One who intends to leave others better off for his having existed.

11/26/14

Wells Fargo declined to provide, admit or deny the following discovery requests of February 27, 2014

In the Matter of; George Hartzman, Complainant, v. Wells Fargo Advisors, LLC., Respondent, Case No. 2013-SOX-00045 with the United States Department of Labor, Office of Administrative Law Judges, presided over by Judge Kenneth A. Krantz, Wells Fargo declined to provide, admit or deny the following discovery requests of February 27, 2014

Request for Production of Documents 6;

Please provide George Hartzman's Wells Fargo personnel file, including A; the number of client accounts managed by George Hartzman in 2007, 2008, 2009, 2010, 2011 and B; as of October 8, 2012, the number of new client accounts opened by George Hartzman in 2007, 2008, 2009, 2010, 2011 and C; as of October 8, 2012, the total assets managed by George Hartzman in 2007, 2008, 2009, 2010, 2011 and D; as of October 8, 2012, how many clients transferred accounts away from George Hartzman in 2007, 2008, 2009, 2010, 2011 and E; as of October 8, 2012, the number of accounts managed by George Hartzman, which were governed by the Investment Advisers Act of 1940 in 2007, 2008, 2009, 2010, 2011 and F; October 8, 2012, and the total of George Hartzman’s gross revenue production in 2007, 2008, 2009, 2010, 2011 and as of October 8, 2012.

Request for Admission 1;

Please admit or deny William Spivey and Aaron Landry's 2009, 2010 and 2011 compensation package metrics provided higher income by employing more Financial Advisors under their supervision with the same revenue production, and lower income by employing fewer Financial Advisors under their supervision with the same revenue production.

Request for Admission 4;

Please admit or deny that Littler Mendelson's Gregory C. Keating incorrectly stated, Wells Fargo's "Clients have no expectations that the Envision program provides a guaranteed outcome." and that Envision "price modeling is not included in Envision's default setting because:"..."(a) there are no products represented in Envision, only asset classes which are not associated with fees; (b) most plans include external assets which are held at other institutions such that the fees for those assets cannot be accurately included..." to the Department of Labor.

Request for Admission 5;

Please admit or deny that Wells Fargo Advisors could cancel existing 4front awards and claw back Financial Advisor 4front payments.

Request for Admission 6;

Please admit or deny that that on September 7, 2012, in front of 25 to 40 financial advisors at the Hyatt Regency St. Louis at The Arch, Greg Shiveley, Envision Sales Manager at Wells Fargo Advisors, said “There are 441,942 households with Envision Plans of Record.” and that Mr. Shiveley stated “The overwhelming majority of Envision Plans do not include investment costs."

Request for Admission 8;

Please admit or deny that Wells Fargo management was aware of George Hartzman’s 401k loan, which defaulted after Mr. Hartzman’s termination.

Request for Admission 9;

Please admit or deny that William Spivey and Aaron Landry's 2009, and/or 2010 and/or 2011 compensation benefited by retaining Financial Advisors via Wells Fargo’s 4front program.

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