and only person that this has ever happened to, so I won't take that chance again.

Hopefully, the word I received that this would be taken care of and the policy would not be abandoned is exactly what will happen.

As a person coming from a management background in customer service, I can say how far customer service has slipped and how saddened I am by 98% of the responses received by those in customer service. Sincerely,

Mona Pollina

On Tue, May 14, 2013 at 12:00 PM, Rich DePaolo <[email protected]> wrote:

Having trouble viewing this email? Click here

Good afternoon Mona,

My purpose today is to explain the LPI abandonment policy. Prior to this year LPI has worked with investors as far as their ability to make premium calls by securing a lien against the individual investors fractional piece and then recouping their money at maturity. This was an interest FREE deal to the investor. Once the SEC entered the picture, LPI was forced to discontinue this gracious practice. Today, it is more important than ever for you to make your premium call payments at the first notification to avoid abandoning your fractional interest. We are very aware that even after you have made your payment you sometimes receive another notification of payment due. Please disregard if you know you made it as the payment and letters just crossed in the mail. This problem is most often encountered with IRA funds because the money must go to Provident and then down to Advance Trust which slows down the process. LPI is being super cautious by repeatedly reminding you so they don't have to enforce the abandonment procedure.

Let me remind you that you have been making premium calls from Day 1 because about 40 to 50% of your investment went to your own individual escrow accounts for each fractional piece. You can see this by going to www.lpi-policies.com and clicking on the tab Atlas Escrow History. Once a policy exceeds the Life Expectancy and your initial premium supply is exhausted then we all get premium payment bills. While each payment does decrease our final ROI, the beauty of this investment is you would have to make ABOUT seven or more payments on a policy before you would ever be upside down and even then you would be losing a very small percentage each year. Compare this with your investments in the stock market where on any given day you can wake up and discover the market crashed and took a substantial portion of your net worth with it. If you happen to be unfortunate enough to be drawing your stock portfolio down while the market is down your nest egg disappears rapidly. The point being an investment in Life Settlements is perfect for a PORTION of your total portfolio and premium calls are a part of this investment. My wife, parents, in-laws and siblings hate

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them as much as everyone does. If you do not know your user name and password for the LPI website above please call customer service at 800-368-5569 to receive a new one.

I also wanted to give you a "heads up" that Provident is working on improving their procedures, which in the short term could result in transactional delays of 1-3 business days from their standard processing times. Provident will be closed this Friday, May 17th, 2013 and will reopen on Monday, May 20th, 2013 at 7:00 am PST.

My best always,

Rich DePaolo

If you no longer wish to receive our emails, click the link below: Unsubscribe 251 E. Southlake Blvd Southlake, Texas 76092 United States

-- Mona Pollina There is no greater gift than JESUS!

App. 1855


Exhibit 122

App. 1856


From: Brian D. Pardo <[email protected]>Sent: Tuesday, November 25, 2014 9:53 AMTo: Merle OwensSubject: RE: charges for services?????

Merle – My email was not intended as a threat. I am just trying to make it clear to you that the charges for the ministerial services are a very small fraction of your investment, or put another way, the value of the death benefits you hold. It strikes me that a sensible investor would not put these at risk due to a lack of communication if LPI were not in the picture. I am satisfied you are aware. You need not respond as it appears we both have chosen the path we want to take in this matter.


From: Merle Owens [mailto:[email protected]] Sent: Tuesday, November 25, 2014 9:16 AM To: Brian D. Pardo Subject: RE: charges for services????? Brian: I’ll respond to your threat, as presented by you. Merle Owens From: Brian D. Pardo [mailto:[email protected]] Sent: Monday, November 24, 2014 3:16 PM To: Merle Owens Subject: RE: charges for services????? Merle – Apparently we are at odds over what a document we both are looking at says or doesn’t say. Regardless, to be completely clear, you must pay the bill as rendered. If you do not pay the bill as rendered you will face the consequences which in my opinion would put your investment in grave danger of being lost completely. The decision is yous. Sincerely,


From: Merle Owens [mailto:[email protected]] Sent: Monday, November 24, 2014 2:37 PM To: Brian D. Pardo Subject: RE: charges for services?????

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Brian: Yes, it is attached., Mine & yours are both dated 10/29. Merle From: Brian D. Pardo [mailto:[email protected]] Sent: Monday, November 24, 2014 2:29 PM To: Merle Owens Subject: RE: charges for services????? Are you talking about the October 29, 2014 email?


From: Merle Owens [mailto:[email protected]] Sent: Monday, November 24, 2014 2:27 PM To: Brian D. Pardo Subject: RE: charges for services????? BRIAN:‐‐‐‐I’m looking “right at it” too. It says—“After reading your letter I agree with you”‐‐‐what does your copy say—if different than the one you sent me on 10/29/14. Copy attached below. Merle Owens From: Brian D. Pardo [mailto:[email protected]] Sent: Monday, November 24, 2014 2:10 PM To: Merle Owens Subject: RE: charges for services????? Merle – My 10/29 email said no such thing! It said to disregard any notices you may receive if you had paid. I am looking right at it!


From: Merle Owens [mailto:[email protected]] Sent: Monday, November 24, 2014 2:02 PM To: Brian D. Pardo Subject: RE: charges for services????? Brian: On October 29th you said “you agreed with me”, regarding the fact that the bills were certainly excessive, and un‐called for. See your email of 10/29/14 attached. Now you tell me “PAY THE BILLS AS RECEIVED” since “we are not adjusting your bill”, “take this up with our CR people”. Please explain what changed your mind?? I haven’t paid the bills. Sincerely, Merle Owens From: Brian D. Pardo [mailto:[email protected]] Sent: Friday, November 21, 2014 1:41 PM

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To: Merle Owens Subject: RE: charges for services????? Merle – I told you if you have paid you may disregard the notice. If you have paid which you said you have do not worry, we are not going to list you with the credit services. To make matters very clear we are not acting on your accounts. That means you must pay the invoices. If you strenuously disagree you may request further consideration. However, that will have to be taken up with our CR people, not me! SO, PAY THE BILLS AS RECEIVED! What I mean to say, we are not adjusting your bill. So, you need to PAY the bill as received. I realize I said we would not take action until I got back with you AND WE HAVE’T!. We have now decided to take no action on your bill which means it must be paid. Sincerely,


From: Merle Owens [mailto:[email protected]] Sent: Thursday, November 20, 2014 9:26 AM To: Brian D. Pardo Subject: RE: charges for services????? Brian: Please re‐read your email to me dated October 29, 2014. You stated that “ I should ignore any reminders I should receive regarding this matter until you get back to me”. You haven’t got back to me, so I’m ignoring this matter. Does your statement sill hold true?? Merle Owens From: Brian D. Pardo [mailto:[email protected]] Sent: Wednesday, November 19, 2014 3:03 PM To: Merle Owens Subject: RE: charges for services????? Merle – If you have paid disregard the notice. We will only report to the credit agencies when we have determined that you are refusing to pay. We would let you know before we did that.


