II

AXA EQUITABLE

Rekasha A. Robinson-McLymont
Lead Director I Associate General Counsel
Tel. (212) 314-5846
Fax (212) 707-7945
Rekasha.a.robinson-mclymont@axa.us.com

redefining / standards

LAW DEPARTMENT

May 13, 2016

Bv Federal. Express Delivery

Mr. Ryan Curioni
76 Liberty St.
Lodi, NJ 07644
Re:

False Statements regarding AXA Equitable

Dear Mr. Curioni:

I am Lead Director and Associate General Counsel of AXA Equitable Life Insurance Company
("AXA Equitable"). This refers to false statements that you have made on your website posted at
http://lodioverhaul.blogspot.com/2016/05/is-treasurer-of-lodi-boys-girls-club.html?m+ 1, regarding
403(b) contributions to AXA Equitable.
Your blog contains a false statement regarding AXA Equitable's business relationship with the Lodi
Board of Education ("Board of Ed"): "There are AXA bills paid by the Lodi Board of Education each
month." In support of this misrepresentation, you include a chart showing the Lodi Board of Ed' s
disbursements for the month of January 2016. The $28,975.16 paid by the Board of Ed to AXA Equitable
for January 2016 are in fact contributions made by Lodi school employees to the Lodi Board of Ed's
retirement plan, for which AXA Equitable is the plan provider. To be clear, the Lodi Board of Ed is not
paying any bills of AXA Equitable.
AXA Equitable views this as a serious matter. We hope that it will be able to be resolved amicably and
quickly. To do so, please confirm in writing no later than May 27, 2016, that you have removed the
false statement described above from your blog. We caution you that AXA Equitable will vigorously
enforce its legal rights where litigation cannot otherwise be avoided.
This letter is without prejudice to any and all rights and remedies to which AXA Equitable may be
entitled, all of which are expressly reserved.

Rekasha A. Robinson-McLymont
cc:

667333

A. Lin, Esq.
S. Keslowitz, Esq.