IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

PRIMERICA LIFE INSURANCE ) COMPANY, ) ) Plaintiff, ) Case No. 1:22-cv-06290 ) v. ) Judge Harry D. Leinenweber ) RUKIYA L. KYLE, RONALD KYLE, III, ) Magistrate Judge Jeffrey T. Gilbert RASHON KYLE, WARREN R. ) WILLIAMS, individually and as ) Independent Administrator of the ) ESTATE OF LATONIA KYLE ) WILLIAMS, ) ) Defendants. )

AGREED MOTION FOR FINAL JUDGMENT ORDER IN INTERPLEADER AND DISMISSAL

Plaintiff Primerica Life Insurance Company (“Primerica”), by its attorneys, Julie F. Wall and Kaitlyn E. Luther of Chittenden, Murday & Novotny LLC, states as follows for its Agreed Motion for Final Judgment Order in Interpleader and Dismissal: 1. On January 29, 2017, Primerica issued Policy No. 0490567553 (the “Policy”) to Latonia Kyle as Owner, on the life of Latonia Kyle, as Insured, with a face value of $100,000 and an Increasing Benefit Rider that increased the benefit by 10% per year starting at the beginning of the Policy’s second year. In the January 18, 2017 Application for Individual Term Life Insurance related to the Policy (the “Application”), Latonia Kyle’s Estate was the designated primary beneficiary of the Policy, and the designated contingent beneficiaries were Rukiya Kyle, daughter, 35%; Ronald Kyle, III, son, 32%; and Rashon Kyle, son, 33%. 2. On July 12, 2019, Latonia Kyle (a/k/a Latonia Kyle Williams or Latonia Williams) and Warren R. Williams married. 3. On February 22, 2020, Latonia Kyle Williams died as a result of multiple gunshot wounds and her manner of death was found to be homicide. On the date of her death, the benefit under the Policy was $130,000 (the “Benefit”), by virtue of increases under the Increasing Benefit Rider. 4. On July 27, 2020, the Circuit Court of Cook County, Illinois, County Department

– Probate Division, in Case Number

, issued Letters of Office – Decedent’s Estate to Warren R. Williams, who was appointed Independent Administrator of the Estate of Latonia Kyle Williams. 5. Primerica received competing claims to the Policy proceeds and conducted a claim investigation. 6. On November 10, 2022, Primerica filed its Complaint for Interpleader pursuant to Fed. R. Civ. P. 22 and

(a) to resolve competing claims to the Benefit payable under the Policy. (Doc. No. 1). 7. On November 15, 2022, the Court granted Primerica’s motion to deposit its

admitted liability under the Policy with the Court. (Doc. No. 9). 8. On November 22, 2022, Rukiya L. Kyle filed her Appearance Form for Pro Se Litigants. (Doc. No. 12). 9. On November 21, 2022, Primerica filed the Waiver of the Service of Summons it received from Warren Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams. (Doc. Nos. 10-11). 10. On November 28, 2022, Primerica deposited its admitted liability under the Policy in the amount of $132,671.23, representing the Policy’s Benefit plus accrued interest, into the Registry of this Court (“Funds on Deposit”), subject to this Court’s further order as to whom among the Defendants is entitled to receive the Benefit. See Notice of Electronic Filing dated November 28, 2022, Receipt No. 4624279441, attached hereto and incorporated herein as Exhibit 1. 11. On January 3, 2023, Primerica filed the Waiver of the Service of Summons it received from Ronald Kyle, III. (Doc. No. 15).

12. On January 3, 2023, Primerica filed the Waiver of the Service of Summons it received from Rukiya L. Kyle. (Doc. No. 16). 13. On January 5, 2023, Primerica served a copy of the Summons and Complaint for Interpleader on Rashon Kyle via personal service. (Doc. No. 18). 14. On January 26, 2023, undersigned counsel for Primerica and Defendants Rukiya L. Kyle, Ronald Kyle, III, and Warren R. Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams, appeared telephonically for a status conference with Judge Leinenweber. During the status conference, Warren R. Williams agreed to disclaim his interest in the Policy’s Benefit. Further, Rukiya L. Kyle and Ronald Kyle, III represented that they and their

brother, Rashon Kyle (who was not present for the telephonic status conference), would be willing to divide the Policy’s Benefit equally. 15. As reflected in the Agreement and Disclaimer attached hereto as Exhibit 2, Defendants Rukiya L. Kyle, Ronald Kyle, III, Rashon Kyle, and Warren R. Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams, have agreed to the relief sought in this Agreed Motion and the associated Agreed Order, including (1) that Primerica Life Insurance Company should be awarded $5,000.00, representing a portion of its actual court costs and attorneys’ fees incurred in connection with prosecuting the Complaint for Interpleader, to be deducted from the Funds on Deposit; and (2) that Rukiya L. Kyle, Ronald Kyle, III, and Rashon Kyle will divide the remainder of the Funds on Deposit as follows: Rukiya L. Kyle shall receive $42,557.08 plus 33 1/3% of any interest accrued on the Funds on Deposit; Ronald Kyle, III shall receive $42,557.08 plus 33 1/3% of any interest accrued on the Funds on Deposit; and Rashon Kyle shall receive $42,557.07 plus 33 1/3% of any interest accrued on the Funds on Deposit. See Agreement and Disclaimer attached hereto and incorporated herein as Exhibit 2; Signed Agreed