From: Merle Owens [mailto:[email protected]] Sent: Wednesday, November 19, 2014 9:53 AM To: Brian D. Pardo Subject: FW: charges for services????? Brian: Yesterday, I received 3 PAST DUE notices from you regarding this matter. Please check this, and make sure NO ONE reports this on our credit report. Natalie & I have spent a lifetime making sure we pay our obligations, and this is no time for something like this to change our spotless credit. Thanks, Merle Owens From: Brian D. Pardo [mailto:[email protected]] Sent: Wednesday, October 29, 2014 3:03 PM

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To: Merle Owens Subject: RE: charges for services????? You might get a reminder so don’t be surprised if you do. You may ignore this matter until we get back with you.


From: Merle Owens [mailto:[email protected]] Sent: Wednesday, October 29, 2014 2:57 PM To: Brian D. Pardo Cc: 'Ryan Cowley'; Scott Peden Subject: RE: charges for services????? Brian: Thanks for your reply, and your further consideration of our position. Merle From: Brian D. Pardo [mailto:[email protected]] Sent: Wednesday, October 29, 2014 1:52 PM To: Merle Owens Cc: Ryan Cowley; Scott Peden Subject: RE: charges for services????? Merle – After reading you letter I agree with you and we are willing to take another look at your position. Please disregard the billing until we contact you. Sincerely,


From: Merle Owens [mailto:[email protected]] Sent: Wednesday, October 29, 2014 9:44 AM To: Brian D. Pardo Cc: 'Ryan Cowley' Subject: charges for services????? More than 4 years ago my wife & I invested our retirement savings $500,000+ with Life Partners. We were told it was SAFE, TROUBLE FREE, & WORRY FREE. We believed all that, and were pleased when we received TWO payouts in the first two years. Although we began to hear of the poor underwriting your organization had & were doing we didn’t experience those problems until the last two & one half years.. It has been nearly thirty (30) MONTHS since we have received a payout, and are now told we will need to supplement our original investment with an additional $10,000 in 2015 to keep our investment in our policies in our name. Then we receive your new PLATFORM SERVICE CHARGE on our three portfolios. The amounts are certainly excessive, no explanation of what you did to earn these amounts, or proof that we agreed to any such service from your organization. All you stated was‐‐‐‐DUE UPON RECEIPT !!!!! Your charge on Natalie’s IRA of $27,000 ‐‐ $564.00 is outrageous. My account (Merle’s) $810.00‐‐‐& our joint account $420.00—or a total of $1794.00, for what? This simply can’t be based on any proper business principal, or performance requirement, but merely figures pulled out of the air to heckle individuals who have supported your company by investing in LPI. We

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have patiently waited for 30 months to see some results from a $500,000 + investment spread over 25+ lives (all 80 + yr. olds) who if they had been properly underwritten would have produced some favorable results by now, and not require a $10,000 supplemental investment in 2015 to back up the improper underwriting by your organization. While I personally doubt you will ever see this email, I do have a record of it being sent. With all the unfavorable response I’m sure you are receiving, do you plan any further explanation of what we can expect from LPI for these EXCESSIVE & UNEXPLAINED charges?? Merle & Natalie Owens

App. 1861


Exhibit 123

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App. 1864


Exhibit 124

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From: Brian D. Pardo <[email protected]>Sent: Friday, October 24, 2014 1:29 PMTo: [email protected]: RE: Update on the new LPI Ministerial Service Fee

I am sorry but it is much more complicated than you may realize. For you to replace us and ATLES every investor of every policy your clients are invested in would have to agree. Take my word for it, it gets more complicated from there. Just pay the fee and get over it. You would, in essence would have to track every policy to determine when a maturity has occurred. You would have to get permission from the insurance carriers to allow you access for management purposes. This is just the beginning. You cannot duplicate 24 years of business evolution and the highly sophisticated technology that does this task. But, if you are able to get every investor in every policy to agree that you should provide the services LPI does we’ll talk.


From: Wilkie Jim [mailto:[email protected]] Sent: Friday, October 24, 2014 9:24 AM To: Brian D. Pardo Cc: 'Tim Terry' Subject: RE: Update on the new LPI Ministerial Service Fee Brian, Again, please let me know who to contact in order to track this and I'll take it from there. Thanks .. Jim Wilkie, CCIM (281) 660-0777

From: Brian D. Pardo [mailto:[email protected]] Sent: Thursday, October 23, 2014 4:34 PM To: [email protected] Subject: RE: Update on the new LPI Ministerial Service Fee

My response is set out above. If you don’t want to pay you can choose to track your own positions or pay someone else to do it for you.


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From: Wilkie Jim [mailto:[email protected]] Sent: Wednesday, October 22, 2014 4:26 PM To: Brian D. Pardo Subject: RE: Update on the new LPI Ministerial Service Fee First, I never called you a 'crook', but your response is telling as to your conscience. Read your tirade! Not impressed. You have my response on the related e-mail string. And as you know, just because a court does not find someone not guilty does not mean they are innocent. Especially in the world of commercial contracts. All I want (and I am not speaking for other clients or any licensees) is the information I need to make a rational decision on my behalf. With whom do you coordinate at the life companies (or elsewhere) in regard to my ownership issues - upcoming payments? Thanks you .. Jim Wilkie, CCIM (281) 660-0777

From: Brian D. Pardo [mailto:[email protected]] Sent: Wednesday, October 22, 2014 10:49 AM To: [email protected] Subject: RE: Update on the new LPI Ministerial Service Fee

Please read my response above. If we were “Crooks” you would think the SEC and Texas AG would have won their cases. So calm down before you say something that you will wish you didn’t.


From: Wilkie Jim [mailto:[email protected]] Sent: Tuesday, October 21, 2014 2:31 PM To: 'Tim Terry' Cc: Brian D. Pardo Subject: RE: Update on the new LPI Ministerial Service Fee Tim, This is a very SAD way to do business and has all the earmarks of a 'bait & switch'. I am not willing to just roll-over and have a fee jammed down my throat half-way through a relationship when this was not fully disclosed before hand. If

App. 1867


3

there is an issue with LPI's cash flow, that is poor business practice as we know they have made tons of income on these transactions to date. At best, this should apply ONLY to new policies acquired AFTER full disclosure and alternative options should be provided. In fact, what I want is the process for checking these items myself. Who do I coordinate with going forward on the 6 units that I have? For $500 a year, this is something I would rather do directly. Thanks ..

