Information about Investor Communications

Information about Investor Communications

(August 16, 2002)

Copied below is the text of a letter sent on August 16, 2002 to the Chairman of Farmer Bros., suggesting standards for the disclosure of information relating to communications between the company and its shareholders.

It was noted in the letter's distribution to Forum participants that the apparent standard for communications between management and investors is different from standards for communications between shareholders, which are generally considered private unless proxy solicitations or actions by holders of more than 5% of the stock require SEC filings. And Forum communications, typically involving independent participants with a moderator who has no ownership or proxy solicitation interests, are governed by the privacy policy stated at the bottom of the pages on this web site: "Participants are expected to make independent use of information obtained through the Forum, subject to the privacy rights of other participants. It is a Forum rule that participants will not be identified or quoted without their explicit permission."

[letterhead]

LUTIN & COMPANY

575 Madison Avenue

New York, New York 10022

Telephone (212) 605-0335

Facsimile (212) 605-0325

August 16, 2002

By telecopier: 310/320-2436

Mr. Roy F. Farmer

Chairman, Board of Directors

Farmer Bros. Co.

20333 South Normandie Avenue

Torrance, California 90502

Dear Mr. Farmer:

Recent reports that Farmer Bros. had declined journalist requests for copies of a letter have raised questions about what should be made public, and by whom. I therefore sought the views of several people familiar with both journalism and investment practices to determine what is broadly accepted.

Aside from SEC and other legal disclosure requirements, there was a general consensus that substantive information relating to non-private communications between a company and investors should be made available to anyone with a legitimate interest. These communications would be considered private only if there was a confidentiality agreement or some other reason for the parties to presume confidentiality, such as a context of negotiation. In general, responsibility for providing the information should be with its source rather than with its recipient.

Consistent with this standard, Franklin Mutual has made copies of its own letters available to the public, but not your letter to them. Since you did not disclose your August 5, 2002 letter, Franklin responded to inquiries about the status of their demand for records by reporting only the substance of your letter's commitment.

Please let me know if you have any suggestions to refine or modify this standard.

Sincerely yours,

Gary Lutin