Herbert V. Kohler, Jr., et al. - Page 30

                                        -30-                                          
               In forecasting the cash flow for the DCF method, Dr. Hakala            
          did not use the expenses in the projections Kohler provided him.            
          He decided to make his own assumptions about expenses.  Dr.                 
          Hakala applied these assumptions without first discussing them              
          with anyone at Kohler.                                                      
               Dr. Hakala created two DCF models, one using revenues from             
          the operations plan and one using revenues from the management              
          plan.  He weighted the results he derived from these two DCF                
          models in a manner inconsistent with the reality of the business.           
          He weighted the realistic management plan based model 20 percent            
          and the more aspirational operations plan based model 80 percent            
          because he thought the aspirational operations plan was a more              
          likely scenario.                                                            
               Dr. Hakala made a last minute correction to the value he               
          determined under the income approach at trial.  His error                   
          resulted in an $11 million overvaluation of the Kohler stock in             
          his report.                                                                 
               Under the market approach, Dr. Hakala used two methods.                
          Like the estate’s experts, he used the guideline company method,            
          but was the only one of the three experts who used the                      
          transaction method.11  While the estate’s experts did not find              

               10(...continued)                                                       
          such as initial public offerings.                                           
               11The guideline company method examines certain financial              
                                                             (continued...)           





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