Jim Wilkie, CCIM

(281) 660-0777

From: Tim Terry [mailto:[email protected]] Sent: Tuesday, October 21, 2014 8:43 AM To: Jim Wilkie Subject: Update on the new LPI Ministerial Service Fee

Jim, Last week we all received a letter and an invoice from Life Partners notifying us of new and unexpected admin fees associated with our life settlement investments. I understand no one likes to be charged for what they have received at no charge in the past. I too am paying this service charge. This certainly could have been handled much better. For instance, they could have notified me and the other licensees in advanced. Unfortunately, many of you were notified before me. They said that this charge was retroactive, but what they meant to say and I have verified this, is that the payment is in "arrears". This simply means that like my home owners insurance, I pay at the beginning and not at the end of the insurance period. I was told that the next invoice would not be for 12 months. I have to remind myself that LPI is like Remax. They find the deal and arrange for the buyers and sellers to come together, but they never handle the money. The only reason that LPI stays involved is to make sure the investors know when premiums are due and to make sure that everyone pays them on time. If one investor decided they did not want to pay further premiums, all the other investors would have that particular life policy in jeopardy for lack of premium payment. Having LPI stay on top of this for us is a real service that up till now they have handled at no charge. They also stay up to date on when these policies mature. Every single day someone needs to check on these policies to make sure that we are notified when the individual passes. LPI again is not required to do this for free. I am so thankful that they do this for all of us. Technically, by contract- (Policy Funding Agreement), LPI is not obligated to provide any further service beyond the policy acquisition. That is why Brian stated in the letter the ministerial services LPI has provided all these years has been more than the contract called for and at LPI's expense.

App. 1868


4

It is not hard to figure out that LPI has been operating at a lose for 8 quarters. I do not know how long they can sustain an operating loss. If LPI were to go under, it would not jeopardize our investment. However, it would be chaotic to say the least. I have a substantial amount invested and if this service fee is what prevents that potential situation from occurring then I will do my part. The last thing we want is to have to monitor these policies ourselves. Most of my investors have had at least one policy maturity. I am getting notified every week as to more maturities. Many of these were purchased in 2009. Well most of us invested in 2010 and 2011. Our time is coming! My recommendation is to pay the fee and stay focused on these maturities that are yielding 10% or better compounded rates as an average. I will continue to monitor this situation carefully and will keep you posted on further information as it becomes available. You are welcome to email Brian Pardo directly if you like. These are simply my thoughts. ([email protected]) My Best Always, Tim Terry 214.616.5116

App. 1869


Exhibit 125

App. 1870


App. 1871


App. 1872


Exhibit 126

App. 1873


Summary of Positions:

Purchases:# of positions 906Purchase Amount 5,901,863.32$ Projected Revenue 20,649,621.87$

Held:# of positions** 32Purchase Amount 166,347.96$ Projected Revenue 587,298.28$

Sold/Resales:# of positions** 875Purchase Amount 5,746,738.40$ Projected Revenue 20,098,687.24$ Sales price 8,836,942.11$ Profit* 3,090,203.71$

Matured:# of positions 0

*Profit does not take into consideration any premiums paid as they are unavailable to be calculated.**Note: Paget held onto 2.95 of the projected revenue of FundingID 178951 and therefore this position is included in both the 'Held' and 'Sold/Resales' category, therefore the total of positions is one more than the number originally purchased.

App. 1874

Summary of Paget Transactions


Exhibit 127

App. 1875


App. 1876


App. 1877


App. 1878


Exhibit 128

App. 1879


1

From: Mark Embry <[email protected]>Sent: Thursday, February 22, 2007 5:02 PMTo: Justin Blount; Brian D. Pardo; Scott Peden; Liz PardoSubject: RE: Deceased Workque and files

I think maybe we should wait until Justin can be with us. Brian, what day next week would be good for you? Mark Embry Life Partners, Inc.

From: Justin Blount Sent: Thursday, February 22, 2007 4:39 PM To: Mark Embry; Brian D. Pardo; Scott Peden; Liz Pardo Subject: RE: Deceased Workque and files All, Sorry, I won’t be able to attend tomorrow. I will be out for a funeral. I can catch everyone up on Monday if anyone has any specific questions regarding any particular file. Justin R. Blount Associate General Counsel Life Partners, Inc. (254) 751-7797 www.lifepartnersinc.com

From: Mark Embry Sent: Thursday, February 22, 2007 4:37 PM To: Brian D. Pardo; Scott Peden; Justin Blount; Liz Pardo Subject: Deceased Workque and files It seems we have an increase in deceased files that have not paid off for whatever reason. I would like to meet around 2:00 tomorrow afternoon or after our visitors leave if they are still here, to discuss our plan of action for these files. Liz, I know you have a lot of information regarding the files that you may want to bring. Justin, you may want to be prepared to discuss the legal issues regarding those with legal problems. Your attendance is requested in the conference room. Mark Embry COO/CIO

App. 1880


2

Life Partners, Inc. (254) 751-7797 www.lifepartnersinc.com

App. 1881


Exhibit 129

App. 1882


‐

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

40,000,000

Total liquid assets

Total dividends paid

App. 1883


Total liquid assets ‐

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

2/1/

2011

4/1/

2011

6/1/

2011

8/1/

2011

10/1

/201

1

12/1

/201

1

2/1/

2012

4/1/

2012

6/1/

2012

8/1/

2012

10/1

/201

2

12/1

/201

2

2/1/

2013

4/1/

2013

6/1/

2013

8/1/

2013

10/1

/201

3

12/1

/201

3

2/1/

2014

4/1/

2014

6/1/

2014

8/1/

2014

10/1

/201

4

Total liquid assets


App. 1884


LPHIFinancial Data Over TimeFrom Public Filings, 10‐Q & 10‐K

Quarterly Reports 2/28/2011 5/31/2011 8/31/2011 11/30/2011 2/29/2012 5/31/2012 8/31/2012 11/30/2012 2/28/2013 5/31/2013 8/31/2013 11/30/2013 2/28/2014 5/31/2014 8/31/2014 11/30/2014Cash and cash equivalents 27,610,564 22,318,811 18,756,886 16,288,749 11,362,688 12,730,186 12,748,717 12,384,255 7,575,579 8,296,491 5,310,165 3,957,670 6,134,731 4,688,166 3,058,878 4,220,749 Certificates of deposit 100,737 100,750 100,762 100,772 100,848 100,937 101,027 101,086 602,316 602,359 351,247 351,385 351,588 351,632 351,804 352,008 Investment in securities 5,110,677 4,115,046 3,125,382 1,900,000 400,000 ‐ Total liquid assets 32,821,978 26,534,607 21,983,030 18,289,521 11,863,536 12,831,123 12,849,744 12,485,341 8,177,895 8,898,850 5,661,412 4,309,055 6,486,319 5,039,798 3,410,682 4,572,757

Dividends paid 4,474,548 3,733,115 3,728,942 3,729,078 3,729,581 1,864,744 1,864,572 1,869,673 1,864,696 1,864,687 932,314 932,568 932,331 930,211 934,566 932,459

Dividends payable 3,736,330 3,736,266 3,736,819 3,737,234 1,872,399 1,872,403 1,873,976 1,869,145 1,869,195 936,886 936,941 936,746 936,788 936,773 936,758 4,297

Total shareholders equity 55,249,967 50,653,154 46,588,389 41,867,665 39,159,616 38,331,899 34,616,429 31,997,938 28,822,110 29,568,910 26,843,328 24,972,099 22,638,512 19,971,155 11,826,616 12,904,561

Total dividends paid 4,474,548 8,207,663 11,936,605 15,665,683 19,395,264 21,260,008 23,124,580 24,994,253 26,858,949 28,723,636 29,655,950 30,588,518 31,520,849 32,451,060 33,385,626 34,318,085