Order attached hereto and incorporated herein as Exhibit 3. 16. As reflected in the Agreement and Disclaimer attached hereto as Exhibit 2, Warren R. Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams, has disclaimed in writing any and all interests and rights Warren R. Williams or the Estate of Latonia Kyle Williams now have or may have in the future related to the Policy, the Policy’s Benefit, and the Funds on Deposit. See Ex. 2; Ex. 3. 17. This Court has jurisdiction over the subject matter of this cause and over the parties. 18. Primerica has done all that is required by law to perfect its interpleader action. 19. Primerica has acted in good faith by interpleading the Policy’s Benefit and

depositing its admitted liability with the Clerk of the Court. 20. Primerica has properly served a copy of this Agreed Motion for Final Judgment Order in Interpleader and Dismissal on all Defendants. 21. A proposed Agreed Order granting the relief requested herein, signed by Rukiya L. Kyle, Ronald Kyle, III, Rashon Kyle, and Warren R. Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams, is submitted pursuant to the Court’s standing order and applicable local rules regarding proposed orders. WHEREFORE, Plaintiff Primerica Life Insurance Company prays this Honorable Court enter an order or orders granting it the following relief: A. Enjoining Defendants Rukiya L. Kyle, Ronald Kyle, III, Rashon Kyle, Warren R. Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams, and the Estate of Latonia Kyle Williams during the pendency of this case and thereafter permanently and perpetually, from commencing or prosecuting any proceeding or claim against Primerica Life Insurance Company and/or its agents in any

state or federal court or other forum with respect to Policy No. 0490567553 and the Benefit thereunder, and on account of the death of Latonia Kyle Williams (a/k/a Latonia Kyle or Latonia Williams), the insured, and that said injunction issue without bond or surety; B. Granting judgment to Primerica Life Insurance Company with the finding that it has no further liability to Defendants Rukiya L. Kyle, Ronald Kyle, III, Rashon Kyle, Warren R. Williams, individually and as Independent Administrator of the Estate of Latonia Kyle Williams, and the Estate of Latonia Kyle Williams, or to any person or entity claiming through them, for the Benefit payable under Policy No. 0490567553,

and on account of the death of Latonia Kyle Williams (a/k/a Latonia Kyle or Latonia Williams); C. Finding that Primerica Life Insurance Company has acted in good faith by interpleading the Benefit and its admitted liability with the Clerk of the Court; D. Ordering the Clerk to disburse the Funds on Deposit as follows: 1) $5,000.00 shall be paid to Primerica via a check made payable to Primerica Life Insurance Company, which shall be mailed to Julie F. Wall, Chittenden, Murday, & Novotny LLC, 303 W. Madison, Suite 2400, Chicago, Illinois 60606; 2) $42,557.08 plus thirty-three and one third percent (33 1/3%) of the accrued interest shall be paid to Rukiya L. Kyle via a check made payable to Rukiya L. Kyle, which shall be mailed to Rukiya L. Kyle, 5610 S. Calumet Ave, Apt. I, Chicago, IL 60637; 3) $42,557.08 plus thirty-three and one third percent (33 1/3%) of the accrued

interest shall be paid to Ronald Kyle, III via a check made payable to Ronald Kyle, III, which shall be mailed to Ronald Kyle, III, 5814 Harriet Tubman Ave., Apt. A, Killeen, TX 76543; and 4) $42,557.07 plus thirty-three and one third percent (33 1/3%) of the accrued interest shall be paid to Rashon Kyle via a check made payable to Rukiya L. Kyle, which shall be mailed to Rukiya L. Kyle, 5610 S. Calumet Ave, Apt. I, Chicago, IL 60637. E. Dismissing this action with prejudice after entry of the Agreed Order submitted herewith and disbursement of the Funds on Deposit as directed therein; and

F. Granting Primerica Life Insurance Company such further and other relief as this Court deems just and appropriate. Dated: March 7, 2023. Respectfully submitted,

By: /s/ Kaitlyn E. Luther Julie F. Wall ([email protected]) Kaitlyn E. Luther ([email protected]) CHITTENDEN, MURDAY & NOVOTNY LLC 303 W. Madison Street, Suite 2400 Chicago, IL 60606 (312) 281-3600 (312) 281-3678 (fax)

Attorneys for Plaintiff Primerica Life Insurance Company CERTIFICATE OF SERVICE

I hereby certify that on March 7, 2023, I electronically filed a copy of the foregoing Agreed Motion for Final Judgment Order in Interpleader and Dismissal, and documents described therein, with the Clerk of the Court for the Northern District of Illinois, Eastern Division, using the CM/ECF system, which sent notification of such filing to the following registered CM/ECF participants:

Rukiya L. Kyle 5610 S. Calumet Ave, Apt. I Chicago, IL 60637 [email protected]

I further certify that on March 7, 2023, I mailed a copy of the foregoing Agreed Motion for Final Judgment Order in Interpleader and Dismissal, and documents described therein, to the following parties or their counsel by enclosing a true and correct copy thereof in a duly addressed, postage prepaid envelope and depositing same in the U.S. Mail chute at 303 West Madison Street, Chicago, Illinois, before the hour of 5:00 p.m.:

Ronald Kyle, III Register No. 81670-380 FCI Three Rivers Federal Correctional Institution P.O. Box 4200 Three Rivers, TX 78071

Rashon Kyle Booking No. 20220810083 Cook County Department of Corrections 2700 S. California Ave. Chicago, IL 60608

Warren R. Williams 420 Indian Wood Blvd. Park Forest, IL 60466 [email protected]

/s/ Kaitlyn E. Luther Kaitlyn E. Luther CHITTENDEN, MURDAY & NOVOTNY LLC 303 W. Madison Street, Suite 2400 Chicago, IL 60606 (312) 281-3600 (312) 281-3678 (fax) [email protected]