Total Paid to Pardo $2,238,616.36 $4,106,293.80 $5,971,883.48 $7,837,541.20 $9,703,450.58 $10,636,382.00 $11,569,227.37 $12,504,624.78 $13,437,532.18 $14,370,435.09 $14,836,871.79 $15,303,435.56 $15,769,880.75 $16,235,265.32 $16,702,828.69 $17,169,337.93

2/28/2001 2/28/2002 2/28/2003 11/30/2004 11/30/2005 11/30/2006 11/30/2007 11/30/2008 11/30/2009 11/30/2010 11/30/2011 11/30/2012 11/30/2013 11/30/2014Total liquid Assets 312,277 4,525,292 5,242,863 5,310,046 5,285,296 5,253,247 8,042,036 22,495,730 26,579,937 34,120,517 18,289,521 12,485,341 4,309,055 4,572,757Total dividends paid 244,234 1,103,369 566,714 486,971 565,689 811,718 821,239 3,715,317 7,457,392 15665683 24994253 30588518 34318085

App. 1885


2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Total liquid Assets 312,277 4,525,292 5,242,863 5,310,046 5,285,296 5,253,247 8,042,036 22,495,730 26,579,937 34,120,517 18,289,521 12,485,341 4,309,055 4,572,757Total dividends paid 244,234 1,103,369 566,714 486,971 565,689 811,718 821,239 3,715,317 7,457,392 15,665,683 24,994,253 30,588,518 34,318,085

‐

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

40,000,000

Total liquid Assets


‐

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,00020

01

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

Total liquid Assets


App. 1886


Exhibit 130

App. 1887


Exhibit Platform Services FeeLife Partners Inc. collection of Platform Services FeeSummary by Month

Month Net Total Collected

October 2014 2,041,375.30$

November 2014 2,296,904.98$

December 2014 1,013,311.40$

January, up to January 20, 2015 193,134.38$

Grand Total 5,544,726.06$

App. 1888


Exhibit 131

App. 1889


LPCN_00102317App. 1890


LPCN_00102317_00002App. 1891


LPCN_00102317_00003App. 1892


Exhibit 132

App. 1893


App. 1894


App. 1895


App. 1896


App. 1897


Exhibit 133

App. 1898


App. 1899


Exhibit 134

App. 1900


8-K 1 v388236_8-k.htm FORM 8-K UNITED STATES

SECURITIES AND EXCHANGE COMMISSIONWashington, D.C. 20549

_____________

FORM 8-K_____________

CURRENT REPORT

Pursuant to Section 13 or 15(d) of The Securities Exchange Act of 1934

Date of Report (Date of earliest event reported): September 2, 2014_____________

LIFE PARTNERS HOLDINGS, INC.(Exact name of registrant as specified in its charter)

Texas 0-7900 74-2962475(State or other jurisdiction

of incorporation)(CommissionFile Number)

(IRS EmployerIdentification No.)

204 WoodhewWaco, Texas 76712

(Address of principal executive offices) (Zip Code)

Registrant’s telephone number, including area code: (254) 751-7797___________________

Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant under any of the following provisions (see General Instruction A.2 below):

Written communications pursuant to Rule 425 under the Securities Act (17 CFR 230.425)Soliciting material pursuant to Rule 14a-12 under the Exchange Act (17 CFR 240.14a-12)Pre-commencement communications pursuant to Rule 14d-2(b) under the Exchange Act (17 CFR 240.14d-2(b))Pre-commencement communications pursuant to Rule 13e-4(c) under the Exchange Act (17 CFR 240.13e-4(c))

Page 1 of 4

10/29/2015https://www.sec.gov/Archives/edgar/data/49534/000114420414053736/v388236_8-k.htmApp. 1901


Item 8.01 Other Events.

On September 2, 2014, the registrant issued a press release announcing that it would pay a quarterly dividend of $0.05 per share to be paid on or about September 17, 2014 for shareholders of record as of September 15, 2014.

Item 9.01 Financial Statements and Exhibits

(d) Exhibits

Exhibit No. Description99.1 Press Release, dated September 2, 2014

Page 2 of 4



SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

LIFE PARTNERS HOLDINGS, INC.

Date: September 2, 2014 By:/s/ Colette PieperColette PieperChief Financial Officer

Page 3 of 4



EXHIBIT INDEX

Exhibit No. Description99.1 Press Release, dated September 2, 2014

Page 4 of 4



EX-99.1 2 v388236_ex99-1.htm EXHIBIT 99.1 Exhibit 99.1

LIFE PARTNERS HOLDINGS, INC. ANNOUNCESQUARTERLY DIVIDEND

Waco, TX – September 2, 2014 – Life Partners Holdings, Inc. (Nasdaq GS: LPHI), parent company of Life Partners, Inc., announced that it would pay a quarterly dividend of $0.05 per share to be paid on or about September 17, 2014 for shareholders of record as of September 15, 2014.

Life Partners is the world’s oldest and one of the most active companies in the United States engaged in the secondary market for life insurance, commonly called “life settlements.” Since its incorporation in 1991, Life Partners has completed over 157,000 transactions for its worldwide client base of over 30,000 high net worth individuals and institutions in connection with the purchase of over 6,500 policies totaling over $3.2 billion in face value.

**********LPHI-D

Contact:

Andrea AtwellLife Partners Holdings, Inc.Shareholder [email protected]

Page 1 of 1

10/29/2015https://www.sec.gov/Archives/edgar/data/49534/000114420414053736/v388236_ex99-1....App. 1905


Exhibit 135

App. 1906


1

From: [email protected]: Tuesday, December 02, 2014 12:53 PMTo: Tad Ballantyne; Scott Peden; Brian D. PardoSubject: RE: Dividend resolution 3Q FY 2015 and officer bonuses

I approve the $.05/share dividend.

Harold E. Rafuse ---- "Brian D. Pardo" <[email protected]> wrote: > Thank you Tad. I approve as well and Harold has indicated he is in agreement and will return the response to Scott as soon as he gets it. I have also asked the Board to set the Officer bonus pool for the third quarter sufficient to deliver a net $25,000 per officer for the truly great job our officers have done especially in regards to the platform fee introduction and collection from a group of roughly 21,000 accounts holding 105,000 active accounts. This accomplishment was recognized by Ziegler as a very positive display of our capabilities. Thank you. Brian > > > > Brian D. Pardo > Life Partners, Inc. > > > > From: Tad Ballantyne [mailto:[email protected]] > Sent: Tuesday, December 02, 2014 12:18 PM > To: Scott Peden > Cc: Brian D. Pardo; Fred Dewald (E-mail); <[email protected]> > Subject: Re: Dividend resolution 3Q FY 2015 and officer bonuses > > > > Gentlemen > > After further review and input from investment bankers I approve a .05 dividend. > > Regard > > Tad > > Tad Ballantyne > > Tel. 262.4974625 mobile

App. 1907


2

> > > > > On Nov 26, 2014, at 11:53 AM, "Scott Peden" <[email protected]> wrote: > > Gentlemen: > > > > Brian has asked me to send out the attached proposed dividend resolution to you for your consideration. He informs me that Zigler is in favor of no changes to the prior dividend policy as they feel a change in policy would make it more difficult to complete the $25MM convertible debenture deal by year end. This was a surprise to Brian, who expected them to advise that the dividend to be reduced or eliminated. > > > > If you have any e-mail discussions on this issue, please copy me so that I may include them in the minutes. If there is a telephonic meeting, please send me notes so we can prepare for the minute book. > > > > > > Members of the Compensation Committee: > > > > Attached is a resolution for a special officer bonus in recognition of the efforts and persistency of all of the officers of both LPHI and LPI in turning the company profitable, continuing to remain with and support the company during the past few years which, as we all know, have been difficult. If there is email discussion or telephonic meeting, please provide me with those e-mails or minutes of the meeting to be included in the minute book. Thank you. > > > > > > <officer bonus resolution 2014.docx> > > <Dividend resolution 3Q FY 2015.docx> >

App. 1908


Exhibit 136

App. 1909


App. 1910


Exhibit 137

App. 1911


App. 1912


Exhibit 138

App. 1913


Exhibit TollesonSummary of Tolleson Payments

Check Number Check Date Description Check Amount

001001 10/29/2014 138056-B Tolleson Investments 35,000.00$






198,227.86$

App. 1914


Exhibit 139

App. 1915


App. 1916


App. 1917


Exhibit 140

App. 1918


App. 1919


App. 1920


App. 1921


Exhibit 141

App. 1922


App. 1923


App. 1924


Exhibit 142

App. 1925


LPCN_00125212App. 1926


Exhibit 143

App. 1927


Summary of Happy Endings 990s2006‐2013EIN 20‐5483593Happy Endings granted tax‐exempt status by IRS in July 2007.

Year Name Title Compensation

Contributions‐Pardo or Robinson

*reconciled with returns

Contributions‐Non‐Pardo or Robinson

Contributions‐Unknown Source

2006 Linda Robinson CEO/President ‐$ 198,089.00$ ‐$ ‐$ No Schedule B‐ Schedule of Contributors provided(cash basis) Unknown ‐$ ‐$ ‐$ 6,195.00$ No Schedule B‐ Schedule of Contributors provided

(17,474)$ 198,089.00$ ‐$ 6,195.00$

2007 Linda Robinson CEO/President ‐$ 1,070,570.00$ ‐$ ‐$ No Schedule B‐ Schedule of Contributors provided(cash basis) Unknown ‐$ ‐$ ‐$ 12,531.00$ No Schedule B‐ Schedule of Contributors provided

198,233$ 1,070,570.00$ ‐$ 12,531.00$

2008 Linda Robinson CEO/President 57,244.00$ 2,250,437.00$ ‐$ ‐$ No Schedule B‐ Schedule of Contributors provided(cash basis) Unknown ‐$ ‐$ ‐$ 122,089.00$ No Schedule B‐ Schedule of Contributors provided

381,266$ 2,250,437.00$ ‐$ 122,089.00$

2009 Linda Robinson CEO/President 161,256.00$ 4,799,554.00$ ‐$ ‐$ No Schedule B‐ Schedule of Contributors provided(cash basis) Unknown ‐$ ‐$ ‐$ 135,848.00$ No Schedule B‐ Schedule of Contributors provided

1,206,109$ 4,799,554.00$ ‐$ 135,848.00$

2010 Linda Robinson CEO/President 284,390.00$ ‐$ ‐$ ‐$ No Schedule B‐ Schedule of Contributors provided(inc tax basis) Brian Pardo Director ‐$ ‐$ ‐$ ‐$ No Schedule B‐ Schedule of Contributors provided

(384,720)$ Unknown ‐$ ‐$ ‐$ 2,904,044.00$ No Schedule B‐ Schedule of Contributors provided‐$ ‐$ 2,904,044.00$

2011 Linda Robinson CEO/President ‐$ 1,979,187.00$ ‐$ ‐$ Schedule B‐ Schedule of Contributors(accrual basis) Brian Pardo Director ‐$ ‐$ ‐$ ‐$ Schedule B‐ Schedule of Contributors

167,480$ Wal‐Mart ‐$ ‐$ 41,611.00$ ‐$ Schedule B‐ Schedule of ContributorsUnknown ‐$ ‐$ ‐$ 3,000.00$ Not listed on Schedule B

1,979,187.00$ 41,611.00$ 3,000.00$

2012 Linda Robinson CEO/President ‐$ ‐$ ‐$ ‐$ Schedule B‐ Schedule of Contributors(accrual basis) Brian Pardo Director ‐$ 1,139,854.00$ ‐$ ‐$ Schedule B‐ Schedule of Contributors

(92,896)$ Wal‐Mart ‐$ ‐$ 37,502.00$ ‐$ Schedule B‐ Schedule of ContributorsStephanie Gledhill ‐$ ‐$ 6,445.00$ ‐$ Schedule B‐ Schedule of ContributorsUnknown ‐$ ‐$ ‐$ 7,867.00$ Listed on Schedule B as Contributions < $5KUnknown ‐$ ‐$ ‐$ 4,881.00$ Listed on Schedule B as Contributions < $5K

1,139,854.00$ 43,947.00$ 12,748.00$ 2013

(accrual basis) Linda Robinson CEO/President ‐$ 365,916.00$ ‐$ ‐$ Schedule B‐ Schedule of Contributors57,102$ Brian Pardo ‐$ 910,136.00$ ‐$ ‐$ Schedule B‐ Schedule of Contributors

Life Partners, Inc. ‐$ ‐$ 130,000.00$ ‐$ Schedule B‐ Schedule of ContributorsStephanie Gledhill ‐$ ‐$ 7,210.00$ ‐$ Schedule B‐ Schedule of ContributorsMWI Veterinary Supplies ‐$ ‐$ 5,000.00$ ‐$ Schedule B‐ Schedule of ContributorsUnknown ‐$ ‐$ ‐$ 3,358.00$ Not listed on Schedule B

1,276,052.00$ 142,210.00$ 3,358.00$

App. 1928


2014Grand Total 502,890.00$ 12,713,743.00$ 227,768.00$ 3,199,813.00$

App. 1929


Exhibit 144

App. 1930


App. 1931


App. 1932


App. 1933


App. 1934


App. 1935


App. 1936


App. 1937


Exhibit 145

App. 1938


1

From: Brian D. PardoSent: Saturday, January 02, 2010 10:42 AMTo: Linda Robinson-PardoSubject: RE: Happy Ending Dog Rescue needs help

Linda - To say the least I am shocked by the size and scope of this latest deficit. I was just beginning to feel that you had matters under control. It has not been personal as you correctly point out, but Linda, you certainly have had the opportunity to talk with me long before things get to the crisis stage they are apparently at now.

I don't have that kind of money laying around and even if I did I would need more than a three or four day notice. The assets of the trust are mainly comprised by LPHI stock and various real estate holdings. We have put the 112' on hold dueto lack of liquidity. Cash is generated by dividends which are heavily taxed. So, even though you think I can't run out of money, I can!

The rescue is near and dear to my heart and you have great compassion as well. But Linda, we cannot fix this problem in a day or so. I can help you with the payroll, but I have to think about how we can deal with the other problems. To make matters worse, property taxes are payable this month on all of the properties owned by the trust. This is a significant amount. When it rains it pours! Let me think about it, but we have a serious problem here Linda. Brian

From: Linda Robinson-Pardo [mailto:[email protected]] Sent: Sat 1/2/2010 3:48 AM To: Brian D. Pardo Subject: Happy Ending Dog Rescue needs help

Brian,

I have tried everything to create additional revenue HEDR to not have to ask for help from you but have been unsuccessful. The brochure mailout has not been successful so far but it is still early. Confirms that services and the donation from the trust & LPHI are all that can be counted on. Clinic is increasing revenue but couldn't make enough money fast enough to stop the financial snow ball effect that started the first of the year. (three payrolls month of Jan/Sept)

HEDR has a total sum of $2,000 in the account. Payroll is this Wednesday and again in two weeks after that. None of the bills for January have been paid and are due on the 5th. We have a few still outstanding from December. Debra Hanford and myself have been working very hard to eliminate excess spending and have reduced expenditures to try to get back on track.

2009 January and again in Seotember had three payroll periods only two are in the budget. Servey, architectural designs, plumbing, HVAC & engineering designs have mostly been paid for Park Meadow (allowing building to be ready to be built when given green light) along with expensive medical treatments taken out of HEDR budget for our personal dogs that just recently reimbursed all of this has contributed to the current lack of funds.

I don't want you to be disapointed or mad at me but even if you are it won't make this go away. This is a business issue not personal. I have tried my best to reorganize and cut back but it has finally caught up with me. The clinic is just too new (opened August) to

App. 1939


2

contribute soon enough. The good news is all taxes are paid providing calculations were corectly deducted each payroll period by CPA. This is a first for HEDR. I have tried to talk to you but have been very limited on time with you. Let's face it you have been pretty occupied with LPHI understandably and not really wanted to listen to me anyway. I don't mean to be a constant drain financially but at this point time is running out and I have no where else to turn. Food order and medical order for supplies have been put on hold by supplier because of non- payment. I really need to be reimbursed by the trust $285,275.65 spent on plans for Big building at Park Meadow. An itemized list is available. This will get HEDR through January until next Wire for Feb comes. Debra and I are working very hard to make sure we can manage after this help on what is donated by Trust and LPHI. Please let me know something ASAP. Linda Robinson-Pardo Owner/Founder/Pack Leader Happy Endings Dog Rescue "He is your friend, your partner, your defender, your dog. You are his life, his love, his leader. He will be yours, faithful and true, to the last beat of his heart. You owe it to him to be worthy of such devotion." "The greatness of a nation and its moral progress can be judged by the way its animals are treated... I hold that, the more helpless a creature, the more entitled it is to protection by man from the cruelty of man." -Mahatma Gandhi-

App. 1940


Exhibit 146

App. 1941


App. 1942


Exhibit 147

App. 1943


App. 1944


Exhibit 148

App. 1945


1

From: Deborah Carr <[email protected]>Sent: Friday, May 04, 2012 8:53 AMTo: Elle FrenchSubject: Re: New Account Documents

It has been a little confusing. What I sent you are the docs for Shamrock for Descartes and Valance portfolios. They are just the standard documents and may overlap some for life settlements. Scott has not involved me in the Robin Rock purchases, so I cannot speak for that. Let me know if I need to do anything there. Otherwise, everything you have from me is for the transfer of ownership between Descartes, Valance, and Shamrock. All my best, Debbie Sent from my iPhone On May 4, 2012, at 5:28 AM, "Elle French" <[email protected]> wrote: > Debbie, > > All of these documents attached are for the first portfolio to Shamrock > Life Settlement right? > > Can you confirm because I think I am getting confused between the docs > you have sent and the docs that Scott has sent. > > The two portfolios I have purcahsed so are are Viaticals Correct? The > first one for Shamrock and the second for Robin Rock Limitd. > > But I have also received a Life Settlements Risk Factors form, is that > for Viaticals too? > > It might be easier if I get two seperate lists of the docs you need for > each purchaser. > > Also, for the second portfolio, purchased by Robin Rock we want to open > an account to pay premiums and some of the docs I have may be for that > but I am a bit confused sorry. > > Elle > > ‐‐‐‐‐Original Message‐‐‐‐‐ > From: "Deborah Carr" <[email protected]> > To: <[email protected]> > Date: Thu, 3 May 2012 11:37:02 ‐0500 > Subject: FW: New Account Documents > >

App. 1946


Exhibit 149

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Exhibit 150

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From: Sonja Pesina <[email protected]>Sent: Tuesday, April 15, 2014 9:14 AMTo: Deborah CarrSubject: FW: Robin Rock

Debbie,

Will you please review Elle's response? I know that is how we processed the transfer from LPI to Robin Rock, but that was a one-time exception. This is a little different. I am also not sure if the money will be transferred directly from Shamrock to Robin Rock and if it will be handled as a direct resale. She is asking if we could waive the $200.00 fee and I know that is not our fee to waive. Do you think we could work on the 6%?

Let me know if you have any suggestions.

Thank you,

Sonja Pesina Life Partners, Inc.

-----Original Message----- From: [email protected] [mailto:[email protected]] Sent: Tuesday, April 15, 2014 5:05 AM To: Sonja Pesina Subject: Re: Robin Rock

Sonja,

I will come back to you in relation to the Tevlin Policies in a seperate email.

I note the amount of the fees to be charged and I was not aware of the extent of the these expenses.

The terms are simple, these positions are being sold as a parcel for a total price of USD 1.7 million, there is no individual price for each position.

As the buyer is not aware of the costs and fees you advise to me, they will have to be paid by the seller and I can make arrangments for that.

As you will be getting 6% on the purchase price, which is not a small amount, and as there are a large number of individual positions can you ask Debbie or Brian whether they would be willing to waive the $200.00 per position charge on this occasion. In any event I would be grateful if you would make a start on the documentation.

Thank you for your help Sonja and I wait to hear from you.

Best regards,

Elle

Quoting Sonja Pesina <[email protected]>:

> Elle, > > If these are being purchased by Shamrock, I need all of the terms. I > need to know how much he position will be sold for. Also, there is a

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> $200.00 fee for each position. There will also be 6% fee for LPI for > each resale. I want for you to be aware of all of the fees before I > draft contracts. > > Also, Debbie mentioned that all of the policies held by Shamrock for > Tevlin were transferred to Alexandra. I need documentation for the > escrow agent to complete the transfer. > > Please let me know if you have any additional questions. > > Thank you, > > Sonja Pesina > Life Partners, Inc. > >

App. 1952


Exhibit 151

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1

From: Deborah Carr <[email protected]>Sent: Monday, February 04, 2013 10:07 AMTo: Debra WoodsSubject: RE: Tevlin Policies

If it's just one $100 fee, we'll pay it. Deborah Carr Life Partners, Inc. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Debra Woods Sent: Monday, February 04, 2013 9:55 AM To: Deborah Carr Subject: RE: Tevlin Policies It's a $100.00 to process fee. Are we paying it or do I need to request it from her? Thank you Debra Woods Life Partners, Inc. ‐‐‐‐‐Original Message‐‐‐‐‐ From: Deborah Carr Sent: Friday, February 01, 2013 2:47 PM To: Debra Woods Subject: FW: Tevlin Policies Importance: High Would you please prepare the documents to have the Tevlin policies transferred from Shamrock to Alexandra. If you have any questions for Elle, you may contact her directly or let me know what you need and I will contact her. I'd like to have the documents to her by Monday. Thanks, Debbie Deborah Carr Life Partners, Inc.

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‐‐‐‐‐Original Message‐‐‐‐‐ From: Elle French [mailto:[email protected]] Sent: Friday, January 25, 2013 3:16 AM To: Deborah Carr Subject: Fwd: Tevlin Policies Debbie, is there any news on this? If there are any problems let me know and we can discuss it. Thanks Elle ‐‐‐‐‐Original Message‐‐‐‐‐ From: "Elle French" <[email protected]> To: [email protected] Date: Thu, 10 Jan 2013 10:13:04 +0100 Subject: Fwd: Tevlin Policies Hi Debbie, Please see my email below of the 13th November. Can you let me know what is happening with the transfer of ownership of these policies. Thanks Elle ‐‐‐‐‐Original Message‐‐‐‐‐ From: "Elle French" <[email protected]> To: "Deborah Carr" <[email protected]> Date: Tue, 13 Nov 2012 09:54:54 +0100 Subject: Tevlin Policies Dear Debbie, I return to this matter of the Tevlin policies as I need to complete the process for my files and for the client. As I understand it, all of the Tevlin policies that we purchased were purchased by Shamrock Life Settlements. The Policies are: Policy ID: 8621 8622 8623 8628 8292

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and I would be grateful if you would check that there are no more Tevlin policies that have been purchased by Shamrock or any of my other clients, Robin Rock Limited, Alexandra Agencies or Cateya Limited. In the case of all those Tevlin policies purchased by Shamrock, we now need to transfer them to the ownership of Alexandra Agencies Limited. Can you please tell me what is required from me to allow you to make the transfers to Alexandra. Also, can you tell me what premiums, if any, have been paid on these policies since date of transfer from Descartes/Valance to Shamrock. Thank you for your help Debbie. Elle

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Exhibit 152

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FILED10 April 1 A9:32Karen MatkinDistrict ClerkMcLennan CountyAccepted by: Ann Henager

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Exhibit 153

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Exhibit 154

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ORIGINAL

LH4

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

SECURITIES AND EXCHANGE

COMMISSION

Plaintiff

V.

LIFE PARTNERS HOLDINGS, INC., BRIAN PARDO, and R. SCOTT' PEDEN,

Defendants

CIVIL ACTION NO. 1-12-C V-33-JRN

VERDICT FORM

Question No. 1 - Section 10(b) and Rule lOb-5 Securities Fraud

Did the SEC prove by a preponderance of the evidence that Defendants Life

Partners Holdings, Inc., Brian D. Pardo, and R. Scott Peden violated Section 10(b) of the

Securities Exchange Act of 1934 and Rule lOb-5?

Answer "Yes" or "No" as to each Defendant.

Life Partners Holdings, Inc.:

Brian D. Pardo: - MO R. Scott Peden: N 0

Case 1:12-cv-00033-JRN-AWA Document 258 Filed 02/03/14 Page 1 of 7

App. 2013


If you answered "No" as to Defendant Life Partners Holdings, Inc. to Question No. 1, do not answer Question No. 2 and proceed directly to Question No. 3. If you answered "Yes" as to Defendant Life Partners Holdings, Inc. to Question No. 1, please proceed to Question No. 2.

Question No. 2 - Aiding and Abetting Violations of Section 10(b) and Rule lOb-5

Did the SEC prove by a preponderance of the evidence that Defendants Brian D.

Pardo and R. Scott Peden, aided and abetted Defendant Life Partners Holdings, Inc.'s

violations of Section 10(b) of the Securities Exchange Act of 1934 and Rules lOb-5?


Brian D. Pardo:

R. Scott Peden:

Question No. 3 - Section 10(b) and Rule lOb-5 - Insider Trading


Pardo and R. Scott Peden violated Section 10(b) of the Securities Exchange Act of 1934

and Rule lOb-5 by engaging in insider trading?

Answer "Yes" or No as to each Defendant.

Brian D. Pardo:

R. Scott Peden: C

-2-


App. 2014


Question No. 4 - Section 17(a) Securities Fraud

Did the SEC prove by a preponderance of the evidence that Defendants Life

Partners Holdings, Inc., Brian D. Pardo, and R. Scott Peden violated Section 17(a)(1) of

the Securities Act of 1933?



Brian D. Pardo:

R. Scott Peden:

Question No. 5 - Section 13(a) and Rules 12b-20, 13a-1, and 13a-13

Did the SEC prove by a preponderance of the evidence that Defendant Life

Partners Holdings, Inc. violated Section 13(a) of the Securities Exchange Act of 1934 and

Rules 12b-20, l3a'l, and 13a-l3?

,, " Answer ies or No".

Life Partners Holdings, Inc.: \JE$

-3-


App. 2015


If you answered "No" as to Defendant Life Partners Holdings, Inc. to Question No. 5, do not answer Question No. 6 and proceed directly to Question No. 7. If you answered "Yes" as to Defendant Life

Partners Holdings, Inc. to Question No, 5, please proceed to Question No. 6.

Question No. 6 Aiding and Abetting Violations of Section 13(a) and Rules 12b-20, 13a- 1, and 13a-13


Pardo and R. Scott Peden aided and abetted Defendant Life Partners Holdings, Inc.'s

violations of Section 13(a) of the Securities Exchange Act of 1934 and Rules 12b-20, 13a-1,

and 13a-13?


Brian D. Pardo:

R. Scott Peden: E5

Question No. 7 Sections 13(b)(2)(A) and 13(b)(2)(B) Books and Records

Did the SEC prove by a preponderance of the evidence that Defendant Life

Partners Holdings, Inc. violated Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities

Exchange Act of 1934 and Rules 12b-20, 13a-1, and 13a-13?

'' ,, '' Answer Yes or No


-4-

No


App. 2016


If you answered "No" as to Defendant Life Partners Holdings, Inc. to Question No. 7, do not answer Question No. 8 and proceed directly to Question No. 9. If you answered "Yes" as to Defendant Life Partners Holdings, Inc. to Question No. 7, please proceed to Question No. 8.

Question No. 8 Aiding and Abetting Violations of Sections 13(b)(2)(A) and 13(b)(2)(B) Books and Records


Pardo and R. Scott Peden aided and abetted Defendant Life Partners Holdings, inc.'s

violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934?

,, "' -. ,, Answer es or o as to each Defendant.

Brian D. Pardo:

R. Scott Peden:

Question No, 9 Section 13(b)(5) and Rule 13b2-1 Books and Records


Pardo and R. Scott Peden violated Section 13(b)(5) of the Securities Exchange Act of 1934

and Rule i3b2-1?


Brian D. Pardo: 0

R. Scott Peden:

-5-


App. 2017


Question No. 10 Rule 13b2-1 Books and Records


Pardo and R. Scott Peden violated Section 13(b)(5) of the Securities Exchange Act of 1934

and Rule 13b2-1?

"' Answer i es or INo as to each Defendant.

Brian D. Pardo:

R. Scott Peden:

Question No. 11 -Rule 13b2-2 Misleading Auditors


Pardo and R. Scott Peden violated Rule 13b2-2?


Brian D. Pardo:

R. Scott Peden:


App. 2018


jon No 12 -Rule 13a-14 False Certifications

Did the SEC prove by a preponderance of the evidence that Defendant Brian D.

Pardo violated Rule l3a-14?


Brian D. Pardo: E S

SO SAY WE ALL, this _3 day of, 2014.

ORiGINAL SIGNATURE

REDACTED PURSUANT TO

E-GOVERNMENT ACT OF 2002

7-


App. 2019


Exhibit 155

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LPCN_00006137App. 2021


LPCN_00006137_00002App. 2022


Exhibit 156

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LPCN_00100982App. 2024


LPCN_00100982_00002App. 2025


LPCN_00100982_00003App. 2026


Exhibit 157

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1

From: Scott Peden <[email protected]>Sent: Wednesday, June 02, 2004 5:21 PMTo: Brian D. PardoSubject: RE: Letter for our staff

Of course. Want to take a stab at it first? Have me take a stab? Talk about it first? Just let me know.

-----Original Message----- From: Brian D. Pardo Sent: Wednesday, June 02, 2004 2:26 PM To: Deborah L. Carr; Scott Peden Subject: FW: Letter for our staff

I'd like to talk with you about this and get some help on it.

-----Original Message----- From: loulondono Londono [mailto:[email protected]] Sent: Tuesday, June 01, 2004 7:32 PM To: Brian D. Pardo Subject: Re: Letter for our staff

Brian, I also wanted to remind you if you can send me (2512 Jardin Drive, Weston, FL 33327) the letter from you to our sales staff, on LPI letterhead and with your signature --- this message below and perhaps other points of strength of LPI would be good.

This would be critical for us as soon as possible.

Thank you for your help. Lou

----- Original Message ----- From: Brian D. Pardo To: Rafael Ardila Cc: Lou Londono ; Lou Londono ; Lou Londono Sent: Tuesday, June 01, 2004 11:47 AM Subject: RE: Queries about AIDS underwriting

Rafael- MBC did the same thing with both AIDS and Senior policies. They manipulated the LE's. Since they did this first on AIDS policies they just excused the whole issue by saying such policies could not be underwritten. Isn't it interesting to note that the ratio's are the same for both types of policies.

What you have to do is explain that there is never a good defense against fraud. Our returns, including 1,800 or so deaths and the on-going purchasing of AIDS policies by our roughly 12,000 strong investor base over nearly 12 years should make your clients realize the strength of our position and the credibility of our underwriting.

Regarding AIDS, our medical underwriting has been done by the same group since the beginning. Dr. Cassidy leads the Oncology Center at Washoe Medical Center, and these people have underwritten ALL of our AIDS policies for 12 years.

We have a very large demand for AIDS policies. If your clients don't want them, concentrate on

App. 2028


2

Seniors, and let them know I said that! Brian -----Original Message----- From: Rafael Ardila [mailto:[email protected]] Sent: Thursday, May 27, 2004 8:39 PM To: Brian D. Pardo Cc: Lou Londono; Lou Londono; Lou Londono Subject: Queries about AIDS underwriting Dear Brian, I know Lou emailed you yesterday with these same queries but due to its urgency I translated your message below and sent it to our agents in an attempt to satisfy their inquiries since some of the questions now are more or less the same we got back in July last year when Mutual Benefits' shifted from HIV policies to other terminal illness and senior life settlements. Today I received mails that insist in having this information from Waco and updated with current data plus two additional questions: 1. Name the physicians, independent medical professionals, laboratories, etc. involved in the underwriting process. 2. Statistics on AIDS' policies that are past the projected date of maturity indicating how long the time is lapsed beyond rated Life Expectancy. It is worthwhile to mention here that the hit/miss ratios published by MB Receiver are: For 6,851 HIV active policies: 98.7% beyond rated Life Expectancy 1.3% not beyond rated Life Expectancy For 806 Non-HIV active policies: 98.7% beyond rated Life Expectancy 1.3% not beyond rated Life Expectancy It is not possible to conclude that the HIV policies were not correctly underwritten or that the Non-HIV policies were correctly underwritten since MB Receiver did not publish how many of these policies still have the projected maturity date to come and how many have past the projected maturity date. In spite of that, Mutual Benefits agents circulate their interpretation in Latin America: They put the blame on new drugs that extend patients life and conclude it is impossible to underwrite AIDS life expectancy. Is it possible to have from Waco a complement to your email below? Finally, I am traveling to Colombia on Monday and I perceive the atmosphere down there is loaded with comments about change in investors' appetite for Senior Life Settlements and it would certainly help a lot to have some SLS inventory. We have an agent in Colombia that assures he can place the whole SLS policies with $100,000 of acquisition cost, which in my opinion is too low but could we at least share portions of $100,000 in SLS policies? Regards,

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Rafael ________________________________ ----- Original Message ----- From: "Brian D. Pardo" <[email protected]> To: "INDUASEO-Corp" <[email protected]>,"Scott Peden" <[email protected]> Subject: RE: Need some background information urgently... Date: Fri, 11 Jul 2003 14:27:37 -0500 Lou- Scott is out of town, so I will respond to your questions. He will send the back-up reports on Monday. 1. AIDS - From a return prospective we have provided our client base of 12,000 investors with average 17% annual returns on capital for 11 years running. This very fact alone speaks to our expertise in underwriting AIDS policies. You are right in that HIV/AIDS patients live longer than before, but AIDS remains the most predictable 100% fatal disease known to man. When the drug cocktails first came out, lives were extended by about 2-3 years on average. This benefit began to slide when mutations began to set in. AIDS is the most mutable disease known to man also. Further, since AIDS is a virus there is no cure, period. When underwriting AIDS policies we first determine that the patient has, indeed, progressed to AIDS. We do not buy HIV policies. Then we look at the progress of the disease and how well the patient is responding to the drugs. When we see that the positive response is largely over we can underwrite the LE. Our medical underwriters are all Oncologists who are used to working with diseases resulting from immune system decline, mostly by chemotherapy. Mutual Benefits says they no longer write AIDS policies because of uncertainty in underwriting, but upon close examination I think you would find the problem within their underwriting process and the subsequent problems they have incurred as a result. 2. We have a detailed report on matured policies that will support what I have just said. These numbers are based on about 1,500 deaths as I recall. Scott will send you a copy as soon as he returns on Monday Good luck! Brian

App. 2030


Exhibit 116 - Life Partners Official Committee Of Unsecured … Appendix.pdf · 2016-03-18 ·...

Documents

Transcript of Exhibit 116 - Life Partners Official Committee Of Unsecured … Appendix.pdf · 2016-03-18 ·...